ML17311A018

New York State EAL Upgrade Project Verification & Validation Rept.

ML17311A018
Person / Time
Site:	Nine Mile Point, Indian Point, Ginna, FitzPatrick
Issue date:	05/13/1994
From:	AFFILIATION NOT ASSIGNED
To:
Shared Package
ML100360331	List: ML17311A018
References
OSSI-93-402A-10, OSSI-93-402A-R, OSSI-93-402A-R00, NUDOCS 9405190289
Download: ML17311A018 (510)

Text

OSSI 93402A-10.Ginna W Q&97fP~~

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'Plant Specific EAL Guideline (PEG,:)

R.E. GIInna OSSX

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4 PlantSpecificEAL(beeline(A,H,Sj R.E. Glnna lC>>: AU1 Any unplanned. release of'gaseous or liquid I'hdloactlvlty to the environment that exceeds two times the radiological Technical

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~.=.~.~~.=;.:.:,.- .. Specifications fear.60 mInutes or longer.

Oji .iVkxie: ...- '4 pllcablllty . Q1'(PwrOps) U2(HSB) 03(HSD) Q4(CSD) 05(Refuel) Q6(Defuel) QAII AU1.1',,=" ', A(J1.2 A'valid reading on one or more of the folhwing monitors that exceeds the "value shown" Confirmed sample analyses for gaseous or liquid releases indicates concentrations or release criterion'and indicates the need to assess the release with I

< 19K mram5r ~

Matrttta Bftffta:fata; hurler artrf < KKmrfttahz airln rlrtaa fran aubh gaaaa

< 3QEmrarnlrr amr organ frrtm L13i. LQ3. 1rilftttnartrf aartimlalaa uilh~Q rfalr half firaa Vote: If the monitor readingsmara sustained for hnger than 60 minutes and the required assessments cannot be completed within this period, then the declaration must be made eased on the valid reading.

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.1)I>+Q (p<Jj~ 'p $ 'pq!Pig> g'gi,~i. PB>lv5 p'.~8 @DC J >I'lfilL

',(bh'L'JAL1)llUl gtPCLJG'~t ))0%')9~N 80140!~'!" 'il' <~ 'e'~ +

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Plant Specific EAL Cbeeline (A,H,S)

R.E. Ginna Bases The term 'Unplanned; as used in this context, includes any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions (e. g., minimum dilution

'low, maximum discharge fhw, alarm setpoints, etc.) on the applicable permit.

i/alid means that a radiation monitor reading has been confirmed by the operators to be correct.

Jnplanned releases in excess of two times the site technical specifications that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the evel of safety. The final integrated dose (which is very low in the Unusual Event emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that he release was not isolated within 60 minutes. Therefore, it is not intended that the release be averaged over 60 minutes. For example, a release of 4 times T/S for 30 minutes does not exceed his initiating condition. Further, the muff QggtU~gf. {~gaunt Qgnttffnaflt1) C4cectoc should not wait until 60 minutes has elapsed, but should declare the event as soon as it is determined hat'the release duration has or will likely exceed 60 minutes.

monitor indications afast~44o calculated on the basis of the methodology of the site Offsite Dose Calculation Manual (ODCM to demonstrate compliance with 10CFR20. Annual average meteorology 4Iouk5be fa used whora4towed.

Iha alarm aafgginfahcfba IhlaIfaznifgra afa amamalnafy aQ 1'nauatIftgbnigaf Gamfiga1ignradigagibd1tf mfaaaaiimifa ha aafgula1alf Iftgfutigal fiumfiga11gn cafaaaa rufaa aa anagifiatf tn LRaftgltgn ~ mngi atzmdatf. Itm~ ~ fgr aagf1 mgnihz la hm liam Kana ffamgndum ng1~ aulgmalig 1ftaLiima ffgaa aaaftzumm1.

'fL>b~lCB,':ll)i-

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( 1 gl 9f!'.jg45~'f.', 2i>>lf".g,g )I ~ "

0

0 Plant Specific EAL Celine R.E. Ginna (A,H,S)

ICO'U2 Unexpected Increase ln plant radiation or airborne concentration.

Op. Mode Applicability Q1 (Pwr Ops) Q 2 (HSB) Q 3 (HSD) Q 4 (CSD) Q 5 (Refuel) Q 6 (Defuel) ~ All AU2.1 AU2.2

~~

AU2.4 VaM ~ ~iatttttd direct area radiation monitor readings z gf~alft Iitgb ~itgg Iigtti~ itagggiigl~ ~g~ increase-by-a-factor-of-'NOOover-normat-'ev4s.

ibad aiaittt mipttlttitK

Plant Specific EAL Cfeieline (A,H,S)

R.E. Ginna Bases Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

All of the above events tend to have long lead times relative to potential for radiological release outside the site boundary, thus impact to public health and safety is very hw.

ln light of Reactor Cavity Seal failure, incidents at two different PWRs and hss of water in the Spent Fuel Pit/Fuel Transfer Canal at a BWR all occurring since 1984, explicit coverage of these types of events via EALs ¹1 and ¹2 is appropriate given their potential for increased doses to plant staff. Classification as an Unusual Event is warranted as a precursor to a more. serious event.

mmh~ail iuadiaimfhml aaaftfnbliaa iamaiQiQg muumihxmahC mm debts aa it lafiQaaaaaQl. hhR2 AL40 ~ applies to plants with licensed dry storage of older irradiated spent fuel to address degradation of this spent fuel.

ML¹4~addresses 2!!iliQiaQf JHKmaL JQYQlk ~~

safety of the Plant. iQfligaligQ gf afaa iatliaiigQ ifQfala ~fta2Qg g P aftiagjQh afa QgmiQaliy. 2ti QQa ~ ~ ~~ QIQIf. Qual sscalates to an Alert per IC AAS, if the increases impair Iita JIQtal gf safe operation. QOJy.attai~

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lima'lta alafm aaigftiQi glim;ala Jjltaa utaffiQga aia

~ aalftf;fatal ~attaa ibaaa gggj~

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unplanned increases in in-plant radiation levels that represent a degradation in the control of radioactive material, and represent a potential degradation in the level of

~ afa mgra iaafiily, jlaQIi~

iimfta ilta alafm aaiggjQi QlfKala QLgyj~ aQ aititfalftQiiltiftalI~ This EAL Qfg.92~ fmQa~amy amaLgarEY MlZaligQfltta12 uaaiaQiaQl,aui iamultraQl, radialhQ htfah Ihai br'mmd 199 iimaa iba alarm aalagiQt.

Plant Specific EAL Celine (A,H,S)

R.E. Glnna IPA': AA1 Any unplanned release of gaseous or llquld radloactlvlty to the environment that exceeds 200 times radtologlcal Technical Speclflcatlons for 15 minutes or longer.

Op. Mode Appllcablllty Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All AA1.1 AA1.2 A valid reading on one or more of the folhwing monitors that exceeds the "value shown" Confirmed sample analyses for gaseous or liquid releases indicates concentrations or release rates in excess of Lhuid Bahama@

~

2Klimaa fKEB29. huruutdix ELMh lLQultimn2 MaQilmlfgr rfhagllfarf graalraioatf aahhgaaaa GaauutaEhtha:m; s 1K ramhz tldlrth hufx aad < KQ aun5r alth rhaa fatm nahh gaafta Xah@2mf. < 3QQ aunhzatty.rtraait fram LQl. L123. 1rilhm anrf parfit;ttiataa Mtilb s Rdalr half Iitaa 19ZEZmm 1BEm 221K~

dfaahhi Vote: If the monitor readings Is ara sustained for longer than 15 minutes and the required assessments cannot be completed within this period, then the declaration must be made eased on the valid reading.

M1.3 AA1.4

Plant Specific EAL (+leline (A,H,S)

R.E. Glnna Bases Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

This event escalates from the Unusual Event by escalating the magnitude of the release by a factor of 100. Prorating the 500 mR/yr criterion for both time (8766 hr/yr and the 200 multiplier, the associated site boundary dose rate would be 10 mR/hr. The required release duration was reduced to 15 minutes in recognition of the increased severity.

Monitor indications eftou!date ara calculated on the basis of the methodology of who 4taOffsite Dose Calculation Manual (ODCM~thet'-site-Annual average meteorohgy ehoul44e ia h!Jl.

Ihmmnumgnfaatgra ara baal ultan tba mittturartf nahfa gaa araaant in rmtar amlant during tba 3222K tulsa ruutuia =ngimaf aaaia&na.

Ginm tbara ia nn high ranga mnnitnr aaaaaiaiadmitb Jiauid affluant mnnitar EL1R and 25h LG.mlua ia holand W ulnar anafa. anindiaatian nf Manafa hi ia nnnattnlati~tafx uaarL BGEdamgn daaa ngiuRm tafamataradnaiimatar manitgia.

BGE damgn dgaa not uiiTiza autrtmatr raatiimadmaaaaaaammt.

Ehfararxaa:

Plant Specific EAL Celine (A,H,S)

R.E. Ginna ICk AA2 MaJor damage to Irradiated fuel or loss of water level that has or will result ln the uncovering of Irradiated fuel outside the reactor vessel.

Op. Mode Applicability Q1 (Pwr Ops) Q 2 (HSB) Q 3 (HSD) Q 4 (CSD) Q 5 (Refuel) Q 6 (Defuel) Q All AA2.1 AA2.2 Mahdt Ih

~

EL2. Qaolaiamaot hraa hhaitor; K mEbr

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fH.Smi hal Eil; 25mBhr EL12Quoluiooml Hubh Gm AA2.3 AA2.4

Plant Specific EAL Cleline (A,H,S)

R.E. Ginna BaSeS This IC applies to spent fuel requiring water coverage and is not intended to address spent fuel which is licensed for dry storage, which is discussed in NUMARC IC AU2, "Unexp'ected Increase in Plant Radiation or Airborne Concentration."

NUREG-0818, "Emergency Action Levels for Light Water Reactors," forms the basis for these EALs.

irradiated fuel is located such as reactor cavity, reactor vessel, or spent fuel pool.

Ihamdiathn monitor ahrm Qmma1ert ni1h 1hh M.mm1 haamfirrnftrt In amirt unrmmuanr shear sign gf nn ftnmmruzdua M a ~amm nhrm ~

ghLQtlrnrQ EALs nrfLrtfttinftrt by the specific area where There is time available to take corrective actions, and there is little potential for substantial fuel damage. In addition, NUREG/CRA982, "Severe Accident in Spent Fuel Pools in Support of Generic Safety Issue 82, July 1987, indicates that even if corrective actions are not taken, no prompt fatalities are predicted, and that risk of injury is hw. In addition, NRC Information Notice No. 90-08, 'KR45 Hazards from Decayed Fuel'resents the folhwing in its discussion:

"In the event of a serious accident involving decayed spent fuel, protective actions would be needed for personnel on site, while offsite doses (assuming an exclusion area radius of one mile from the phnt site) would be well behw the Environmental Protection Agency's Protective Action Guides. Accordingly, it is important to be able to properly survey and monitor for Kr-85 in the event of an accident with decayed spent fuel.

Humh ng indjgalignihaimaiar lmt in ihft mm1 Itrftlmal re. Dttttftiinggmitx bmdruunft~I h Itm 1m'f It@ ftrfttgihftr Ihan hx ~ ghmmiign. 2am hh22 addmau mal g!2fuutign gf hrftt IIQR?YfUy M.6622h llnnftQKHK. 2ER IhtILIIIR Qn IErftllnrtiKIIQQ%RICE IQ Ihk Itrftllisl&fftLQRQRL Yhlsl ghkfHYQIIQQ Qf RE% Qf YQIftfIQYIIIfrgIIIII2!2? hft rftg!IIEQIL M'~ h Thus, an Alert Classification for this event is appropriate. Escalation, if appropriate, would occur via Abnormal Rad level/Radiological Effluent or Quiff,5gnftnrjaz {htrgftngy. Qgrtrrfinatgd Quoctoc judgement.

Plant Specific EAL C+leline (A,H,S)

R.E. Ginna IC¹'A3 Release of radioactive material or Increases in radiation levels within the facility that Impedes operation of systems required to maintain safe operations or to establish or malntaln cold shutdown.

Op. Mode Applicability Q1(Pwrops) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII AA3.1 AA3.2 V4id ~lttltttt~gg radiation monitor reading greater than 15 mR/hr in Ihft:

(site-specific) 9 functions.

~~ radiation monitor readings greater than in areas requiring infrequent access to maintain plant safety Catnap Buum= E1Qzfrul Eham hhahar QB ~e-specific}-list, QBR=hr ma mlmt ftuflRL¹hx uum azau.

Plant Specific EAL eline (A,H,S)

R.E. Ginna

~ ~~ ~ ~ ~ ~ ~ iifIIIftgfI~

Bases Valid means that a radiation monitor reading has been confirmed by the operators to be correct. Qgfy. grgjgftgftfj gggmfjftt+ ~ ftgIIIIgftggg deahra&uduakaauummhmmfhmaaafy.mdiaihn lmhihuthhjbf.fflfatftdaREbr.

This IC addresses increased radiation levels that impede necessary access to operating stations, or other areas containing equipment that must be operated manually, in order to maintain safe operation or perform a safe shutdown. It is this impaired ability to operate the plant that results in the actual or potential substantial degradation of the level of safety of the plant. The cause and/or magnitude of the increase in radiation levels is not a concern of this IC. The 55551g}ga(hgr gtmfgftat;y.QggrdjrtalgQC4ce4oc must consider the source or cause of the increased radiation levels and determine if any other IC may be involved. For example, a dose rate of 15 mR/hr in the control room may be a problem in itself. However, the increase may also be indicative of high dose rates in the containment due to a LOCA. In this latter case, an SAE or GE may be indicated by the fission product barrier matrix ICs.

This IC is not meant to apply to increases in the containment dome radiation monitors as these are events which are addressed in the fission product barrier matrix ICs. Nor is it intended to apply to anticipated temporary increases due to planned events (e. g., incore detector movement, radwaste container movement, deplete resin transfers, etc.)

QjIII~off-normal operating procedures, emergency operating procedures, the 10CFR50 Appendix R analysis, identifying areas containing safe shutdown equipment.

coos~~~~~~ <~~

Areas requiring continuous occupancy include the control room an jf~Q~g fiftjg~~ft. The value of 15 mR/hr is derived from the GDC 19 value of 5 rem in 30 days with adjustment for expected occupancy times. Although Section III.D.3 of NUREG-0737, Clarification of TMI Action Plan Requirements, provides that the 15 mR/hr value can be averaged over the 30 days, the value is used here without averaging, as a 30 day duration implies an event potentially more significant than an Alert.

ased on ~zzmal radiation levels which result in exposure control measures intended to maintain doses within normal occupational exposure guidelines and limits (i. e., 10CFR20), and in doing so, will impede necessary access.

10

Plant Specific EAL deline (A,H,S)

R.E. Ginna IC¹: AS1 Boundary dose resulting from an actual or imminent release of gaseous radloactlvlty exceeds 100 or 500 mR QhMQQE Thyroid for the actual or projected duration of the release.

gg~ JEDE Op. Mode Appllcablllty Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All AS1.1 AS1.2 A valid reading on one or more of the following monitors that indicates the need to assess the release with EEEki9. Zaalral Baum Dusa hs:asmant" flu.2. afhzfutft dala 192M'.

Note: If the monitor reading(s) is sustained for longer than 15 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading.

AS1.3 AS1.4 Valid dose assessment capability indicates dose consequences greater than 100 mR Jjgf. Field survey results indicate site boundary dose rates exceeding 100 mR/hr IEQE expected to whela4ody or 500 mR4Nd QQE thyroid. continue for more than one hour; or analyses of field survey samples indicate child QQE thyroid dose commitment of 500 mR for one hour of inhalation.

11

Plant Specific EAL (deline (A,H,S)

R.E. Ginna BaSeS Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

The 100 mR 3EQQ integrated dose in this initiating condition is based on the proposed 10CFR20 annual average population exposure. This value also provides a desirable gra'dient (one order of magnitude) between the Alert, Site Area Emergency, and General Emergency classes. It is deemed that exposures less than this limit are not consistent with the Site Area Emergency dass description. The 500 mR integrated~cL4hyrotcl QQE tbttrajd dose was established in consideration of the 1$ ratio of the EPA Protective Action Guidelines for IEQF. whoto4ody and QQF.

thyroid.

' based on a site boundary dose of 100 mR/hour u/hotaho4y TEDE or 500 mR/hour whichever is more limiting (depends on source term assumptions).

IhamtuaaahaMfntttara dalarminad U

~"

EPJR.~%antral Elm Dna haaasmnanL" laaaduaan mhahhadx arafura. Iha aalaulatjalta mada lha aaaumatian af naulral atahilittr andante I th ~

ritahtfdnd aaaad. IhLta aandjtjana raaraamt annual atfaraaa malaaialaatf. REE k1R maajfiaa ihaltldtafahadxdaaa ja jimjtjna mich raaaaat ta atnalganm afaamfjaatlanand arataatjttaaatjan IIXL hltbauah EEEkikrtrmidaa far 8-'BQ2mhmadatftlmjaatjana. tba~arj.68jtlr af amulh haaduaantbanumhar af ~anrlar ZCaaraatudaa thamaaf amr ajngfamaajtar dafauhmhm far thaaa man!tars.

The CESAR QJQ~ ~

monitors on that pathway.

source terms applicable to each monitored pathway shoutrLbo hasta htan used in conjunction with annual average meteorology in determining indications for the 2.EZZkiRQardrulBaun Daaa&aaamttttnt

2. ERB Iabja22 4 ELF Qiana Hualaar 2unar Hant Iaatzjaa! Bmifiaatjarta. hmtndmattt kh. M hrliahu XKLi1hru R222 12

Plant Specific EAL deline (A,H,S)

R.E. Ginna IC¹: AG1 Boundary dose resulting from an actual or Imminent release of gaseous radioactivity exceeds 1000 f~R ~EDE eHWlNele Sedy or 5000 mR~HOQDE Thyroid for the actual or projected duratton of the release using actual meteorology.

Op. Mode Appllcablllty Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII AG1.1 AG1.2 A valid reading on one or more of the following monitors that ERE~ ZaafLul Ehum Dma MftmnanL";

Note: lf the monitor reading(s) is sustained for longer than 15 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading.

AG1.3 Valid dose assessment capability indicates dose consequences greater than 1000 mR whohkody or 5000 mR Q}f4@d thyroid.

~ AG1.4 Field survey results indicate site boundary dose rates exceeding 1000 mR/hr ~ expected to continue for more than one hour; or analyses of field survey samples indicate child QQP thyroid dose commitment of 5000 mR for one hour of inhalation.

13

Plant Specific EAL deline (A,H,S)

R.E. Ginna Bases Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

The 1000 mRIFJ}Ewhohkody and the 5000 mR ~et@4 thyroid integrated dose are based on the EPA protective action guidance which indicates that public protective actions are indicated if the dose exceeds 1 rem ~whola4ody or 5 rem ~4@d thyroid. This is consistent with the emergency class description for a General Emergency. This level constitutes the upper level of the desirable gradient for the Site Area Emergency. Actual meteorology is specifically identified in the initiating condition since it gives the most accurate dose assessment. Actual meteorology (including forecasts) should be used whenever possible.

based on site boundary doses for either whota4c4y TEDE or~44hyroid ~grgiri, whichever is more limiling (depends on source term assumpthns(s).

Ihamtuaa ahaMm mtra datarminati utilizire ERE muhlfrmti anaatL IhLta mmhttgna ranraaanl

~

annual Xnntrttl Ehum lhm EhsaumanC hami ultnmhnta haCh attanattra. Iha calmlatirtna matia iha aaaumatitIn al nautral atabilitlr anti an8 a~rttraga matttairtlagy. EEE kikmagifm 1hal mhah hrtrix rinaa ia limtttnam1hraarmt M amfi~xmmm dumfigatign anti urrttagtnraadhn U

hk M IJEd htthnugh EEEklRarttiitiaa igr EZL22raiaaaa rtatarminatjgna. thaxariability.af ra2tjta ha2ttiurtgniha numharul hBQanrhtr2Ca mlutiaa ihauaar~f air Rngiamzitgr gaia(aujt mhmhr 1haaa mrtnjtnra.

The ESAR5QQEQ on that pathway.

~ source terms applicable to each monitored pathway sbouldka hasta haan used in conjunction with annual average meteorohgy in determining indications for the monitors 2.EEZ~Qzitul Haun Dm hzaa2nant

3. ESMIabia22 4 B.E.Qiana Hualttar Razor PJani Iaahnltzl Sumfimtittna. hmmdmant hh. Mhrihtm XR1J. 1hru far H1$ hBt EhLa.MLS. Eolfhi1 Eita ELLERY XX'.Xahutathna 14

Plant Specific EAL (deline (A,H,S)

R.E. Ginna IC¹: HU1 Natural and destructive phenomena affecting the protected area.

Op. Mode Applicability Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All HU1.1 HU1.2 Report by plant personnel of tornado~ within rtiani protected area ~fntiZZ.

Eadbuuaira & inrtlani hlr gna rtr mgraaiantrtaaraiigna narazuial PHD Qanfirtnaiittnrtf aanbttttaitad aniniatpiix araaiar ibanQJHa aaidimiad hx rad LED an aimtrnttiianagt;ahgraaah a~taniindigaittr liar GRRX@1hauaifa EmarganmPJao HU1.3 HU1.4 Assessment by the control room that an event has Vehicle crash into ar grgiagiiia ltrblgiiltrtrtagia plant structures or systems within protected area occurred. boundary.

HU1.5 HU1.6 Report by plant personnel of an unanticipated explosion within protected area boundary Report of turbine failure resulting in casing penetration or damage to turbine or generator seals.

resulting in visible damage to permanent structure or equipment.

Deer Creek fhoding over entrance road bridge OR Lake level > 252 ft. OR Screen House Suction Bay water level < 15 feet (hw-hw level alarm) 15

Plant Specific EAL (deline (A,H,S)

R.E. Ginna Bases The protected area boundary is~ical that part wffhin the security isolation zone and is defined in the site security plan.

agkuKll Damage may be caused to some portions of the site, but should not affect ability of safety functions to operate. Method of detection caa4oz based on instrumentation, validated by a reliable sourc . As defined in.the EPRI-sponsored "Guidelines for Nuclear Plant Response to an Earthquake", dated October 1989, a "felt earthquake is:

An earthquake ot sufficient intensity such that: (a) the inventory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of control room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches ot the plant are activated. For most plants with seismic instrumentation, the seismic switches are set at an acceleration of about 0.01 g.

EAL ¹~ is based on the assumption that a tornado striking (touching down) within the protected boundary may have potentially damaged plant structures containing functions or systems required for safe shutdown of the plant. If such damage is confirmed visually or by other in-plant indications, the event may be escalated to Alert.

EAL ¹~ allows for the control room to determine that an event has occurred and take appropriate action based on personal assessment as opposed to verification (i. e., an earthquake is felt but does not register on any plant-specific instrumentation, etc.).

EAL ¹~4 is intended to address such items as plane or helicopter crash, barge crash gr jmgaafa al nlhfu: aiajttaljjfm that may potentially damage plant structures containing functions and systems required for safe shutdown of the plant. If the crash is confirmed to affect a plant vital area, the event may be escalated to Alert.

For EAL ¹~5, only those exphsions of sufficient force to damage permanent structures or equipment within the protected area should be considered. As used here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to near by structures and materials. No attempt is made in this EAL to assess the actual magnitude ot the damage. The occurrence of the exphsion with reports of evidence of damage (e. g., deformation, scorching) is sufficient for dedaration. The 5bjft

~g@yjgg lEmfugftagg Qaa1diaalaf) Coactor also needs to consider any security aspects of the explosion, if applicable.

EAL ¹~6 is intended to address main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals ot the turbine generator. Of major concern is the potential for leakage of combustible fluids (lubricating oils) and gases (hydrogen cooling) to the plant environs. Actual fires and flammable gas build up are appropriately classified via HU2 and HU3. This EAL is consistent with the definition of an Unusual Event while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment. Escalation of the emergency classification is based on potential damage done by missiles generated by the failure or by the radiohgical releases

. These latter events would be dassified by the radiohgical ICs or fission product barrier ICs.

EAL ¹Qfg 7 covers jijgjL e precursors of more serious events.

Dm mmk jjaadjag ayfIL ftalfaaaa raadhadga may. auu Jidft ftmftrgftmrmauma amuanftj ammed

@gm. Laka nahr jftttftj~ 252 f1. uurmumh 1a dmiga lmah. &zest Sum Gurdian Bm lfttatj s nfl. aanmauada 1a 1'Ja jftttftjalaun uaja1 aad mhhhrftauirm jaad Laduafiaahalun 5kb.

Ehlftrftnut; 1.~5ah lhtatftr LEkmdl EmftfgftmHun

2. ~LmtlamftajtumEahr Lml 2.2k% Eattjlauajla Emftrgttam Ban 4 2taERREaa

5. jalfuujfjmbhum" RfftftajlumBaua Bm Euhr lmLdaimt ~ ltd Imu M(bifa jfam YKiam Bauin mt daffm Eallj~

16

Plant Specific EAL Celine (A,H,S)

R.E. Gtnna ICk HU2 Fire within protected area boundary not extinguished within 15 minutes of detection.

Op. Mode Applicability Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All HU2.1 ggftf~ fire in buildings or areas contiguous to any of the foliowi areas not extinguished within 15 minutes of control room notification alarm:

17

Plant Specific EAL Cleline (A,H,S}

R.E. Ginna BaSeS The purpose of this IC is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. This excludes such items as fires within administration buildings, waste-basket fires, and other small fires of no safety consequence. This IC applies to buildings and areas that are not contiguous or immediately adjacent to plant vital areas.

Escalation to a higher emergency class is by IC HA2, 'Fire Affecting the Operability of Plant Safety Systems Required for the Current Operating Mode".

18

Plant Specific EAL (deline (A,H,S)

R.E. Glnna IC¹: HU3 Release of toxic or flammable gases deemed detrimental to safe operation of the plant.

Op. Mode Appllcablllty Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All HU3.1 HU3.2

~~lft~within the Report or detection of toxic or flammable gases that could enter fly giglftgfgf area boundary in amounts that can affect lhthbtifbgf glggtl ~gftftttlftr aaaratign gf le ulant

~ Report by heal, county or state official for potential evacuation of site personnel based on offsite event.

19

Plant Specific EAL eline (A,H,S)

R.E. Ginna Bases This IG is based on releases in concentrations within the@to ~gfftf;fft~ boundary that will affect the health of plant personnel or affecting the safe operation of the plant with the plant being within the evacuation area of an offsite event (i. e., tanker truck accident releasing toxic gases, etc.). The evacuation area is as determined from the DOT Evacuation Tables for Selected Hazardous Materials, in the DOT Emergency Response Guide for Hazardous Materials.

20

Plant Specific EAL (deline (A,H,S)

R.E. Glnna IC¹: HU4 Confirmed security event which Indicates a potential degradatlon In the level of safety of the plant.

Op. Mode Appllcablllty F1(Pvvrops) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All HU4.1 HU4.2 Bomb device discovered within plant protected area arear

~ and outside the lail~jag plant vital Other security events as determined from~~~fie) Safeguards Contingency Plan.

QaafrulRuikiiarr Bhtglgr Qrtalaiamanl Building huziliaz Jhi1dinlt turbid Jhiidino EamrmtmDiml Quisling Randhx huziTiarx Ettttdnatttr Building GaaanHausa Qaa1ral hhon Ratian 21

Plant Specific EAL deline (A,H,S)

R.E. Ginna Bases This EAL is based o . Security events which do not represent at least a potential degradation in the level of safety of the plant, are reported under 10CFR73.71 or in some cases under 10CFR50.72. The plant protected area boundary is4ypicatf that part within the security isolation zone and is defined in the-HK1 YIIQIKRRR KR @Lid MQQdElihh I!tftQLQGR 52fdldb'. Qgftliftgftrtgy,QZL Bomb devices discovered within the Plant vital area would result in EAL escalation.

22

Plant Specific EAL (leline (A,H,S)

R.E. Ginna IC¹: HU5 Other conditions existing which In the judgement of the gglf Qggi~lm LEEg~ny 4Rreeter warrant declaration of an Unusual Event.

Op. Mode Applicability Q1 (PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5 (Refuel) Q 6(Defuel) Q AII HU5.1 Other conditions exist which in the judgement of the ~ gg>~~ ~~

QgZfiaglgQ Qireetor indicate a potential degradation of the level of safety of the plant.

23

Plant Specific EAL (deline (A,H,S)

R.E. G irma Bases This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant dedaration of an emergency because conditions exist which are believed by the 21ift QllQEYhQl {hf gguZQg~1gQ Qiroctor to fall under the Unusual Event emergency class.

From a broad perspective, one area that may warrant gaff QgQ~QI. gglftfgftflgyg~fjjafggQQiroctoc judgement is related to likely or actual breakdown of site specific event mitigating actions. Examples to consider Include inadequate emergency response procedures, transient response either unexpected or not understood, failure or unavailability of emergency systems during an accident in excess of that assumed in accident analysis, or insufficient availability of equipment and/or support personnel.

Specific example of actual events that may require 2Ijjtglggflfj~~gflfigy Qggfffjgg~C4coctor judgement for Unusual Event declaration are listed here for consideration. However, this list is by no means all inclusive and is not intended to limit the discretion of the site to provide further examples:

~ Uncontrolled RCS cooklown due to secondary depressurization It is also intended that the ~ Q~~~ {jggtfgftflgyQgQffjj~~Ouectoc judgement not be limited by any list of events as defined here or as augmented by the site. This list is provided solely as examples for consideration and it is recognized that actual events may not always follow a pre-conceived description.

24

Plant Specific EAL- deline (A,H,S)

R.E. Ginna tC¹: HA1 Natural and destructive phenomena affecting the plant vital area.

Op. Mode Applicability Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) 06(Defuel) ~ All HA1.1 HA1.2 Eafthmjtfthjtioojaothy.ontt or aurft ujaotuuftroiiuu aftn oonftj siotf Qaofirmntionol ftnttlmmjta-ol an jotftoaitx granter thanks@ aa dfttftrmjnfttthx IEG Riltr

~Mttltlfujtft EamrgftnmPJun" HA1.3 HA1.4 the following plant structures:

ing~Condensate-storage4an~ntrof-r~ (Site-sf~f'A1.5 Vehicle crash Meeting Ot OtniZfijftjmOnnt~

ftnMjnmftO1 jn plant vital areas.

gZrJttt~ Nttmnttftj ~ 1'r tisane~

HA1.6

~

Turbine failure generated missiles result in any visible structural damage to of4he following-plan~fees t Qjnni agtOOmftnt Flood water accumalating on screenhouse operating floor OR Lake level > 253 ft. OR Screen House Suction Bay water level < 13 feet 25

Plant Specific EAL deline (A,H,S)

R.E. Ginna Bases Each of these EALs is intended to address events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial "report" should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the Releases/Radiological Effluent, or ~

actual magnitude of the damage. Escalation to a higher emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad Qgggryjagt {Emftrgaftgy. Qggtfjjautgt10iroctoc Judgement ICs.

¹~1 choukLbo is based on~~ocifg FSAR design basis of QJg g,.

EAL EAL ~shoukLbo is based cause damage to safety functions.

on~~ocif+ FSAR4eciga4asie ua~mafj ~ Seismic events of this magnitude can cause damage to safety functions.

afttfifgftlmaotujjgufjimLgggfiitiga of sustained ~ mph ~ Qg ~. Wind loads of this magnitude can

¹~3 should specify~~pecific) structures containing systems

~

EAL and functions required for auja gjuftt gaatutjftft EAL ~~

uhaftgmafta uta jofjjgatafj in tha mnttgj tom ata ufjmfulajygium hx tha maul'nuhhh M. Hald.12aofj12uta Itm mftthgfja hx nhhh fjatftrmiftfKIhatajgta thafa ja ftg ftaafj jar thja EBL ufui fjaatuxtim EAL ¹~5 is intended to address such items as plane or helicopter crash, , train crash, or barge crash into a plant vital area.

EAL ~4eJatertdoclto .<ddressaa the threat to safety related equipment imposed by missiles generated by main turbine rotating component failures. Tha jfttfghfad attttt;ttttaa uta safety-related equipment, their controls, and their power supplies. This EAL is, therefore, consistent with the definition of an ALERT in that if missiles have damaged safety-related equipment the potential exists for substantial degradation of the level of safety of the plant.

EAL ¹~7 covers hjgjLaftdJM jajtfL am!1 jn jgaa uj ~ ahn1 aattjamaaL Eh'atar xztfmalatjLtg an 1ha ataanhufaa gaafutifta jigger at jail Lmh 2: 252 {Lmrrmgfttja ta lmh thraathaiag ~xgtfjumaftt. 5mmn Humkztjga Qm jaded she {Lmrfaafzftfjah 1haajamlian shishraatfjtfja ja 1hamgtgr:fjmaa jjratffatar aumumtfgthnhmhhaauujag uftmmafj.

X~Hiah Ea1ar {HggfQEmargatuz Elan 2.~Lmr Ggtaafthguaa Eutar Lml 2.22k jhdhatfujtaEmftrmmmEan 6 BGEEGBBkmtiun3.22M

5. EEE22Qbiujftjag MfttftgLghgigul Qutuuftfj Eerguata age thiar ~ jn Eamtafuz Em Maaamaat S. Jntamjfhabhmm "Gataanhgffaa Buna Bar Eater LmLfjutafj 2BM IaIatfy. Ebita {tgmYElliamEhuin uftd daffm Emlumj 26

I Plant Specific EAL C+leline (A,H,S)

R.E. Ginna IC¹'A2 Fire or explosion affecting the operability of plant safety systems required to establish or maintain safe shutdown.

Op. Mode Applicability Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All HA2.1 The following conditions exist:

a. Fire or exphsion in any of the foliowi areas:

AND

b. Affected system parameter indications show degraded performance or plant personnel report visible damage to permanent structures or equipment within the struc'tufes of equipment within the specified area.

27

Bases N All&&'""'"'" "" " " ""~W Plant Specific EAL C+leline (A,H,S)

R.E. Glnna lB EIE"" '

consulted tor equipment and plant areas required for the applicable mode. This will make it easier to determine if the fire or explosion is potentially affecting one or more redundant trains of safety systems. Escalation to a higher emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad Releases/Radiological Effluent, or Emergency Director Judgement ICs.

With regard to exptosions, only those exphsions of sufficient force to damage permanent structures or equipment required for safe operation within the identified plant areas should be considered. As used here, an explosion is a rapid, violent, uncontined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to nearby structuresandmaterials. Theindusionota reportofvisibledamage shouldnotbeinterpretedasmandatingalengthydamageassessmentpriortoclassification. Noattemptismadeinthis 5llggY~ gmgrgftttgy. QggtfjnglgQOicoctoc with the resources needed to perform these damage assessments. The any security aspects of the exptosions, if applicable.

~

EAL to assess the actual magnitude of the damage. The occurrence of the exphsion with reports ot evidence of declaration of an Alert and the activation of the TSC will provide'the5bift 5gg~gt; {pmgrgtttlgy Qggt~1gQOirectoc also needs to consider 28

Plant Specific EAL Cdeline (A,H,S)

R.E. Ginna lCk HA3 Release of toxic or flammable gases within a facility structure which Jeopardizes operation of systems required to malntaln safe operations or to establish or maintain cold shutdown.

Op. Mode Applicability 01(pwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) +All HA3.1 HA3.2 Report or detection of toxic gases within a~ttilftlyjttgfacility structure in concentrations Report or detection of flammable gases within a tbfLittil~~ in concentrations that

'that will be life threatening to plant personnel: will QEgllldR RKRK lg, flgdgmftat QK~tty. far~ the safestructure operation of the plant:

29

Plant Specific EAL (deline (A,H,S)

R.E. Ginna Bases This IC is based on gases that have entered a plant structure gfftgjtffjjftg ~ g ftftg~~

ftfttfjgfftftg 5ZMecting the safe operation of the plant. This IC applies to buildings and areas contiguous to plant vital areas or other significant buildings or areas (i. e., Service Water Pump house). The intent of this IC is not to include building. (i. e., v:err h~ u>> ") r:r ".her:.

not contiguous or immediately adjacent to plant vital areas. It is appropriate that increased monitorino be donr. <

r; r "..- '. ", e emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad ReleasesIRadioiogical Effluent, or ~r ~~vi gr ft~rn r~ny QQQLdjmfaQ4irector Judgement ICs.

30

Plant Specific EAL (eline (A,H,S)

R.E. Ginna IC¹: HA4 Security event ln a plant protected area.

Op. Mode Appllcablllty Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) 06(Defuel) ~ All HA4.1 HA4.2 Intrusion into plant protected area by aft gtdymaZ~Ne-force Other security events as determined from+ite~eeifie)

Contingency Plan.

31

Plant Specific EAL (eline (A,H,S)

R.E. Ginna Bases This class of security events represents an escalated threat to plant safety above that contained in the Unusual Event. For the purposes of this IC, jft~tjga Q fta~iilftfj~gmgrZftj 1hz

~

protected area boundary can be considered g ~fjfdttlf~IILjIII,ijIZ@Mtostih-force. Intrusion into a vital area by~tila4orco ftftattfitgrj~

gmttaaftj will escalate this event to a Site Area Emergency.

32

0 Plant Specific EAL ( eline (A,H,S)

R.E. Glnna fC¹: HA5 Control room evacuation has been initiated.

Op. Mode Applicability Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All HA5.1 Entry into evacuation.

g ~~ ~i;~~jjjttt.for control room 33

Plant Specific EAL Celine (A,H,S)

R.E. Ginna Bases With the control room evacuated, additional support, monitoring and direction through the Technical Support Center and/or other Emergency necessary. Inability to establish plant control from outside the control room will escalate this event to a Site Area Emergency.

Qg>~ QgjJj~

34

Plant Specific EAL C+leline (A,H,S)

R.E. Ginna IC¹'A6 Other conditions existing which ln the judgement of the gllfiQ~ryhgr QQner(gllQL 44-eetet: warrant declaration of an Alert.

Op. Mode Appllcablllty Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All HA6.1

,Other conditions existing which in the judgement of the Quiff QggttLttjgz gmgrggngy QgggfjgggQoirector indicate that plant safety systems may be degraded and that increased monitoring of plant functions is warranted.

35

Plant Specific EAI Celine (A,H,S)

R.E. Ginna Bases This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Quiff QgftftrttjgZ LEmergency Coordinator) to fall under the Alert emergency class.

36

Plant Specific EAL Celine (A,H,S)

R.E. Ginna IC¹: HS1 Security event In a plant vital area.

Op. Mode Applicability Q1 (Pwr Ops) 0 2 (HSB) D 3 (HSD) 04 (CSD) 05 (Refuel) Q 6 (Defuel) g All HS1.1 Intrusion into IhL(ttiittttflttgplant Mmnirmd hz itm Gmuily.lhiklugtttiaZ:

~ttrily. vital are~ by hatt atitt~gpJ a4tostite4orce ~

HS1.2 Other security events as determined from(eit~pecNe)

Contingency Plan.

~ ~~Mfeguarde-37

Plant Specific EAL C+eline (A,H,S)

R.E. Ginna Bases This class of security events represents an escalated threat to plant safety above that contained in the Alert IC in that m~grztry.~ progressed from the protected area to the vital area.

ItmQinaaurfthzhd muQuodzx hilim~mflmM ~law Ehfaauzft; 38

0 Plant Specific EAL Ctleline (A,H,S)

R.E. Ginna ICttf: HS2 Control room evacuation has been initiated and plant-control gf ~ gggJJng cannot be established.

Op. Mode Applicability 01(PwrOps) Q2(HSB) 03(HSD) 04(CSD) 05(Refuel) 06(Defuel) ~ All HS2.1 The folhwing conditions exist:

a. Control room evacuation has been initiated.

AND J. ~~~

b. Control of aZJing the~nt cannot be established per ]eit~pecific~ocedure Jtht~gguttttltttt within (site-specific) + minutes.

39

Plant Specific EAL (deline (A,H,S)

R.E. Ginna Bases twas indicated.~~~~

~ ~

Expeditious transfer of safety systems has not occurred but fission product barrier damage may not yet be time for transfer ~ based on analysis or assessments ihk QBzhHlQ1 1tmR fQC Ehhh Q?Qtfgl Q1 QIRQt ~iftm'.I trullgn{fgr ~~

as to how quickly control must be reestablished without core uncovering and/or core damage. Qiana bugftQdQI B mbmiifal iadimim 1bat 29 miQtt QQQdtitQQz In cold shutdown and refueling modes, operator concern is directed toward maintaining core cooling such as is discussed in Generic Letter 88-17, "Loss of Decay Heat Removal." In power operation, hot standby, and hot shutdown modes, operator concern is primarily directed Abnormal Rad Releases/Radiological Effluent, or ~ ~~gi toward maintaining critical safety functions and thereby assuring fission product barrier integrity. Escalation of this event, if appropriate, would be by Fission Product Barrier Degradation,

{~gfLnnQggL~i.i~) director Judgement ICs.

With respect to protection of the public and safe plant operations, "plant control" must focus primarily on the ability to maintain the reactor in a cooled condition. Therefore, it is appropriate to change the IC and EAL so fhat it emphasizes the need for core cooling when controlling the plant from outside the Control Room.

h~Qmfrul Emm JQQggft:mhiliiy.

humdixB Rmiha~ uamkX 40

Plant Specific EAL Cbeeline (A,H,S)

R.E. Ginna IC4: HS3 Other conditions which ln the judgement of the Shift Qg?gnhar {EGEKQQIEy. Qkreetet: warrant declaration of Site f

Area mergency.

Op. Mode Appllcablllty Q1 (Pwr Ops) 0 2 (HSB) 0 3 (HSD) Q 4 (CSD) Q 5 (Refuel) 0 6 (Defuel) ~ All HS3.1 Other conditions which in the judgement of the Qhif1 Qlgtttttjsftr {EmargtLzy. Quardjtta~

Director warrant declaration of Site Area Emergency.

41

Plant Specific EAL C+leline (A,H,S)

R.E. Ginna Bases This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the 5hjft 5gguyjaZ {Emgggnay. Q~djttalgQOirectoc to fall under the emergency class description for Site Area Emergency.

42

Plant Specific EAL Celine (A,H,S)

R.E. Glnna IC¹'G1 Security event resulting In loss of ablllty to reach and maintain cold shutdown.

Op. Mode Applicability Q1 (PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5 (Refuel) 0 6 (Defuel) ~ All HG1.1 Loss of ftlattt+yefeaI control of BHI2

~ the control room due to security event.

HG1.2 Lumaf uhniml match 81!tft.rmmh Cuddmfft muahiltIX the h mmrhr fLffLIL 43

Plant Specific EAL deline (A,H,S)

R.E. Ginna Bases This IC encompasses conditions under which a hostile force has taken physical control of vital area required to reach and maintain safe shutdown.

Mitffttttniht amahr M.

Iht ~nf;ftglhtfft5, iby.

mf maiaiain am au!ing. Itmrftfftrftihh lm bftftn mttdiM cahot a af @leaf ma1ud fern hnih iht matral arm mf ftunatift Mifhtlfnuanah.

0 im

~ gf ~ in 44

Plant Specific EAL (deline (A,H,S)

R.E. Ginna IC¹: HG2 Other conditions existing which In the judgement of the Qblft 51gpZyiagj: QIBKggrmy Qkreeter warrant declaration of General Emergency.

Op. Mode Applicability 01(PwrOps) 02(HSB) 03(HSD) 04(CSD) 05(Refuel) 06(Defuel) QAII HG2.1 Other conditions existing which in the judgement of the Rllf1 Glg9LYIRZ (EKQlQQQt'Y QgzfjglgQ Director indicate: (1) actual or imminent substantial core degradation with potential for hss of containment, or (2) potential for uncontrolled radionuclide releases.

These releases can reasonably be expected to exceed EPA PAG plume exposure levels outside the site boundary.

45

Plant Specific EAL deline (A,H,S)

R.E. Ginna Bases This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the R1Jff SQSYhQI {Etmrgttttgy. Qggrdiaa1gQOirectoc to fall under the General Emergency class.

46

Plant Specific EAL (deline (A,H,S)

R.E. Ginna IC¹: SU1 Loss of all offslte power to essential busses for greater than 15 minutes.

Op. Mode Applicability Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII SU1.1 The following conditions exist:

0

a. Loss of power to~~peeNe):

Raiiun httttIIIaulmmfzmr 32k Ratha hmEiau Xrmhum 1KB for greater than t5 minutes.

AND M

i IBIS i!I lliIIKiiil 47

Plant Specific EAL (kleline (A,H,S)

R.E. Gtnna Bases Prolonged loss of ~AC power ~fling~ reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete loss of AC power (station blackout). Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

EGA BGEZ

~ Ehgldml DhlfihuiigttMlftfn" 3$ BL Qhlrihulign 48

Plant Specific EAL deline (A,H,S)

R.E. Ginna ICk SU2 Inability to reach required shutdown within Technical Specification Llmnlt.

Op. Mode Applicability 51 (Pwr Ops) ~ 2 (HSB) 5 3 (HSD) Q 4 (CSD) Q 5 (Refuel) Q 6 (Defuel) 0 All SU2.1 Plant is not brought to required operating mode withiQeite-speeNc) Technical Specifications LCO Action Statement Time.

49

Plant Specific EAL 'deline (A,H,S)

R.E. Ginna Bases Limiting Conditions of Operation (LCOs) require the plant to be brought to a required shutdown mode when the Technical Specification required configuration cannot be restored. Depending on the circumstances, this may or may not be an emergency or precursor to a more sever condition. In any case, the initiation of plant shutdown required by the site Technical Specification requires a one hour report under 10CFR50.72 (b) non-emergency events. The plant is within its safety envehpe when being shut down within the alhwable action statement time in the Technical Specifications. An immediate Notification of an Unusual Event is required when the plant is not brought to the required operating mode within the allowable action statement time in the Technical Specifications. Declaration of an Unusual Event is based on the time at which the LCO-specified action statement time period elapses under the site Technical Specifications and is not related to how hng a condition may have existed. Other required Technical Specification shutdowns that involve precursors to more serious events are addressed by other System malfunction Hazards, or Fission Product Barrier Degradation ICs.

Ieahaiaal5uft&m1iuulm;Ihn XQ 50

Plant Specific EAL 'deline (A,H,S)

R.E. Ginna ICO: SU3 Unplanned loss of most or all safety system annunciation or indication In the control room for greater than 15 minutes.

Op. Mode Appllcablllty 01(PwrOps) %2(HSB) 03(HSD) Q4(GSD) Q5(Refuel) Q6(Defuel) QAII SU3.1 The following conditions exist:

annunciators gL ~ggfj~

stems. for greater than 15 minutes.

AND

c. In the opinion of the Shift Supervisor, the hss of the annunciators or indicators requires increased surveillance to safely operate the unit(s).

AND

d. Annunciator or indicator loss does not result from planned action.

51

Plant Specific EAL deline (A,H,S)

R.E. Ginna BaSeS This IC and its associated EAL are intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment.

Recognition of the availability of computer based indication equipment is considered (SPDS, plant computer, etc.)

"Unplanned'oss of annunciators or indicator exdudes scheduled maintenance and testing activities.

dagjarafiannf an hhui hami nn )bier ~

specific plant design and subsequent retrofits. ~ ~"

Compensatory non-alarming indications: in this context includes computer based information such as SPDS . This should include all computer systems available for this use depending on dASd h II It is not intended that plant personnel perform a detailed count of instrumentation hst but ihft use gf ~tu~ judgement hy ~ Qjff ~ftnt~ ~ ibft threshold for determining the severity of the plant conditions. This judgement is supported by the specific opinion of the Shift Supervisor that additional operating personnel will be required to provide increased monitoring of system operation to safely operate the unites).

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicatois should remain a function of that specific system or component operability status. This will be addressed by their specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument hss will be reported via 10CFR50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on SU2, Inability to Reach Required Shutdown Within Technical Specification Limits."

~~pocITIc) Annunciators ~ac4ca~ for this EAL must include those identified in the Abnormal Operating procedures, in the Emergency Operating Procedures, and in other EALs (e. g., area, process, and/or effluen1 rad monitors, etc.).

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Due to the limited number of safety systems in operation during cold shutdown, refueling, and defueled modes, no IC is indicated during these modes of operation.

This Unusual Event will be escalated to an Alert if a transient is in progress during the loss of annunciation or indication.

52

Plant Specific EAL Cleline (A,H,S)

R.E. Ginna IM SU4 Fuel clad degradatlon.

Op. Mode Appllcablllty Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All SU4.1 SU4.2 readings > 2 R/hr 44ieatwg-fvel- (Sit~peeifie)-coolant sam pie activity

~af RSE uQlamhfalmmTtt'adiYi1x

~ uQilam dam atttthtalttnt L131 anti lhtt auditiana nf Iaah.Guar ~3h are muttt<ittti 53

Plant Specific EAL Cdeline (A,H,S)

R.E. Ginna Bases This IC is induded as an Unusual Event because it is considered to be a potential degradation in the level of safety of the plant and a potential precursor of more serious problems.

EAL ¹~1 hhhmllaftmgahgf: madim {2Ebdmhhhmmmuh M1I fed failumlhzmhr iha~5mm.~ aadiilxfimihL EAL ¹~ addresses coolant samples exceeding pr'oduct barrier degradation monitoring ICs.

foal gzai fig aaalam aalht'IIy. ~ coolant technical specifications Escalation of this IC to the Alert level is via the fission Bahrftagft; J. Zxh5ummihn ~

2. L2$adiaIign Hgnagnag Gxaittm.

3. ERE &165zfiua L21h 54

Plant Specific EAL Celine (A,H,S)

R.E. Ginna ICO: SU5 RCS leakage.

Op. Mode Applfcablllty %1(PwrOps) 52(HSB) g3(HSD) Q4(CSD) 05(Refuel) 06(Defuel) DAII SU5.1 Either of the following conditions exist:

a. Unidentified or pressure boundary leakage greater than 10 gpm OR

b. Identified leakage greater than 25 gpm.

55

Plant Specific EAL Celine (A,H,S)

R.E. Ginna Bases This IC is included as an Unusual Event because it may be a precursor of more serious conditions and, as a result, is considered to be a potential degradation of the level'of safety of the plant.

The 10 gpm value for the unidentified and pressure boundary leakage was selected as it is observable with normal control room indications. Lesser values must generally be determined through time~nsuming surveillance test (e. g., mass balances). The EAL for identified leakage is set at a higher value due to the lesser significance of identified leakage in comparison to unidentified or pressure boundary leakage. In either case, escalation of this IC to the Alert level is via Fission Product Barrier Degradation ICs or IC SA3, "Inability to Maintain Plant in Cold Shutdown."

Only operating modes in which there is fuel in the reactor coolant system and the system is pressurized are specified.

56

Plant Specific EAL Celine (A,H,S)

R.E. Ginna lC¹: SU6 Unplanned loss of all onslte or offslte communications capabllltles.

Dp. Mode Appllcablllty 0 1 (Pwr Ops) 0 2 (HSB) 0 3 (HSD) 0 4 (CSD) Q 5 (Refuel) 0 6 (Defuel) g All BU6.1 Either of the following conditions exist:

a. Loss of allgsi~peciffc-fist) rt~rtii~arr onsite communications capability affecting the ability to perform routine operations:

Hant tfthithrtrmmtftm; trtuddum dial mtttm.iatftdmumi1b Elms aumf Ntttrttmd pram sfuttliaamtttr uruut

@nlrb rrtgm tu iffy rrtrtm. mat tiamttat an1rul reunite turhiaft huiidiart zotel reunite BRkEEatm Quftru1hm

~ auttiTiaz huiidiart aad iaittrmttdiah huilditttr antzl raun trt Emftrgmzr Rum Qaahr QhdiaLirta Eian rtahQ h I ~ h hd OR x

Ihl' 'R Loss of allgsite~ecific-list) rtLtitfL(glitatijmroffsite communications capability:

I C

EtnftiltftamHatifiuatha Sxahmihz t;ttmmuaimtiaa

~Emir Ha!mate

~

l8EQRl HBQl Jurat tfthrtttttafr mtmn; tazb~ dial mhm Hhhamiatatiaar.

aatral amm hdaun BGKiJafr Qrtftraittr EQ.Etnftrrrftamkzm Qmhcaad Rarity. Qffim~~i 1aIIm 57

Plant Specific EAL Celine (A,H,S)

R.E. Ginna Bases The purpose of this IG and its associated EALs is to recognize a toss of communications capability that either defeats, the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate problems with offsite authorities. The loss of offsite communications ability is expected to be significantly more comprehensive than the condition addressed by 10CFR50.72.

radios/walkie talkies).

i'"I.',

Z and dedicated EPP phone systems. This EAL is intended to be used only when extraordinary means are being utilized to make communications possible (relaying of information from radio transmissions, individuals being sent to offsite locations, etc.).

58

Plant Specific EAL Celine (A,H,S)

R.E. Ginna IC¹: SU7 Unplanned loss of required DC power during cold shutdown or refueling mode for greater than 15 minutes.

Op. Mode Applicability Q1(PwrOps) Q2(HSB) Q3(HSD) S4(CSD) S5(Refuel) Q6(Defuel) QAII SU7.1 Eftfter ~ of the folhwing conditions exist:

a. Unplanned hss of vital DC power to required DC busses based on-(ei~peeNe) ~<

bus voltage indications

o. Failure to restore power to at least one required DC bus within 15 minutes from the time of loss.

59

Plant Specific EAL Celine (A,H,S)

R.E. Ginna BaSeS The purpose of this IC and its associated EALs is to recognize a hss of DC power compromising the ability to monitor and control the removal of decay heat during cold shutdown or refueling operations. This EAL is intended to be anticipatory in as much as the operating crew may not have necessary indication and control of equipment needed to respond to the loss.

Unplanned is included in this IC and EAL to preclude the declaration of an emergency as a result of planned maintenance activities. Routinely plants will perform maintenance on a train related basis during shutdown periods. It is intended that the loss of the operating (operable) train is to be considered. If this hss results in the inability to maintain cold shutdown, the escalation to an Alert will be per SA3 Inability to Maintain Plant in Cold Shutdown."

+~peciTic) ~ bus voltage shoukLbo 5 based on the minimum bus voltage necessary for the operation of safety related equipment. This voltage value should incorporate a margin of at least 15 minutes of operation before the onset of inability to operate those hads. This voltage is usually near the minimum voltage selected when battery sizing is performed. Typically the value for the entire battery set is approximately 105 volts per cell. For a 56 string battery set the minimum voltage is typically 1.81 volts per cell.

~GER Jna1ftamm1 Guam'G Bmr kulmlL 60

Plant Specific EAL Cleline (A,H,S)

R;E. Ginna fC¹: SA1 Loss of all offslte power and loss of all onslte AC power to essential busses during cold shutdown or refueling mode.

Op. Mode Applfcablllty Q1(PwrOps) Q2(HSB) Q3(HSD) 54(CSD) ~ 5(Refuel) 06(Defuel) QAII SA1.1 The folhwing conditions exist:

a. Loss of power t<eitrH peeTiie):

Rathnhtfttifiarzlrmfzmar 32B, 859 Rathn huzilizxlraaafutmftL 129

~ ~

AND

o. Failure of/sit~pacific)ttglb @~gftftgy ammlmfmfmaurda hum LEDG3hl azf 16QZ LEDG1Bl AND

= Failure to restore power to busses ~gQQ~QQ~gQQ3fQ~ea~ne emergency-bua within 15 minutes from the time of loss of both oflsite and onsite AC power.

61

Plant Specific EAL Cleline (A,H,S)

R.E. Ginna BaSeS Loss of all AC power compromises all plant safety systems requiring electric power including RHR, ECCS, containment heat removal, Spent Fuel Heat Removal and the Ultimate Heat Sink. When in cold shutdown, refueling, or defueled mode the event can be classified as an Alert, because of the significantly reduced decay heat, lower temperature and pressure, increasing the time to restore one of the emergency busses, relative to that specified for the Site Area Emergency EAL. Escalating to the Site Area Emergency, if appropriate, is by Abnormal Rad Levels/Radiological Effluent, or 5455gggryjg~ ~~gggy QgftffgggfgQOirectoc Judgement ICs. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

62

Plant Specific EAL Celine (A,H,S)

R.E. Ginna ICS: SA2 Failure of Reactor Protection system Instrumentatlon to complete or Initiate an automatic reactorwefatR Protection system setpolnt has been exceeded and~r manual+eram~rf was not successful,

~ once a Reactor.

Op. Mode Appllcablllty %1(PwrOps) 82(HSB) Q3(HSD) 04(CSD) Q5(Refuel) Q6(Defuel) QAII BA2.1 sxcssdsd-and-automatic-scrarndid~t-occu~nd-a-succsssfu4nanuaaoccurred QBBHGKur BPJ? ualhinHL12dzrilimlih s!Od Emarattam fhra1hn ia LttauiuuL 63

Plant Specific EAL 6'.eline (A,H,S)

R.E. Ginna bye

~

3ases fallowed XhhEiM.addmamnnxmanunl triaar adam.ttia tria2anal manunl triatMhiah faihia~daxrn tharttnatar farm ttrtttntrttattirinartmttraItnaxhaintlan.

this condition indicates failure of the automatic rnnnunt protection system to tria ceram the reactor ia thtt attaint ttrhiah azatudtu thtt rttnataihttina metr ~ritiant. This condition is more than a potential degradation of a safety system in that a front line automatic protection system did not function in response to a plant transient and thus the plant safety has been compromised, and design limits of the fuel may have been exceeded. An Alert is indicated because conditions exist that lead to potential ioss of fuel clad or RCS.

A manual tria~

tny set of actions by the reactor operator(s) at the reactor control console which causes control rods to be rapidly inserted into the core and brings the reactor subcritical (e. g., reactor trip is sutton).

Ihia IG andrmultina EhL hnxtt httttn mttaifianllx madifittd ia marut nauratttlx dttIina that aanditian dmqihttdhx the tatnttria haau aa naalittdia armurizmf mahr rttnatm. aha fnituirt af rutamatiainitiutianaf nrtmataiiria faliatxttdhx 2taamful manual inItIutian adiuu xrhiah annhtr ruuidix tultttnut thtt atnatar aantraf mmh dumnat mmnaatttntinlhmaf aiIhttr futtf aindar fit 3QR haundarta.

2KQMllzL,thttirt hLt httttnrt fniturtr Ia ~ ~

the aantinuItd aritianiitx undttr aaziitium rttauirina n amid mum ttthiah mum thtt aatttntinl thrift ia BSQ ar fuff aloof intttarilx. lfnn QBBHGE aath mhh an HU.

daxm thtt rtt~ar. hut xtithaut mhstnntial htmt attnttratian. IhKdt aanditiatm rttarrt2tnt n aattIntiuf Rm af that furtf alnd haunrIntx. and r dttaiarntian af hiEBL QKGI Guharitianlitx = QBB5GE aath ia antttrM bmoc an faitum af this intttrmttdiattr runnier ibad ~rant rah rnanihm ia indiautrt nttantixtr ar um fallaxtina atnaIar triL 6 utdaf it2tif.a arttaurm 1a foehn araduat harnttr Narmhtian. Ihtr EZR aitum in thtr BPR mhm ann huxrt na chai immL lf immmHattr mununl ~~

na athttr funatian hut ta initial ittnatai trim. IftttrItIarit.anat'ie ~

nanual tria ia anx aa1 af acthna ttx thtt rttnatar aartrutarLQ nt Iha atnatai aantral micah xrhiah meal aantral cub labia raaidix imttrtttd inta that aarrt nnd hriaaa thtt maatar mharitianl fKa nnatar iria huttan). fi h ahu imaartanl 1a naia that tha hiturtt af thtt rttnatar aratttatian mbun la initialtt nn nutaa+tia iria dam na1 infttr actual ar aatltial failure af athrtr

~ mm mba nar h i1. in hu hutn zumuullx triaattd.

ta tna thtt amhz nrtt 2zmfuf faliaxrina utaagnitian af nn nutatnatia 1ria failure thm ia na thrift la alant ashlar Qmhaaraduat intttgritxrttlatttdta tlmnutamatiairia faiturtt. IbhMiatianhamhtttnt niththis ahiia2ahxafmahna naaurn!tr n.aan2tixntixrt af~iTiantL~m.

'LR1 HL1 ~ritianlity Mmnaata Baaatar Bate!hI5Z

l. EEL%2 Jhmaan2t taLmaaf Qm2tutdann.

64

Plant Specific EAL 0'eline (A,H,S)

R.E. Ginna ICN: SA3 Inablllty to malntaln plant In cold shutdown.

Op. Mode Appllcablllty Q1(PwrOps) Q2(HSB) Q3(HSD) ~ 4(CSD) g5(Refuel) Q6(Defuel) QAII SA3.1 The following conditions exist:

b. HttKtttt: aglgnt temperature increase that either:

~ Exceeds 200 'F OR

~ Results in uncontrolled temperature rise approaching 200 'F 65

Plant Specific EAL C'eline (A,H;S)

R.E. Ginna BaSeS This EAL addresses complete loss of functions required for core cooling during refueling and cold shutdown modes. Escalation to Site Area Emergency or General Emergency would be via Abnormal Rad Levels/Radiological Effluent or ggtgggftftf~[E8tttrg@~Qggrding~QuMoc Judgement ICs.

For PWRs, this IC and its associated EAL are based on concerns raised by Generic Letter 88-17, "Loss of Decay Heat Removal." A number of phenomena such as pressurization, vortexing, steam generator U-tube draining, RCS level differences when operating at a mid-hop condition, decay heat removal system design, and level instrumentation problems can. lead to conditions where decay heat removal is lost and core uncovery can occur. NRC analyses show that sequences that can cause core uncovery in 15 to 20 minutes and severe core damage within an hour after decay heat removal is lost. Under these conditions, RCS integrity is lost and fuel clad integrity is hst or potentially lost, which is consistent with a Site Area Emergency. QSIt~cific) indicators for these EALs are those methods used by the plant in response to Generic Letter 88-17 which include core exit temperature monitoring and RCS water level monitoring. In addition, radiation monitor readings may also be appropriate as an indicator of this condition.

"Uncontrolled means that system temperature increase is not the result of planned actions by the plant staff.

The EAL guidance related to uncontrolled temperature rise is necessary to preserve the anticipatory philosophy of NUREG-0654 for events starting from temperatures much hwer than the cold shutdown temperature limit.

Escalation to the Site Area Emergency is by IC SS5, "Loss of Water Level in the Reactor Vessel that has or will Uncover Fuel in the Reactor Vessel, or by Abnormal Rad Levels/Radiological Effluent ICs.

1. hEJ3BE1 Jam'UR

2. Iaahkmm. 2tgtign12

3. hE3HE2~af EiB5hihQmaliaud BftduzfiKR htfftgfgiy.Qzdiliz:~

66

Plant Specific EAL Cieline (A,H,S)

R.E. Glnna IC¹: SA4 Unplanned loss of most or all safety system annunciation or indication In control room with either (1) a significant transient In progress, or (2) compensatory non-alarming Indicators are unavailable.

Op. Mode Applicability 51(PwrOps) g2(HSB) g3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII SA4.1 The folhwing conditions exist:

a. Loss of most or ail-(eft~peelfie) annunciators for greater than 15 minutes.

AND x In the opinion of the Shift Supervisor, the loss of the annunciators or indicators requires ncreased surveillance to safely operate the unit(e).

AND Annunciator or indicator loss does not result from planned action.

AND

f. Either of the following:

~~

~ A significant plant transient is in progress OR tlons are fs unavailable.

67

Plant Specific EAL Gleline (A,H,S)

R.E. Ginna BaSeS This IC and its associated EAL are intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a transient. Recognition of the availability of computer based indication equipment is considered (SPDS, plant computer, etc.).

"Planned loss of annunciators or indicators included scheduled maintenance and testing activities.

It is not intended that plant personnel perform a detailed count of the instrumentation hst but ~ use gf thavatu~ judgement +~ ~~@~~~~

threshold for determining the severity of the plant conditions. This judgement is supported by the specific opinion of the Shift Supervisor that additional operating personnel will be required to provide increased monitoring of system operation to safely operate the unit(s).

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is induded in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10CFR50.72. If the shutdown'is not in compliance with the Technical Specification action, the Unusual Event is based on SU2 "Inability to Reach Required Shutdown Within Technical Specification Limits.

(Si~pectTie) Qnnunciators ~dicatcue for this EAL must include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e. g.,

area, process, and/or effluent rad monitors, etc.).

'Significant Transient includes response to automatic or manually initiated functions such as scrams, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power oscillations of 10% or greater.

'Compensatory non-alarming indications in this context includes computer based information such as SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits. If both a major portion of the annunciation system and all computer monitoring are unavailable to the extent that the additional operating personnel are required to monitor indications, the Alert is required.

Due to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes. No IC is indicated during these modes of operation.

This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor the transient in progress.

68

Plant Specific EAL Celine (A,H,S)

R.E. Ginna C¹: SA5 AC power capability to essential busses reduced to a single power source for greater than 15 minutes such that any additional single failure would result in station blackout.

Dp. Mode Applicability 51(PwrOps) g2(HSB) 53(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII 3A5.1 has-bean degraded-to one (train-of)emergency%us(ses)powered.

KG3h KG3B Raliun hmI!Inn'rmhrfnrtr 32k Raiiunhuziliuu jrmuhrrnftr 32B 69

0 Plant Specific EAL leline (A,H,S)

R.E. Glnna BaSeS This IC and the associated EALs are intended to provide an escalation from IC SU1 "Loss of All Offsite Power to Essential Busses for Greater than 15 Minutes." The condition indicated by this IC is the degradation of the offsite power with a concurrent failure of one emergency generator to supply power to its emergency busses. Another related condition could be the loss of all offsite power and hss of onsite emergency diesels with only one train of emergency busses beingbadcfed from the unit main generator, or the loss of onsite emergency diesels with only one train of emergency busses being backfed from offsite power. The subsequent loss of this single power source would escalate the event to a Site Area Emergency in accordance with IC SS1 "Loss of All Offsite and Loss of All Onsite AC Power to Essential Busses."

Example EAL ¹~1b should be expanded to identify the control room indication of the status gf offsite-specific power sources and distribution busses that, if unavailable, establish a single failure vulnerability.

~GHi~EhafriaulDhiohu1igrC

'GE2.~ DhifihdkuL 70

Plant Specific EAL 9/eline (A,H,S)

R.E. Ginna f(A:. SS1 Loss of all offslte power and loss of all onslte AC power to essential busses.

Op. Mode Appffcablffty 51 (PwrOps) ~ 2(HSB) g3(HSD) Q4(CSD) Q5 (Refuel) Q6(Defuel) QAII SS1.1 The folhwing conditions exist:

a. Loss of power tQslt~peeifie):

RatiunhuzI!IauIHimfzamr 32h G1a1iunhuziTimIrmhrmar 32R AND .

b. Failure of~~peeiTie) emergency-generators-are-supplying-power-to.

AND

c. Failure to restore power to within 15 minutes from the time of loss of both offsite and onsite AC power.

71

0

~,

'rohnged Plant Specific EAL 8eline (A,H,S)

R.E. Ginna Bases Loss of all AC power compromises all plant safety systems requiring electric power hss of all AC power will cause core uncovering and loss of containment integrity, thus this event can escalate to a General Emergency. Th+sit~eci~ time duration should be selected to exclude transient or momentary power losses, but should not exceed 15 minutes.

lJ3EQ=R~EhglfhalDhirihu1ha5+haL

'ERZ~DvdabuhgfL 72

Plant Specific EAL G'eline (A,H,S)

R.E. Ginna lCS: SS2 Failure of Reactor Protection system Instrumentatlon to complete or Initiate an automatic reactor~et'am~ once a Reactor, Protection system setpolnt has been exceeded and~r manual ~us~rl was not successful, ~nLhh @ger gggggglgg,

~l Op. Mode Appllcablllty %1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII BS2.1 73

Plant Specific EAL 0 ',eline (A,H,S)

R.E. Ginna Bases Ihia Qgotfitlgn addlaaaQK hemaouaf trfnrtr autttmath tria mgoal fttltunftdhx a manual trirt nbhhfaih tn ahut dmtn tha raptor.

M2 Hmtgr aztfar ~Pl Automatic and manual scram are not considered successful if action away from the reactor control console was required to scram the reactor.

QKGl Guhglitigality. = BED itath la Ihla ggndithn iodigataa faihla ttfhtih thft autttmatir. and manual rtztat;titn mba'n

~

totttrad haaftd an faituia rtf canal rantm iodimtittn trt dftgrftaaa htioMt Pl hlIttttttiog a ttmtar tliL Ihh aurtion rtf tha'M.addlftaaftamxmaoual tritt rtr auIomatio tlirtaignal fttlittmad bxa manual trio tithe faih trt ahut dttMtn lha ttactttr tn an atttaot that iha rotor ia nmiuoiotr mala haat had for lha aafatx atratatoa ttrara dttaigrtarL trin tha ftagtttr in mmuztignm1h a faitula rtf altaroata hzatign atratama tn lftduga laager anted tafttttf damhftat iatrftla. Iha atmttioatittn gf faituia ttf ttgth flrtot lina aod hadutn ltrttttmtign mtftma M fmzthn in raanrtnaa trt a afaot tran:~t. aittna tffithlha mntirtuadurudugtirtn af htat rtnaaa a dimt thlaat tn fuftfofad and BQR iotttgrittr and thua marraoh daglaratign 8 a 2h Bam Eatargangy.

15 minutaa la altaiTiad ta aiittMt timtt fttr marganrr bttratittn ttt tta afftztira and arntridfta a diagrimioatttr hatmttan RQJ. aod GSK1.

that amalgaoaX httratittn ia nttt or tjttil!not ha affarJitta in rttdtzion taactttr trotter baittmt ~ Iha dz&ioatittn ahttuld ha mada aa attain aa it ia ait ttaraot Although this IC may be viewed as redundant to the Fission Product Barrier Degradation IC, its indusion is necessary to better assure timely recognition and emergency response.

~gangy QggidjnatttQ Oicoctor Judgement ICs.

Escalation of this event to a General Emergency would be via Fission Product Barrier Degradation or 5h5 ~iZZ

3. Hh1 ~zritioalh

2. ELR1 Jhaaugoaa @ Haagtgr Hmtart!BZMZ

3. QUR2 Jhuitnoaa ttt Lma ttf Qm Ghutduno 74

Plant Specific EAL (feline (A,H,S)

R.E. Ginna IC¹: SS3 Loss of all vital DC power.

Op. Mode Applicability g1(PwrOps) S2(HSB) ~ 3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII SS3.1 Loss of all vital DG power based on-(eit~peeifie) ~c~dt; bus voltage indications ~)25 for greater than 15 minutes.

75

Plant Specific EAL Qfeline (A,H,S)

R.E. Gtnna Bases Loss of all DC power compromises ability to monitor and control plant safety functions. Prolonged loss of all DC power will cause core uncovering and hss of containment integrity when there is significant decay heat and sensible heat in the reactor system. Escalation to a General Emergency would occur by Abnormal Rad Levels/Radiohgical Effluent, Fission Product Barrier Degradation, or Qh55gtfttttizg gmgrgtzgy. QgmjjttatgQQirectac Judgement ICs. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

3. HGE2 Jmfaunftai fbi'nd JK Emnu Guaulx Gnlfttn 76

Plant Specific EAL 6'eline (A,H,S)

R.E. Glnna ICO: SS4 Complete loss of function needed to achieve or maintain hot shutdown.

Op. Mode Applicability g1(PwrOps) g2(HSB) g3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII SS4.1 Complete loss of anygeite~eciffc) function required for hot shutdown m lzjjcalzf bg QEQ aaihaa HhKHE4ZRHK 77

Plant Specific EAL Cfeline (A,H,S)

R.E. Gfnna Bases This EAL addresses complete loss of functions, including ultimate heat sink and reactivity control, required for hot shutdown with the reactor at pressure and temperature. Under these conditions, there is an actual major failure of a system intended for protection of the public. Thus, declaration of a Site Area Emergency is warranted. Escalation to a General Emergency would occur by Abnormal Rad Levels/Radiological Effluent, Fission Product Barrier Degradation, or Shift 5ggfttttjaz fjmgrgatigy. QggttfitiafgQOirectoa Judgement ICs.

tuu gf atibgfjtiga!ity.h aumd,at tha2h ham Kauuumx fmJ hfdf. Ehl,25? Um gf mhm fmxtjgiiarttmir&tumaitihm hatafititfhttfa md' jna BED uathgnfba HEhI RHKQKSl.

78

Plant Specific EAL !eline (A,H,S)

R.E. Ginna IC4'S5 Loss of Q5L water level that has or will uncover fuel in the ~

Op. Mode Applfcablllty Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII SS5.1 Loss of RPV amafgr ~ water level as indicated by:

79

Plant Specific EAL 1eline (A,H,S)

R.E. Ginna Bases Under the conditions specified by this IC, severe core damage can occur and reactor coolant system pressure boundary integrity may not be assured.

N inward.

For PWRs, this IC covers sequences such as prohnged boiling following hss of decay heat removal.

llnantranr nf 1ha fual irraamfira nf fha a~ran1 1hat amm fual unauanr la rualiTiaafian ainna far daalarina a Sih hm Eamrmzx. 2rmrtfbar atranfa anuld laad fn fual unseal ahufdntlrn ar rafual n1har 1han a inaa nf dray. haal ramn~fal naaabiTitx. i1 ia inaaarartria1aln hm 1ha M. nn fhia nna a~ranf. Bz nthar r~rtara1ing mndaa. fuel unauanr fan lnaa rtf fha Qml Gad and BQR htarriara~ rartuiraa daalaralinn nf a2la ham Ernargane.

Thus, declaration of a Site Area Emergency is warranted under the conditions specified by the IC. Escalation to a General Emergency is via radiohgical effluence IC AG1.

80

Plant Specific EAL 'eline (A,H,S)

R.E. Glnna IC¹: SS6 Inablllty to monitor a slgnlf leant transient In progress.

Op. Mode Appllcablllty A1(PwrOps) g2(HSB) ~ 3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII SS6.1 All of the folhwing conditions exist:

a. Loss of-(eit~~fie) annunciators ~indi b.

AND AND

~ gad ~ ar~

c. Indications needed to monitor-(site-specific) aaft at maLftat unavailable.

Bftadz Bmtar. Intftrmftdiattt riagft 2lB.RurmBangft aumh. kum Bzgft RJK Qtm IQa. iadiaatiaa af BGEa ruaainL ELL5.BQR Ermm. AS HKQuld Lftg IftlaaftLattirft. M Hamm BaagaltaIIILEE Etta'.292mmra Qnataiamttat Pamitfft. Quataiamftat LtafftL Qantaiamttat Badiatian. PZB Ltatal AND

d. Transient in progress.

81

0 Plant Specific EAL 'eline (A,H,S)

R.E. Ginna BaSeS This IC and its associate EAL are intended to recognize the inability of the control room staff to monitor the plant response to a transient. A Site Area Emergency is considered to exist if the control room staff cannot monitor safety functions needed for protection of the public.

~~pec~ Annunciators for this EAL should be limited to include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e. g.,

rad monitors, etc.).

"Compensatory non-alarming indications in this context includes computer based information such as SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits.

Significant Transient includes response to automatic or manually initiated functions such as scrams, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power oscillations of 10% or greater.

Indications needed to monitor safety functions necessary for protection of the public must include control room indications, computer generated indications and dedicated

'~pec~

annunciation capability. The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled and in a eoolable geometry, to remove heat from the core, to maintain the reactor coolant system intact, and to maintain containment intact.

'Planned actions are excluded from this EAL since the hss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.

Bahrangft; 82

Plant Specific EAL R.E.

(

Ginna

'eline (A,H,S)

IClf: SG1 Prolonged loss of all offslte power and prolonged loss of all onslte AC power.

Op. Mode Applicability ~ 1(Pwrops) Q2(HSB) 53(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII SG1.1 Prolonged loss of all offsite and onsite AC power as indicated by:

a. Loss of power to ~-(eit~pecific):

~

RahabhuzIliuu Xrmfarmar12h Rathn huziTiauIramhzmfttl2B

b. Failure of~~pecific)

~ Restoration of

~>

c. At least one of the folhwing conditions exist:

hours is not Ikeiy at least one ~mtofjgf emergency bus within(cite-cpecifuc) g QHBHGE a BEDaathgtt &h? ~ QQQL59" 83

Plant Specific EAL 'eline (A,H,S)

R.E. Ginna BaSeS Loss of all AC power compromises all plant safety systems requiring electric power induding RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink. Prohnged loss of all AC power will lead to loss of fuel dad, RCS, and containment. The 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to restore AC power can be based on site blackout coping analysis performed in conformance with 10CFR50.63 and Regulatory Guide 1.155, 'Station Blackout, as available, with appropriate allowance for offsite emergency response. Although this IC may be viewed as redundant to the Fission Product Barrier Degradation IC, its inclusion is necessary to better assure timely recognition and emergency response.

This IC is specified to assure that in the unlikely event of prolonged station blackout, timely recognition of the seriousness of the event occurs and that declaration of a General Emergency occurs as early as is appropriate, based on a reasonable assessment of the event trajectory.

The likelihood of restoring at least one emergency bus should be based on a realistic appraisal of the situation since a delay in an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions.

In addition, under these conditions, fission product barrier monitoring capability may be degraded. Although it may be difficult to predict when power can be restored, it is necessary to give the Emergency Director a reasonable idea of how quiddy (s)he may need to declare a General Emergency based on two major considerations:

1. Are there any present indications that core aeling is already degraded to the point that Loss or Potential Loss of fission product barriers is imminent? (

frtfocmatio+

2. If there are no present indications of such core cooling degradation, how likely is it that power can be restored in time to assure that a loss of two barriers with a potential loss of the third barrier can be prevented?

Thus, indication of continuing core cooling degradation must be based on fission product barrier monitoring with particular emphasis on ~5ggftitfjmIIgmgigftZp QglZfifiaigQC4cectoc judgement as it relates to imminent loss or potential loss of fission product barriers and degraded ability to monitor fission product barriers.

fhlftrftilgft; 1 HL2.~QQQlJEG

2. 5fKLftiiftr@Dr.hlmmhda1mflP922 JK Qiana Helms Bmr Heal Gialhn hjmIIIhnulzmQIQbKM9l

2. BE%4~ Ehattiml Dhiiihuihn GXSIfun 6 BEGZ~Dhidhulign.

84

Plant Specific EAL 0'eline (A,H,S)

R.E. Ginna IC¹: SG2 Failure of the Reactor Protection System to complete an automatic scram and manual scram was not successful and there Is lndlcatlon of an extreme challenge to the ablllty to cool the core.

Op. Mode Appllcablllty 5 1 (Pwr Ops) Q 2 (HSB) 0 3 (HSD) Q 4 (CSD) Q 5 (Refuel) 0 6 (Defuel) Q All SG2.1 ul, AND

2. Either of the following:

85

Plant Specific EAL 'eline (A,H,S)

R.E. Ginna BaSeS Automatic and manual scram are not considered sucessful if action away from the reactor control console is required to scram the reactor.

Under the conditions of this IC and its associated EALs, the efforts to bring the reactor subcritical have been unsuccessful and, as a result, the reactor is producing more heat load for which the safety systems were designed. Although there are capabilities away from the reactor control console, such as emergency boration in PWRs the continuing temperature rise indicates that these capabilities are not effective. This situation could be the precursor for a core melt sequence. Qgf~5ghantlangy - QQQ anthhaatftrftff ~anta~

~

fnlturfr

~

af aalffftrrangfrintfiantfantatfftarftmahftlfntf@fallrntfinaa rfhratar triL Ihh aartlanaf thft EhL mhhtmam.manual trlaar nutmmtla tuamgfhtl fallanftffhlram tnualtdamhhh faih ffaMfn tharmlar 1aanalftftnt that thfrrfbtatarharaffuaiaamarft htnt far thfr whar.mhmlffftrfrsbulgnftff. Ihhaanffitlan indim1mhiturft afhath thft mtamatlalfinff annual aratftatlan axatmna ta tda the rftnatar in aaniunatian mith a fahrfr af altftrnutft harafian mtfum ta rftthafrrfmtar aamfftr hthm ffftany.blent lych.

For PWRs, the extreme challenge to the ability to cool the core is intended to mean that the core exit temperatures are at or approaching 1200 'F or that the reactor vessel water level is below the top of active fuel. For plants using CSFSTs, this EAL equates to a Core Cooling RED condition.

Another consideration is the inability to initially remove heat during the early stages of this sequence. For PWRs, if emergency feedwater fhw is insufficient to remove the amount of heat required by design from at least one steam geneator, an extreme challange shoul be considered to exist. For plants using CSFSTs, this equates to a HEAT Sink RED condition. EocBQlAa In the event either of these challenges exist at a time that the reactor has not been brought behw the power associated with the safety system design (typically 3 to 5% power) a core melt sequence exists. In this situation, core dedaration can occur rapidly. For this reason, the General Emergency declaration is intended to be anticipatory of the fission product barrier matrix dedaration to permit maximum offsite intervention time.

IM1~

2 Hh2.XQBEQQQlJH9

3. HL2 MBIRA KEKR1. Ehsuunaa ta Bftnatar BmtnrISIMtS 5.EELR2.Bmaanmr talmaf Qm5hutffam 86

Plant Specific EAL.ideline (FPB)

R.E. Ginna PWR FPB ICO: FC1 Barrier: Fuel Claddin Type: Potential Loss Desorfptloll: Critical Safety Function Status FC1.2 RANGE gr BKaalhift ER2.QZK QQQL59 FC1.3 CococxeNng - RED path in F-0.3, HEAT SINK Bases:

Core Cooling - ORANGE indicates subcooling has been lost and that some clad damage may occur. Heat Sink - RED indicates the ultimate heat sink function is under extreme challenge and thus these two items indicate potential loss of the fuel clad barrier.

3. QKGIHh? Qum QuftiiaL fhyhiun 2

?. QKGIHL3. Haat2ak. Bftvimua 2 87

Plant Specific EALsideline (FPB)

R.E. Ginna PWR FPB ICN: FC2 Barrier: Fuel Claddin Type: Loss DesCrfptlort: Primary Coolant Activity Level FC2.1 Coolant activity greater than 2KCizCLQ1 Bases:

This~~~ value corresponds to 300 pCi/cc l-131 equivalent. Assessment by the NUMARC EAL Task Force indicates that this amount of coolant activity

'here is no equivalent "Potential Loss EAL for this item.

88

Plant Specific EALsideline (FPB)

R.E. Ginna PWR FPB IC¹: FC3 Barrier: Fuel Claddin Type: Loss DesCrlptlon: Core Exit Thermocouple Readings FC3.1 Greater tha+si~peci~

Bases:

The "Loss EA+si~cif+ reading should correspond to significant superheating of the coolant. This value typically corresponds to the temperature reading that indicates core cooling-RED in fuel clad barrier EAL ¹1 which is usually about 1200 'F.

1, QKSI Hh2. Qm Qunling. B~hn 2

2. GLGX Bmgumah Imhttttah Qum QttnlinL B~inn 2 89

Plant Specific EALsideline (FPB)

R.E. Ginna PWR FPB ICg: FC3 Barrier: Fuel Claddin Type: Potential Loss DesCrfptlotl: Core Exit Thermocouple Readings FC3.2 Greater than~~peci~ ZQ}X Bases:

The Potential Loss EAL~~ci~ reading should correspond to loss of subcooling. This value typically corresponds to the temperature reading that indicates core cooling - ORANGE in fuel dad barrier EAL ¹1 which is usually about 700 to 900 'F. 5giK Ibh t}t}nftiit}nh221hZ!f Qf QKGIHK2 QQBE QQQLEG

3. QKGIHL2.Qt}n}Gut}ling.Bttttimt}a2

2. EMXBmuanmlt} Inadept}ttata Qf}LtdQt}alias Bfnfhinn Z 90

Plant Specific EALL.ideline (FPB)

R.E. Ginna PWR FPB IC¹: FC4 Barrier: Fuel Claddin Type: Potential Loss Descrlptloll: Reactor Vessel Water Level FC4.1 RVLIS ~% w/ no RCPs running (46% adverse containment Bases:

There is no "Loss EAL corresponding to this item because it is better covered by the other fuel clad barrier "Loss" EALs.

The~~elf+ value for the Potential Loss" EAL corresponds to the top of the active fuel. For sites using CSFSTs, the "Potential Loss" EAL is defined by the Core Cooling -ORANGE path. The~~coif+ value in this EAL should be consistent with the CSFST value.

91

Plant Specific EALOiideline (FPB)

R.E. Ginna PWR FPB IC¹: FC5 Barrier: Fuel Claddin Type: Loss DesCrlptlo0: Containment Radiation Monitor Reading FC5.1 Containment rad monitor reading greater tha+si~pecific)

Bases:

The+~pecif~eading is a value which indicates the release of reactor coolant, with elevated activity indicative of fuel damage, into the containment. The reading should be calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with a concentration of 300 pCi/gm dose equivalent l-131 into the containment atmosphere. Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations (including iodine spiking) allowed within technical specifications and are therefore indicative of fuel damage (approximately 2-5 % clad failure depending on core inventory and RCS volume). This value is higher than that specified for RCS barrier loss EAL ¹4. Thus, this EAL indicates a loss of both the fuel clad barrier and a loss of RCS barrier.

There is no "Potential Loss EAL associated with this item.

Ehhrftfzm; LLHadiaiign hixilziag Gmfftfn. Ehtdmfta QZ. 2@1hn 2ZZR ag LR2 92

Plant Specific EALIIIideline (FPB)

R.E. Ginna PWR FPB IC¹: FC6 Barf let'uel Claddin Type: Loss

==

Description:==

Other (site specific) indications FC6.1 Failed Fuel Monitor (R-9) reading > 10,000 mRem/hr Bases:

>fthm- tftftgi~ instrumentation. g ~ Elitism Em6 ftnitftf,~

This EAL is to cover other~~ecific) indications that may indicate hss or potential hss of the fuel clad barrier, including indications from containment air monitors or any other af lKQKalsttfIllhE attH~Qntfk h Flu fttftffailttt~

1 LLHadiatign ldzitzna Gxatfttn. Gotha L22L aa LR2 2.EEZ~ Qua Datttagft Eslitnatiftn 93

0 Plant Specific EAL sideline (FPB)

R.E. Glnna PWR FPB ICN: FC6 Barrier: Fuel Claddin Type: Loss

==

Description:==

Other (site specific) indications FC6.1 Failed Fuel Monitor (R-9) reading > 10,000 mRem/hr Bases:

This EAL is to cover other~~pecific) indications that may indicate loss or potential hss of the fuel clad barrier hi Qana. Euihd Ettftl hhniiz rftntfina ftf1KKQ mHmndzazmmda in PY htftl failure.

z LR2

2. EPZ ~

1L9.8adiaiiftnhlziiftfinaGmiftm. 5z!ha 2ZK5.

Qm Dzaam &ima1iftn

Plant Specific EALsideline (FPB)

R.E. Ginna PWR FPB ICg: FC6 Barrier: Fuel Claddin Type: Potential Loss

==

Description:==

Other (site-specific) indications FC6.2 Bases:

95

Plant Specific EALetjideline (FPB)

R.E. Ginna PWR FPB IC¹: RCS1 Barrier: RCS Type: Potential Loss

==

Description:==

Critical Safety Function Status RCS1.1 QC~tegrip- Red ~gft~Q+fff RCS1.2 Reebok- Red ~ ftft ~

Bases:

This EAL is for PWRs using Critical Safety Function Status Tree (CSFST) monitoring and functional recovery procedures. RED path indicates an extreme challenge to the safety function derived from appropriate instrument readings, and these CSFs indicate a potential loss of RCS barrier.

There is no "Loss" EAL associated with this item.

References:

1. CSFST F-0.3 HEAT SINK

2. CSFST F<.4 INTEGRITY

Plant Specific EALsideline (FPB)

R.E. Ginna PWR FPB IC¹: RCS2 Barrier: RCS Type: Loss

==

Description:==

RCS Leak Rate ACS2.< Greater than available makeup capacity as indicated by BQRmthaftliag s EZEiabSHGUBQQQL59 Bases:

The Loss" EAL addresses conditions where leakage from the RCS is greater than available inventory control capacity such that a loss of subcooling has occurred. The loss of subcooling is the fundamental indication that the inventory control systems are inadequate in maintaining RCS pressure and inventory against the mass loss through the leak.

97

Plant Specific EALideline (FPB)

R.E. Ginna PWR FPB ICg: RCS2 Barrier: RCS Type: Potential Loss

==

Description:==

RCS Leak Rate RCS2.2 Bases:

The Potential Loss EAL is based on the inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) by normal operation of the Chemical and Volume Control System which is considered as one ~matrifugat charging pumps discharging to the charging header. In conjunction with the SG Tube Rupture "Potential Loss EAL this assures that any event that results in significant RCS inventory shrinkage or hss (e. g., events leading to reactor scram and ECCS actuation) will result in no lower than an "Alert emergency classification.

98

Plant Specific EALuideline (FPB)

R.E. Gjnna PWR FPB ICtff: RCS3 Barrier: RCS Type: Loss 08SCrfptloll: SG Tube Rupture RCS3.1 GanamlarIuhe fhuhm" Bases:

This EAL is intended to address the full spectrum of Steam Generator (SG) tube rupture events in conjunction with containment barrier "Loss" EAL ¹4 and fuel clad barrier EALs. The "Loss EAL addresses ruptured SG(s) with an unisolable secondary line break corresponding to the loss of 2 o3 fission product barriers (RCS barrier and containment barrier - this EAL will always result in containment barrier "Loss EAL ¹4). This allows the direct release of radioactive fission and activation products to the environment. Resultant offsite dose rates are a function of many variables. Examples include: coolant activity, actual leak rate, SG carry over, iodine partitioning, and meteorohgy. Therefore, dose assessment in accordance with IC AGt, "Site-Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity that Exceeds 1000 mR Whole Body or 5000 mR Child Thyroid for the Actual or Projected Duration of the Release Using Actual Meteorology, is required when there is indication that the fuel matrix/clad is potentially lost.

(Sf~pecific) indication should be consistent with the diagnostic activities of the emergency operating procedures (EOPs)+Lauaitabto. This should indude indication of reduction in primary coolant inventory, increased secondary radiation levels, and an uncontrolled or complete depressurization of the ruptured SG. Secondary radiation increases should be observed via radiation monitoring of condenser air ejector discharge, SG blowdown, mains steam, and/or SG sampling system. Determination of the "uncontrolled depressurization of the ruptured SG should be based on indication that the pressure decrease in the ruptured steam generator is not a function of operator action. This should prevent declaration based on a depressurization that results from an EOP induced cooldown of the RCS that does not involve the prolonged release of contaminated secondary coolant from the affected SG to the environment. This EAL should encompass steam breaks, feed breaks, and stuck open safety or relief valves.

Bfthrftarm; GagftfahzIuha BtmfuIIL 99

Plant Specific EALsideline (FPB)

R.E. Ginna PWR FPB IC¹: RCS3 Barrier: RCS Type: Potential Loss

==

Description:==

SG Tube Rupture RCS3.2 ruuturft aa iritta1jfjftrfin BED

&2~ &ummtur Iuht BuaturfL Edmauh wmufaulMmh ~ Kgum Bases:

The Potential Loss EAL is based on the inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) by normal operation of the Chemical and Volume Control system which is considered as oneceatrifugal Q@gjnrr pump discharging to the charging header. ln conjunction with the RCS leak rate "Potential Loss EAL this assures that any event that results in significant RCS inventory shrinkage or loss (e. g., events leading to reactor scram and ECCS actuation) will result in no hwer than an "Alert" emergency classification.

Ehhrmzm;

1. M ~ Ganam1gr lutm Buuturtb 100

Plant Specific EALsideline (FPB)

R.E. Ginna PWR FPB IC¹: RCS4 Barrier: RCS Type: Loss

==

Description:==

Containment Radiation Monitoring RCS4.1 Containment radiation monitor reading greater tha+si~pec~ 10 R/hr Bases:

The~~ reading is a value which indicates the release of reactor coolant to the containment. The reading should be calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with normal operating concentrations (i. e., within TIS) into the containment atmosphere. This reading will be less than that specified for fuel clad barrier EAL ¹5. Thus, this EAL would be indicative of a RCS leak only. If the radiation monitor reading increased to that specified by fuel dad barrier EAL ¹3, fuel damage would also be indicated.

However, if the site-specific physical location of the containment radiation monitor is such that radiation from a cloud of released RCS gases could not be distinguished from radiation from nearby piping and components containing elevated reactor coolant activity, this EAL should be omitted and other site-specific indications of RCS leakage substituted.

There is no 'Potential Loss EAL associated with this item.

fhhrmzft;

1. BLLQuntainmftnL Bayisinn 2

2. EBZJ. fhszuat hhgh QaatuinmiUIt Bmliathn LfnntL Bfnthha 2 2.EEZkl6.Qua Damnga Qlimatinn 101

Plant Specific EA. Sideline (FPB)

R.E. Ginna PWR FPB ICg: RCS5 Barrier: RCS Type: Loss Descrlptloo: Other (Site-specific) indications RCS5.1 Bases:

This EAL is to cover other~~pecific) indications that may indicate loss or potential loss of the RCS barrier, including indications from containment air monitors or any other~~pecific) instrumentation.

102

Plant Specific EAL Sideline (FPB)

R.E. Ginna PWR FPB IC¹: RCS5 Barrier: RCS Type: Potential Loss

==

Description:==

Other (site-specific) indications RCS5.2 Bases:

This EAL is to cover other (site-specific) indications that may indicate loss or potential loss of the RCS barrier, including indications from containment air monitors or any other (site-specific) instrumentation.

103

Plant Specific EA.OLideline (FPB)

R.E. Ginna PNR FPB ICg: RCS6 Barrier: RCS Type: Loss/Pot. Loss DeSCriptlOn: ggi~fttm~ gZmume guutljaa~ girector Judgement RCS6.1 Any condition in the judgment of the Emergency Director that indicates hss or potential loss of the RCS barrier.

Bases:

addition, the inability to monitor the barrier should also be incorporated in this EAL as a factor in ~

This EAL addresses any other factors that are to be used by the Shies 5ggmhgz gmfttgttttgy QgggfjttaIIIQ Qirectoc in determining whether the RCS barrier is lost or potentially lost. In Qgg~jmti ~gftftgy. Qgggggg~Oiroctor. judgement that the barrier may be considered hst or potentially hst. (See also IC SGt, "Prohnged Loss of All Offsite Power and Prohnged Loss of All Onsite AC Power", for additional information.)

104

Plant Specific EA.OLideline (FPB)

R.E. Ginna PWR FPB IC¹: PC1 Barrier: Prima Containment Type: Potential Loss Desorlptlort: Critical Safety Function Status PC1.1 Coataiameat- Red ~~

Bases:

This EAL is for PWRs using Critical Safety Function Status Tree (CSFST) monitoring and functional recovery procedures. RED path indicates an extreme challenge to the safety function derived from appropriate instrument readings and/or sampling results, and thus represents a potential loss of containment.

Conditions leading to a containment REDpath result from RCS barrier and/or fuel clad barrier loss. Thus, this EAL is primarily a discriminator between Site Area Emergency and General Emergency representing a potential hss of the third barrier.

There is no "Loss EAL associated with this item.

b 105

Plant Specific EALuideline (FPB)

R.E. Ginna PWR FPB IC¹: PC2 Barrier: Prima Containment Type: Loss

==

Description:==

Containment Pressure PC2.1 Rapid eaexptaiaodurtgzirgil+ decrease in Containment Pressure following initial increase PC2.2 maud'hui containment pressure or sump level response not consistent with LOCA conditions.

amrtrti mlainabhrluft Itt mcatrtr adhrugrmirurutiif;mhmudha:~

~ urtftzrt~+~~ ~ iri~

Bases:

Rapid unexplained loss of pressure (i. e., not attributable to containment spray rtr Eart Qgrtijrtg ~ or condensation effects) following an initial pressure increase indicates a loss of containment integrity. Containment pressure and sump levels should increase as a result of the mass and energy release into containment from a LOCA. Thus, sump level or pressure not increasing indicates containment bypass (V-sequence) and a loss of containment integrity.

1. hhrmmltrtrmrtrrtmrturft. hfhklKBfttrimiz5

2. hlarmmugrtmtrtrmdurft.hkkUK fhmhrt 5

2. ELE.QinnallafahfIE2B.Eigum522IbrftugbkL5.

106

Plant Specific EAL'foiideline (FPB)

R.E. Ginna PWR FPB IC¹: PC2 Barrier: Prima Containment Type. Potential Loss

==

Description:==

Containment Pressure PC2.3 ~pec~ psig and increasing PC2.4 R 2 httrirrtgttn cuncttairatirtn in mntninmttai Outride PC2.5 LQQh milh iftss thun ihft miaitnum maiaiitrnttai marina Mmumrds ftrtuirttnftairtnftiatiag; QHhK @ms:drm s2R usia 2QHhlI Ebmiz Gas QRI ltmssum M) rtsig;2QHhKGurax Bamu QB 2QHhKEhcira Eans and 1QhlhKGurm Ban@

Bases:

The+~ocifQ Qg psig for potential loss of containment g is based on the containment design pressure. Existence of an expbsive mixture Q Qriirtgfta) means a hydrogen and oxygen concentration of at least the tower deflagration limit curve exists. The indications of potential loss under this EAL corresponds to some of those leading to the RED path in EAL ¹1 above and may be declared by those sites using CSFSTs. As described above, this EAL is primarily a discriminator between Site Area Emergency and General Emergency representing a potential toss of the third barrier.

Theaeconrrihlrrl potential loss EAL represents a potential loss of containment in that the containment heat removal/depressurization system which the equipment was supposed to have actuated.

~ containment sprays, Elftgim, 6

5. KF QinnallEShKSachu522J

5. ELE. Giona ilEGhK ~

ERZJ. Httsrtrtasft irt Bah Qrtaiaiataftat PrftssurL Ehtrisirta 3 ling~

5222. ag k222 nnrf Gaum ~

-17965

Plant Specific EAL ideline (FPB)

R.E. Ginna PWR FPB IC¹: PCS Barrier: Prima Containment Type: Loss

==

Description:==

Containment Isolation Valve Status After Containment Isolation PC3.1 Etta; Q gt Q5 iaglatign tagujtad and Q at QQ QR valve(s) not closed ~ Laauita inability. ta iaaiata any. afimaQI ayatam dim;hatginlt auhida aantaittmant AND 4ownstrearnradialgjaai Laiaaaa pathway to the environment exists Bases:

This EAL is intended to address incomplete containment isolation that allows direct release to the environment. It represents a loss of the containment barrier.

Iha phraaa~

aanhinmant hauntfaty.hut ~

JnahiTity. ta halata any. arise altatam dhaharaim auhida mntainmanc haa haan addad Maaaturaunhaiatahla laai~a fram thaaa anmaty. altatama mhhh atttand haand tha aithar du nut hatla autantatir i.'mlalian funatiana ac arattida a ditaat @cindia'aiaaaa aath br aaatar aaalant autmda 1ha amtainmanl.

There is no "Potential Loss EAL associated with this item.

fhfarmza; EEZ12haaztaa ta Eah Quttaittmant Emaauta 108

Plant Specific EALI4ideline (FPB)

R.E. Ginna PWR FPB Ic¹: PC4 Barrier: Prima Containment Type: Loss

==

Description:==

SG Secondary Side Release with Primary to Secondary Leakage PC4.1 Release of secondary side to atmosphere with primary to secondary leakage greater than tech spec allowable'J ~ gftt.~gftftft@~

Bases:

This EAL addresses SG tube ruptures. Secondary side releases to atmosphere include those from the condenser air ejector, atmospheric dump valves, and mainsteam safety valves. For smaller breaks, not exceeding the normal charging capacity threshold in RCS barrier "Potential Loss EAL ¹2 (RCS leak rate) or EAL ¹3 (SG tube rupture), this EAL results in an Unusual Event.

For larger breaks, RCS barrier "Loss" or "Potential Loss EAL ¹2 would result in an Alert. For SG tube ruptures which may involve multiple steam generators or unisolable secondary line breaks,thisEALwouldexistinconjunctionwithRCSbarrier Loss" EAL¹3andwouldresultinaSiteAreaEmergency. EscalationtoGeneralEmergencywouldbebasedon "PotentialLoss of the fuel clad barrier.

109

I Plant Specific EALuideline (FPB)

R.E. Gjnna PWR FPB IC¹: PCS Barrier: Prima Containment Type: Potential Loss

==

Description:==

Significant Radioactive Inventory in Containment PC5.1 Containment radiation monitor reading greater tha~i~pecif+ 1999 93K Bases:

The~~flc) ~~ reading is a value which indicates significant fuel damage well in excess of the EALs associated with both loss of fuel clad and loss of RCS barriers. As stated in Section 3.8, a major release of radioactivity requiring offsite protective actions from core damage is not possible unless a major failure of fuel cladding allows radioactive material t be released from the core into the reactor coolant. Regardless of whether containment is challenged, this amount of activity in containment, if released, could have such severe consequences that it is prudent to treat this as a potential loss of containment, such that a General Emergency dedaration is warranted. NUREG-1228 "Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates that such conditions do not exist when the amount of dad damage is less than 20%. Unless there is afrite-specific analysis justifying a higher value, it is recommended that a radiation monitor reading corresponding to )20% fuel clad damage be specified here.

There is no "Loss EAL associated with this item.

Hftfmftfxr.

ERE~ Qiana Rahu Emi Kahaliga md Glmifica1jun. Ebuhiga 32 EEZ21L Bura Daautgft Esiiatatiaa Iadmjumhr Emax Bmu Hu. EU~

110

Plant Specific EALsideline (FPB)

R.E. Ginna PWR FPB tCN: PC6 Barrier: Prima Containment Type: Potential Loss

==

Description:==

Core Exit Thermocouples PC6.1 EKQ2. Baaftgaaa tg Quhrataff ~

Core exit thermocouples in excess of 1200 'F and restoration procedures E~

Qggljag. not effective within 15 minutes Bftaagaat tg laatfagZta QZg QZjjag. EHg Baaggaaa tg QQgraffaff QZR QggjjaL aarf PC6.2 Core exit thermocouples in excess ot 700 'F with Jaadagtlata QKt Qgg!iaa EfK2. BasgaH tg DQgratfatf QQE QEliog aatf

~ ~(ag ~ ~

E~g. Baaggaaa zfyftraa ggatajaiiaaatj and restoration procedures tg Qglg[atftffQgz Qggjjag. not effective within 15 minutes E~

Bases:

ln this EAL, the function restoration procedures are those emergency operating procedures that address the recovery ot the core cooling critical safety functions. The procedure is considered effective if the temperature is decreasing or if the vessel water level is increasing.

The conditions in this potential hss EAL represent imminent melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment tailure. In conjunction with the core exit thermocouple EALs in the fuel and RCS barrier columns, this EAL would result in the dedaration ot a General Emergency hss of two barriers and the potential loss of a third. It the function restoration procedures are ineffective, there is not success" path.

Severe accident analyses (e. g., NUREG-1150) have concluded that function restoration procedures can arrest core degradation within the reactor vessel in a significant fraction of the core procedures to arrest the core melt sequence. Whether or not procedures will be effective should be apparent within 15 minutes. The ~ ~yjagr ~gaagy damage scenarios, and that the likelihood of containment failure is very small in these events. Given this, it is appropriate to provide a reasonable period to allow function restoration gggrtfjaa~Ouectoc should make the declaration as soon as it is determined that the procedures have been, or will be effective. The reactor vessel level chosen should be consistent with the emergency response

~

guides applicable to the facility.

There is no "Loss" EAL associated with this item.

Hob; hdtfaraa ggataiamaat mtttaa ahattitf ha uaatf Iffhtatafar mataiamaat araaattra ia graatar ihaa 5 amg gr amtaiiamaat raffiatiga ia graatar ihaa

1. HL2. Qam Qadiau QKGL Bfa.jmga 2

2. EKQZ.BLIggaaa tg lhgratfaff Qum Qggiiag. Baldmga 5. attta Ka CO P 0 Orv ~at a ta A~e~Awi f wee f'mali~ Dea~r ne C Lint+

111

Plant Specific EALsideline (FPB)

R.E. Ginna PWR FPB ICg: PC7 Barrier: Prima Containment Type: Loss DesCrfptlOA: Other (site-specific) indications PC7.1 fhfhriftgrartrtftrtrtrtmataitfttfta1 sickest 93 anahilifx h ahm mnfairtilrtaaf ara.mta raiiftfar rtttrga mhmuhhh ttatt!ta ia a radiahaiaal raiaaaa aafhtttax itt iha art~tirtuttnartk Bases:

This EAL should cover other~~~ indications that may unambiguously indicate hss or potential loss of the containment barrier, induding indications from area or ventilation monitors in containment annulus or other contiguous buildings.

112

Plant Specific EALideline (FPB)

R.E. Ginna PWR FPB IC¹: PC7 Barrier: Prima Containment Type: Potential Loss

==

Description:==

Other (site-specific) indications PC7.2 Bases:

This EAL should cover other (site-specific) indications that may unambiguously indicate hss or potential loss of the containment barrier, including indications from area or ventilation monitors in containment annulus or other coritiguous buildings.

113

'0 Plant Specific EALsideline (FPB)

R.E. Ginna PWR FPB ICN: PCS Barrier: Prima Containment Type: Loss/Pot. Loss

==

Description:==

Emergency Director Judgement PC8.1 Any condition in the judgment of the ~ Qlg~~ ]FJIIftt gory. Qg~~OIrector that indicates hss or potential loss of the containment barrier Bases:

addition, the inability to monitor the barrier should also be incorporated in this EAL as a factor in ~ ~II~~

This EAL addresses any other factors that are to be used by the ~5gftttzhgr ttftrgftagy QggrtfiaatgQC4coctor in determining whether the containment barrier is hst or potentially lost. In

~gtftLgftagy. Qg~~gQQiroctoc judgement that the barrier may be considered lost or potentially lost. (See also IC SG1, Prohnged Loss of All Offsite Power and Prohnged Loss of All Onsite AC Power", for additional information.)

114

Plant Specific EALuideline (FPB)

R.E. Ginna PWR FPB IC¹: FC1 Barrier: Fuel Claddin Type: Loss

Description:

Critical Safety Function Status FC1.1 Bases:

Core Cooling - RED indicates significant superheating and core uncovery and is considered to indicate loss of the Fuel Clad Barrier.

EhfftrmmL'.

QKGIHh2.Qm Quftliag. EhLYiga2 115

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAI. Evaluation. Rev. 0 Fi ionPro c 8 r 1 Il

~Revi i n R. E. Ginna Nuclear Power Station Operations Support Services, Inc.

233 Water Street 2nd Floor Plymouth, MA 02360

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Evaluation of Gimm Fission Product Barrier Eme enc Action Levels The Fission Product Barrier (FPB) degradation category for a PWR plant is illustrated in the following table which is designated "Table 4" in NESP-007, Revision 2.

The Initiating Condition (IC) for each of the four emergency classifications (Unusual Event, Alert, Site Area Emergency, and General Emergency) are designated FU1, FAl, FSl, and FGl, respectively.

Each IC is defined by one or more EALs or combination of EALs which are indicative of a loss or potential loss of one or more of the three fission product barriers. The three fission product barriers are:

Fuel Clad (FC)

Reactor Coolant System (RCS)

Primary Containment (PC)

NESP-007, Revision 2, prescribes example EALs for each of the three fission product barriers. An EAL is defined by one or more plant conditions. For example, there are seven FC barrier example EALs.

eight RCS barrier example EALs, and eleven PC example EALs. Each EAL may consist of one or more conditions representing a loss of the barrier and a potential loss of the barrier. Some EALs may have only loss conditions, others only potential loss conditions, some have both loss and potential loss conditions. Each EAL is given a sequential number in Table 4. In the following list, NESP-007 EALs with a defined condition (i. e., labeled as needing "site-specific" input in Table 4) are identified with a "yes", and those without a defined condition (i. e. labeled "not applicable" in Table 4) are identified with a "no":

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0

'UMARC Ginna

~Brri r EAL ¹ FC la Yes Yes "

Yes(FC1.1) Yes(FC1.2) lb No Yes No Yes(FC1.3) 2 Yes No Yes(FC2. 1) No 3 Yes Yes Yes(FC3.1) Yes(FC3.2) 4 No Yes No Yes(FC4.1) 5 Yes No Yes(FC5.1) No 6 Yes Yes Yes(FC6.1) No 7 Yes Yes Yes(FC7.1) Yes(FC7. 1)

RCS la No Yes No Yes(RCS 1. 1) lb No Yes No Yes(RCS1.2) 2 Yes Yes Yes(RCS2.1) Yes(RCS2.2) 3a Yes Yes Yes(RCS3. 1) No 3b Yes No No Yes(RCS3.2) 4 Yes No Yes(RCS4.1) No 5 Yes Yes No No 6 Yes Yes Yes(RCS6.1) Yes(RCS6.1)

PC 1 No Yes No Yes(PC l. 1) 2a Yes Yes Yes(PC2.1) Yes(PC2.3) 2b Yes Yes Yes(PC2.2) Yes(PC2.4) 2c No Yes No Yes(PC2.5) 3 Yes No Yes(PC3.1) No 4 Yes No Yes(PC4. 1) No 5 No Yes No Yes(PC5.1) 6a No Yes No Yes(PC6. 1) 6b No Yes No Yes(PC6.2) 7 Yes Yes Yes(PC7. 1) No 8 Yes Yes Yes(PCS. 1) Yes(PCS. 1)

Based on the classification key given at the beginning of Table 4, the number of example EALs, and the number of loss and potential loss conditions, the set of conditions that can yield a given emergency classification can be computed.

The maximum, theoretically possible set of conditions that can yield an Unusual Event classification is given in column 1 of Table A. These consist of the PC loss and PC potential loss conditions.

The maximum, theoretically possible set of conditions that can yield an Alert classification is given in column 1 of Table B. These consist of FC loss and potential loss conditions. and RCS loss and potential loss conditions.

The maximum, theoretically possible set of conditions that can yield a Site Area Emergency classification is given in column 1 of Table C.

These consist of any of the following conditions: ~

~ Loss of FC and RCS. or

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAI. Evaluation, Rev. 0

~ Potential loss of FC and RCS, or Potential loss of FC or RCS GIld Loss of another barrier The third set of conditions listed above can be represented by the following conditions to eliminate reference to "loss of another barrier":

~ Potential loss of FC and loss of RCS, or

~ Potential loss of FC and loss of PC, or

~ Potential loss of RCS and loss of FC, or

~ Potential loss of RCS and loss of PC The maximum,, theoretically possible set of conditions that can yield a General Emergency classification is given in column 1 of Table D.

These consist of the following conditions:

~ Loss of any two barriers, and

~ Potential loss of a third These conditions can be represented by the following conditions to correlate barrier loss and potential loss to the three speciAc barriers:

~ Loss of FC and loss of RCS and potential loss of PC, or

~ Loss of RCS and loss of PC and potential loss of FC, or

~ Loss of PC and loss of FC and potential loss of RCS Note that the loss of all three barriers justifies a General Emergency classification as well.

Since the EAL conditions are listed numerically in Table 4, Tables A through D utilize a similar numbering system which is modified by letter abbreviations to define each set of conditions. For example, condition "FC2-loss" corresponds to a loss of the Fuel Clad barrier due to primary coolant activity level greater than 300 p,Ci/gm I-131.

Similarly, "RCSlb-pot. loss" corresponds to a potential loss of the Reactor Coolant System barrier due to a Critical Safety Function Status Heat Sink-RED condition, and so on.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 An evaluation of each condition or set of conditions listed in Tables A through D is made to determine if it properly defines the appropriate threshold for the classification. If a condition or set of conditions is appropriate, a comment reflecting this conclusion is recorded in the "Remarks" column. If a condition or set of conditions is determined to be inappropriate, it is lined out and the reason for this conclusion is similarly recorded in the "Remarks" column. Where additional space is required to complete comments, the comments are recorded by number in Appendix 1 of this document. The numbers of the comments are recorded in the "Remarks" column with the associated condition or set of conditions to which they apply.

A summary of the results of the fission product barrier evaluation is presented in Appendix 2.

RECOGNITION CATEGORY F FISSION PRODUCT BARRIER DEGRADATION INITIATINGCONDITION MATRIXTABLE 4 PWR UNUSUAL EVENT ALERT SITE AREA EMERGENCY GENERAL EMERGENCY FUl Any loss or any Fhl Any loss or any FSl Loss of both fuel clad Loss of any two potential loss of potential loss of either and RCS barriers containment fuel clad or RCS. OR AND Potential loss of both PotenUal loss of third Op. Modes: Op. Modes: fuel clad and RCS barrier.

Power operation Hot Power operaUon Hot OR Shutdown Shutdown PotenUal loss of either Op. Modes:

fuel clad or RCS, and Power operation Hot loss of any addiUonal Shutdown barrier.

Op. Modes:

Power operaUon Hot Shutdown NOTES:

I. Although thc logic used for these Initiating conditions appears overly complex, it Is necessary to reflect the following considerations:

~ The fuel clad barrier and thc RCS barrier are weighted morc heavily than the containment barrier (sec SecUons 3.4 and 3.8 for more Iniormation on this point). Unusual Event ICs associated with RCS and Fuel Clad barriers are addressed under System MalfuncUon ICs.

~ At the Site Area Emergency level, there must be some ability to dynamically assess how far present condiUons are for General Emergency.

For example. IfFuel Clad barrier and RCS barrier "Loss" EALs existed, this would indicate to the Emergency Director that, In addiUonal to offsite dose assessments, continual assessments of radioactive inventory and containment Integrity must be focused on. If, on the other hand, both Fuel Clad barrier and RCS barrier "Potential Loss" EALs existed, the Emergency Director would have more assurance that there was no immediate need to escalate to a General Emergency.

~ The ability to escalate to higher emergency classes as an event gets worse must be maintained. For example, RCS leakage steadily increasing would represent an Increasing risk to public health and safety.

2. I"lssion Product IIarrtcr ICs must be capable of addressing event dynamics. Thus, the EAL Reference Tables 3 and 4 state that IMMINENl (I e., within I to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) loss or potential loss should result In a classti)caUon as If the affected threshold(s) are already exceeded, parUcularly for the higher emergency classes.

RECOGNITION CATEGORY F INITIATINGCONDITION MATRIXTABLE 4 PWR Fuel Clad Barrier Example EAL8 Core cooling - red Core cooling - orange OR Heat sink - red t etv Coolant activity greater than (site-speclAc) value Not applicable Greater than (site.spcciAc) 'F Greater than (site-speclflc) 'F V W Not applicable Level less than (site-speciflc) value fn to lto Containment rad monitor reading greater than (site-speciflc) Not applicable R/hr

6. th slt- c I dfcatlo (site-speciflc) as appllcablc (site-speclflc) as applfcable Any condltfon ln the Judgment of thc Emergency Director that Indicates loss or potcntlal loss of the fuel clad barrier Determine which combination of the three barriers are lost or have a potential loss and usc the following key to classffy the event. Also, an event for multiple events could occur which result ln the conclusion that exceeding the loss or potenttal loss thresholds is fmminent (I. e.,

within I to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />). In this Imminent loss situation. use Judgment and classify as If the thresholds arc exceeded.

RECOGNITION CATEGORY F INITIATINGCONDITION MATRIXTABLE 4 PWR RCB Barrier Erample EALs otential Loss Not applicablc RCB Integrity - red OR l feat sfnk - rcd

2. @~@~tate Greater than availablc makeup capacity as Indicated by a loss Unisolable leak exceeding the capacity of one charging pump in the of RCB subcooling normal charging mode (site-specfAc) Indication that a SC is ruptured AND has an non- (site.specific) Indication that a SG Is ruptured fsolable secondary line break AND OR the primary-to-secondary leak rate exceeds the capacity of one (site-speci Ac) Indication that a SC Is ruptured AND a prolonged charging pump tn the normal charging mode release of contaminated secondary coolant Is occurring from the affected SG to the environment t a tio on tori Containment radiation monitor reading greater than (site- Not applicable speciffc) R/hr s df Io s (site-speclAc) as applicable (site-specfAc) as applfcable Any condition In thc Judgment of the Emergency Director that Indicates loss or potential loss of thc RCS barrier

RECOGNITION CATEGORY F INITIATINGCONDITION MATRIXTABLE 4 PWR Containment Barrier Example EALS ote tial Loss Not appllcablc Contalnmcnt - red Rapid unexplained decrcasc iollowing initial increase (site-spcciAc) psig and increasing OR OR Containmcnt prcssure or sump level rcsponsc not consistent Explosive mixture exists with LOCA conditions OR Containment pressure greater than containment depressurimtion system setpoint with less than one full train of deprcssurization equipment operating

3. a ato Vive tausat so at Valve(s) not closed Not applicable AND downstream pathway to the environment exists o a S a -to- d w a Relcasc of secondary side to atmosphere with primary to secondary leakage greater than tech spec allowable Not applicable v v Not appllcablc Containment radlaUon monitor reading greater than (site-spec!Ac)

R/hr

RECOGNITION CATEGORY F INITIATINGCONDITION MATRIXTABLE 4 PWR Containment Barrier Example EALS

~ss otential Loss Not appllcablc Core exit thcrmocouples ln excess of 1200'F AND restoration procedures not effective within 15 minutes OR Core exit thermocouples in excess of 700 'F with reactor vessel level below top of active fuel AND restoratfon procedures not effective within 15 minutes

7. Ot sit -s d at s (site-specific) as applicable (site-specf lie) as applicable c o J> t Any condition ln the Judgment of the Emergency Director that indicates loss or potential loss of the containment barrier

OSSI 92-402A-2-REG RE. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table A Qiana Fission Product Barrier Unusual Events NESP-007 ~Rm~rkc>

Loss or pot. loss of PC QC4-Cess Condition not supported in PEG.

ess 1 FQQb-1ess PC:~ess PCS-1ess PC4: jos'9@j:;.'%>'g8:qP'+NqR PCS-less Pea-1ess 2

Condition not supported ln PEG.

3 gg~~g445':.j<<:+3:!:(c~N$ 8@:e1:::<<4:::<<gg!::.'-'.4 .':.<g)N Condition not supported in PEG.

Condition not supported in PEG.

PCGMess Condition not supported ln PEG.

PCS-1ess Subsumed in "Judgment" EAL.

4 5

6 Condition not supported in PEG.

Condition not supported in PEG.

8 9

10 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

10

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table BGinna Fission Product Barrier NESP-007 ~Rem rks Loss or pot. loss of FC FCka-1ess ll 1~ass Condition not supported in PEG.

FCQ-1 ass 9 1~ass Condition not supported in PEG.

ess 18 P,

FC7-lass

.>jg".">';:!co,.~"..'> ';.;g::c;:,c','c'. ~;. ~

>'..xc .',;. ~

g0'; . c~P: 3~xi5<',.".;,",';

Subsumed in "Judgment" EAL.

x>;;:gx> .',N <'?~s~;.c~?'~ ~

3 'if'>"+>> '" '

s.

12 13 Condition not supported in PEG.

14 15 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Loss or pot. loss of RCS RCSka-less Condition not supported in PEG.

Rt,'~-1ass Condition not supported in PEG.

RCSSa-1ess 17 RCSSb-1ass Condition not supported in PEG.

LRCS4,'-:loss:",::.,'-;l','=e 1 CSS-1ess Condition not supported In PEG.

RCS6-1ass Subsumed In "Judgment" EAL.

!RCSla,>>.'pat--;:3o'ise 19

,RC82"-.j'ot

,loss Condition not supported in PEG.

20 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table CGinna Fission Product Barrier Site Area Emergencies N~EP-007 ~Rem rks Loss of FC and RCS Condition not supported In PEG.

Condition not supported in PEG.

ll ll Condition not supported in PEG.

ll Condition not supported in PEG.

Subsumed fn "Judgment" EAL.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

22

'RCSS'afoNsN'so'.'-":::':-'>~'"S~>'i'"'::::k.-':i(":I-Condition not supported in PEG.

FQ2-loss .0 RGS5-loss 22 Condition Subsumed not supported fn PEG.

in "Judgment" EAL.

Condition not supported in PEG.

- RCS I b-loss Condition not supported in PEG.

9 F63-loss . E RCSeb-loss 9

Condition not supported in PEG.

9 Condition not supported in PEG.

RGS6-loss Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

12

OSSI 92-402A-2-REG R.E. Ginna FIssion Product Barrier EAL Evaluation, Rev. 0 Table C Ginna Fission Product Barrier Site Area Emergencies NESP-007 Remarks Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

17 Condition not supported ln PEG.

21 Condition not supported in PEG.

ess Subsumed ln "Judgment" EAL.

FC6-1 Condition not supported ln PEG.

Condition not supported in PEG.

17 Condition not supported In PEG.

23 Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Condition not supported In PEG.

Condition not supported ln PEG.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Pot. loss of FC and RCS ll 11 13

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table C Ginna Fission Pxoduct Barrier Site Area Emergencies NESP-007 ~Remark Condition not supported in PEG.

ll CondiUon not supported in PEG.

Condition not supported in PEG.

13 13 CondiUon not supported 1n PEG.

13 CondiUon not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

14, 25 14 14 Condition not supported in PEG.

14 aCS-poM~RCS4-pot%sos Condition not supported in PEG.

Cond1tion not supported in PEG.

F64-pot loss ~ -RGB'-pot loss Subsumed 1n "Judgment" EAL.

15, 24 15 F44-pod-loss +--RCS3a-pot loss 15 CondiUon not supported 1n PEG.

15 Condition not supported in PEG.

14

OSSI 92-402A-2-REG R.E. Ginna Ffssfon Product Barrier EAL EvaluaUon, Rev. 0 Table C Ginna Fission Product Barrier Site Area Emergencies NESP-007 Re~mt~rk Condition not supported ln PEG.

Subsumed ln "Judgment" EAL.

CondiUon not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

CondlUon not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condftion not supported in PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Conditfon not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Pot. loss of FC and loss of RCS not supported ln PEG.

-'PCS-'p'cia'~loss-'ondition Condition not supported ln PEG.

12 Condition not supported in PEG.

12 Condition not supported ln PEG.

15

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table C Ghana Fission Product Barrier Site Area Emergencies .

NE P-007 ~Rm~rk Subsumed ln "Judgment" EAL.

Condltfon not supported ln PEG.

Condition not supported ln PEG.

12 12 Condition not supported in PEG.

12 Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

14 Condition not supported fn PEG.

FC3-pot loss ~ RGS5-loss 14 Condition Subsumed not supported ln PEG.

ln "Judgment" EAL.

Condltfon not supported in PEG.

FC4-poW~RCSl b-loss Condition not supported ln PEG.

15 15 F84-pot-loss-~ RGS3b-loss Condition not supported in PEG.

15 EQ4-poMoss 1 RC66-loss Condition Subsumed Condition not supported ln PEG.

ln "Judgment" EAL.

not supported ln PEG.

Condition not supported ln PEG.

16

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0

"'able C Ghana Fission Product Barrier Area Emergencies I'ite NESP-007 ~Rmarks Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported In PEG.

CondlUon not supported ln PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

ess Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Pot. loss of FC and loss of PC Condition not supported In PEG.

.P":", ' 4.'w '"'b '"'":' C:""

Condition not supported ln PEG.

.!>epws >r ': .. s 'p+:... ggr v<e:.e.. ss>wow @we)>we@<>'>c x +s zqye q.. . .

ii',"'"'i!iiiiiiiii,ii,"",,",,,"'),'ll:,:-:

ii'iiiiiii'i!i(iiiiiii(!ilia:'::i:::iliaiiiiiii~iiii ess 12 FC4a-pe ess Condition not supported In PEG.

Condition not supported ln PEG.

FC4a-pe Condition not supported ln PEG.

12 Subsumed ln "Judgment" EAL.

ess Condition not supported in PEG.

1 2

Condition not supported ln PEG.

3 13 Condition not supported in PEG.

Condition not supported in PEG.

17

OSSI 92-402A-2-REG R.E. Glnna Fission Product Barrier EAL Evaluation, Rev. 0 Table CGinna Fission Product Barrier Site Area Emergencies NESP-007 Remarks Condition not supported ln PEG.

13 Subsumed ln "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

1 2

Condition not supported ln PEG.

3 14 Condition not supported ln PEG.

FC3-yotAoss + PC6b-loss Condition not supported in PEG.

Condition not supported ln PEG.

14 RC4-pot-loss + PG 1-loss Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

1 F64-pot-1oss ~ = PC2o-loss 2

Condition not supported ln PEG.

3 F64-pod-loss + PC5-loss 15 Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

18

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table C Ghana Fission Product Barrier Site Area Emergencies NESP-007 ~Rm~rk 14 Subsumed fn "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

1 Condition not supported in PEG.

3 Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

40 Subsumed In "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Condltfon not supported ln PEG.

Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL.

Condition not supported ln PEG.

Condltfon not supported fn PEG.

Condition not supported In PEG.

Subsumed in "Judgment" EAL.

19

OSSI 92-402A-2-REG R.E. Glnna Fission Product Barrier EAL Evaluation, Rev. 0 Table C Ginna Fission Product Barrier Site Area Emergencies NESP-007 ~Rm~rk Subsumed ln "Judgment" EAL.

Pot. loss of RCS and loss of FC Condition not supported in PEG.

ll 22 Condition not supported in PEG.

21 Subsumed ln "Judgment" EAL.

ll Condltfon not supported in PEG.

19 9

Condition not supported in PEG.

19 ll Condition not supported ln PEG.

20 9

Condition not supported ln PEG.

20

'.RC$2'-':riot:;"';lorn>,,:":-.-+ F/6 '$' ';Q>>y@ FFMg+>'++I> Q~ "Q ':Sp>:i~~ ~<, Y+.?W;'RiX>, %N4$<%5'PNW~4?45 ... i Subsumed ln "Judgment" EAL.

Condltfon not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

20

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table C Ginna Fission Product Barrier Site Area Emergencies, NESP-007 ~Rm~rk ll Condition not supported ln PEG.

20 9

Condition not supported in PEG.

20 20 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Condition not supported fn PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Pot. loss of RCS and loss of PC Condition not supported fn PEG.

21

OSSI 92-402A-2-REG R.E. Gfnna Fissfon Product Barrier EAL Evaluation, Rev. 0 Table C Ghana Fission Product Barrier Site Area Emergencies NESP-007 ~Rm~rk Condition not supported in PEG.

3 47 Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

40 Subsumed fn "Judgment" EAL.

Condition not supported in PEG.

1 Condition not supported in PEG.

3 19 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

19 Subsumed in "Judgment" not supported fn PEG.

EAL.'ondition 1

2 Condition not supported fn PEG.

3 Condltfon not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Subsumed ln "Judgment" EAL.

Condition not supported ln PEG.

Condltfon not supported fn PEG.

Condition not supported in PEG.

22

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Tahle C Qiana Fission Product Barrier Site Area Emergencies NESP-007 ~Rem rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

1 2

CondlUon not supported in PEG.

3 20 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

20 Subsumed in "Judgment" EAL.

CondlUon not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

RQS4-pot loss + P-C3-loss Condition not supported ln PEG.

h RQS4-peM Condition not supported ln PEG.

Condition not supported in PEG.

RCS4-pot-loss + PC6a-loss Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

RCS4-pot&oss --+ PCS-loss Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

RCSS-pot-loss ~ PC2b-loss Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

OSSI S2-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table C Ginna Fission Product Barrier Site Area Emergencies NESP-007 ~Rem rks Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported In PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment", EAL.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL.

0 OSSI 92-402A-2-REG RE. Glnna Fission Product Barrier EAI. Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-IEQ Rem~re Loss of FC+ loss of RCS+ pot. loss of PC Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

1 X

~

FC4a-loss ~RCS2-loss-~Pic-pot-loss 11, 27 Condition not supported in PEG.

Condition not supported in PEG.

",'PCGb'potgassg'::IXX;,.27:,":2S".CCxed4N~l~-.',""':"..:!:,=,'.:"':g=':.':<"'-:i",:yQ Condition not supported in PEG.

FCZ~oss ~RCS2-loss ~PC8-pot-loss Subsumed in "Judgment" EAL.

4,11 11, 26 25

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP- 07 ~Rem rk 11,6 11, 29 Condition not supported in PEG.

Condition not supported in PEG.

ll 11,9 11, 30 Condition not supported in PEG.

Subsumed in "Judgment" EAL Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

11,4 ll, 26 11,6 FC-&-loss ~RCS4-loss-~P~c-potAoss 11, 29 Condition not supported in PEG.

Condition not supported in PEG.

FC4a-loss ~RCS4-loss +PCS-po4-loss 11,8 11,9 11, 30 CS4-loss-~PQ7-po4-1oss Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

1W&-loss ~RCS5-loss~P&2a-pot-1oss Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

26

OSSI 92-402A-2-REG R.E. Glnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D . Ginna Fission Product Barrier General Emergencies NESP-007 ~R~m~rk Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL Subsumed fn "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported In PEG.

Subsumed fn "Judgment" EAL Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

8Mb-loss ~RCS-1a-loss ~PG4-pot-loss Condition not supported In PEG.

Condition not supported In PEG.

Condltfon not supported ln PEG.

CS-le-los~PG6b-potAoss Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

CS 1 b-loss-~Pal-pot-loss Condltfon not supported ln PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

27

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier

'General Emergencies NE P-007 ~Rem rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

CondiUon not supported in PEG.

CondiUon not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Conditfon not supported in PEG.

Condition not supported In PEG.

CondlUon not supported in PEG.

CondlUon not supported fn PEG.

Condftion not supported in PEG.

Condition not supported in PEG.

F~-loss ~RCS3a-loss-+ PC6b-po4-loss Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

FCZb-1oss ~CS3b-losr~PW1-pot% oss Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

FC1-b-loss ~RCS3b-loss~C2a-pot loss Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

BC'-loss ~RCS3b-los~-PG5-potAoss Condition not supported fn PEG Condition not supported ln PEG.

Condition not supported in PEG.

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rem rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG, Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported 1n PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported 1n PEG.

Condition not supported in PEG.

Cond1tfon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported 1n PEG.

Condition not supported in PEG.

FC1-b-loss~RCS5-loss~PCS-pot-loss Condition not supported 1n PEG.

Condition not supported in PEG.

Condition not supported in PEG.

l C14-loss ~RQS6-loss~PQ2b-pot-loss Condition not supported in PEG.

Condition not supported in PEG.

Conditfon not supported fn PEG.

FC14-loss ~RCS6-loss~PG4-pot loss Conditfon not supported in PEG.

Condition not supported 1n PEG.

Condition not supported in PEG.

FC-1-b-loss ~gCS6-loss +Pub-pot-loss Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported 1n PEG.

29

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk~;

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported In PEG.

4 FC2-loss ~RCS2-loss-~PCS-pot% oss 26 i

~CS2-loss + PC3-potAoss 1'iiiiiii!'-iiiiiiiii'll'CR-1oss Condition not supported In PEG.

Condition not supported In PEG.

9 F62-loss ~RCS2-loss ~C6a-pot loss 9 10 Condition not supported in PEG.

F62-loss ~RGS2-loss ~PCS-pot&oss Subsumed In "Judgment" EAL.

4 26

OSSI 92-402A-2-REG R.E. GInna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm rks 6

Condttton not supported In PEG.

Condition not supported in PEG.

8 9

10 Condition not supported in PEG.

Subsumed In "Judgment" EAL.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed In "Judgment" EAL.

4 26 6

F62-1oss ~RGS4-loss ~Q2c-pot&oss 35, Addressed inAct5Glo+Dep stpt pres, above.

Condition not supported In PEG.

Condition not supported In PEG.

CS4-loss~PC5-pot loss 8 9

10 F42-loss ~RCS4-loss ~PQ7-pot loss Condition not supported in PEG.

Subsumed In "Judgment" EAL Condition not supported In PEG.

FC2-loss ~RQS5-loss~PC2a-po4-loSs Condition not supported In PEG.

~

Condition not supported In PEG.

Condition not supported In PEG.

31

OSSI S2-402A-2-REG R.E. Ginna FissIon Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier

'I General Emergencies NESP-007 ~Rm rks Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Subsumed in "Jument" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

PCS-loss ~RGS-la-loss-~P-G4-pot-loss Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

F83-1ess ~RCS-la-loss~PC6b-pot loss Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

FC3-loss ~RCS I b-loss~ PC4-potAoss Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

F63-loss ~RCSI b-loss-+ PC2c-pot-loss Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

32

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rem rk Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

9, ll 9, ll 9, 11 9,11 Condition not supported in PEG.

Condition not supported fn PEG.

9, 11

9. 11 9,11 CondiUon not supported In PEG.

Subsumed in "Judgment" EAL.

9, ll 9, 11 9,11 9, ll Condition not supported In PEG.

Condition not supported In PEG.

9,11 PCS-loss ~RCS3a-loss-~PC6a-potWoss 9,11 9, ll Condition not supported in PEG.

FG3-loss ~CS3a-loss-~PCS-pot loss Subsumed in "Judgment" EAL.

Condition not supported In PEG.

Condition not supported In PEG.

F63-1oss ~RCS3b-loss~ PC2b-po4-loss Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

33

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 Re~m~rk Condition not supported fn PEG.

Condftfon not supported fn PEG.

Subsumed fn "Judgment" EAL.

9,11 9, ll 9,11 9, 11 Condition not supported fn PEG.

Condition not supported fn PEG.

9, ll 9,11 9, ll Condition not supported fn PEG.

Subsumed fn "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Conditfon not supported fn PEG.

Condition not supported fn PEG.

FC3-loss ~RGS5-loss-~PQ7-po4-loss Condition not supported fn PEG.

Subsumed fn "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

FC3-loss ~RCS6-loss~PCS-poMoss Subsumed in "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Subsumed fn "Judgment" EAL.

F63-loss ~RQS6-loss ~PC6a-pot-loss Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

S OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAI EvaluaUon, Rev. 0 Table D Ghana Fission Product Barrier General Emergencies NESP-007 ~Rm~rk.q Subsumed in "Judgment" EAL Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

, CondiUon not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

CondIUon not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

FQ4-1oss ~RCS2-loss ~PWI-pot% oss Condition not supported in PEG.

Condition not supported In PEG.

FC4-1oss + RQS2-loss-~PG2c-pot-loss Condition not supported In PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

FQ4-loSS ~RGS2-loss~~-pot loss Condition not supported ln PEG.

Condition not supported ln PEG.

CondlUon not supported in PEG.

~oss ~RCS2-loss ~C8-po4-1oss CondIUon not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

35

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginaa Fission Product Barrier General Emergencies, NESP-007 ~Rm~rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condftion not supported fn PEG.

Condition not supported In PEG.

~oss ~RCS4-loss ~Pic-pot loss Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

FC4-loss ~GS4-loss~PCS-potatoes Condition not supported in PEG.

Condition not supported in PEG.

Condftfon not supported In PEG.

F64-1oss ~RCS4-loss-~PC7-pot loss Condftfon not supported In PEG.

Condition not supported fn PEG.

Conditfon not supported in PEG.

FC4-loss ~CS5-loss~PC2a-pot-loss Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP- 07 ~R~m~k CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported In PEG.

CondiUon not supported In PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condltfon not supported ln PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

FCG-loss ~RCS-fa-lo~PC4-pot-loss Condition not supported In PEG.

Conditfon not supported ln PEG.

CondlUon not supported fn PEG.

FQS-1oss ~RCSla-loss~PC6b-pot loss Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported In PEG.

PCS-1oss ~RCS 1 b-loss-~PW1-po4-loss Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

37

OSSI 92-402A-2-REG R.E. GInna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported In PEG.

CondIUon not supported in PEG.

4 26 6

['-,-.'-:.-

i: !-'"'-":-i:-.:!~ii:;iiP:'ondition not supported in PEG.

Condition not supported in PEG.

8 9, ll 10 Condition not supported in PEG.

Subsumed In "Judgment" EAL.

26 Condition not supported In PEG.

Condition not supported in PEG.

8 FCS-loss ~RCS3a-loss~PG6a-pot loss 9, II 10 Condition not supported in PEG.

CS3a-loss~PCS-pot loss Subsumed In "Judgment" EAL.

Condition not supported In PEG.

Condition not supported in PEG.

PCS-loss ~RCS3b-loss~P&2b-potAoss Condition not supported In PEG.

CondIUon not supported In PEG.

CondIUon not supported in PEG.

Condition not supported in PEG.

CondiUon not supported In PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL 4

26 6

34, Addressed in Rad5%+Dep stpt pres, above.

Condition not supported in PEG.

Condition not supported 1n PEG.

8 9,11 10 Condition not supported 1n PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Cond1tion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

F65-loss ~RCS5-loss ~F7-po4-loss Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

FQS-loss ~RQS6-loss ~Pea-po4-loss Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL FQS-loss ~RGS6-ioss~C3-pot loss Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

F45-loss ~RCS6-loss ~PQ6a-pot-loss Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

39

QSSI 92-402A-2-REG R.E. Glnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Subsumed in "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

CondlUon not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

CondiUon not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

26 6

) g ~ggphPA'g~Pgg .VIVIV~. I l'P())P(v(epg~lv ~w +, gv-

+; PC2e-yot."~Boss"".'"'.-: '::32.':FSM696""+'.Dj'p"'.itjit'.:y'its'4%5,-::"~~A~":~:::

CondlUon not supported in PEG.

Condition not supported ln PEG.

8 9, ll 10 Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

4

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Remark 26 6

Condition not supported fn PEG.

Condition not supported in PEG.

8 9, ll 10 Condition not supported fn PEG.

Subsumed fn "Judgment" EAI Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condftion not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Conditfon not supported fn PEG.

Conditfon not supported in PEG.

FCG-1 ess Condition not supported fn PEG.

Condition not supported in PEG.

Subsumed fn "Judgment" EAL.

4 26 6

35, Addressed in FFM + Dep stpt pres, P.40 Condition not supported In PEG.

Condition not supported in PEG.

8 9,11 10 Condition not supported In PEG.

Subsumed In "Judgment" EAL.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

41

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rem rks Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Subsumed in "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed fn "Judgment" EAL Subsumed fn "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported In PEG.

Condition not supported in PEG.

Condftfon not supported In PEG.

Condition not supported fn PEG.

FC7-1oss ~RGS-fa-loss-+ PG3-po4-loss Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

F67-loss ~RGS-la-loss-+ PG6a-pot loss Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

F67-1oss ~RGS la-loss~PG8-potAoss CondItion not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

F67-loss ~RGS lb-loss~PG2b-pot-loss Condition not supported in PEG.

Condftfon not supported fn PEG.

Condition not supported In PEG.

42

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~R~m~rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

FC7-loss ~RCS3a-loss~PCS-po4-loss Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

~oss Subsumed in "Judgment" EAL.

+ RCS3a-loss-~PC7-pot&oss Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

FQ7-loss ~RCS3b-los~PC2a-pot loss Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

F47-1oss ~RCS3b-loss-~PC3-potAoss Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL Subsumed In "Judgment" EAL.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL Subsumed In "Judgment" EAL.

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm rks Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Loss of RCS+ has of PC+ pot. loss of FC Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

CondlUon not supported fn PEG.

CondiUon not supported fn PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

CondlUon not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

RCS4a-loss-I-PG2b-loss-~FC3-po Moss Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condftfon not supported ln PEG.

Condltfon not supported ln PEG.

RCSka-loss-+-PG2c-loss~PC-14-po4-loss Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

RCS4a-loss-~G2c-loss ~FC4-po4-1oss Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ghana Fission Product Barrier General Emergencies NE P-007 ~Rem rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condltfon not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condltfon not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condltfon not supported ln PEG.

RCS4a-1oss-~PGS-loss ~FC6-pot loss Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condftion not supported ln PEG.

Condltfon not supported in PEG.

Condftfon not supported in PEG.

Condition not supported in PEG.

Condftfon not supported in PEG.

RC$ 1a-1oss-+ PC6a-loss +F67-potAoss Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies

~NE P-OD7 ~Rm~rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Rt $1.b-loss~Pal-l t loss Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

RQ$ 1b-los~M1-loss ~FC4-pot loss Condition not supported in PEG.

Condition not supported in PEG.

Condition not'supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NE P-0 7 ~Rm rks Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

CondlUon not supported in PEG.

CondiUon not supported fn PEG.

Condftfon not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

CondfUon not supported in PEG.

Condition not supported ln PEG.

Condftion not supported fn PEG.

pot~loss Condition not supported fn PEG.

CondlUon not supported fn PEG.

Condition not supported in PEG.

Condftion not supported fn PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

-C4-loss ~FC5-po4-1oss Condition not supported ln PEG.

Condition not supported fn PEG.

Subsumed in "Judgment" EAL

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NE P-007 ~Rm ark Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

RCS1b-loss-+-PC6b-loss-~l'C7-po4-loss Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

49

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

CondlUon not supported fn PEG.

Condition not supported fn PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not sup orted fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Subsumed ln "Judgment" EAL Condftlon not supported fn PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

CondfUon not supported fn PEG.

Condition not supported fn PEG.

s OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~R~m~rk Condition not supported In PEG.

Condition not supported In PEG.

Condttion not supported tn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed fn "Ju4gnent" EAL.

s s s

s s s o o

s o s o s Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Subsumed fn "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condftfon not supported In PEG.

Condltfon not supported ln PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condltfon not supported fn PEG.

Condition not supported in PEG.

Condition not supported In PEG.

51

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 40 Condition not supported ln PEG.

40 40 Condition not supported fn PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAI Condition not supported ln PEG.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL Condltfon not supported in PEG.

Condition not supported ln PEG.

Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Conditfon not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

'drwe~ erkwv)N ri +:FC3 got.-":joss j~j::::::."37:;.,::!85i8"+::CET700~i~i'::i':..'::::;:4':~ji~>".:~+~i.".":::::

52

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Gonna Fission Product Barrier General Emergencies NESP-007 ~Rem rk Condition not supported fn PEG.

CondiUon not supported fn PEG.

Subsumed in "Judgment" EAL.

39 39 39 39 CondlUon not supported ln PEG.

Subsumed In "Judgment" EAL.

Condition not supported in PEG.

CondlUon not supported In PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

39 39 Condition not supported ln PEG.

39 39 Condition not supported In PEG.

Condition not supported In PEG.

Subsumed In "Judgment" EAL.

39 39 Condition not supported in PEG.

39 39 Condition not supported ln PEG.

Condition not supported fn PEG.

RCSSa Subsumed in "Judgment" EAL.

Condition not supported ln PEG.

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~R~m~rk Condition not supported'fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Conditfon not supported fn PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

Condltfon not supported fn PEG.

Condition not supported fn PEG.

40 Condition not supported in PEG.

40 40 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed fn "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~R~m~rk Subsumed in "Judgment" EAL.

Condltfon not supported fn PEG.

Condition not supported in PEG.

Subsumed In "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported In not supported In PEG.

PEG.'onditfon Condition not supported ln PEG.

Condftlon not supported in PEG.

Condition not supported fn PEG.

ess Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condftlon not supported fn PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

55

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrfer EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Condition not supported fn PEG.

Condition not supported in PEG.

CondlUon not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

CondlUon not supported fn PEG.

Condltfon not supported in PEG.

Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

CondfUon not supported In PEG.

Condition not supported ln PEG.

CondlUon not supported ln PEG.

Condition not supported in PEG.

CondlUon not supported In PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condltfon not supported In PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

OSSI 92-402A-2-REG R.E. Glnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported ln PEG.

Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

37 39 Condition not supported ln PEG.

39 39 57

OSSI 92-402A-2-REG R.E. Glnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rem rk Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

39 39 Condition not supported in PEG.

39 39 Condition not supported ln PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Conditfon not supported ln PEG.

39 39 Condition not supported fn PEG.

39 39 Condition not supported fn PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

39 ."

39 Condition not supported ln PEG.

39 39 Condition not supported ln PEG.

Conditfon not supported in PEG.

Subsumed in "Judgment" EAL.

OSSI 92-402A-2-REG R.E. Glnna Fission Product Barrfer EAL Evaluatfon, Rev. 0 Table D . Ghana Fission Product Barrier General Emergencies

~NESP-0 7 ~Rm~rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Conditfon not supported ln PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

40 40 Condition not supported ln PEG.

40 40 Condltfon not supported ln PEG.

Condition not supported fn PEG.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL Condition not supported ln PEG.

59

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condftlon not supported In PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Subsumed In "Judgment" EAL.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condftlon not supported fn PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Subsumed In "Judgment" EAL.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Conditfon not supported In PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Remark CondiUon not supported ln PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

CondlUon not supported ln PEG.

Subsumed in "Judgment" EAL CondlUon not supported In PEG.

Condition not supported In PEG.

CondiUon not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Conditfon not supported ln PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Conditfon not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

61

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condftion not supported In PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condltfon not supported in PEG.

Subsumed ln "Judgment" EAL Subsumed fn "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Condition not supported In PEG.

Subsumed fn "Judgment" EAL.

Condition not supported fn PEG.

Condftfon not supported In PEG.

Condltfon not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Subsumed in "Judgment" EAL Subsumed In "Judgment" EAL Condition not supported fn PEG.

Subsumed in "Judgment" EAL.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL EvaluaUon, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm ark Subsumed in "Judgment" EAL.

Condition not supported in PEG.

CondIUon not supported In PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL CondiUon not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

CondItion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported In PEG.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

CondiUon not supported in PEG.

OSSI 92-402A-2-REG R.E. Ginna Ffssion Product Barrier EAL Evaluation, Rev. 0 Table D . Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Conditfon not supported ln PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Conditfon not supported ln PEG.

Condition not supported ln PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL Subsumed fn "Judgment" EAL.

OSSI 92-402A-2-REG RE. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier

'General Emergencies NESP-007 ~Rm rks Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm ark Loss of PC+ loss of FC+ pot. loss of RCS Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Conditfon not supported fn PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Conditfon not supported fn PEG.

Condftfon not supported in PEG.

Condition not supported fn PEG.

PMI-loss ~FC2-loss ~RQSS-pot-loss Condition not supported in PEG.

Condftfon not supported fn PEG.

Condition not supported in PEG.

PCZ-1oss ~F43-loss ~RGS4b-pot loss Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

P~loss ~FC3-loss-~RGS3b-pot loss Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

PC 1-loss ~F63-loss ~RCS6-pot-loss Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

OSSI 92-402A-2-REG R.E. Glnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NE P-007 ~Rm ark Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

P~loss ~FC7-loss ~R Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

loss ~RQS3b-pot loss Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

p~oss ~FCr.-loss~RCS6-pot loss Condition not supported ln PEG.

11 Pea-loss ~I'C.l a-loss-~RCS2-potAoss ll Condition not supported ln PEG.

ll 67

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rem rk Condition not supported in PEG.

Condition not supported in PEG.

Subsumed fn "Judgment" EAL.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

41 41 Condition not supported fn PEG.

41 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL 9, ll 9,11 9,11 PC2a-loss ~FC3-loss + RQS3b-pot-loss Condition not supported fn PEG.

9, ll Condition not supported in PEG.

Condition not supported in PEG.

-loss-.-~RGS6-pot loss Subsumed fn "Judgment" EAL.

Condition not supported fn PEG.

Condition not supported fn PEG.

FC4-loss ~RQS2-pot loss Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D . Ginna Fission Product Barrier General Emergencies NESP-007 ~Rem rk 41 41 Condition not supported ln PEG.

41 Condition not supported ln PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL 41 41 Condition not supported ln PEG.

41 Condition not supported ln PEG.

Condition not supported ln PEG.

Subsumed ln "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Condition not supported ln PEG.

Subsumed ln "Judgment" EAL.

Condition not supported ln PEG.

Subsumed ln "Judgment" EAL.

Subsumed In "Judgment" EAL.

ll 11 Condition not supported ln PEG.

11 Condition not supported In PEG.

Condition not supported In PEG.

Subsumed ln "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 Remarks Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

42 42 Condition not supported in PEG.

42 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

9,11 9,11 9,11 Condition not supported in PEG.

9, 11 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

PC2b-loss ~FC4-loss ~RCS2-pot loss Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

PCS'4ossj;:::,:::+'.: FC5-loss +-RCS-1a'-pro'ss'.".':""42,'! Ini)oc'a":re'sy'";i;:::BidÃi6'i>>,"'.:

42 42 PC2b-1oss~FC5-loss ~-RCS3a-pot loss Condition not supported in PEG.

42 Condition not supported in PEG.

70

0 OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 Remarks Condition not supported in PEG.

Subsumed in "Judgment" EAL.

42 42 Condition not supported In PEG.

42 Condition not supported In PEG.

Condftfon not supported In PEG.

Subsumed In "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported fn PEG.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported In PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Conditfon not supported ln PEG.

Condltfon not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condftlon riot supported In PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

71

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~R~m~rk Condition not supported in PEG.

Condition not supported in PEG.

CondIUon not supported In PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported In PEG.

CondIUon not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

CondItion not supported fn PEG.

P~os~-FC5-loss~RQS la-pot lose Condition not supported In PEG.

Condftfon not supported in PEG.

Condition not supported fn PEG.

-loss ~RCS3a-pot loss Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported In PEG.

-loss= -~RCS5-pot loss Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

-loss-- +-RCS-1-b-potAoss Condition not supported fn PEG.

CondfUon not supported In PEG.

Condition not supported in PEG.

72

OSSI 92-402A-2-REG R.E. Gonna Fission Product Barrier EAI. Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NE P-007 ~Rem rk Condltfon not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

ll Condition not supported in PEG.

ll Condltfon not supported ln PEG.

Condition not supported ln PEG.

Subsumed in "Judgment" EAL Condition not supported ln PEG.

Condition not supported ln PEG.

Condltfon not supported ln PEG.

Conditfon not supported in PEG.

Condition not supported in PEG.

AA're ~~.' )> g vg Condition Nhv vQ Bah'v not supported in PEG.

4'hre lw vr'pq +pl'. l ghv@'gh '()v rr&vg'pg'Av(

h%h h%%

PQ3-loss ~I'C2-loss =~RCSIb-pot~

- 43 43 Condition not supported ln PEG.

2-loss-. ~RGS3b-po toss- 43 Condition not supported ln PEG.

Condition not supported in PEG.

73

OSSI 92-402A-2-REG R.E. Glnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D . Ginna Fission Product Barrier General Emergencies NESP-007 Remarks Subsumed in "Judgment" EAL.

9,11 9,11 9,11 Condition not supported ln PEG.

9,11 Condition not supported in PEG.

Condition not supported ln PEG.

Subsumed in "Judgment" EAL Condition not supported fn PEG.

PCS-1 Condition not supported ln PEG.

PCS-1 Condition not supported in PEG.

QC3-1 Condition not supported fn PEG.

Condition not supported ln PEG.

p-cs-l Condition not supported In PEG.

Condftion not supported ln PEG.

Condition not supported ln PEG.

43 43 p-c3-1 Condition not supported fn PEG.

43 PCS-1 Condition@gal!!J'ch,zptvgv not supported In PEG.

Condition not supported ln PEG.

t:,Ã!i  :..

ii:.:-':';--"::-:::,:-i:

i "~iiiiii,!'i,Ul'ilii'i,,

.p Subsumed In "Judgment" z4p'cAvr 43

'!Ap(QQ, ~ %vs !w~! ~

EAL.

- .F !

43 PCS-1 Condltfon not supported In PEG:

p-cs-l 43 Condition not supported ln PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

74

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~R~m~rk Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Subsumed In "Judgment" EAL.

Condition not supported ln PEG.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

ll ll Condition not supported in PEG.

ll Condition not supported ln PEG.

Condition not supported ln PEG.

Subsumed in "Judgment" EAL.

Condition not supported ln PEG.

ess Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

i:,:i ii!" "'i!i'll!i'l:, -'! 'i'l'-':::,'i'~i'i'i,',i"i""'"',"',"i,""""':ill,'i!i'"'i i!i i!i'NI%!ilia!'di(ii:

PC4-loss ~FC2-loss + RCS-15-po4-loss 45 45 Condition not supported In PEG.

PC4-loss ~FC2-loss- --+ RCS3b-pot loss 45 Condition not supported In PEG.

Condition not supported ln PEG.

PC4-loss ~FC2-loss- - +-RCS6-pot loss Subsumed in "Judgment" EAL.

9,11 9,11 PC4-loss ~FC3-loss- -~RCS2-pot&oss 9, 11 Condition not supported in PEG.

9, 11 75

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ghana Fission Product Barrier General Emergencies NESP-007 ~Rem rk Condition not supported fn PEG.

Condition not supported in PEG.

Subsumed fn "Judgment" EAL.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

45 45 Condition not supported In PEG.

45 Condition not supported in PEG.

Conditfon not supported in PEG.

Subsumed fn "Judgment" EAL.

so-?

45 45 Condition not supported In PEG.

PC4-1oss ~FG6-loss ~RCS3b-potAoss 45 Condltfon not supported ln PEG.

Condltfon not supported fn PEG.

P loss ~RCS6-pot loss Subsumed In "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Subsumed ln "Judgment" EAL.

P~oss ~FG7-lo~RGss-posJoss Subsumed m "Judgment EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Subsumed ln "Judgment" EAL.

76

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NE P-007 R<'m hark,q Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condltfon not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

loss ~RCS2-pot<oss Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

1oss~RGS4-poiAoss Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

loss +-RGSls-pot loss Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

77

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 I

Table D Ginna Fission Product Barrier General Emergencies NE P-007 ~Rm~rk Condition not supported in PEG.

Condition not supported In PEG.

CondlUon not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condltfon not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported ln PEG.

Condition not supported fn PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

CondiUon not supported ln PEG.

Condition not supported ln PEG.

Conditfon not supported ln PEG.

Condition not supported in PEG.

PQS lo~RQ7 loss ~RQS2 poMoss Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condltfon not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

PQSa-loss t-RQ1 a-loss~RQS la-pot&ass Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

PC6a-1oss ~1'C.l~-loss~RQS3a-pot-loss Condition not supported In PEG.

.CondlUon not supported in PEG.

Condition not supported in PEG.

78

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D; Ginna Fission Product Barrier General Emergencies RESP- D7 ~Rm~rk Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

PG6a-loss ~FC3-loss ~RGS4-pot loss Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

loss- ~GS.la-pot>oss Condltfon not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

PG6a-loss ~FC4-loss ~RGS3a-pot-loss Condition not supported in PEG.

Condltfon not supported in PEG.

Conditfon not supported in PEG.

PG6a-Ioss ~I C4-loss ~RGS5-pot-loss Condition not supported in PEG.

Condition not supported in PEG.

Condftfon not supported in PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAI. Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

PC6b-loss ~I'C-la-loss~RQQa-pot-loss Condition not supported In PEG.

Condltfon not supported in PEG.

Condition not supported ln PEG.

PC6b-1oss mf C-I.a-loss~RCS3a-pot loss Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

PC6b-1oss ~I C-la-loss~RCS5-po4-loss Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

PC6b-loss ~I Cl b-loss- -+-RCS.1b-pot~ Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

OSSI 92-402A-2-REG R.E, Gfnna Fission Product Barrier EAI. Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NE P-007 Re~m~rk Condition not supported fn PEG.

Conditfon not supported in PEG.

CondiUon not supported in PEG.

CondiUon not supported in PEG.

Conditfon not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Cond1Uon not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondfUon not supported fn PEG.

Condition not supported 1n PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported 1n PEG.

CondfUon not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported 1n PEG.

Condition not supported fn PEG.

PQ6b-loss-~I'C4-loss ~RQS3a-potAoss Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

loss ~RGS5-pot loss Condition not supported fn PEG.

Condftfon not supported in PEG.

Condition not supported in PEG.

-loss ~RGB b-potAoss Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

-loss ~RCSSb-po4-1ess Condition not supported in PEG.

Cond1Uon not supported 1n PEG.

Cond1Uon not supported fn PEG.

81

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-0 7 ~Rem rk Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condftfon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

ll ll Condftfon not supported fn PEG.

ll Condition not supported fn PEG.

PQ7-1oss ~f'G.la-loss + RCS5-pot loss Condition not supported in PEG.

Subsumed fn "Judgment" EAL.

Condition not supported fn PEG.

b-loss~RGSl b-pot loss Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

PG7-loss ~FG l b-loss~RGS3b-pot loss Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

PC7-loss ~FC-lb-loss~RGS6-po4-loss Condition not supported in PEG.

40 82

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NE P-007 ~Rm;~rk 40 Condition not supported in PEG.

40 Condit1on not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

9, ll 9, ll 9, ll Condition not supported in PEG.

9, ll Cond1tion not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condit1on not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported 1n PEG.

40 40 40 Condition not supported in PEG.

P-Q7-I -loss ~RCS3b-pot loss 40 Condition not supported in PEG.

Condition not supported in PEG.

PC7-loss ~FC5-loss ~RCS6-pot loss Subsumed 1n "Judgment" EAL.

40 40

-loss-~RCS2-pot loss 40 Condition not supported in PEG.

40

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D . Ginna Fission Product Barrier General Emergencies NESP-007 ~R~m>rk,q Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported ln PEG.

Subsumed ln "Judgment" EAL.

Condition not supported ln PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

PCS-loss ~FC.1 b-loss~RCS3b-pot-loss Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

PCS-1 1b-loss-~RCS6-pot loss Condition not supported ln PEG.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

PAMoss ~FC2-1oss~RGS2-pot-loss Subsumed in "Judgment" EAL Condition not supported ln PEG.

Subsumed in "Judgment" EAL.

PCS-1oss ~I'C2-loss -~RCS4-pot-loss Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NE P-007 ~Rm;~rk Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported fn PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported In PEG.

Subsumed In "Judgment" EAL.

Condition not supported In PEG.

P-CS-I oss ~RCS6-pot loss Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed fn "Judgment" EAL.

loss- ~RCS2-pot loss Subsumed fn "Judgment" EAL Conditfon not supported in PEG.

Subsumed in "Judgment" EAL.

PCS-loss ~FC6-loss -~RCS4-po4-loss Conditfon not supported In PEG.

Subsumed fn "Judgment" EAL.

Subsumed in "Judgment" EAL 7-loss-~RCS-Ia-pot~ Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL Subsumed In "Judgment" EAL.

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NE P-0 7 ~Rm~rk Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported fn PEG.

Subsumed ln "Judgment" EAL Subsumed fn "Judgment" EAL.

Loss of FC + loss of RCS+ has of PC Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

FC4a-1 Condition not supported in PEG.

FC-1a-loss ~RCS-1b-loss-~PC3-loss Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

FC-1a-loss ~RCS14-loss'6a-loss Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

FC-1a-loss ~RCS4b-loss-~PCS-loss Condition not supported in PEG.

Condition not supported ln PEG.

11, 26 ll Condition not supported ln PEG.

ll

l 5'.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NE P-007 ~Rm~rk ll CondfUon not supported in PEG.

Condition not supported in PEG.

ll Subsumed in "Judgment" EAL Condition not supported in PEG.

ll, 26 11,6 Condition not supported in PEG.

ll ll Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

ll Subsumed in "Judgment" EAL.

CondiUon not supported in PEG.

CondfUon not supported fn PEG.

CondiUon not supported fn PEG.

Condftfon not supported in PEG.

CondfUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

FC-1a-loss ~RCS3b-loss-~PC6a-loss Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

FCka-loss ~RCS3b-loss-~PCS-loss Condition not supported fn PEG.

Condition not supported fn PEG.

11, 26 FQ4a-loss ~RCS4-loss~PC2b-loss 11,6 Condition not supported in PEG.

ll FC4a-loss ~RCS4-1 ll Condition not supported fn PEG.

Condition not supported in PEG.

87

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation. Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NE P- 07 ~Rm~rk Condition not supported in PEG.

ll Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondIUon not supported in PEG.

CondiUon not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Condition not supported in PEG.

Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

FC1-a-loss ~RQS6-loss ~P-C7-1oss Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL.

CondiUon not supported in PEG.

1 Chess ~CS4a-loss~PQ2a-loss Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

FC4b-loss ~RCS-la-loss-+ P-C3-loss Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

C$ 1a-loss-+ PC6a-loss Condition not supported in PEG.

,Condition not supported in PEG.

Condition not supported in PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D, Ghana Fission Product Barrier General Emergencies N~EP- 07 ~R~m~rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condftlon not supported ln PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

FCi4-loss ~RCS3a-loss-+ PCS-loss Condition not supported In PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

FC-14-Joss I-RCS3a-lo~PC3-loss Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

FC@b-loss ~RCS3a-los~PG6a-loss Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

PM14-loss ~RCS3a-loss~P-Q8-loss Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported in PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL EvaluaUon, Rev. 0 Table D '- Ginna Fission Product Barrier General Emergencies .

NE P-007 ~Rm rks Condition not supported in PEG.

CondiUon not supported in PEG.

CondfUon not supported in PEG.

Condition not supported in PEG; Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Conditfon not supported fn PEG.

Condition not supported in PEG.

CondfUon not supported In PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftfon not supported fn PEG.

Condition not supported in PEG.

Condftfon not supported in PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

FQ-~loss ~RCS5-loss +PC2o-loss Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

FC44-less ~CS5-loss~PCS-loss Conditfon not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

l44b-less-~RCS5-loss~PC7-loss Condition not supported fn PEG.

Condition not supported in PEG.

CondfUon not supported in PEG.

l~-loss ~RCS6-lor~~PC2a-loss Conditfon not supported fn PEG.

'Condition not supported fn PEG.

Condition not supported In PEG.

OSSI 92-402A-'2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

FC2-loss ~RGS-I-b-loss-~PC4-loss Condition not supported In PEG.

Condition not supported fn PEG.

F62-1oss + RCS-lb-loss-~PG6b-loss Condition not supported Condition not supported fn PEG.

In PEG.

Condition not supported In PEG.

Condition not supported In PEG.

F62-1oss ~RCS2-loss~PWI-loss Condition not supported in PEG.

26 42 F62-1oss ~RCS2-loss-~PC2o-loss Condition not supported In PEG.

43 45 91

QSSI 92-402A-2-REG R.E. Glnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier

'General Emergencies NESP-007 ~Rem rk Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

26 6,42 Condition not supported ln PEG.

43 45 Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

40

.Subsumed in "Judgment" EAL Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

F62-1oss ~RGS3b-Joss-+ PG6a-loss Condition not supported ln PEG.

Condltfon not supported ln PEG.

Condltfon not supported ln PEG.

F62-1oss ~RGS3b-loss~PCS-loss Condition not supported fn PEG.

Condition not supported ln PEG.

26 FC2-1oss ~RGS4-loss~PG2b-Joss 6,42 Condition not supported in PEG.

43 F62-Joss ~GS4-loss ~P-G4-loss 45 Conditfon not supported in PEG.

Condition not supported in PEG.

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ghana Fission Product Barrier General Emergencies NESP-007 ~Rm rks Condition not supported In PEG.

CondlUon not supported in PEG.

Subsumed In "Judgment" EAL.

CondfUon not supported In PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

CondfUon not supported ln PEG.

CondiUon not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

CondfUon not supported In PEG.

Condition not supported fn PEG.

Subsumed In "Judgment" EAL.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL Condition not supported in PEG.

PCS-loss ~CS-la-loss-~PC2a-loss Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

PCS-1oss ~RCSla-los~PC3-loss Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

F83-loss ~CS-la-loss-~C6a-loss Conditfon not supported fn PEG.

Condition not supported In PEG.

Condition not supported in PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. Q Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rmark Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

9, 11,26 9, 11,42 Condition not supported in PEG.

43 45 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

4Q Subsumed in "Judgment" EAL.

FC3-1oss ~GS3a-loss-~PCS-loss Condition not supported in PEG.

9, 11,26 F43-1oss + RGS3a-loss~PC2c-loss 9, 11,42 Condition not supported in PEG.

43 45 FC3-1oss ~RGS3a-loss~PCS-loss Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

FC3-loss ~RGS3a-loss~ P-G7-loss 4Q Subsumed in "Judgment" EAL.

CondiUon not supported in PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NE P- 07 ~Rm~rk Condition not supported fn PEG.

Condition not supported 1n PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Conditfon not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Subsumed 1n "Judgment" EAL.

Condition not supported fn PEG.

9, 11,26 9, 11,42 Condition not supported fn PEG.

43 45 Condition not supported fn PEG.

Condition not supported in PEG.

Condftfon not supported fn PEG.

40 Subsumed in "Judgment" EAL.

Condftfon not supported in PEG.

Condition not supported 1n PEG..

RCS5-loss ~PC2b-loss Cond1tion not supported 1n PEG.

Condition not supported in PEG.

Conditfon not supported in PEG.

F63-1oss RCS5-loss-~PC4-loss

+ Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

PCS-loss ~RCS5-loss ~PC6b-loss Condition not supported fn PEG.

Condition not supported fn PEG.

Subsumed fn "Judgment" EAL F63-1ess ~RCS6-loss~PC-1-loss Conditfon not supported in PEG.

Subsumed fn "Judgment" EAL.

Subsumed 1n "Judgment" EAL 95

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftfon not supported fn PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condltfon not supported In PEG.

Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

FQ4-loss ~RCS.lb-loss-I-PC3-lass Condition not supported In PEG.

Condftfon not supported in PEG.

Condition not supported in PEG.

FQ4-lass ~RCS1 b-loss-+-PG6a-loss Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

FC4-loss ~RGS1b-l~-PGS-loss Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

F44-lass ~RGS2-loss ~PG2b-loss Condition not supported fn PEG.

CondlUon not supported ln PEG.

Condftion not supported fn PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product &wrier

'General Emergencies NESP-007 ~Rm rks Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondIUon not supported in PEG.

Condition not supported in PEG.

Condftion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Conditfon not supported in PEG.

Condition not supported in PEG.

Conditfon not supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

FQ4-loss ~RCS3b-loss-+ Pea-loss Condition not supported In PEG.

Condition not supported in PEG.

Conditfon not supported in PEG.

FC4-1oss ~RQS3b-loss-~PCS-loss Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

FG4-loss ~RCS4-loss ~Pub-loss Condftfon not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

FQ4-loss ~RCS4-loss~ P-C4-loss Condftion not supported in PEG.

CondiUon not supported In PEG.

Condition not supported in PEG.

97

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAI. Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP- 07 ~Rm~rk Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported In PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported In PEG.

FC4-los~RGS6-loss ~P~oss Condition not supported In PEG.

F64-1 Condition not supported fn PEG.

CondNon not supported in PEG.

FG5-loss ~RCSIa-loss-t PC2a-loss Condition not supported In PEG.

Condition not supported in PEG.

Conditfon not supported In PEG.

PCS-1oss ~RCSla-lo~PC3-loss Condition riot supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

F65-loss ~RCSla-loss-~PC6a-loss Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ghana Fission Product Barrier General Emergencies NE P-0 7 ~Rm~rk.q Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Conditfon not supported in PEG.

26 6,42 Conditfon not supported in PEG.

43 45 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 Subsumed in "Judgment" EAL.

F45-loss ~RCS3a-loss-+ PC4-loss Condition not supported in PEG.

26 6,42

-loss-+ PC2o-loss Condition not supported in PEG.

43 45 PCS-1oss ~RCS3a-loss-+ PC5-loss Condition not supported in PEG.

Condition not supported fn PEG.

Conditfon not supported in PEG.

FCS-1oss ~RCS3a-loss~PC7-loss 40 Subsumed in "Judgment" EAL.

Conditfon not supported fn PEG.

I Ai

,I

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rem rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

26 6,42 Condition not supported In PEG.

43 45 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 Subsumed in "Judgment" EAL.

Conditfon not supported in PEG.

Condition not supported In PEG.

FC5-loss ~RCS5-loss-~PCS-loss Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

FC5-1oss ~RCS5-loss~PC4-loss Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

FCS-1oss ~RCS5-loss ~PC6b-loss Condition not supported fn PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

~RCS6-loss ~PC-1-loss 'CS-1oss Condition not supported in PEG.

Subsumed In "Judgment" EAL.

Subsumed In "Judgment" EAL.

OSSI 92-402A-2-REG R.E. Glnna Fission Product Barrier EAL Evaluation, Rev. 0 Table D; Ginna Fission Product Barrier General Emergencies NESP-007 ~Rem rk Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL..

Condition not supported ln PEG.

Condition not supported in PEG.

Condftion not supported ln PEG.

Subsumed in "Judgment" EAL Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

Condltfon not supported ln PEG.

Conditfon not supported ln PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condltfon not supported In PEG.

Condition not supported In PEG.

Condition not supported In PEG.

Condition not supported in PEG.

Condltfon not supported In PEG.

Condltfon not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported In PEG.

Condition not supported ln PEG.

41 42 Condition not supported ln PEG.

43 101

OSSI 92-402A-2-REG R.E. Gfnna Fission Product Barrier EAL EvaluaUon, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm rks 45 Condition not supported in PEG.

Condition not supported fn PEG.

CondiUon not supported in PEG.

40 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

26 6,42 Condition not supported in PEG.

43 45 Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

40 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported 1n PEG.

Condition not supported 1n PEG.

Condftfon not supported in PEG.

Condftion not supported in PEG.

FC6-loss ~RCS3b-loss-+ PG5-loss Condition not supported fn PEG.

Condition not supported in PEG.

FC6-1ess + RCS3b-loss-~-PG7-loss Condition Condition not supported not supported fn PEG.

in PEG.

Condition not supported fn PEG.

.Conditfon not supported fn PEG.

F66-less ~RCS4-loss~PG2a-loss 26 6,42 Condition not supported in PEG.

F46-1ess ~RGS4-loss ~PC3-loss 43 45 Condition not supported in PEG.

102

OSSI 92-402A-2-REG R.E. Gfnna Ffssfon Product Barrier EAL EvaluaUon, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-0 7 Re~m~rk Condition not supported in PEG.

Condition not supported fn PEG.

40 Subsumed fn "Judgment" EAL.

CondiUon not supported fn PEG.

CondIUon not supported fn PEG.

Condition not supported In PEG.

CondItfon not supported In PEG.

CondIUon not supported fn PEG.

CondfUon not supported fn PEG.

CondiUon not supported fn PEG.

Condition not supported fn PEG.

CondfUon not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed fn "Judgment" EAL.

Subsumed In "Judgment" EAL.

Condition not supported in PEG.

Conditfon not supported In PEG.

FQ6-loss ~RGS6-loss ~PG6b-loss Condition not supported fn PEG.

Subsumed In "Judgment" EAL.

Subsumed fn "Judgment" EAL.

~oss ~RQ$ 1a-loss-+ PG-I-loss Condition not supported fn PEG.

Condftfon not supported In PEG.

Condition not supported in PEG.

FC7-loss ~RGS la-loss~PG2o-loss Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

FC7-1oss ~RGS la-loss ~PG5-loss Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

OSSI S2-402A-2-REG R.E. Ginna Fission Product Barrfer EAL Evaluation, Rev. 0 1

Table D Ginna Fission Product Barrier General Emergencies NESP- 07 ~Rm~rk Condition not supported in PEG.

Condition not supported in PEG.

Condftion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condftfon not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Subsumed fn "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported fn PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Conditfon not supported In PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

FC7-loss ~RGS2-los~ PGS-loss Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

F67-loss ~GS3a-loss-+ PG2b-loss Subsumed In "Judgment" EAL.

Condition not supported In PEG.

Subsumed In "Judgment" EAL.

FC7-1oss ~RGS3a-loss~PG4-loss Subsumed In "Judgment" EAL.

Condftion not supported in PEG.

~oss Condition not supported fn PEG.

+ RGS3a-loss~C6b-loss Condition not supported In PEG.

Subsumed fn "Judgment" EAL.

Subsumed fn "Judgment" EAL.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D Ginna Fission Product Barrier General Emergencies NESP-007 ~Rm~rk Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed In "Judgment EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported In PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

F47-loss ~RGS5-loss-~PG2a-loss Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Condition not supported in PEG.

~oss ~RGS5-loss~PG3-loss Subsumed In "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

FC7-loss ~RGS5-loss ~PG6a-loss Condition not supported in PEG.

Condition not supported in PEG.

Subsumed In "Judgment" EAL.

F67-1oss ~RGS5-loss~PGS-loss Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

105

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Table D . Ginna Fission Product Barrier General Emergencies NESP-007 ~Rem rk Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

OSSI 92-402A-2-REG R,E. Ginna Fission Product Barrier EAI. Evaluation, Rev. 0 Appendix 1 Fission Product Barrier Remarhs The only source of signiQcant containment pressure increase other than a faulted steam generator is an RCS boundary breach. By definition, loss of the RCS boundary and the loss of the primary containment boundary require a Site Area Emergency classification.

Therefore, this EAL is unnecessary and can be deleted.

2. If an inconsistent loca response is observed, a loss of the RCS has .

occurred. By definition, loss of the RCS boundary and the loss of the primary containment boundary require a Site Area Emergency classiQcation. Therefore, this EAL is unnecessary and can be deleted.

3. The initiation signal for containment isolations are result of an RCS breach. By deQnition, loss of the RCS boundary and the loss of the primary containment boundary require a Site Area Emergency classification. Therefore, this EAL is unnecessary and can be deleted.

4, In order to reach containment-red on the CSFST, containment design pressure has been reached or exceeded. This is indicative of a loss of RCS boundary. It is not possible to reach this condition without also being in a Heat Sink-Red or Core Cooling-Red CSFST which is a loss of RCS and the fuel clad barrier. The source of energy must be the result of severe degr'adation of core cooling or loss of heat sink. Since the EAL is a potential loss of containment by definition, this combination of conditions requires the declaration of a General Emergency.

Therefore, this EAL is unnecessary and can be deleted.

5. Containment design pressure can only be reached as a result of a severe loca event. This represents'a loss of the RCS barrier and a potential loss of the fuel cladding. By definition, this combination of conditions requires the declaration of at least an Alert classification.

Therefore. this EAL is unnecessary and can be deleted.

6. Generation of this level of hydrogen concentration in the containment indicates that.a loss of fuel clad barrier and loss of RCS barrier has occurred with a potential loss of the primary containment barrier. By deQnition, this combination of conditions requires the declaration of a General Emergency. Therefore, this EAL is unnecessary and can be deleted.

7'. The conditions listed in this EAL represent a loss of the RCS barrier with a potential loss of containment. By definition. the loss of the RCS barrier requires the declaration of an Alert. Therefore, this EAL is unnecessary and can be deleted.

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Appendix 1 Fission Product Barrier Remarks

8. These containment radiation levels can only be reached as a result of a severe core damage. This represents a loss of the fuel clad barrier and the loss of the RCS barrier with a potential loss of the primary containment. By definition, this combination of conditions requires the declaration of a General Emergency. Therefore, this EAL is unnecessary and can be deleted.

9. Core Exit Thermocouple readings )1200 'F with a failure of restoration procedures represent a potential loss of the primary containment, a loss of fuel clad barrier, and a loss of subcooling which is a fundamental indication of a loss of the RCS barrier. By definition, this combination of conditions requires the declaration of a General Emergency. Therefore, this EAL is unnecessary and can be deleted,

10. A Core Exit Thermocouple reading 2700 'F with reactor vessel water level below the top of active fuel requires entry to the Core Cooling-Red CSFST and warrants declaration of a General Emergency. See justification ¹11. Therefore, this EAL is unnecessary and can be deleted.

Core Cooling-Red on the CSFST is indicative of a Core Exit Thermocouple reading of )1200 'F, or reactor vessel water level below the top of active fuel with a Core Exit Thermocouple reading of )700

'F. EAL¹ FC3.1 and EAL¹ FC3.2 represent a loss and potential loss of the fuel clad based on Core Exit Thermocouple readings of 1200 'F and 700 'F, respectively. EAL¹ RCS2.1 represents a loss of subcooling, therefore, entry into Core Cooling-Red also represents a loss of the RCS barrier. EAL¹ PC6.2 is indicative of a Core Exit Thermocouple reading )700 'F and represents a potential loss of primary containment barrier. Thus, entry into Core Cooling-Red requires declaration of a General Emergency. Therefore, this EAL is unnecessary and can be deleted.

12. Core Cooling-Orange on the CSFST represents a potential loss of the fuel clad barrier and a loss of subcooling which is indicative of a loss of the RCS barrier. By deQnition, this combination of conditions requires the declaration of a Site Area Emergency. Therefore, this EAL is unnecessary and can be deleted.

13. Heat Sink-Red on the CSFST represents an extreme challenge to the heat sink function and, by EAL¹ SS4.1, requires the declaration of a Site Area Emergency. Therefore, this EAL is unnecessary and can be deleted.

1-2

OSSI 92-402A-2-REG R.E. Gipna Fission Product Barrier EAI. Evaluation, Rev. 0 Appendix 1 Fission Product Barrier Remarks

14. A Core Exit Thermocouple reading t700 'F represents a potential loss of the fuel clad and a loss of subcooling which is a loss of the RCS barrier. By definition, this combination of conditions requires the declaration of a Site Area Emergency. Therefore, this EAL is unnecessary and can be deleted.

15. RVLIS less than or equal to the top of active fuel requires, by EAL¹ SS5.1, the declaration of a Site Area Emergency. Therefore, this EAL is unnecessary and can be deleted,

16. Deleted

17. A SGTR with a resultant path to the environment represents breach of both the RCS and the primary containment barriers, This combination of conditions requires, by definition, a Site Area Emergency declaration. Therefore, this EAL is unnecessary and can be deleted.

18. The containment radiation monitor reading for EAL¹ RCS4.1 bounds the reading given in EAL¹ FC5.1. Therefore, EAL¹ FC5.1 is unnecessary and can be deleted.

19. Heat Sink-Red on the CSFST represents a potential loss of the fuel clad barrier and the RCS barrier. This combination of conditions requires, by definition, the declaration of a Site Area Emergency.

Therefore, this EAL is unnecessary and can be deleted.

20. The RCS leakage for EAL¹ RCS2.2 bounds the leakage given in EAL¹ RCS3.2. Therefore, EAL¹ RCS3.2 is unnecessary and can be deleted.

21. EAL¹ FC5.1 is a containment radiation level corresponding to 5% fuel clad failure. It is also indicative of an RCS failure because EAL¹ RCS4.1 will always be a value less than EAL¹ FC5.1. Therefore, EAL¹ FC5.1 alone requires declaration of a Site Area Emergency.

22. This combination of conditions would produce a containment radiation level at least at the level of EAL¹ FC5.1. Therefore, this combination of conditions is unnecessary and can be deleted.

23. EAL¹ FC6.1 is equivalent to the radiation level corresponding to EAL¹ FC5.1. Containment radiation levels associated with an RCS loss would be indicated'by EAL¹ FC5.1. Therefore, this combination of conditions is unnecessary and can be deleted.

1-3

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Appendix 1 Fission Product Barrier Remarks

24. EAL¹ FC4.1 is indicative of reactor vessel water level less than the top of active fuel. This condition always requires a CSFST entry to Core Cooling-Orange or Core Cooling-Red. Core Cooling-Orange is addressed in EAL¹ FC1.2 and Core Cooling-Red is addressed in EAL¹ FC1.l. Therefore, declaration of a Site Area Emergency due to EAL¹ FC4.1 is unnecessary and can be deleted.

25.. EAL¹ FC3,2 is indicative of a Core Exit Thermocouple reading at or above 700 'F. This condition always requires a CSFST entry to Core Cooling-Orange or Core Cooling-Red. Core Cooling-Orange is addressed in EAL¹ FC1.2 and Core Cooling-Red is addressed in EAL¹ FCl.l. Therefore, declaration of a Site Area Emergency due to EAL¹ FC3.1 is unnecessary and can be deleted.

26. EAL¹ PC2.1 is an entxy into Containment Cooling-Red CSFST which requires a declaration of a General Emergency under EAL¹ PCl.l.

Therefore, all combinations of conditions involving EAL¹ PC2.1 are unnecessary and can be deleted.

27 EAL¹ RCS2.1 is indicative of a loss of subcooling. EAL¹ FC1.1 is based on entry to Core Cooling-Red CSFST which is indicative of a loss of subcooling. Therefore, EAL¹ RCS2.1 can be deleted from this combination of conditions.

28. EAL¹ PC6.2 is indicative of a Core Exit Thermocouple reading of 700

'F. EAL¹ FC1.1 is based on entry to Core Cooling-Red CSFST. Core Cooling-Red cannot be entered without exceeding a 700 'F Core Exit

,Thermocouple reading. Therefore, this combination of conditions is unnecessary and can be deleted.

29. This combination of conditions is adequately covered by EAL¹ FC1.l in combination with EAL¹ PC2.5.

30. EAL¹ PC6.2 is indicative of a Core Exit Thermocouple reading at or above 700 'F and reactor vessel water level below the top of active fuel.

These conditions require an entry to Core Cooling-Red. Core Cooling-Red defines EAL¹ FC1.1. Therefore, EAL¹ PC6.2 can be deleted from this combination of conditions.

31. EAL¹ PC6.2 is indicative of a Core Exit Thermocouple reading at or above 700 'F with a failure of'restoration procedures. Core Exit Thermocouple reading at or above 700 'F is a loss of subcooling which 1-4

OSSI 92-402A-2-REG RE. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Appendix 1 Fission Product Barrier Remarks is the condition that defines EAL¹ RCS2.1. Therefore, EAL¹ RCS2.1 is unnecessary and can be deleted from this combination of conditions.

32. The purpose of EAL¹ RCS2.1 is to indicate the loss of the RCS barrier.

In order to reach the condition of EAL¹ PC2.5, a breach of the RCS barrier is required. Thus, EAL¹ RCS2.1 is bounded by EAL¹ PC2.5.

Therefore, EAL¹ RCS2.1 is unnecessary and can be deleted from this combination of conditions.

33. EAL¹ PC2.5 is indicative of a loss of the RCS barrier and a potential loss of the primary containment barrier. EAL¹ RCS3.1 is indicative of a loss of both RCS and primary containment barriers. A potential loss of primary containment barrier is irrelevant to this combination of conditions. Therefore, EAL¹ PC2.5 is unnecessary and can be deleted from this combination of conditions.

34. EAL¹ RCS4.1 corresponds to a containment radiation level which is always less than that in EAL¹ FC5.1. EAL¹ RCS4.1 only indicates a loss of the RCS barrier where as EAL¹ FC5.1 indicates a loss of both RCS and fuel clad barriers. Therefore, EAL¹ RCS4.1 is unnecessary in defining the General Emergency conditions. With this change, the resulting combination of conditions is identical to those given above with )ustification ¹32.

35, EAL¹ RCS4.1 represents containment radiation levels resulting from a loss of the RCS barrier. However, EAL¹ PC2.5 is indicative of a potential loss of the primary containment barrier and a loss of the RCS barrier. Therefore, EAL¹ RCS4.1 is bounded by EAL¹ PC2.5 and can be deleted from this combination of conditions.

36. EAL¹ FC1.2 is an entry to Core Cooling-Orange on the CSFST. EAL¹ RCS2.1 is an indication of a loss of subcooling and is also an entry to Core Cooling-Orange on the CSFST. Thus, EAL¹ FC1.2 bounds EAL¹ RCS2-.1. Therefore, EAL¹ RCS2.1 is unnecessary and can be deleted from this combination of conditions.

37. RCS3.1 represents both a loss of RCS and loss of primary containment barrier. Therefore, PC2.1 can be deleted from any combination of RCS3.1 loss and fuel clad potential loss,

38. EAL¹ PC2.1. EAL¹ PC2.2, EAL¹ PC3.1, and EAL¹ PC4.1 represent a loss of the RCS and primary containment barriers. Therefore, EAL¹ RCS2.1 which represents a loss of RCS barrier is unnecessary and can be deleted from this combination of conditions.

1-5

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Appendix 1 Fission Product Barrier Remarks

39. By justification ¹38 above, any combination of EAL¹ PC2.1, EAL¹ PC2.2, EAL¹ PC3.1, or EAL¹ PC4.1 and any of the following: EAL¹ FC1.2, EAL¹ FC3.1, EAL¹ FC4,1, or EAL¹ FC6,2, results in the declaration of a General Emergency. Therefore, this combination of conditions is redundant and can be deleted.

40. EAL¹ PC7.1 is used only as loss of primary containment barrier for the Unusual Event declaration. For the Site Area Emergency and the General Emergency declaration, EAL¹ PC7.1 is subsumed into the "Judgment" EAL. Loss of containment airlock doors is event dependent. It is the only NUMARC primary containment barrier loss which is not associated with a loss of the RCS barrier., The airlock doors may be open for reasons other than an emergency situation (e.

gmaintenance activities, etc.). Shift personnel will rapidly respond to failure of other barriers by reclosing the doors. If the doors are not reclosed, any loss of the RCS barrier that occurs with the doors open will appear as an inconsistent loca response. Therefore, this event need not be used to indicate a loss of the primary containment barrier unless the Emergency Director determines such a declaration is needed.

41. EAL¹ PC2.1 is indicative of a loss of the primary containment barrier and a loss of the RCS barrier. Any combination of EAL¹ PC2.1 with a loss of the fuel clad barrier alone requires declaration of a General Emergency. Therefore, the third EAL condition is unnecessary and can be deleted. Any other combinations of conditions using EAL¹ PC2.1 and fuel clad barrier losses are redundant and can be deleted.

42. EAL¹ PC2.2 is indicative of a loss of the primary containment barrier and a loss of the RCS barrier. Any combination of EAL¹ PC2.2 with a loss of the fuel clad barrier alone requires declaration of a General Emergency. Therefore, the third EAL condition is unnecessary and can be deleted. Any other combinations of conditions using EAL¹ PC2.2 and fuel clad barrier losses are redundant and can be deleted.

43. EAL¹ PC3.1 is indicative of a loss of the primary containment barrier and a loss of the RCS barrier. Any combination of EAL¹ PC3.1 with a loss of the fuel clad barrier alone requires declaration of a General Emergency. Therefore, the third EAL condition is unnecessary and can be deleted. Any other combinations of conditions using EAL¹ PC3.1 and fuel clad barrier losses are redundant and can be deleted.

1-6

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Appendix 1 Fission Product Barrier Remarks

45. Any combination of PC4.1 and either of following: FC2.1, FC3.1, FC5.1 or FC6.1 warrants declaration of a general emergency. Therefore this combination can be deleted.

46. Deleted

47. While RCS 1.1 is a potential loss of RCS, the concern for RCS loss is reactor vessel integrity. PC4.1 is a loss of containment in that a secondary side release with primary to secondary leakage > Tech.

Spec. provides a pathway from the RCS to outside containment. While it is feasible for both of these conditions to exist simultaneously, they are not related such that the failure associated with red path integrity (reactor vessel structural failure) interfaces with the containment loss mechanism (steam generator tube leakage). Therefore this combination is not appropriate.

1-7

N OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Appendix 2 Suxnznaxy of Fission Product Barrier Evaluation The following summarizes the EALs which resulted from the analysis performed of the fission product barrier methodology of NUMARC-007 for R.E. Ginna:

Unusual Event

~ PC4. 1-loss

~ PC7,1-loss

~ Emergency Director Judgement Alert:

~ FC2. 1-loss

~ FC6.1 loss

~ RCS1.1-pot loss

~ RCS2. 1-loss

~ RCS4. 1-loss

~ RCS2.2-pot loss

~ Emergency Director Judgement Site Area Emer enc:

~ FC1.2-pot loss

~ FC1.3-pot loss/RCS1.2-pot loss

~ RCS3. 1-loss

~ FC5. 1-loss

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Appendix 2 Suaumaxy of Fission Product Barrier Evaluation Site Area Emer enc cont:

~ FC6.1 loss + ANY:

-RCS l. 1-pot. loss

-RCS2.2-pot. loss

-RCS2. 1-loss

~ PC2. 1-loss

~ PC2.2-loss

~ PCS.1-loss

~ RCS2.2-pot loss + PC4.1-loss

~ Emergency Director Judgement General Emer enc:

~ PC1.1-pot. loss

~ FC1. 1-loss

~ PC2.4-pot. loss

~ PC5.1-pot. loss

~ PC2.5-pot loss + ANY:

-FC2. 1-loss

-FC5. 1-loss

-FC6. 1-loss

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Appendix 2 Summary of Fission Product Barrier Evaluation General Emer enc cont:

~ RCS3. 1-loss + ANY:

-FC1.2-pot loss

-FC1.3-pot loss 1-loss 'FC2.

-FC3.2-pot loss

-FC4. 1-pot loss

-FC5. 1-loss

-FC6.1 loss

~ PC2,1-loss + ANY:

-FC1.2-pot loss

-FC1.3-pot loss

-FC2. 1-loss

-FC3,2-pot loss

-FC4. 1-pot loss

-FC5. 1-loss

-FC6.1 loss

~ PC2.2-loss + ANY:

-FC1.2-pot loss

-FC1.3-pot loss

-FC2.1-loss

-FC3.2-pot loss

-FC4. 1-pot loss

-FC5; 1-loss

-FC6.1 loss

~ PC3.1-loss + ANY:

-FC1.2-pot loss

-FC1.3-pot loss

-FC2. 1-loss

-FC3.2-pot loss

-FC4. 1-pot loss

-FC5. 1-loss

-FC6.1 loss 10

OSSI 92-402A-2-REG R.E. Ginna Fission Product Barrier EAL Evaluation, Rev. 0 Appendix 2 Suamaary of Fission Product Barrier Evaluation General Emer enc cont:

~ PC4.1-loss + ANY:

-FC1.2-pot loss

-FC1.3-pot loss

-FC2. 1-loss

-FC3.2-pot loss

-FC4.1-pot loss

-FC5. 1-loss

-FC6.1 loss

~ PC6.1-pot. loss

~ PC6.2-pot loss

~ Emergency Director Judgement

OSSI 92-402A-3-PWR PWR EAL Bhang Document, Rev. 0 P%'R EAL Binnin Document New York Power Authorit J. A. Fitzpatrick Nuclear Power Plant Indian Point Nuclear Power Plant Unit 3 Ni ara Mohawk Power Co oration Nine Mile Point Unit 1 Nine Mile Point Unit 2 Consolidated Edison Com an Indian Point Station Unit 2 Rochester Gas and E1ectric Com an R. E. Ginna Nuclear Power Station Operations Support Services, Inc.

233 Water Street 2nd Floor Plymouth, MA 02360

OSSI 92-402A-3-PWR PWR EAL BInntng Document, Rev. 0 1.0 CSFST Status Subcriticality CSFST Status SA2.1 SS2.1 Core Cooling CSFST Status FC1.1 (General)

FC1.2 (SAE)

PC6. 1(General)

PC6.2(General)

SG2.1 (Core Cooling) 1.3 Heat Sink CSFST Status FC1.3/RCS1.2 (SAE)

SS4.1 SG2.1 (Heat Sink) 1.4 Integrity CSFST Status RCS1.1 (Alert) 1.5 Containment CSFST Status PC1.1 (General) 2.0 Reactor Fuel 2.1 Coolant Activity SU4.2 FC2.1 (Alert) 2.2 Failed Fuel Detectors (Ginna only)

SU4.1 FC6.1 (Alert)

FC6.1 + RCS1.1 (SAE)

+ RCS2.2 (SAE)

+ RCS2.1(SAE) 2.3 Containment Radiation RCS4. 1 (Alert)

FC5.1 (SAE)

PC5.1 (General) 2.4 Refueling Accidents or Other Radiation Monitors AU2.1 AA2.1 AA2.2

OSSI 92-402A-3-PWR PWR EAL Bfnning Document, Rev. 0 3.0 Reactor Coolant System RCS Leakage SU5.1 RCS2.2 (Alert)

SS5.1 3.2 Primary to Secondary Leakage PC4.1 (NUE)

PC4.1 + RCS2.2 (SAE) 3.3 RCS Subcooling RCS2.1 (Alert) 4.0 Containment 4.1 Contai nment Integrity Status PC7.1 (NUE)

PC2.1 (S AE)

PC2.2 (S AE)

PC3.1 (S AE)

PC2.5 + FC2.1 (General)

+ FC5.1

+ FC6.1(Ginna only)

PC2.1 + FC1.2(General)

+ FC1.3

+ FC2.1

+ FC3.2

+ FC4.1

+ FC5.1

+ FC6.1(Ginna only)

PC2.2 + FC1.2(General)

+ FC1.3

+ FC2.1

+ FC3.2

+ FC4.1

+ FC5.1

+ FC6.1(Ginna only)

PC3.1 + FC1.2(General)

+ FC1.3

+ FC2.1

+ FC3.2

+ FC4.1

+ FC5.1

+ FC6.1(Ginna only)

OSSI 92-402A-3-PWR PWR EAL Btnrdng Document, Rev. 0 4.2 . SG Tube Rupture with Secondary Release RCS3.1(SAE)

~

RCS3.1 + FC1.2(General)

+'FC1.3

+ FC2.1

+ FC3.2

+ FC4.1

+ FC5.1

+ FC6.1(Ginna only)

PC4.1 + FC1.2(General)

+ FC1.3

+ FC2.1

+ FC3.2

+ FC4.1

+ FC5.1

+ FC6.1(Ginna only) 4.3 Combusible Gas Concentrations PC2.4(General) 5.0 Radioactivity Release / Area Radiation 5.1 EQluent Monitors AU1.1 AA1.1 AS1.1 AG1.1 5.2 Dose Projections/ Environmental Measurements AU1.2 AA1.2 AS>.3 AS1.4 AG1.3 AG1.4

, 5.3 Area Radiation Levels AU2.4 AA3.1 AA3.2

OSSI 92-402A-3-PWR PWR EAL Blnning Document, Rev. 0 6.0 Electrical Failures 6.1 Loss of AC Power Sources SU1.1 SA1.1 SA5.1 SS1.1 SG1.1 Loss of DC Power Sources SU7.1 SS3.1 7.0 Equipment Failures 7.1 Technical SpeciQcation Requirements SU2.1 7.2 System Failures or Control Room Evacuation HU1.6 HA1.6 HA5.1 HS2.1 SA3.1 7.3 Loss of Indications/Alarm/Communication Capability SU3.1 SU6.1 SA4.1 SS6.1

OSSI 92-402A-3-PWR PWR EAL Binning.Document, Rev. 0 8.0 Hazards 8.1 Security Threats HU4.1 HU4.2 HA4.1 HA4.2 HS1.1 HS1.2 HG1.1 HG1.2 8.2 Fire or Explosion HU2.1 HA2.1 8.8 Man-Made Events HU1.4 HU1.5 HU3.1 HU3.2 HA1.5 HA3.1 HA3.2 8.4 Natural Events HU1.1 HU1.2 HU1.3 HU1.7 HAl.l HA1.2 HA1.3 HA1.7 9.0 Other FC7.1 RCS6.1 PC8.1 HU5.1 HA6.1 HS3.1 HG2.1

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 i

New York EAL Upgrade Project R.E. Ginna Emergency Action Levels Technical Bases Revision 0 3/15/94 Operations Support Services, Inc.

233 Water Street 2nd Floor Plymouth, MA 02360

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 PURPOSE The purpose of this document is to provide an explanation and rationale for each of the emergency action levels (EALs) included in the EAL Upgrade Program for R.E. Ginna Nuclear Power Station (REGNPS). It is also intended to facilitate the review process of the REGNPS EALs and provide historical documentation for future reference. This document is also intended to be utilized by those individuals responsible for implementation of EPIP-1-0 "Ginna Station Event Evaluation and Classification" as a technical reference and aid in EAL interpretation.

DISCUSSION EALs are the plant-specific indications, conditions or instrument readings which are utilized to classify emergency conditions defined in the REGNPS Emergency Plan.

Subsequent to the acceptance by the NRC of MB~C/NESP-007 "Methodology for Development of Emergency Action Levels" as an acceptable alternative to the NI.tREG 0654 EAL guidance, the four nuclear utilities in the State of New York decided to perform a joint implementation of the new methodology. This upgrade project involved the following plants:

~ Nine Mile Point Unit 1 (NMPC)

~ Nine Mile Point Unit 2 (NMPC)

~ James A. FitzPatrick Nuclear Power Plant (NYPA)

~ Indian Point Station 2 (ConEd)

~ Indian Point 3 Nuclear Power Station (NYPA)

~ R.E. Ginna Nuclear Power Station (RG&E)

While the upgraded EALs are site specific, an objective of the upgrade project was to ensure conformity and consistency between the sites to the extent possible.

The revised EALs were derived from the Initiating Conditions and example EALs given in the REGNPS Plant-Specific EAL Guideline (PEG). The PEG is the REGNPS interpretation of the NUNC methodology for developing EALs. The PEG identifies deletions from the NUMARC methodology by striking out words and phrases that are not applicable to REGNPS; additions are identified by underlining new words and phrases. The source of documents for PEG changes from MB~C methodology are listed in the references section of the PEG.

Many of the EALs derived from the NUMARC methodology are fission product barrier based. That is, the conditions which define the EALs are

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 based upon loss or potential loss of one or more of the three fission product

.barriers.

E The primary fission product barriers are:

A. l i The fuel cladding is comprised of the zirconium tubes which house the ceramic uranium oxide pellets along with the end plugs which are welded into each end of the fuel rods.

B.

C. ~ TE m

t

'he RCS is comprised of the reactor vessel shell, vessel head, vessel nozzles and penetrations and all primary systems directly connected to the reactor vessel up to the first containment isolation valve.

I E I tt containment structure and all isolation valves required to maintain containment integrity under accident conditions.

I The following criteria serves as the bases for event classification related to fission product barrier loss:

IE Any loss or potential loss of containment

~Al ~

Any loss or any potential loss of either fuel clad or RCS i Ar E r n Any loss of both fuel clad and RCS or Any potential loss of both fuel clad and RCS or Any potential loss of either fuel clad or RCS with a loss of any additional barrier Loss of any two barriers with loss or potential loss of a third Those EALs which reference one or more of the fission product barrier IC designators (FC, RCS and PC) in the PEG Reference section of the technical bases are derived from the Fission Product Barrier Analysis. The analysis entailed an evaluation of every combination of the plant specific barrier loss/potential loss indicators applied to the above criteria.

OSSI-92-402A-4-REG Ginna EAI Technical Bases Document, Rev 0 Where possible, the EALs have been made consistent with and utilize the conditions defined in the REGNPS Critical Safety Function Status Trees (CSFSTs). While the symptoms that drive operator actions specified in the CSFSTs are not indicative of all possible conditions which warrant emergency classification, they do define the symptoms, independent of initiating events, for which reactor plant safety and/or fission product barrier integrity are threatened. Where these symptoms are clearly representative of one of the PEG Initiating Conditions, they have been utilized as an EAL. This allows for rapid classification of emergency situations based on plant conditions without the need for additional evaluation or event diagnosis. Although some of the EALs presented here are based on conditions defined in the CSFSTs, classification of emerge'ncies using these EALs is not dependent upon Emergency Operating Procedures (EOPs) entry or execution. The EALs can be utilized independently or in conjunction with the EOPs.

To the extent possible, the EALs are symptom based. That is, the action level is defined by values of key plant operating parameters which identify emergency or potential emergency conditions. This approach is appropriate because it allows the full scope of variations in the types of events to be classified as emergencies. But, a purely symptom based approach is not sufiicient to address all events for which emergency classification is appropriate. Particular events to which no predetermined symptoms can be ascribed have also been utilized as EALs since they may be indicative of potentially more serious conditions not yet fully realized.

The EALs are grouped into nine categories to simplify their presentation and to promote a rapid understanding by their users. These categories are:

1. CSFST Status

2. Reactor Fuel

3. Reactor Coolant System 4 Containment

5. Radioactivity Release / Area Radiation

6. Electrical Failures

7. Equipment Failures

8. Hazards

9. Other Catego'ries 1 through 5 are primarily symptom based. The symptoms are indicative of actual or potential degradation of either fission product barriers or personnel safety.

Categories 6, 7 and 8 are event based. Electrical Failures are those events associated with losses of either AC or vital DC electrical power. Equipment Failures are abnormal and emergency events associated with vital plant system failures, while Hazards are those non-plant system related events which have affected or may affect plant safety.

OSSI-92-402A-4-REG Ginna EALTechrdcal Bases Document, Rev 0 Category 9 provides the Emergency Coordinator (Shift Supervisor) the latitude to classify and declare emergencies based on plant symptoms o' events which in his judgment warrant classification. This judgment includes evaluation of loss or potential loss of one or more fission product barriers warranting emergency classification consistent with the NUldARC barrier loss criteria.

Categories are further divided into one or more subcategories depending on the types and number of plant conditions that dictate emergency classifications. For example, the Electrical Failures category has two subcategories whose values can be indicative of losses of electrical power sources: loss of AC power sources and loss of DC power sources. An EAL may or may not exist for each sub category at all four classification levels.

Similarly, more than one EAL may exist for a sub category in a given emergency classification when appropriate (i.e. no EAL at the General Emergency level but three EALs at the Unusual Event level).

For each EAL, the following information is provided:

~ Classification: Unusual Event, Alert, Site Area Emergency, or General Emergency

~ Operating Mode Applicability: One or more of the following plant operating conditions are listed: Power Operation, Hot Shutdown, Cold Shutdown, Refuel and Defueled

~ EAL: Description of the condition or set of conditions which comprise the EAL

~ Basis: Description of the rationale for the EAL

~ PEG

Reference:

PEG IC(s) and example EAL(s) from which the EAL is derived

~ Basis Reference(s): Source documentation from which the EAL is derived

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 The identified ope'rating modes are defined as follows Reactor shutdown margin is less than Technical Specification minimum required with coolant temperature (Tavg) at or above normal operating temperature.

HatShhm Reactor shutdown margin greater than or equal to Technical Specification minimum required with coolant temperature (Tavg) less than normal operating temperature.

~l Reactor shutdown margin greater than or equal to Technical Specification minimum required with coolant temperature (Tavg) less than or equal to 200 'F.

~f~l Reactor shutdown margin greater than or equal to Technical Specification minimum required for refueling operations and coolant temperature (Tavg) less than or equal to 140 'F.

X>~ehd Reactor vessel contains no irradiated fuel.

These operating modes correlate to the NUMARC-007 and PEG identified operating modes as follows:

Power Operations Power Operations Startup/Hot standby Power Operation Hot Shutdown Hot Shutdown Cold Shutdown Cold Shutdown Refuel Refuel Defueled Defueled All All

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Plant Emergency Operating Procedures (EOPs) are designed to maintain and/or restore a set of critical safety functions which are prioritized for restoration efforts during accident conditions. By monitoring the critical safety functions status, the impact of multiple events can be inherently addressed.

The critical safety functions are monitored through the use of Critical Safety Function Status Trees (CSFSTs). When certain plant parameters exceed threshold values specified by the CSFST, the plant operator is directed to one or more functional restoration and/or EOPs in an attempt to restore those parameters to within acceptable limits. The following CSFSTs are utilized to be indicative of failures or potential failures of one or more fission product barriers:

C g Rdpthl I'IIFST'dl t I f reactivity control which may pose a threat to fuel clad and RCS integrity.

C g Rdpth I tl'SFSTI dl t I f core subcooling and thus pose a direct threat to the integrity of the reactor fuel clad.

~ Qgg~ink The Red path of this CSFST is indicative of a loss of ability to remove decay heat from the core and thus poses a direct threat to fuel clad integrity.

~ Lnnzgzi~ The Red path of this CSFST is indicative of a direct threat to RCS barrier integrity.

R dp h f hl CSFSTI I d' fRCS barrier and direct threat to the containment barrier integrity.

1-1

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 1.0 CSFST Status 1.1 Subcriticality, 1.1.1 Alert ORANGE or RED path F-0.1 SUBCRITICALITY AND Emergency boration is required Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Subcriticality - ORANGE path is entered based on failure of the intermediate range startup rate monitors to indicate negative or zero following reactor trip. This EAL addresses any manual trip or automatic trip signal followed by a manual trip which fails to shut down the reactor to an extent requiring emergency boration. A manual trip is any set of actions by the reactor operator(s) at the reactor control console which causes control rods to be rapidly inserted into the core and brings the reactor subcritical (e.

g., reactor trip button).

This condition indicates failure of the automatic and manual protection systems to trip the reactor to the extent which precludes the reactor being made sub-critical. Although a front line automatic protection system did not function in response to a plant transient, it is the continued criticality under conditions requiring a reactor trip which poses the potential threat to fuel clad integrity and thus warranting declaration of an Alert.

PEG

Reference:

SA2.1 Basis Reference(s):

1. CSFST F-0.1, Subcriticality

2. FR-S,1, Response to Reactor Restart/ATWS

3. FR-S.2, Response to Loss of Core Shutdown 1-2

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 1.0 CSFST Status 1.1 Subcriticality 1.1.2 Site Area Emergency RED path in F-0.1 SUBCRITICALITY AND either:

Emergency boration is inoperable OR Power range not ( 6% within 15 min. of initiation of emergency boration Mode Applicability:..

Power Operations, Hot Shutdown Basis:

CSFST Subcriticality - RED path is entered based on failure of power range indication to decrease below 5% following a reactor trip. This portion of the EAL addresses any manual trip or automatic trip signal followed by a manual trip which fails to shut down the reactor to an extent that the reactor is producing more heat load for which the safety systems were designed. A manual trip is any set of actions by the reactor operator(s) at the reactor control console which causes control rods to be rapidly inserted into the core and brings, the reactor subcritical (e. g., reactor trip button).

This condition indicates failure of both the automatic and manual protection systems to trip the reactor in conjunction with a failure of alternate boration systems to reduce reactor power below decay heat levels. The combination of failure of both front line and backup protection systems to function in response to a plant transient, along with the continued production of heat poses a direct threat to fuel clad and RCS integrity and thus warrants declaration of a Site Area Emergency.

15 minutes is specified to allow time for emergency boration to be effective and provides a discriminator between SA2.1 and SS2.1. The classification should be made as soon as it is apparent that emergency boration is not or will not be effective in reducing reactor power below 5%.

PEG

Reference:

SS2.1 1-3

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Basis Reference(s):

1. CSFST F-0.1, Subcriticality

2. FR-S.1, Response to Reactor RestartJATWS

3. FR-S.2, Response to Loss of Core Shutdown 1-4

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 1.0 CSFST Status 12 Co're Cooling 1.2.1 Site Area Emergency ORANGE or RED path in F-0.2, CORE. COOLING Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Core Cooling - ORANGE path is entered based on either:

~ Core exit thermocouples > 700 'F OR

~ RVLIS level < 43% w/ no RCPs (TAF)

Either condition indicates subcooling has been lost and that some clad damage may occur. It must also be assumed that the loss of RCS inventory is a result of a loss of RCS barrier. Therefore a Site Area Emergency is warranted based upon the potential loss of fuel clad with loss of RCS barriers.

PEG

Reference:

FC1.2 FC3.2 FC4.1 Basis Reference(s):

1. CSFST F-0.2, Core Cooling 1-5

OSSI-92<02AM-REG Ginna EAL Technical Bases Document, Rev 0 1.0 CSFST Status 12 Core Cooling 12.2 General Emergency RED path in F-0.2, CORE COOLING AND Functional restoration procedures not effective within 15 min.

Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Core Cooling - RED path is entered based on either:

~ Core exit thermocouples ) 1200 'F OR

~ Core exit thermocouples ) 700 'F AND

~ RVLIS level ( 43% (TAF)

Either condition indicates significant core exit superheating and core uncovery and is considered a loss of the Fuel Clad Barrier. It must also be assumed that the loss of RCS inventory is a result of a loss of RCS barrier.

These conditions, ifnot mitigated, will likely lead to core melt which will in turn result in a potential loss of containment. Therefore, declaration of a General Emergency is warranted.

Severe accident analyses (e. g., NUREG-1150) have concluded that function restoration procedures can arrest core degradation within the reactor vessel in a significant fraction of the core damage scenarios, and that the likelihood of containment failure is very small in these events. Given this, it is appropriate to provide a reasonable period to allow function restoration procedures to arrest the core melt sequence. Whether or not procedures will be effective should be apparent within 15 minutes. The Emergency Coordinator should make the declaration as soon as it is determined that the procedures have not been, or will not be effective.

For the purpose of this EAL the term 'effective'ith regards to functional restoration procedures means that the CSFST Core Cooling - RED'path entry criterion no longer exists.

1-6

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 PEG

Reference:

FC1.1 SG2.1 (Core Cooling)

PC6.1 PC6.2 Basis Reference(s):

1. CSFST F-0.2, Core Cooling 1-7

Ossr-92-402'-4-REG Ginna EAL Technical Bases Document, Rev 0 1.0 CSFST Status '8 1 Heat Sink 1.3.1 Site Area Emergency RED path in F-0.3, HEAT SINK Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Heat Sink - RED path is entered based on both:

~ both SIG's narrow range level 5%(

AND

~ Total feedwater flow to S/Gs < 200 gpm The combination of these two conditions indicates the ultimate heat sink function is under extreme challenge. This EAL addresses loss of functions required for hot shutdown with the reactor at pressure and temperature.

Under these conditions, there is an actual major failure of a system intended for protection of the public with potential for multiple fission product barrier loss. Therefore, declaration of a Site Area Emergency is warranted.

PEG

Reference:

FC1.3 RCS1.2 SS4.1 Basis Reference(s):

1. CSFST F-0.3, Heat Sink 1-8

i OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 1.0 CSFST Status 18 Heat Sink 1.3.2 General Emergency RED path in F-0.3, HEAT SINK AND RED path in F-0.1, SUBCRITICALITY Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Heat Sink - RED path is entered based on both:

~ both S/G's narrow range level < 5%

AND

~ Total feedwater flow to S/Gs < 200 gpm CSFST Subcriticality - RED path is entered based on 2 5% reactor power following a reactor trip.

The combination of these two conditions (Heat Sink-RED and reactor power >

5%) indicates the ultimate heat sink function is under extreme challenge.

Additionally, the efforts to bring the reactor subcritical have been unsuccessful and, as a result, the reactor is producing more heat load for which the safety systems were designed. This situation could be the precursor for a core melt sequence.

A major consideration is the inability to initiallyremove heat during the early stages of this sequence. Ifemergency feedwater flow is insufficient to remove the amount of heat required by design from at least one steam generator, an extreme challenge should be considered to exist. This equates to a HEAT Sink RED condition.

In the event this challenge exists at a time when the reactor has not been brought below the power associated with safety system design power (5%) a core melt sequence is considered to exist. In this situation, core degradation can occur rapidly. For this reason, the General Emergency declaration is intended to be anticipatory of the fission product barrier matrix declaration to permit maximum offsite intervention time.

PEG

Reference:

SG2.1(Heat Sink) 1-9

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Basis Reference(s):

1. CSFST F-0.3, Heat Sink

2. 'SFST F-0.1, Subcriticality

3. FR-S.1, Response to Reactor Restart/ATWS

4. FR-S.2, Response to Loss of Core Shutdown 1-10

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 1.0 CSFST Status 1.4 Integrity 0

1.4.1 Alert RED path on F-0.4, INTEGRITY Mode Applicability:

Power Operhtions, Hot Shutdown Basis:

CSFST Integrity - RED path is entered based on both:

~ exceeding RCS cooldown rate of 100 'F/hr AND

~ all RCS cold leg temperatures to the leR of the RCS Pressure/RCS Cold Leg Temperature Curve The combination of these two conditions indicates the RCS barrier is under significant challenge and should be considered a potential loss of RCS barrier.

Any loss or potential loss of RCS barrier warrants declaration of an Alert.

PEG

Reference:

RCS1.1 Basis Reference(s):

1. CSFST F-0.4, Integrity 1-11

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 1.0 CSFST Status 1.4 Integrity 1.4.2 Site Area Emergency RED path on F-0.4, INTEGRITY AND Release of secondary side to atmosphere with primary to secondary leakage >

0.1 gpm per steam generator Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Integrity - RED path is entered based on both:

~ exceeding RCS cooldown rate of 100 'F/hr AND

~ all RCS cold leg temperatures to the left of the RCS Pressure/RCS Cold Leg Temperature Curve The combination of these two conditions indicates the RCS barrier is under significant challenge and should be considered a potential loss of RCS barrier.

The release of secondary side to atmosphere with primary to secondary leakage greater than O.l GPM per steam generator is considered a loss of containment integrity.

The combination of excessive RCS cooldown in conjunction with SG tube leakage with release to the environment represents a potential loss of RCS barrier with loss of containment and therefore warrants declaration of a Site Area Emergency.

PEG

Reference:

RCS1.1+ PC4.1 Basis Reference(s):

1. CSFST F-0.4, Integrity

2. Technical Specifications Section 3.1.5.2 1-12

OSSI-92-402A-4-REG " ~

Ginna EAL Technical Bases Document, Rev 0 1.0 CSFST Status 1.5 Containment 1.5.1 General Emergency RED path F-0.5, CONTAINIKENT Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Containment - RED path is entered based on exceeding containment design pressure of 60 psig. This pressure is well in excess of that expected from the design basis loss of coolant accident. This is indicative of a loss of both RCS and fuel clad boundaries in that it is not possible to reach this condition without also being in a Heat Sink-RED or Core Cooling-RED CSFST. The source of energy must be the result of severe degradation of core cooling or loss of heat sink. Since containment pressures at or approaching design levels is also a potential loss of containment, this combination of conditions requires the declaration of a General Emergency.

PEG

Reference:

PC1.1 Basis Reference(s):

1. CSFST F-0.5, Containment 1-12

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 The reactor fuel cladding serves as the primary fission product barrier. Over the useful life of a fuel bundle, the integrity of this barrier should remain intact as long as fuel cladding integrity limits are not exceeded.

Should fuel damage occur (breach of the fuel cladding integrity) radioactive fission products are released to the reactor coolant. The magnitude of such a release is dependent upon the extent of the damage as well as the mechanism by which the damage occurred. Once released into the reactor coolant, the highly radioactive fission products can pose significant radiological hazards inplant from reactor coolant process streams. Ifother fission product barriers were to fail, these radioactive fission products can pose significant offsite radiological consequences.

The following parameters/indicators are indicative of possible fuel failures:

~IAi'D'gdp ti, t i tfi product activity is very low. Small concentrations of fission products in the coolant are primarily from the fission of tramp uranium in the fuel cladding or minor perforations in the cladding itself. Any significant increase from these base-line levels is indicative of fuel failures.

~ il As with coolant activity, any fuel failures will release fission products to the reactor coolant. These fission products will be circulated with the reactor coolant and be detected by the failed fuel radiation detector in the RCS letdown line.

~ n in i Although not a direct indication or measurement of fuel damage, exceeding predetermined limits on containment high range radiation monitors under LOCA conditions is indicative possible fuel failures.

~ f lin A '

h r i 'M ni r Bothareaand process radiation monitoring systems designed to detect fission products during refueling conditions as well as visual observation can be utilized to indicate loss or potential loss of spent fuel cladding integrity.

2-1

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 2.0 Reactor Fuel 2.1 Coolant Activity 2.1.1 Unusual Event Coolant sample activity:

>100%%uo of 84/E bar'p,Ci/cc total specific activity OR

> 0.2 p.Ci/gm I-131 equivalent and the conditions of Technical Specifications 3.1.4.3.b are exceeded Mode Applicability:

Basis:

Elevated reactor coolant activity represents a potential degradation in the level of safety of the plant and a potential precursor of more serious problems.

This EAL addresses reactor coolant samples exceeding coolant technical specifications.

PEG

Reference:

SU4.2 Basis Reference(s):

1. Technical Specifications section 3.1.4 2-2

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 2.0 Reactor Fuel 2.1 Coolant Activity 2.1.2 Alert Coolant activity > 800 pCi/cc I-131 equivalent Mode Applicability:

Power operation, hot shutdown Basis:

Elevated reactor coolant activity represents a potential degradation in the level of safety of the plant and a potential precursor of more serious problems.

This amount of coolant activity corresponds to about 2% t'o 5% fuel clad damage. When reactor coolant activity reaches this level, signi6cant clad heating has occurred and thus the fuel clad barrier is considered lost.

Therefore, declaration of an Alert is warranted.

PEG

Reference:

FC2.1 Basis Reference(s):

None

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 2.0 Reactor Fuel 2.2 Failed Fuel Detectors 2.2.1 Unusual Event Letdown Line Monitor R-9 > 2 R/hr Mode Applicability:

Basis:

Elevated letdown line activity represents a potential degradation in the level of safety of the plant and a potential precursor of more serious problems.

This radiation level (2 R/hr) corresponds to 1% fuel failure (bases for the Technical Specifications coolant activity limits). Therefore, declaration of an Unusual Event is warranted.

PEG

Reference:

SU4.1 Basis Reference(s):

1. Technical Specifications section 3.1.4

2. P-9 "Radiation Monitoring System"

3. EPIP 2-16 section 6.2.l.b

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 2.0 Reactor Fuel '.2 Failed Fuel Detectors 2.2.2 Alert Letdown Line Monitor R-9 > 10 R/hr Mode Applicability:

Power operation, hot shutdown Basis:

This condition indicates the loss of the fuel clad barrier. Failed Fuel Monitor readings of 2 R/hr corresponds to 1% fuel failures. Failed Fuel Monitor readings of 10 R/hr corresponds to 5% fuel failures and is considered an actual loss of fuel clad.

Note: Monitor R-9 automatically shifts scale from mR/hr to R/hr when indicated values exceed 1000 mR/hr.

PEG

Reference:

FC6.1 FC6.2 Basis Reference(s):

1. EPIP 16 "Core Damage Estimation"

2. P-9 "Radiation Monitoring System"

3. EPIP 2-16 section 6.2.l.b 2-5

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 2.0 Reactor Wel 2.2 Failed Fuel Detectors 2.2.3 Site Area Emergency Letdown Line Monitor R-9 > 10 R/hr and any of the following:

~ RED path on F-0.4, INTEGRITY

~ Primary system leakage > 46 gpm

~ RCS subcooling < EOP Fig. MIN SUBCOOLING Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses combinations of fuel clad potential loss with RCS loss and potential loss indicators.

Failed Fuel Monitor readings of 10 R/hr corresponds to 5% fuel failures. This condition indicates the loss of the fuel clad barrier. Note: Monitor R-9 automatically shifts scale from mR/hr to R/hr when indicated values exceed 1000 mR/hr. This condition in combination with any of the following RCS loss/potential loss indicators warrants declaration of a Site Area Emergency:

RED path on F-0.4, INTEGRITY: RED path indicates an extreme challenge to the safety function derived from appropriate instrument readings, and indicates a potential loss of RCS barrier.

RCS subcooling < EOP Fig. MIN SUBCOOLING: This indicator addresses conditions where leakage from the RCS is greater than available inventory control capacity such that a loss of subcooling has occurred. The loss of subcooling as determined from E-O, Reactor Trip or Safety Injection is the fundamental indication that the inventory control systems are inadequate in maintaining RCS pressure and inventory against the mass loss through a leak.

Primary system leakage > 46 gpm: This potential loss of RCS is based on the inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) by normal operation of the Chemical and Volume Control System which is considered as two positive displacement charging pumps discharging to the charging header.

PEG

Reference:

2-6

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 PEG

Reference:

FC6.2+ RCS1.1, RCS2.1, RCS2.2, RCS4:1 and PC4,1 Basis Reference(s):

1. EPIP 16 "Core Damage Estimation"

2. CSFST F-0.4 Integrity

3. Reactor Trip or Safety Injection

'-O, 4 F-0.5, Containment

5. FR-Z.1, Response to High Containment Radiation Level

6. Technical Specifications Section 3.1.5.2

7. FSAR Table 9.3.6 2-7

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 2.0 Reactor Fuel 2.3 Containment Radiation 2.3.1 Alert Containment radiation monitor R-29/R-30 reading > 10 R/hr Mode Applicability:

Power operation, hot shutdown Basis:

The10 H/hr reading is a value which indicates the release of reactor coolant to the containment. The reading was derived assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with normal operating concentrations (i. e., within T/S) into the containment atmosphere. This EAL is indicative of a RCS leak only. Ifthe radiation monitor reading increased to that specified by Reactor Fuel EAL 2.3.2, significant fuel damage would also be indicated.

PEG

Reference:

RCS4.1 Basis Reference(s):

1. F-0.5, Containment

2. FR-Z.1, Response to High Containment Radiation Level

3. EPIP 2-16, Core Damage Estimation

OSSI-92-402A-4-RE 6 Ginna EAL Technical Bases Document, Rev 0 2.0 Reactor Fuel 2.3 Containment Radiation 2.3.2 Site Area Emergency Containment radiation monitor R-29/R-30 reading > 100 R/hr Mode Applicability:

Power operation, hot shutdown Basis:

The 100 R/hr reading is a value which indicates the release of reactor coolant, with elevated activity indicative of fuel damage, into the containment. The reading is calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with a concentration of 300 p,Ci/gm dose equivalent I-131 into the containment atmosphere. Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations (including iodine spiking) allowed within technical specifications and are therefore indicative of fuel damage (approximately 2-5 % clad failure depending on core inventory and RCS volume). This value is higher than that specified in EAL 2.3.1 which would be indicative of only the RCS barrier. Thus, this EAL indicates a loss of both the fuel clad barrier and a loss of RCS barrier warranting declaration of a Site Area Emergency.

PEG

Reference:

FC5.1 Basis Reference(s):

1. P-9, Radiation Monitoring System, Section 2.2.2.6, pg. P-9:2 2: EPIP 2-16, Core Damage Estimation 2-9

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 2.0 Reactor Fuel 2.8 Containment Radiation

'.8.8 General Emergency Containment radiation monitor R-29/R-30 reading ) 1000 R/hr Mode Applicability:

Power operation, hot shutdown Basis:

The 1000 R/hr reading is a value which indicates significant fuel damage

()20% clad failure) well in excess of the EALs associated with both loss of fuel clad and loss of RCS barriers. A major release of radioactivity requiring offsite protective actions from core damage is not possible unless a major failure of fuel cladding allows radioactive material to be released from the core into the reactor coolant. Regardless of whether containment is challenged, this amount of activity in containment, ifreleased, could have such severe consequences that it is prudent to treat this as a potential loss of containment, such that a General Emergency declaration is warranted.

NUREG-1228 "Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents," indicates that such conditions do not exist when the amount of clad damage is less than 20%.

PEG

Reference:

PC5.1 Basis Reference(s):

l. EPIP 1-0, Ginna Station Event Evaluation and Classification

2. EPIP 2-16, Core Damage Estimation

3. NUREG-1228 "Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents" Technology for Energy Report No. R-81-012 2-10

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 2.0 Reactor Fuel 2.3 Refueling Accidents or Other Radiation Monitors 2.4.1 Unusual Event Spent fuel pool (reactor cavity during refueling) water level cannot be restored and maintained above the spent fuel pool low water level alarm setpoint Mode Applicability:

Basis:

In light of Reactor Cavity Seal failure, incidents at two different PWRs and loss of water in the Spent Fuel Pit/Fuel Transfer Canal at a BWR all occurring since 1984, explicit coverage of these types of events via EALs ¹1 and ¹2 is appropriate given their potential for increased doses to plant staK Classification as an Unusual Event is warranted as a precursor to a more serious event.

The spent fuel pool low water level alarm setpoint of 20 in. below top of pool is actuated by LC-661. The definition of"... cannot be restored and maintained above ..." allows the operator to visually observe the low water level condition, ifpossible, and to attempt water level restoration instructions as long as water level remains above the top of irradiated fuel. Water level restoration instructions for loss of refueling cavity water level during refueling are performed in accordance with the RF-65 series of procedures.

When the fuel transfer canal is directly connected to the spent fuel pool and reactor cavity, there could exist the possibility of uncovering irradiated fuel in the fuel transfer canal. Therefore, this EAL is applicable for conditions in which irradiated fuel is being transferred to and from the RPV and spent fuel pool.

PEG

Reference:

AU2.1 Basis Reference(s):

l. ER-SFP.l "Loss of Spent Fuel Pit Cooling"

2. AR-K-29 3, RF-65 series 2-11

~ N C

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 2.0 Reactor Fuel 2.3 ReAxeling Accidents or Other Radiation Monitors 2.4.2 Alert Confirmed sustained alarm on any of the following radiation monitors resulting from an uncontrolled fuel handling process:

~ R-2 Containment Area Monitor

~ R-5 Spent Fuel Pit

~ R-12 Containment Noble Gas Mode Applicability:

Basis:

NUREG-0818, "Emergency Action Levels for Light Water Reactors," forms the basis for this EAL. This EAL is defined by the specific area where irradiated fuel is located such as reactor cavity, reactor vessel, or spent fuel pool.

NUREG/CR-4982, "Severe Accident in Spent Fuel Pools in Support of Generic Safety Issue 82,". July 1987, indicates that even ifcorrective actions are not taken, no prompt fatalities are predicted, and that risk of injury is low. In addition, NRC Information Notice No. 90-08, "KR-85 Hazards from Decayed Fuel" presents the following in its discussion:

"In the event of a serious accident involving decayed spent fuel, protective actions would be needed for personnel on site, while offsite doses (assuming an exclusion area radius of one mile from the plant site) would be well below the Environmental Protection Agency's Protective Action Guides. Accordingly, it is important to be able to properly survey and monitor for Kr-85 in the event of an accident with decayed spent fuel."

An "uncontrolled fuel handling process" is defined as any event or activity related to the movement of irradiated fuel which results in unexpected or uncontrolled conditions. This terminology has been specifically added to exclude anticipated increases in area radiation levels as a result of actions performed in accordance with approved procedures during refueling operations.

Thus, an Alert Classification for this event is appropriate. Escalation, if appropriate, would occur via Emergency Coordinator judgment in EAL Category 9.0.

2-12

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 The basis for the Containment Area Monitor setpoint (50 mH/hr) and Spent Fuel Pit monitor setpoint (25 mR/hr) are a spent fuel handling accident and is, therefore, appropriate for this EAL.

PEG

Reference:

AA2.1 Basis Reference(s):

1. P-9 Radiation Monitoring System

2. NUREG-0818, "Emergency Action Levels for Light Water Reactors,"

3. NUREG/CR-4982, "Severe Accident in Spent Fuel Pools in Support of Generic Safety Issue 82" 2-13

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 2.0 Reactor Fuel 2.3 RefuelingAccidentsorOtherRadiation Monitors 2.4.3 Alert Report of visual observation of irradiated fuel uncovered Mode Applicability:

Basis:

This EAL is defined by the specific areas where irradiated fuel is located such as reactor cavity, reactor vessel, or spent fuel pool.

There is no indication that water level in the spent fuel pool or refueling cavity has dropped to the level of the fuel other than by visual observation.

Since there is no level indicating system in the fuel transfer canal, visual observation of loss of water level would also be required.

Sufficient time exists to take corrective actions for these conditions and there is little potential for substantial fuel damage. NUREG/CR-4982 "Severe Accident in Spent Fuel Pools in Support of Generic Safety Issue 82" indicates that even ifcorrective actions are not taken, no prompt fatalities are predicted and the risk of injury is low. In addition, NRC Information Notice No. 90-08, "ER-85 Hazards from Decayed Fuel" presents the following it its discussion:

"In the event of a serious accident involving decayed spent fuel, protective actions would be needed for personnel on site, while offsite doses (assuming an exclusion area radius of one mile'rom the plant site) would be well below the Environmental Protection Agency's Protective Action Guides. Accordingly, it is important to be able to properly survey and monitor for Kr-85 in the event of an accident with decayed spent fuel.

Thus, an Alert Classification for this event is appropriate. Escalation, if appropriate, would occur via radioactivity release category 5.0 or Emergency Coordinator judgment in EAL Category 9.0.

This EAL applies to spent fuel requiring water coverage and is not intended to address spent fuel which is licensed for dry storage.

2-14

k OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 PEG

Reference:

AA2.2 Basis Reference(s):

1. P-9 Radiation Monitoring System

2. NUREG/CR-4982 "Severe Accident in Spent Fuel Pools in Support of Generic Safety Issue 82" NRC Information Notice No. 90-08, "KR-85 Hazards from Decayed Fuel" 2-15

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 The reactor vessel provides a volume for the coolant which covers the reactor core. The reactor vessel and associated pressure piping (reactor coolant system) together provide a barrier to limit the release of radioactive material should the reactor fuel cladding integrity fail.

There are three RCS parameters which are indicative of conditions which

~R*

may pose a threat to RCS or fuel cladding integrity:

I I>>T I 'SSRM tl )RCSIS indications are utilized to indicate potential pipe cracks which may propagate to an extent threatening f'uel clad, RCS and containment g

integrity. RCS leakage of a degree requiring ECCS to maintain RCS inventory poses a direct threat to fuel clad integrity. Reactor vessel water level is also directly related to the status of adequate core cooling, and therefore fuel cladding integrity.

~ rim n L k A subset of RCS leakage, excessive primary to secondary leakage in conjunction with unisolable secondary releases to environment may result in losses of containment integrity as well as threaten fuel clad integrity for more severe SG tube ruptures.

Al fRCS I llgl II d ttldl tl that the inventory control systems are inadequate in maintaining RCS pressure and inventory against mass loss through a leak.

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 3.0 Reactor Coolant System '.1 RCS Leakage 8.1.1 Unusual Event Unidentified or pressure boundary leakage o 10 gpm OR Identified leakage > 25 gpm Mode Applicability:

Power operation, hot shutdown Basis:

The conditions of this EAL may be a precursor of more serious conditions and, as a result, is considered to be a potential degradation of the level of safety of the plant. The 10 gpm value for the unidentified leakage and pressure boundary leakage was selected because it is observable with normal Control Room indications. Smaller values must be determined through time-consuming surveillance tests (e. g., mass balances). The 25 gpm value for identified leakage is set at a higher value because of the significance of identified leakage in comparison to unidentified or pressure boundary leakage.

Only operating modes in which there is fuel in the reactor coolant system and the system is pressurized are specified.

PEG

Reference:

SU5.1 Basis Reference(s):

None

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 3.0 Reactor Coolant System 3.1 RCS Leakage 3.1.2 Alert Primary system leakage ) 46 gpm I

Mode Applicability:

Power operation, hot shutdown Basis:

This EAL is based on the inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) by normal operation of the Chemical and Volume Control System which is considered as two positive displacement charging pumps discharging to the charging header.

PEG

Reference:

RCS2.2 Basis Reference(s):.

1. FSAR Table 9.3.6 3-3

cC' OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 3.0 Reactor Coolant System 3.1 RCS Leakage 3.1.3 Site Area Emergency RVLIS cannot be maintained > 43%%uo with no RCPs rurining OR With the reactor vessel head removed, it is reported that water level in the reactor vessel is dropping in an uncontrolled manner and core uncovery is likely Mode Applicability:

Basis:

The reactor vessel water level used in this EAL is the top of active fuel (TAF).

This value corresponds to the level which is used in CSFSTs to indicate challenge to core cooling and loss of the fuel clad barrier. This is the minimum water level to assure core cooling without further degradation of the clad. Severe core damage can occur and reactor coolant system pressure boundary integrity may not be assured ifreactor vessel water level is not maintained above that corresponding to RVLIS at 43%. RVLIS dynamic range indications are not utilized in this EAL since the RCPs would not be running under conditions where vessel level is approaching TAF.

Thus, declaration of a Site Area Emergency is warranted under the conditions specified by this EAL. Escalation to a General Emergency would be via radioactivity release category 5.0.

PEG

Reference:

SS5.1 FC4.1 Basis Reference(s):

1. FR-C.1 "Response to Inadequate Core Cooling"

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 3.0 Reactor Coolant System 3.2, Primary to Secondary Leakage 3.2.1 Unusual Event Release of secondary side to atmosphere with primary to secondary leakage )

0.1 gym per steam generator Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses SG tube leaks indicative of a loss of containment.

Secondary side releases to atmosphere include those from the condenser air eje'ctor, atmospheric dump valves, and mainsteam safety valves. For small leaks, not exceeding the normal charging capacity threshold in RCS leakage EAL 3.1.2, this EAL results in an Unusual Event. For larger leaks, RCS leakage EAL 3.2.2 would result in a Site Area Emergency. For SG tube ruptures which may involve multiple steam generators or unisolable secondary line breaks, SG tube rupture EAL 4.2.1 would also result in a Site Area Emergency.

PEG

Reference:

PC4.1 Basis Reference(s):

1. Technical Specifications Section 3.1.5.2

OSSI-92-402AM-REG Ginna EAL Technical Bases Document, Rev 0 3.0 Reactor Coolant System 3.2 Primary to Secondary Leakage.

8.2.2 Site Area Emergency Unisolable release of secondary side to atmosphere with primary to secondary leakage > 46 gpm

.Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses SG tube leaks indicative of a loss of both RCS and containment barriers. Secondary side releases to atmosphere include those from the condenser air ejector, atmospheric dump valves, and mainsteam safety valves. Primary to secondary leakage > 46 gpm is based on the inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) by normal operation of the Chemical and Volume Control System which is considered as two positive displacement charging pumps discharging to the charging header. For primary to secondary leakage > 46 gpm in the absence of any secondary to atmosphere release, an Alert would be declared based on EAL 3.1.2.

This EAL represents the loss of both RCS and containment barriers and therefore warrants declaration of a Site Area Emergency.

PEG

Reference:

PC4.1+ RCS2.2 Basis Reference(s):

1. Technical Specifications Section 3.1.5.2

2. E-3 "Steam Generator Tube Rupture"

3. FSAR Table 9.3.6

OSSI-92-402AMREG Ginna EAL Technical Bases Document, Rev 0 3.0 Reactor Coolant System '.3 RCS Subcooling 3.3.1 Alert RCS subcooling < EOP Fig. MIN SUBCOOLING Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses conditions where leakage from the RCS is greater than available inventory control capacity such that a loss of subcooling has occurred. The loss of subcooling is the fundamental indication that the inventory control systems are inadequate in maintaining RCS pressure and inventory against the mass loss through the leak.

Loss of the RCS barrier warrants declaration of an Alert.

PEG

Reference:

RCS2.1 Basis Reference(s):

1. E-O, Reactor Trip Or Safety Injection

OSSI-92<02A-4-REG Ginna EAL Technical Bases Document, Rev 0 The containment structure is an atmospheric vapor containment system. It forms a fission product barrier designed to contain the radioactive fission products generated from any postulated accident so as to preclude exceeding ofFsite exposure limits.

The containment structure is a low leakage system housing the reactor vessel, the reactor coolant piping, steam generators and other branch connections of the reactor primary system. The containment is equipped with isolation valves for systems which penetrate the containment boundary.

These valves automatically actuate to isolate systems under emergency conditions.

There are three containment parameters which are indicative of conditions which may pose a threat to containment integrity or indicate degradation of RCS or reactor fuel clad integrity.

~ n in Abnormally high containment pressure or failure of containment cooling systems following a LOCA are indicative of potential losses of the containment barrier integrity.

The existence of an unisolable CI or CVI line break outside containment constitutes a loss of containment integrity as well as a loss of RCS boundary. Inconsistent containment response to a known LOCA is also indicative of containment loss in conjunction with RCS barrier breach. Should a loss of fuel cladding integrity occur under either of these conditions, the potential for release of large amounts of radioactive materials to the environment exists.

~ m n r 1 'Gtube ruptures in conjunction with a secondary system line break resulting in release to the environment constitutes losses of both RCS and containment integrity.

Primary to secondary leakage in excess of Technical Specifications in conjunction with fuel clad damage and secondary system leakage to the environment constitutes losses of fuel clad, RCS and containment integrity. This condition provides the potential for release of large amounts of radioactive materials to the environment.

~ m n r 'he existence of combustible gas concentrations in containment pose a severe threat to containment integrity and are indicative of severely degraded reactor core and RCS conditions.

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 4.0 Contaixunent 4.1 Containment Integrity Status 4.1.1 Unusual Event Both doors open on containment airlock OR Inability to'close containment pressure relief or purge valves which results in a radiological release pathway to the environment Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses an indication that unambiguously indicates loss of the containment barrier under conditions when containment integrity is required.

It is important to note however, that loss of containment due to both airlock doors being open is event dependent. Upon recognition, shift personnel would rapidly respond in an attempt to reestablish containment integrity. Ifthe doors cannot be reclosed, any loss of the RCS barrier that occurs with the doors open would appear as an inconsistent LOCA response. Therefore, this event is not used as a definitive indicator of loss of the primary containment barrier for purposes of defining higher classification EALs. Rather it is left to the Emergency Coordinator's judgment whether such a loss has occurred.

PEG

Reference:

PC7.1 Basis Reference(s):

None

OSSI-92<02A-4-REG Ginna EAL Technical Bases Document, Rev 0 4.0 Contaixunent '.1 Containment Integrity Status'.1.2 Site Area Emergency Rapid uncontrolled decrease in containment pressure following initial increase OR Loss of primary coolant inside containment with containment pressure or sump level response not consistent with LOCA conditions Mode Applicability:

Power operation, hot shutdown Basis:

Rapid unexplained loss of pressure (i. e., not attributable to containment spray or Fan Cooling Units or condensation eFects) following an initial pressure increase indicates a loss of both RCS and containment integrity.

Containment pressure and sump levels should increase as a result of the mass and energy release into containment from a LOCA. Thus, sump level or pressure not increasing indicates containment bypass (V-sequence) and a loss of containment integrity.

This EAL indicates loss of both RCS and containment and therefore warrants declaration of a Site Area Emergency.

PEG

Reference:

PC2.1 PC2.2 Basis Reference(s):

1. Alarm response procedure, AR-C-18, Revision 6

2. Alarm response procedure, AR-C-19, Revision 4

3. R. E. Ginna Updated FSAR, Figure 6.2-3 through 6.2-5 4-3

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 4.0 Contahiment 4.1 Containment Integrity Status 4.1.3 Site Area Emergency Either:

CI or CVI valve(s) not closed when required following confirmed LOCA OR Inability to isolate any primary system discharging outside containment AND Radiological release pathway to the environment exists Mode Applicability:

Power operation, hot shutdown Basis:

This EAL is intended to address incomplete containment isolation that allows direct release to the environment. It represents a loss of both the RCS and containment barrier and therefore warrants declaration of a Site Area Emergency.

Failure of CI or'CVI valves to isolate is intended to address incomplete containment isolation that allows direct release to the environment, It represents a loss of both the RCS and containment barrier.

"Inabilityto isolate any primary system discharging outside containment" is intended to address other primary systems, either direct or indirect, which the inability to isolate indicate loss of both RCS and containment.

PEG

Reference:

PC3.1 Basis Reference(s):

1. FR-2.1 "Response to High Containment Pressure"

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 4.0 Contaixunent 4.1 Containment Integrity Status 4.1.4 General Emergency Safety injection signal due to LOCA with less than minimum operable containment heat removal equipment, Table 4.3 AND Any indicators of fuel clad loss, Table 4.1 Table4.3 MinimumO erable ContainmentHeatRemovalE ui ment CNMT Pressure Recirc Fans 0 erable S ra Pum sRe uired

<28 psig N/A

>28 psig Table 4.1 Fuel Clad Loss Indicators

1. Coolant activity > 300 pCi/cc of I-131

2. Containment rad monitor R-29/R-30 reading >100 R/hr"

3. Letdown Monitor R-9 reading > 10 R/hr Mode Applicability:

Power operation, hot shutdown Basis:

This EAL represents a potential loss of containment in conjunction with losses of both RCS and fuel clad.

A potential loss of containment is considered to exist in that the containment heat removaVdepressurization systems (e. g., containment sprays, Recirc.

Fans, but not including containment venting strategies) are either lost or performing in a degraded manner, as indicated by plant parameters such as containment pressure, pressurizer level and steam line pressure in excess of the setpoints at which the equipment was supposed to have actuated.

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 RCS is also assumed to be lost in this condition due to exceeding safety injection initiation setpoints: containment pressure (>4 psig) or low pressurizer (< 1723 psig).

Table 4.1 presents fuel clad loss indicators which represent 2 - 5% clad failures. Refer to EAL ¹'s 2.1.2, 2.2.2, and 2.3.2 for bases of these indicators.

PEG

Reference:

PC2.5+ FC2.1, FC5.1 and FC6.1 Basis Reference(s):

l. Technical Specifications, Table 3.5-4, pg. 3.5-17

2. R. E. Ginna UFSAR, Section 6.2.2.1.2.4, pg. 6.2-28

3. Technical Specifications, Article 5.2.1, pg. 5.2-1 4 FR-Z.1, Response to High Containment Pressure, Revision 3

5. R. E. Ginna UFSAR, Section 6.2.2.1, pg. 6.2-24b

6. R. E. Ginna UFSAR, Section 6.2.2.2, pg. 6.2-32 and Figure 6.2-11

7. EPIP 2-16, Core Damage Estimation

8. P-9, Radiation Monitoring System, Revision 67, Section 2.2.2.6, pg. P-9:2 4-6

OSSI-92<02A-4-REG Ginna EAL Technical Bases Document, Rev 0 4.0 Contauunent, 4.1 Containment Integrity Status 4.1.5 General Emergency Either:

Rapid uncontrolled decrease in containment pressure following initial increase OR Loss of primary coolant inside containment with containment pressure or sump level response not consistent with LOCA conditions AND Any indicators of fuel clad damage, Table 4,2 Table 4.2 Fuel Clad Dam e Indicators ORANGE or RED path in F-0.2, CORE COOLING RED path in F-0.3, HEAT SINK Coolant activity > 300 pCi/cc of I-131 Containment rad monitor R-29/R-30 reading >100 R/hr Letdown Monitor R-9 reading.> 10 R/hr Mode Applicability:

Power operation, hot shutdown Basis:

This EAL indicates loss of both RCS and containment with loss or potential loss of the fuel cladding and therefore warrants declaration of a General Emergency.

Rapid unexplained loss of pressure (i. e., not attributable to containment spray or Fan Cooling Units or condensation effects) following an initial pressure increase indicates a loss of both RCS and containment integrity.

Containment pressure and sump levels should increase as a result of the mass and energy release into containment from a LOCA. Thus, sump level or pressure not increasing indicates containment bypass (V-sequence) and a loss of containment integrity.

II@ 44 OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Table 4.2 presents fuel'clad loss and potential loss indicators:

~ ORANGE path in F-0.2, Core Cooling: Refer to EAL ¹1.1.1 basis

~ RED path in F-0.3, Heat Sink: Refer to EAL ¹1.2.1 basis

~ Coolant activity > 300 pCi/cc of I-131: Refer to EAL ¹2.1.2 basis

~ Containment rad monitor reading >100 R/hr: Refer to EAL ¹2.3.2 basis

~ Letdown Monitor R-9 reading > 10 R/hr: Refer to EAL ¹2.2.2 basis PEG

Reference:

PC2.1/PC2.2+ FC1.2, FC1.3, FC2,1, FC3.2, FC4.1, FC5.1 and FC6.1 Basis Reference(s):

l. Alarm response procedure, AR-C-18, Revision 6

2. Alarm response procedure, AR-C-19, Revision 4

3. R. E. Ginna Updated FSAR, Figure 6.2-3 through 6.2-5 4 EPIP 2-16, Core Damage Estimation

5. CSFST F-0.2, Core Cooling, Revision 3

6. CSFST F-0.3, Heat Sink, Revision 3

7. FR-C.l, Response to Inadequate Core Cooling, Revision 7

8. FR-C.2, Response to Degraded Core Cooling, Revision 6, step 9.a

9. FR-C.2, Response to Degraded Core Cooling, Revision 6, Note, pg. 3

10. P-9 "Radiation Monitoring System"

OSSI-92402A-4-REG Ginna EAL Technical Bases Document, Rev 0 4.0 Containment 4.1 Containment Integrity Status 4.1.6 General Emergency Either:

CI or CVI valve(s) not closed when required following confirmed LOCA OR Inability to isolate any primary system discharging outside containment AND Radiological release pathway to the environment exists AND Any indicators of fuel clad damage, Table 4.2 Table 4.2 Fuel Clad Dam e Indicators ORANGE or RED path in F-0.2, CORE COOLING RED path in F-0.3, HEAT SINK Coolant activity > 300 pCi/cc of I-131 Contaimnent rad monitor R-29/R-30 reading >100 R/hr Letdown Monitor R-9 reading > 10 R/hr Mode Applicability:

Power operation, hot shutdown Basis:

This EAL indicates loss of both RCS and containment with loss or potential loss of the fuel cladding and therefore warrants declaration of a General Emergency.

Failure of CI or CVI valves to isolate is intended to address incomplete containment isolation that allows direct release to the environment. It represents a loss of both the RCS and containment barrier.

"Inability to isolate any primary system discharging outside containment" is intended to address other primary systems, either direct or indirect, which the inability to isolate indicate loss of both RCS and containment.

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Table 4.2 presents fuel clad loss and potential loss indicators:

~ ORANGE path in F-0.2, Core Cooling: Refer to EAL ¹1.1.1 basis

~ RED path in F-0.3, Heat Sink: Refer to EAL ¹1.2.1 basis Coolant activity > 300 p,Ci/cc of I-131: Refer to EAL ¹2.1.2 basis

~ Containment rad monitor reading )100 Rlhr: Refer to EAL ¹2.3.2 basis

~ )

Letdovm Monitor R-9 reading 10 R/hr: Refer to EAL ¹2.2.2 basis PEG

Reference:

PC3.1+ FC1.2, FC1.3,'FC2.1, FC3.2, FC4.1, FC5.1 and FC6.1 Basis Reference(s):

1. FR-2.1 "Response to High Containment Pressure"

2. CSFST F-0.2, "Core Cooling"

3. FR-C.l, "Response to Inadequate Core Cooling" 4 EPIP 2-16, Core Damage Estimation

5. CSFST F-0.2, Core Cooling, Revision 3

6. CSFST F-0.3, Heat Sink, Revision 3

7. FR-C.l, Response to Inadequate Core Cooling, Revision 7

8. FR-C.2, Response to Degraded Core Cooling, Revision 6, step 9.a

9. FR-C.2, Response to Degraded Core Cooling, Revision 6, Note, pg. 3

10. P-9 "Radiation Monitoring System" 4-10

OSSI-92-402AM-REG Ginna EAL Technical Bases Document, Rev 0

'.0 Conhmuaent 4.2, SG Tube Rupture w/ Secondary Release 4.2.1 Site Area Emergency secondary side line break with SG tube rupture as identified in E-

'nisolable 3 "Steam Generator Tube Rupture" Mode Applicability:

Power operation, hot shutdown Basis:

This EAL is intended to address the full spectrum of Steam Generator (SG) tube rupture events in conjunction with a loss of containment due to a significant secondary line break. This EAL addresses ruptured SG(s) with an unisolable secondary line break corresponding to the loss of 2 of 3 fission product barriers (RCS barrier and containment barrier). This allows the direct release of radioactive fission and activation products to the environment. Resultant offsite dose rates are a function of many variables.

Examples include: coolant activity, actual leak rate, SG carry over, iodine partitioning, and meteorology.

The indications utilized should be consistent with the diagnostic activities of the emergency operating procedures (EOPs), ifavailable. This should include indication of reduction in primary coolant inventory, increased secondary radiation levels, and an uncontrolled or complete depressurization of the ruptured SG.. Secondary radiation increases should be observed via radiation monitoring of condenser air ejector discharge, SG blowdown, main steam, and/or SG sampling system. Determination of the "uncontrolled" depressurization of the ruptured SG should be based on indication that the pressure decrease in the ruptured steam generator is not a function of operator action. This should prevent declaration based on a depressurization that results from an EOP induced cooldown of the RCS that does not involve the prolonged release of contaminated secondary coolant from the aA'ected SG to the environment. This EAL encompasses steam breaks, feed breaks, and stuck open safety or relief valves.

PEG

Reference:

RCS3.1 4-11

0 1

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Basis Reference(s):

1. E-3 "Steam Generator Tube Rupture" 4-12

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 4.0 Contaixunent 4.2 SG Tube Rupture w/ Secondary Release

. 4.2.2 General Emergency Release of secondary side to atmosphere with primary to secondary leakage >

0.1 gpm per steam generator AND Any indicators of fuel clad damage, Table 4.2 Table 4.2 Fuel Clad Dama e Indicators ORANGE or RED path in F-0.2, CORE COOLING RED path in F-0.3, HEAT SINK Coolant activity > 300 pCi/cc of I-131 Containment rad monitor R-29/R-30 reading >100 R/hr Letdown Monitor R-9 reading > 10 R/hr Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses SG tube leaks indicative of a loss of containment in conjunction with a loss or potential loss of fuel cladding. Secondary side releases to atmosphere include those from the condenser air ejector, atmospheric dump valves, and mainsteam safety valves.

Table 4.2 presents fuel clad loss and potential loss indicators:

~ ORANGE path in F-0.2, Core Cooling: Refer to EAL ¹1.1.1 basis

~ RED path in F-0.3, Heat Sink: Refer to EAL ¹1.2.1 basis

~ Coolant activity > 300 pCi/cc of I-131: Refer to EAL ¹2.1.2 basis

~ Containment rad monitor reading >100 R/hr: Refer to EAL ¹2.3.2 basis

~ Letdown Monitor R-9 reading > 10 R/hr: Refer to EAL ¹2.2.2 basis This condition represents a loss of both RCS and primary containment with the loss or potential loss of fuel cladding and thus warrants declaration of a General Emergency.

4-13

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 PEG

Reference:

PC4.1/RCS 3.1+ FC1.2, FC1.3, FC2.1, FC3.2, FC4.1, FC5.1 and FC6.1 Basis Reference(s):

l. Technical Specifications Section 3.1.5.2

2. EPIP 2-16, Core Damage Estimation

3. CSFST F-0.2, Core Cooling, Revision 3 4 CSFST F-0.3, Heat Sink, Revision 3

5. FR-C.1, Response to Inadequate Core Cooling, Revision 7

6. FR-C.2, Response to Degraded Core Cooling, Revision 6, step 9.a

7. FR-C.2, Response to Degraded Core Cooling, Revision 6, Note, pg. 3

8. P-9 "Radiation Monitoring System" 4- 14

P OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 4.0 Containment 4.3 Combustible Gas Concentrations 4.3.1'eneral Emergency

> 4% hydrogen concentration in containment Mode Applicability:

Power operation, hot shutdown Basis:

Existence of an explosive mixture (4% hydrogen) means a hydrogen and oxygen concentration of at least the lower deflagration limit curve exists.

When hydrogen and oxygen concentrations reach or exceed the deflagration limits, imminent loss of the containment barrier exists. To generate such levels of combustible gas, loss of the fuel clad and RCS barriers must have occurred.

This EAL represents loss of both fuel clad and RCS with the potential loss of containment and therefore warrants declaration of a General Emergency.

PEG

Reference:

PC2.4 Basis Reference(s):

1. Dater]

4-15

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Many EALs are based on actual or potential degradation of fission product barriers because of the increased potential for offsite radioactivity release.

Degradation of fission product barriers though, is not always apparent via non-radiological symptoms. Therefore, direct indication of increased radiological effluents or area radiation levels are appropriate symptoms for emergency classification.

At lower levels, abnormal radioactivity releases may be indicative of a failure of containment systems or precursors to more significant releases. At higher release rates, offsite radiological conditions may result which require offsite protective actions. Increased area radiation levels in plant may also be indicative of the failure of containment systems or preclude access to plant vital equipment necessary to ensure plant safety.

There are two basic indications of radioactivity release rates and one for'rea radiation levels which warrant emergency classifications.

~fft Direct indication of e6luent radiation monitoring systems provides a rapid assessment mechanism to determine releases in excess of classifiable limits.

~ D r n n l Projected offsite doses (based on effluent monitor readings) or actual offsite field measurements indicating doses or dose rates above classifiable limits.

~ r Sustained general area radiation levels in excess of those indicating loss of control of radioactive materials or those'levels which may preclude access to vital plant areas also warrant emergency classification.

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Radioactivity Release / Area Radiation 6.1 EfGuent Monitors 6.1.1 Unusual Event A valid reading on any monitors Table 5.1 column "NUE" for > 60 min.

Table 5.1 Effluent Monitor Classification Thresholds Monitor R-11 1.62E6 cpm N/A N/A N/A R-12 7.80E6 cpm 1.07E7 cpm N/A N/A R-13 2.20E4 cpm N/A N/A N/A R-14 6.40E5 cpm 1.61E6 cpm N/A N/A R-15 4.00E5 cpm 2.31E7 cpm N/A N/A R-18 3.60E5 cpm offscale hi N/A N/A R-12A(7/9) N/A N/A 6.00 pCi/cc 60.00 pCi/cc R-14A(7/9) N/A N/A 5.33E-1 pCi/cc 5.33 pCi/cc R-15 A(7/9) N/A N/A 11.50 pCi/cc 115.00 pCi/cc Mode Applicability:

Basis:

The "value shown" for each monitor is two times the calculated Technical Specification release rates as specified in P-9 section 2.4.

Unplanned releases in excess of two times the site technical specifications that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very, low in the Unusual Event emergency class) is not the primary concern, here; it is the degradation in plant control implied by the fact that the release was not isolated within 60 minutes. Therefore, it is not intended that the release be averaged over 60 minutes. For example, a release of 4 times T/S for 30 minutes does not exceed this initiating condition.

Further, the Emergency Coordinator should not wait until 60 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has.or will likely exceed 60 minutes.

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Monitor indications are calculated on the basis of the methodology of the site 06'site Dose Calculation Manual (ODCM). Annual average meteorology is used.

Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

PEG

Reference:

AU1.1 Basis Reference(s):

1. EPIP 2-3 Emergency Release Rate Determination

2. P-9 Radiation Monitoring System

3. EPIP 2-18 Control Room Dose Assessment 4 Technical Specifications, Amendment No. 24, Articles 3.9.1.1 thru 3.9.2.3

5. "Calculations for NUNARC EALs" by P.S. Polfleit File EAL.XLS

6. RD-15.0 ODCM

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Radioactivity Release / Area Radiation 6.1 E61uent Monitors 6.1.2 Alert A valid reading on any monitors Table 5.1 column "Alert" for > 15 min.

Table 5.1 EfBuent Monitor Classification Thresholds Monitor R-11 1.62E6 cpm N/A N/A N/A R-12 7.80E6 cpm 1.07E7 cpm N/A N/A R-13 2.20E4 cpm N/A N/A N/A R-14 6.40E5 cpm 1.61E6 cpm N/A N/A R-15 4.00E5 cpm 2.31E7 cpm N/A N/A R-18 3.60E5 cpm offscale hi N/A N/A R-12A(7/9) N/A N/A 6.00 pCi/cc 60.00 p,Ci/cc R-14A(7/9) N/A N/A 5.33E-1 pCi/cc 5.33 pCi/cc R-15A(7/9) N/A N/A 11.50 pCi/cc 115.00 pCi/cc Mode Applicability:

Basis:

This event escalates from the Unusual Event by escalating the magnitude of the release by a factor of 100. Prorating the 500 mR/yr criterion for both time (8766 hr/yr) and the 200 multiplier, the associated site boundary dose rate would be 10 mR/hr. The required release duration was reduced to 15 minutes in recognition of the increased severity.

Monitor indications are calculated on the basis of the methodology of the EPIP 2-18 Control Room Dose Assessment. Annual average meteorology is used.

As previously stated, the 10 mR/hr value is based on a proration of 200 times the 500 mR/yr basis of the 10CFR20 non-occupational MPC limits, rounded down to 10 mR/hr. The values for the gaseous effluent radiation monitors are based upon not exceeding 10 mR/hr at the site boundary as a result of the release.

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 The conversion factors are. based upon the mixture of noble gas present in reactor coolant during the 1/25/82 tube rupture - normal operations.

Since there is no high range monitor associated with liquid effluent monitor R-18 and the 200x Technical Specification value is beyond it's upper scale, an indication of "offscale hi" is conservatively used.

Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

PEG

Reference:

AA1.1 Basis Reference(s):

1. EPIP 2-3 Emergency Release Rate Determination

2. P-9 Radiation Monitoring System

3. EPIP 2-18 Control Room Dose Assessment

4. Technical Specifications, Amendment No. 24, Articles 3.9.1.1 thru 3.9.2.3

5. "Calculations for NUMARC EALs" by P.S. Polfleit File EAL.XLS

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 5.0 Radioactivity Release / Area Radiation 5.1 E61uent Monitors 5.1.3 Site Area Emergency A valid reading on any monitors Table 5.1 column "SAE" for > 15 min.

Table 5.1 EfQuent Monitor Classification Thresholds Monitor R-11 1.62E6 cpm N/A N/A N/A R-12 7.80E6 cpm 1.07E7 cpm N/A N/A R-13 2.20E4 cpm N/A N/A N/A R-14 6.40E5 cpm 1.61E6 cpm N/A N/A R-15 4.00E5 cpm 2.31E7 cpm N/A N/A R 18 3.60E5 cpm oKscale hi N/A N/A R-12A(7/9) N/A N/A 6.00 pCi/cc 60.00 p,Ci/cc R-14A(7/9) N/A N/A 5.33E-1 p,Ci/cc 5.33 p.Ci/cc R-15 A(7/9) N/A N/A 11.50 pCi/cc 115.00 pCi/cc Mode Applicability:

Basis:

The values shown were determined utilizing EPIP 2-18 "Control Room Dose Assessment" based upon a 100 mR whole body exposure. The calculations made the assumption of neutral stability and an 8 mph wind speed. These conditions represent annual average meteorology. EPIP 2-18 specifies that whole body dose is limiting with respect'to emergency classification and protective action recommendations based upon the assumption of a noble gas to iodine ratio of lE-4.

The 100 mR integrated dose is based on the proposed 10CFR20 annual average population exposure. This value also provides a desirable gradient (one order of magnitude) between the Alert, Site Area Emergency, and General Emergency classes. It is deemed that exposures less than this limit are not consistent with the Site Area Emergency class description. The 500 mR integrated child thyroid dose was established in consideration of the 1:5 ratio of the EPA Protectiv'e Action Guidelines for whole body thyroid.

'I I~

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Integrated doses are generally not monitored in real-time. In establishing the emergency action levels, a duration of one hour is assumed, based on a site boundary dose of 100 mR/hour whole body or 500 mR/hour child thyroid, whichever is more limiting (depends on source term assumptions).

Although EPIP 2-18 provides for R-31/32 release determinations, the variability of results based upon the number of ARV's and/or SVs precludes the use of any single monitor default value for these monitors.

Valid means that a radiation monitor reading has been con6rmed by the operators to be correct.

PEG

Reference:

ASl.l Basis Reference(s):

1. P-9 Radiation Monitoring System

2. EPIP 2-18 Control Room Dose Assessment

3. FSAR Table 2.3

4. "Calculations for NUMARC EALs" by P.S. Polfieit File EAL.XLS

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Radioactivity Release / Area Radiation 6.1 E61uent Monitors 6.1.4 General Emergency A valid reading on any monitors Table 5.1 column "GE" for ) 15 min.

Table 5.1 EfBuent Monitor Classification Thresholds Monitor R-11 1.62E6 cpm N/A N/A 'N/A R-12 7.80E6 cpm 1.07E7 cpm N/A N/A R-13 2.20E4 cpm N/A N/A N/A R-14 6.40E5 cpm 1.61E6 cpm N/A N/A R-15 4.00E5 cpm 2.31E7 cpm N/A N/A R-18 3.60E5 cpm offscale hi N/A N/A R-12 A(7/9) N/A N/A 6.00 pCi/cc 60.00 pCi/cc R-14A(7/9) N/A N/A 5.33E-1 p,Ci/cc 5.33 p,Ci/cc R-15 A(7/9) N/A N/A 11.50 p,Ci/cc 115.00 pCi/cc Mode Applicability:

Basis:

The values shown were determined utilizing EPIP 2-18 "Control Room Dose Assessment" based upon a 1000 mR-whole body exposure. The calculations made the assumption of neutral stability and an 8 mph wind speed. These conditions represent annual average meteorology. EPIP 2-18 specifies that whole body dose is limiting with respect to emergency classification and protective action recommendations based upon the assumption of a noble gas to iodine ratio of 1E-4. II The 1000 mR whole body and the 5000 mR child thyroid integrated dose are based on the EPA protective action guidance which indicates that public protective actions are indicated ifthe dose exceeds 1 rem whole body or 5 rem child thyroid. This is consistent with the emergency class description for a General Emergency. This level constitutes the upper level of the desirable gradient for the Site Area Emergency.

Integrated doses are generally not monitored in real-time. In establishing the emergency action levels, a duration of one hour is assumed, based on a

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 site boundary dose of 1000 mH/hour whole body or 5000 mR/hour child thyroid, whiche'ver is more limiting (depends on source term assumptions).

l Although EPIP 2-18 provides for R-3V32 release determinations, the variability of results based upon the number of ARV's and/or SV's precludes the use of any single monitor default value for these monitors.

Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

PEG

Reference:

AG1.1 Basis Reference(s):

1. P-9 Radiation Monitoring System

2. EPIP 2-18 Control Room Dose Assessment

3. FSAR Table 2.3 4 "Calculations for NUMARC EALs" by P.S. Polfleit File EAL.XLS

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Radioactivity Release / Ar'ea Radiation 6.2 Dose Projections/ Environmental Measurements/ Release Rates 6.2.1 Unusual Event Confirmed sample analyses for gaseous or liquid release rates > 2 x technical specifications limits for > 60 min.

Mode Applicability:

Basis:

Unplanned releases in excess of two times the site technical specifications that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the Unusual Event emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that the release was not isolated within 60 minutes. Therefore, it is not intended that the release be averaged over 60 minutes. For example, a release of 4 times T/S for 30 minutes does not exceed this initiating condition.

Further, the Emergency Coordinator should not wait until 60 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has or will likely exceed 60 minutes PEG

Reference:

AU1.2 Basis Reference(s):

1. Technical Specifications, Amendment No. 24, Articles 3.9.1.1 thru 3.9.2.3 5-10

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 5.0 Radioactivity Release / Area Radiation 5.2 Dose Projections/ Environmental Measurements/ Release Rates 5.2.2 Alert Confirmed sample analyses for gaseous or liquid release rates > 200 x technical specifications limits for > 15 min.

Mode Applicability:

Basis:

Confirmed sample analyses in excess of two hundred times the site technical specifications that continue for 15 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. This event escalates from the Unusual Event by increasing the magnitude of the release by a factor of 100 over the Unusual Event level (i. e.,

200 times Technical Specifications). Prorating the 500 mR/yr basis of the 10CFR20 non-occupational MPC limits for both time (8766 hr/yr) and the 200 multiplier, the associated site boundary dose rate would be 10 mH/hr. The required release duration was reduced to 15 minutes in recognition of the increased severity.

PEG

Reference:

AA1.2 Basis Reference(s):

1. Technical Specifications, Amendment No. 24, Articles 3.9.1.1 thru 3.9.2.3

5. 11

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Radioactivity Release / Area Radiation 6.2 Dose Projections/ Environmental Measurements/ Release Rates 6.2.3 Alert Dose projections or field surveys which indicate doses / dose rates > Table 5.2 column "Alert" at the site boundary or beyond.

Table 5.2 Dose Pro ection/Env. Measurement Classification Thresholds TEDE 10 mR 100 mR 1000 mR CDE Thyroid N/A 500 mR 5000 mR TEDE rate 10 mEUhr 100 mH/hr 1000 ma/hr CDE Thyroid rate N/A 500 ma/hr 5000 nQUhr Mod,e Applicability:

Basis:

Offsite integrated doses in excess of 10 mR TEDE or dose rates in excess of 10 ma/hr TEDE represent an uncontrolled situation and hence, a potential degradation in the level of safety. This event escalates from the Unusual Event by increasing the magnitude of the release by a factor of 100 over the Unusual Event level (i. e., 200 times Technical Specifications). Prorating the 500 mR/yr basis of 10CFR20 for both time (8766 hr/yr) and the 200 multiplier, the associated site boundary dose rate would be 10 mR/hr.

As previously stated, the 10 mR/hr value is based on a proration of 200 times the 500 mR/yr basis of 10CFR20, rounded down to 10 mR/hr.

5-12

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 PEG

Reference:

AA1.2 Basis Reference(s):

Technical Specifications, Amendment No. 24, Articles 3.9.1.1 thru 3.9.2.3

2. EPIP 2-3 Emergency Release Rate Determination

3. P-9 Radiation Monitoring System 4 EPIP 2-18 Control Room Dose Assessment 5-13

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 5.0 Radioactivity Release / Area Radiation 5.2 Dose Projections/ Environmental Measurements/ Release Rates 5.2.4 Site Area Emergency Dose projections or field surveys which indicate doses / dose rates > Table 5.2 column "SAE" at the site boundary or beyond.

Table 5.2 Dose Pro ection / Env. Measurement Classification Thresholds TEDE 10 mR 100 mR 1000 mR CDE Thyroid N/A 500 mR 5000 mR TEDE rate 10 mH/hr 100 mH/hr 1000 mH/hr CDE Thyroid rate N/A 500 mH/hr 5000 mEUhr Mode Applicability:

Basis:

The 100 mR integrated TEDE dose in this EAL is based on the proposed 10CFR20 annual average population exposure. This value also provides a desirable gradient (one order of magnitude) between the Alert, Site Area Emergency, and General Emergency classes. It is deemed that exposures less than this limit are not consistent with the Site Area Emergency class description. The 500 mR integrated CDE thyroid dose was established in consideration of the 1:5 ratio of the EPA Protective Action Guidelines for whole body thyroid. In establishing the dose rate emergency action levels, a duration of one hour is assumed. Therefore, the dose rate EALs are based on a site boundary dose rate of 100 mH/hr TEDE or 500 mH/hr CDE thyroid, whichever is more limiting.

PEG

Reference:

AS1.3 AS1.4 5-14

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Basis Reference(s):

Technical Specifications, Amendment No. 24, Articles 3.9.1.1 thru 3.9.2.3

2. EPIP 2-3 Emergency Release Rate Determination

3. P-9 Radiation Monitoring System 4 EPIP 2-18 Control Room Dose Assessment 5-15

i /ac OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Radioactivity Release /Area Radiation 6.2 Dose Projections/ Environmental Measurements/ Release Rates 6.2.6 General Emergency Dose projections or field surveys which indicate doses / dose rates > Table 5.2 column "GE" at the site boundary or beyond.

Table 5.2 Dose Pro ection/ Env. Measurement Classification Thresholds TEDE 10 mR 100 mR 1000 mR CDE Thyroid N/A 500 mR 5000 mR TEDE rate 10 mH/hr 100 mR/hr 1000 mR/hr CDE Thyroid rate N/A 500 mH/hr 5000 mH/hr Mode Applicability:

Basxsi The General Emergency values of Table 5.2 are based on the boundary dose resulting from an actual or imminent release of gaseous radioactivity that exceeds 1000 mR TEDE or 5000 mR CDE thyroid for the actual or projected duration of the release. The 1000 mR TEDE and the 5000 mR CDE thyroid integrated dose are based on the EPA protective action guidance which indicates that public protective actions are indicated ifthe dose exceeds 1 rem TEDE or 5 rem CDE thyroid. This is consistent with the emergency class description for a General Emergency. This level constitutes the upper level of the desirable gradient for the Site Area Emergency. Actual meteorology is specifically identified since it gives the most accurate dose assessment.

Actual meteorology (including forecasts) should be used whenever possible.

In establishing the dose rate emergency action levels, a duration of one hour is assumed. Therefore, the dose rate EALs are based on a site boundary dose rate of 1000 mH/hr TEDE or 5000 mH/hr CDE thyroid, whichever is more limiting.

5-16

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 PEG

Reference:

AG1.3 AG1.4 Basis Reference(s):

Technical Specifications, Amendment No. 24, Articles 3.9.1.1 thru 3.9.2.3

2. EPIP 2-3 Emergency Release Rate Determination

3. P-9 Radiation Monitoring System EPIP 2-18 Control Room Dose Assessment 5-17

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Radioactivity Release /Area Radiation 6.8 Area Radiation Levels I

6.8.1 Unusual Event Any sustained direct ARM readings ) 100 x alarm or offscale hi resulting from an uncontrolled process Mode Applicability:

Basis:

Valid elevated area radiation levels usually have long lead times relative to the potential for radiological release beyond the site boundary, thus impact to public health and safety is very low. It should be noted that the CAS and SAS do not have installed radiation monitors. Therefore, evaluation of this EAL would require survey of these areas.

This EAL addresses unplanned increases in radiation levels inside the plant.

These radiation levels represent a degradation in the control of radioactive material and a potential degradation in the level of safety of the plant. Area radiation levels above 100 times the alarm setpoint have been selected because they are readily identifiable on ARM instrumentation. Since ARM setpoints are nominally set one decade over normal levels, 100 times the alarm setpoint provides an appropriate threshold for emergency classi6cation. For those ARMs whose upper range limit are less than 100 times the alarm setpoint, a value of offscale high is used. This EAL escalates to an Alert, ifthe increases impair the level of safe plant operation.

PEG

Reference:

AU2.4 Basis Reference(s):

None 5-18

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Radioactivity Release / Area Radiation 6.3 Area Radiation Levels 6.3.2 Alert Sustained area radiation levels > 16 mXUln in either:

Control Room OR Central Alarm Station and Secondary Alarm Station Mode Applicability:

Basis:

This EAL addresses increased radiation levels that impede necessary access to operating stations requiring continuous occupancy to maintain safe plant operation or perform a safe plant shutdown. Areas requiring continuous occupancy include the Control Room, the central alarm station (CAS) and the secondary security alarm station (SAS). The security alarm stations are included in this EAL because of their importance to permitting access to areas required to assure safe plant operations.

The value of 15 mWhr is derived from the GDC 19 value of 5 rem in 30 days with adjustment for expected occupancy times. Although Section III.D.3 of NUREG-0737, "Clarification of TMI Action Plan Requirements", provides that the 15 mR/hr value can be averaged over the 30 days, the value is used here without averaging. A 30 day duration implies an event potentially more significant than an Alert.

It is the impaired ability to operate the plant that results in the actual or potential degradation of the level of safety of the plant. The cause or magnitude of the increase in radiation levels is not a concern of this EAL.

The Emergency Coordinator must consider the source or cause of the increased radiation levels and determine ifany other EALs may be involved.

For example, a dose rate of 15 mR/hr in the Control Room may be a problem in itself. However, the increase may also be indicative of high dose rates in the containment due to a LOCA. In this latter case, a Site Area Emergency or a General Emergency may be indicated by other EAL categories.

5-19

OSSI-92<02A-4-REG Ginna EAL Technical Bases Document, Rev 0 This EAL is not intended to apply to anticipated temporary radiation increases due to planned events (e. g., radwaste container movement, depleted resin transfers, etc.).

PEG

Reference:

AA3.1 Basis Reference(s):

1. GDC 19

2. NUREG-0737, "Clarification of TMI Action Plan Requirements",

Section III.D.3

3. P-9 Radiation Monitoring System Rev. 67 5-20

Qg" =

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Radioactivity Release / Area Radiation 5.8 Area Radiation Levels 6.3.8 Alert Sustained abnormal'rea radiation levels > 8 R/hr within any areas, Table 5.3 AND Access is required for safe operation or shutdown Table 5.3 Plant Areas

~ Reactor Containment Building

~ Auxiliary Building

~ Turbine Building

~ Emergency Diesel Building

~ Screen House II

~ Standby Auxiliary Feedwater Building Mode Applicability:

Basis:

This EAL addresses increased radiation levels in areas requiring infrequent access in order to maintain safe plant operation or perform a safe plant shutdown. Area radiation levels at or above 8 R/hr are indicative of radiation fields which may limit personnel access or adversely affect equipment whose operation may be needed to assure adequate core cooling or shutdown the reactor. The basis of the value is described in NMPC memo File Code NMP31027 "Exposure Guidelines For Unusual/Accident Conditions". The areas selected are consistent with those listed in other EALs and represent those structures which house systems and equipment necessary for the safe operation and shutdown of the plant.

It is the impaired ability to operate the plant that results in the actual or potential degradation of the level of safety of the plant. The cause or magnitude of the increase in radiation levels is not a concern of this EAL.

The Emergency Coordinator must consider the source or cause of the increased radiation levels and determine ifany other EAL may be involved.

For example, a dose rate of 8 R/hr may be a problem in itself. However, the increase may also be indicative of high dose rates in the containment due to a 5-21

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 LOCA. In this latter case, a Site Area Emergency or a General Emergency may be indicated by other EAL categories.

This EAL is not meant to apply to increases in the containment radiation monitors as these are events which are addressed in other EALs. Nor is it intended to apply to anticipated temporary radiation increases due to planned events (e. g., radwaste container movement, deplete resin transfers, etc.).

PEG

Reference:

AA3.2 Basis Reference(s):

1. Niagara Mohawk Power Corporation memo File Code NMP31027 "Exposure Guidelines For Unusual/Accident Conditions", Revision 1, 3/18/93 5-22

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Loss of vital plant electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity.

The events of this category have been grouped into the following two loss of electrical power types:

r 'his category includes losses of onsite and/or ofFsite AC power sources including station blackout events.

~ L fD r This category involves total losses of vital plant 125 vdc power sources.

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Electrical Failures 6.1 Loss of AC Power Sources 6.1.1 Unusual Event Loss of ability to supply power to the safeguard buses from ofFsite circuits 751 and 767 for > 15 min.

Mode Applicability:

Basis:

Prolonged loss of all offsite AC power reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete loss of AC power (station blackout). Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

PEG

Reference:

SU1.1 Basis Reference(s):

1. RGE-6 "4160V Electrical Distribution System"

2. RGE-7 "480V Distribution "

OSSI-92<02A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Electrical Failures 6.1 Loss of AC Power Sources 6.1.2 Alert Loss of all safeguards bus AC power for > 15 min.

Mode Applicability:

Cold Shutdown, Refueling, Defueled Basis:

Loss of all AC power compromises all plant safety systems requiring electric power. This EAL is indicated by: loss of all offsite AND onsite AC power to safeguards buses 14/18 AND 16/17 for greater than 15 minutes. When in cold shutdown, refueling, or defueled mode the event can be classified as an Alert, because of the significantly reduced decay heat, lower temperature and pressure, increasing the time to restore one of the emergency busses, relative to that specified for the Site Area Emergency EAL. Escalating to the Site if Area Emergency, appropriate, is by Abnormal Rad Levels/Radiological EfHuent, or Emergency Coordinator Judgment ICs. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

PEG

Reference:

SA1.1 Basis Reference(s):

1. ROE-6 "4160V Electrical Distribution System"

t- g OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Electrical Failures 6.1 Loss of AC Power Sources 6.1.3 Alert Available safeguard train AC power reduced to only one of the following for >

15 min.:

~ EDG lA (14/18)

~ EDG 1B (16/17)

~ Sthtion AuxiliaryTransformer 12A

~ Station AuxiliaryTransformer 12B Mode Applicability:

Power operation, hot shutdown Basis:

The condition indicated by this EAL is the degradation of the offsite power with a concurrent failure of one emergency generator to supply power to its emergency busses. Another related condition could be the loss of all ofFsite power and loss of onsite emergency diesels with only one train of emergency busses being fed from the unit main generator, or the loss of onsite emergency diesels with only one train of emergency busses being fed from offsite power. The subsequent loss of this single power source would escalate the event to a Site Area Emergency.

PEG

Reference:

SA5.1 Basis Reference(s):

N

1. RGE-6 "4160V Electrical Distribution"

2. RGE-7 "480v Distribution"

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Electrical Failures 6.1 Loss of AC Power Sources 6.1.4 Site Area Emergency Loss of all safeguards bus AC power for > 15 min.

Mode Applicability:

Power operation, hot shutdown Basis:

Loss of all AC power compromises all plant safety systems requiring electric power. This EAL is indicated by: loss of all offsite AND onsite AC power to safeguards buses 14/18 AND 16/17 for greater than 15 minutes, Prolonged loss of all AC power will cause core uncovery and loss of containment integrity, thus this event can escalate to a General Emergency. The time duration should be selected to exclude transient or momentary power losses, but should not exceed 15 minutes.

PEG

Reference:

SS1.1 Basis Reference(s):

1. RGE-6 "4160V Electrical Distribution"

2. RGE-7 "480v Distribution"

OSSI-92<02A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Electrical Failures 6.1 Loss of AC Power Sources 6.1.5 General Emergency Loss of all safeguards bus AC power AND either:

Power cannot be restored to any safeguards bus in < 4 hrs OR ORANGE or RED path on F-0.2, "CORE COOLING" Mode Applicability:

Power operation, hot shutdown Basis:

Loss of all AC power compromises all plant safety systems requiring electric Prolonged loss of all AC power will lead to loss of fuel clad, RCS, and 'ower.

containment. Although this EAL may be viewed as redundant to the RPV Water Level EALs, its inclusion is necessary to better assure timely recognition and erne'rgency response.

This EAL is specified to assure that in the unlikely event of prolonged station blackout, timely recognition of the seriousness of the event occurs and that declaration of a General Emergency occurs as early as is appropriate, based on a reasonable assessment of the event trajectory.

The likelihood of restoring at least one emergency bus should be based on a realistic appraisal of the situation since a delay in an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions.

In addition, under these conditions, fission product barrier monitoring capability may be degraded. Although it may be diKcult to predict when power can be restored, the Emergency Coordinator should declare a General Emergency based on two major considerations:

1. Are there any present indications that core cooling is already degraded to the point that Loss or Potential Loss of fission product barriers is imminent?

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0

2. Ifthere are no present indications of such core cooling degradation, how likely is it that power can be restored in time to assure that a loss of two barriers with a potential loss of the third barrier can be prevented?

Thus, indication of continuing core cooling degradation must be based on fission product barrier monitoring with particular emphasis on Emergency Coordinator judgment as it relates to imminent loss or potential loss of fission product barrier's and degraded ability to monitor fission product barriers.

The time to restore AC power is based on site blackout coping analysis performed in conformance with 10CFR50.63 and Regulatory Guide 1.155, "Station Blackout", with appropriate allowance for offsite emergency

response, PEG

Reference:

SG1.1 Basis Reference(s):

1. F-0.2, "CORE COOLING,"

2. NRC letter to Dr. Mecredy dated 1/30/92 "RE Ginna Nuclear Power Plant Station Blackout Analysis (TAC M68548)

3. RGE-6 "4160v Electrical Distribution System" 4 RGE-7 "480v Distribution"

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Electrical Failures 6.2 Loss of DC Power Sources 6.2.1 Unusual Event

< 105 vdc bus voltage indications on 125 vdc batteries 1A and 1B for > 15 min.

Mode Applicability:

Cold Shutdown, Refueling Basis:

The purpose of this EAL is to recognize a loss of DC power compromising the ability to monitor and control the removal of decay heat during cold shutdown or refueling operations. This EAL is intended to be anticipatory in as much as the operating crew may not have necessary indication and control of equipment needed to respond to the loss.

The bus voltage is based on the minimum bus voltage necessary for the operation of safety related equipment. This voltage value incorporates a margin of at least 15 minutes of operation before the onset of inability to operate loads.

PEG

Reference:

SU7.1 Basis Reference(s):

1. RGE-9 "Instrument Bus and DC Power System"

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 6.0 Electrical Failures 6.2 Loss of DC Power Sources 6.2.2 Site Area Emergency

> 105 vdc bus voltage indications on 125 vdc batteries 1A and 1B for > 15 min.

Mode Applicability:

Power operation, hot shutdown Basis:

Loss of all DC power compromises ability to monitor and control plant safety functions. Prolonged loss of all DC power will cause core uncovering and loss of containment integrity when there is significant decay heat and sensible heat in the reactor system. Escalation to a General Emergency would occur by other EAL categories. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

The bus voltage is based on the minimum bus voltage necessary for the operation of safety related equipment. This voltage value incorporates a margin of at least 15 minutes of operation before the onset of inability to operate loads.

PEG

Reference:

SS3.1 Basis Reference(s):

1. RGE-9 "Instrument Bus and DC Power System"

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Numerous plant system related equipment failure events which warrant emergency classification, based upon their potential to pose actual or potential threats to plant safety, have been identified in this category.

The events of this category have been grouped into the following event types:

~

'nlyone related to the failure of the EAL falls under this event type plant to be brought to the required plant operating condition required by technical specifications.

'l' This category includes events which are indicative of losses of operability of safety systems such as ECCS, isolation functions, Control Room habitability or cold and hot shutdown capabilities.

n m ni Certain events which degrade the plant operators ability to effectively assess plant conditions or communicate with essential personnel within or external to the plant warrant emergency classification. Under this event type are losses of annunciators and/or communication equipment.

7-1

'5

(

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 V.o Eguipment Failures V.1 Technical Speci6cation Requirements V.1.1 Unusual Event Plant is not brought to required operating mode within Technical Specifications LCO Action Statement Time.

Mode Applicability:

Power operation, hot shutdown Basis:

Limiting Conditions of Operation (LCOs) require the plant to be brought to a required shutdown mode when the Technical Specification required configuration cannot be restored. Depending on the circumstances, this may or may not be an emergency or precursor to a more severe condition. In any case, the initiation of plant shutdown required by the site Technical Speci6cation requires a one hour report under 10CFR50.72 (b) non-emergency events. The plant is within its safety envelope when being shut down within the allowable action statement time in the Technical Specifications. An immediate Notification of an Unusual Event is required when the plant is not brought to the required operating mode within the allowable action statement time in the Technical Specifications. Declaration of an Unusual Event is based on the time at which the LCO-specifiied action statement time period elapses under the site Technical Specifications and is not related to how long a condition may have existed. Other required Technical Speci6cation shutdowns that involve precursors to more serious events are addressed by other EALs.

PEG

Reference:

SU2.1 Basis Reference(s):

1. Technical Specifications Section 3.0 7-2

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 V.O Equipment Failures V.2 System Failures or Control Room Evacuation 7.2.1 Unusual Event Report of main turbine failure resulting in casing penetration or damage to turbine seals or generator seals.

Mode Applicability:

Power Operation, hot shutdown Basis:

This EAL is intended to address main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator. Of major concern is the potential for leakage of combustible fluids (lubricating oils) and gases (hydrogen cooling) to the plant environs. Actual fires and flammable gas build up are appropriately classified through other EALs. This EAL is consistent with the definition of an Unusual Event while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment.

PEG

Reference:

HU1.6 Basis Reference(s):

None 7-3

OSSI-92-402A-4-RE 6 Ginna EAL Technical Bases Document, Rev 0 V.O Equipment'Failures 7.2 System Failures or Control Room Evacuation V.2.2 Alert Turbine failure generated missiles result in any visible structural damage to plant vital equipment Mode Applicability:

Power Operations, Hot Shutdown Basis:

This EAL addresses the threat to safety related equipment imposed by missiles generated by main turbine rotating component failures. The involved equipment includes safety-related equipment, their controls, and their power supplies. This EAL is consistent with the definition of an ALERT in that, ifmissiles have. damaged or penetrated areas containing safety-related equipment, the potential exists for substantial degradation of the level of safety of the plant.

PEG

Reference:

HA1.6 Basis Reference(s):

None 7-4

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 7.0 Equipment Failures 7.2 'ystem Failures or Control Room Evacuation 7.2.3 Alert Control Room evacuation Mode Apphcability:

Basis:

With the Control Room evacuated, additional support, monitoring and direction through the Technical Support Center and/or other emergency operations center is necessary. Inability to establish plant control from outside the Control Room will escalate this event to a Site Area Emergency.

PEG

Reference:

HA5.1 Basis Reference(s):

1. AP-CR.1 Control Room Inaccessibility 7-5

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 7.0 Equipment Failures 7.2 System Failures or Control Room Evacuation 7.2.4 Alert Reactor coolant temperature cannot be maintained ( 200 'F Mode Applicability:

Cold Shutdown, Refueling Basis:

This EAL addresses complete loss of functions required for core cooling during refueling and cold shutdown modes. Escalation to Site Area Emergency or General Emergency would be through other EALs.

A reactor coolant temperature increase that approaches or exceeds the cold shutdown technical specification limit warrants declaration of an Alert irrespective of the availability of technical specification required functions to maintain cold shutdown. The concern of this EAL is the loss of ability to maintain the plant in cold shutdown which is defined by reactor coolant temperature and not the operability of equipment which supports removal of heat from the reactor.

PEG

Reference:

SA3.1 Basis Reference(s):

l. AP-RHR.1 "Loss of RHR"

2. Technical Specifications Section 1.2

3. AP-RHR-2 "Loss of RHR While Operating at Reduced RCS Inventory Conditions" 7-6

OSSI-92<02A-4-REG Ginna EAL Technical Bases Document, Rev 0 V.O Equipment Failures V.2 System Failures or Control Room Evacuation V.2.5 Site Area Emergency Control Room evacuation AND Core cooling cannot be established per AP-CR.1 "Control Room Inaccessibility" in 5 20 min.

Mode Applicability:

Basis:

This EAL indicates that expeditious transfer of safety systems has not occurred but fission product barrier damage may not yet be indicated. The time interval for transfer is based on analysis or assessments as to how quickly control must be reestablished without core uncovering and/or core damage.

REGNPS Appendix R submittal indicates that 20 minutes is the maximum time for which control of plant safety systems should occur under worst case conditions.

In cold shutdown and refueling modes, operator concern is directed toward maintaining core cooling such as is discussed in Generic Letter 88-17, "Loss of Decay Heat Removal." In power operation, and hot shutdown modes, operator concern is primarily directed toward maintaining critical safety functions and thereby assuring fission product barrier integrity.'EG

Reference:

HS2.1 Basis Reference(s):

l. AP-CR.1 Control Room Inaccessibility

2. Appendix R Section 6.4.5 page 6-35

3. Generic Letter 88-17, "Loss of Decay Heat Removal."

7-7

OSSI-92-402AM-REG Ginna EAL Technical Bases Document, Rev 0 V.O Equipment Failures V.S Loss of Indications /Alarms /

Capability 'ommunication V.8.1 Unusual Event Unplanned loss of annunciators or indications on any Control Room Panels, Table 7.3 for > 15 min.

AND Increased surveillance is required for safe plant operation Table 7.3 Vital Control Room Panels A AA B C D E F Mode Applicability:

Power operation, hot shutdown Basis:

This EAL recognizes the difficultyassociated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment. Recognition of the availability of computer based indication equipment is considered (PPCS and SAS).

"Unplanned" loss of annunciators or indicators excludes scheduled maintenance and testing activities.

It is not intended that plant personnel perform a detailed count of the instrumentation lost but the use ofjudgment by the Shik Supervisor as the threshold for determining the severity of the plant conditions. This judgment is supported by the specific opinion of the Shift Supervisor that additional operating personnel will be required to provide increased monitoring of system operation to safely operate the plant.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies.

While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difhculty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This willbe addressed by their specific Technical Specification. The initiation of a Technical Specification 7-8

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 imposed plant shutdown related to the instrument loss willbe reported via 10CFR50.72. Ifthe shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on EAL 7.1.1, Inability to Reach Required Shutdown Within Technical Specification Limits.

Annunciators or indicators for this EAL must include those identified in the Abnormal Operating procedures, in the Emergency Operating Procedures, and in other EALs (e. g., area, process, and/or effluent rad monitors, etc.).

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Due to the limited number of safety systems in operation during cold shutdown, refueling, and defueled modes, this EAL is not applicable during these modes of operation.

This Unusual Event will be escalated to an Alert ifa transient is in progress during the loss of annunciation or indication.

PEG

Reference:

SU3.1 Basis Reference(s):

None 7-9

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 7.0 Equipment Failures . 7.3 Loss of Indications /Alarms /

Communication Capability 7.8.2 Unusual Event Loss of all communications capability affecting the ability to either:

Perform routine operations OR Notify offsite agencies or personnel Mode Applicability:

Basis:

The purpose of this EAL is to recognize a loss of communications capability that either defeats the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate problems with offsite authorities. The loss of offsite communications ability is expected to be signi6cantly more comprehensive than the condition addressed by 10CFR50.72.

The onsite communications loss must encompass the loss of all means of routine communications (i. e., phones, sound powered phone systems, page party system, and radios/walkie talkies).

The offsite communications loss must encompass the loss of all means of communications with offsite authorities. This should include ENS, Bell lines, FAX transmissions, and dedicated phone systems. This EAL is intended to be used only when extraordinary means are being utilized to make communications possible (relaying of information from radio transmissions, individuals being sent to offsite locations, etc.).

PEG

Reference:

SU6.1 Basis Reference(s):

l. A-56, "Communication Systems at,Ginna Station" 7-10

OSSI-92-402A-4-RE 6 Ginna EAL Technical Bases Document, Rev 0 7.0 Equipment Failures 7.3 Loss of Indications /Abuses /

Communication Capability 7.3.3 Alert Unplanned. loss of annunciators or indications on any Control Room Panels, Table 7.3 for > 15 min.

AND Increased surveillance is required for safe plant operation AND either:

A plant transient in progress OR PPCS and SAS are unavailable Table 7.3 Vital Control Room Panels A AA 8 C D E Mode Applicability:

Power operation, hot shutdown Basis:

This EAL recognizes the dif6culty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a transient. Recognition of the availability of computer based indication equipment is considered (PPCS, SAS, etc.).

"Unplanned" loss of annunciators or indicators doe's not include scheduled maintenance and testing activities.

It is not intended that plant personnel perform a detailed count of the instrumentation lost but the use ofjudgment by the Shift Supervisor as the threshold for determining the severity of the plant conditions. This judgment is supported by the specific opinion of'the Shift Supervisor that additional operating personnel will be required to provide increased monitoring of system operation to safely operate the plant.

It is further recognized that most plant designs provide redundant safety system indication powered &om separate uninterruptable power failure of a lar'ge portion of annunciators is more likely than a failure of supplies.'hile a large portion of indications, the concern is included in this EAL due to difFiculty associated with assessment of plant conditions. The loss of specific, 7-11

~

't 1

OSSI-92-402A-4-REG . Ginna EAL Technical Bases Document, Rev 0 or several, safety system indicators should remain a function of that specific ~

system or component operability status. This willbe addressed by the specific Technical Specification. The initiation of a Technical Specification impose'd plant shutdown related to the instrument loss willbe reported via 10CFR50.72.

Annunciators or indicators for this EAL includes those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e. g., area, process, and/or effluent rad monitors, etc.).

"Significant transient" includes response to automatic or manually initiated functions such as trips, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power oscillations of 10% or greater.

Ifboth a major portion of the annunciation system and all computer monitoring are unavailable to the extent that the additional operating personnel are required to monitor indications, the Alert is required.

Due to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes, no EAL is indicated during these modes of operation.

This Alert will be escalated to a Site Area Emergency ifthe operating crew cannot monitor the transient in progress.

PEG

Reference:

SA4.1 Basis Reference(s):

None 7-12

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 V.O Equipment Failures V.S Loss of Indications /Alarms /

Communication Capability V.8.4 Site Area Emergency Loss of annunciators or indications on any Control Room Panels, Table 7.3 AND Complete loss of ability to monitor all critical safety function status AND A plant transient in progress Table 7.3 Vital Control Room Panels A AA B C D E F 0 Mode Applicability:

Power operation, hot shutdown Basis:

This EAL recognizes the inability of the Control Room staff to monitor the plant response to a transient. A Site Area Emergency is considered to exist if the Control Room staff cannot monitor safety functions needed for protection of the public.

Annunciators for this EAL should be limited to include those identified in the Abnormal Operating Procedures, in the CSFST's and Emergency Operating Procedures, and in other EALs (e. g., rad monitors, etc.).

"Significant transient" includes response to automatic or manually initiated functions such as scrams, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power oscillations of 10% or greater.

Indications needed to monitor critical safety functions necessary for protection of the public must include Control Room indications, computer generated indications and dedicated annunciation capability. The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled and in a eoolable geometry, to remove heat from the core, to maintain the reactor coolant system intact, and to maintain containment intact.

7-13

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 "Planned" actions are excluded from the EAL since the loss of instrumentation of this magnitude is of such signi6cance during a transient that the cause of the loss is not an ameliorating factor.

I'EG

Reference:

SS6.1 Basis Reference(s):

None 7- 14

i 'p OSSI-92-402A-4-RE 6 Ginna EAL Technical Bases Document, Rev 0 Hazards are those non-plant system related events which can directly or indirectly impact plant operation or reactor plant and personnel safety.

fi into the Protected Area well bomb threats and as as fifi 'i The events of this category have been grouped into the following types:

fifi'ifi~' t tt fit sabotage attempts.

Also addressed are actual security compromises threatening loss of physical control of the plant.

fi fi 'ifi'fi tfi

'eactor safety. Appropriate for classi6cation are fitfi 1 fi Qres within the site Protected Area or which may afFect operability of vital equipment.

Man-made events are those non-naturally occurring events which can cause damage to plant facilities such as aircraft crashes, missile impacts, toxic or flammable gas leaks or explosions from whatever source.

'vents such as hurricanes, earthquakes or tornados which have potential to cause damage to plant structures or equipment signi6cant enough to threaten personnel or plant safety.

OSSI-92-402A-4-RE 6 Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.1 Security Threats 8.1.1 Unusual Event Bomb device or other indication of attempted sabotage discovered within plant Protected Area.

Mode Applicability:

All Basis:

This EAL is based on the REGNPS Security Contingency Plan. Security events which do not represent at least a potential degradation in the level of safety of the plant, are reported under 10CFR73.71 or in some cases under 10CFR50.72.

The plant Protected Area boundary is within the security isolation zone and is defined in the security plan. Bomb devices discovered within the plant vital area would result in EAL escalation.

PEG

Reference:

HU4.1 HU4.2 Basis Reference(s):

1. REGNPS Security Contingency Plan

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.1 Security Threats 8.1.2 Alert Intrusion into plant Protected Area by an adversary.

Mode Applicability:

Basis:

This class of security events represents an escalated threat to plant safety above that contained in the Unusual Event. For the purposes of this EAL, the intrusion by unauthorized personnel inside the Protected Area boundary can be considered a significant security threat. Intrusion into a vital area by unauthorized personnel will escalate this event to a Site Area Emergency.

PEG

Reference:

HA4.1 HA4.2 Basis Reference(s):

l. REGNPS Security Contingency Plan

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.1 Security Threats 8.1.3 Site Area Emergency Intrusion into a plant security vital area by an adversary.

Mode Applicability:

Basis:

This class of security events represents an escalated threat to plant safety above that contained in the Alert in that unauthorized personnel have progressed from the Protected Area to the vital area.

PEG

Reference:

HS1.1 HS1.2 Basis Reference(s):

1. REGNPS Security Contingency Plan

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.1 Security Threats 8.1.4 General Emergency Security event which results in:

Loss of plant control Rom the Control Room AND Loss of remote shutdown capability Mode Applicability:

Basis:

This EAL encompasses conditions under which unauthorized personnel have taken physical control of vital areas required to reach and maintain safe shutdown.

PEG

Reference:

HG1.1 HG1.2 Basis Reference(s):

1. REGNPS Security Contingency Plan

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0

'.0 Hazards 8.2 Fire or Explosion 8.2.1 Unusual Event Confirmed fire in any plant area, Table 8.2 or 8.3 not extinguished in 5 15 min. of Control Room notification:

Table 8.2 Plant Areas

~ Turbine Building

~ TSC

~ Service Building

~ Contaminated Storage Building Table 8.3 Plant Vital Areas

~ Control Building

~ Reactor Containment Building

~ Auxiliary Building

~ Intermediate Building

~ Emergency Diesel Building

~ Standby Auxiliary Feedwater Building

~ Screen House Mode Applicability:

Basis:

The purpose of this EAL is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. This excludes such items as fires within administration buildings, waste-basket fires, and other small fires of no safety consequence.

PEG

Reference:

HU2.1 Basis Reference(s):

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0

1. Site Plot Plan

OSSI-92-402AM-REG Ginn'a EAL Technical Bases Document, Rev 0 8.0 Hazards 8.2 Fire or Explosion 8.2.2 Alert Fire or explosion in any plant area, Table 8.2 or Table 8.3 which results in damage to plant equipment or structures needed for safe plant operation Table 8.2 Plant Areas

~ Turbine Building

~ TSC Service Building

~ Contaminated Storage Building Table 8.3 Plant Vital Areas

~ Control Building

~ Reactor Containment Building

~ AuxiliaryBuilding

~ Intermediate Building

~ Emergency Diesel Building

~ Standby AuxiliaryFeedwater Building

~ Screen House Mode Applicability:

Basis:

The listed areas contain functions and systems required for the safe shutdown of the plant. The REGNPS safe shutdown analysis was consulted for equipment and plant areas required for the applicable mode.

With regard to explosions, only those explosions of sufficient force to damage permanent structures or equipment required for safe operation within the identified plant areas should be considered. As used here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to nearby structures and materials. No attempt is made in this EAL to assess the actual magnitude of the damage. The declaration of an Alert and the activation of the TSC will provide the Emergency Coordinator, with the resources needed

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 to perform damage assessments. The Emergency Coordinator also needs to consider any security aspects of the explosions.

PEG

Reference:

HA2.1 Basis Reference(s):

1. Site Plot Plan

OSSI-92<02A-4-REG Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.3 Man-Made Events 8.3.1 Unusual Event Vehicle crash into or projectile which impacts plant structures or systems within Protected Area boundary Mode Applicability:

Basis.

The Protected Area boundary is within the security isolation zone and is defined in the site security plan.

This EAL addresses such items as plane, helicopter, train, barge, car or truck crash, or impact of other projectiles that may potentially damage plant structures containing functions and systems required for safe shutdown of the plant. Ifthe crash is confirmed to affect a plant vital area, the event may be escalated to Alert.

PEG

Reference:

HU1.4 Basis Reference(s):

'. Site Plot Plan 8-10

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.3 Man-Made Events 8.3.2 Unusual Event Report by plant personnel of an explosion within Protected Area boundary resulting in visible damage to permanent structures or equipment Mode Applicability:

Basis:

The Protected Area boundary is within the security isolation zone and is defined in the site security plan.

For this EAL, only those explosions of sufficient force to damage permanent structures or equipment within the Protected Area should be considered. As used here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to near by structures and materials. No attempt is made in this EAL to assess the actual magnitude of the damage. The occurrence of the explosion with reports of evidence of damage (e. g., deformation, scorching) is sufBcient for declaration. The Emergency Coordinator also needs to consider any security aspects of the explosion.

PEG

Reference:

HU1.5 Basis Reference(s):

1. Site Plot Plan 8-11

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.3 Man-Made Events 8.3.3 Unusual Event Report or detection of toxic or flammable gases that could enter or have entered within the Protected Area boundary in amounts that could affect the health of plant personnel or safe plant operation OR Report by local, county or state officials for potential evacuation of site personnel based on offsite event Mode Applicability:

Basis:

This EAL is based on releases in concentrations within the site boundary that will affect the health of plant personnel or affecting the safe operation of the plant with the plant being within the evacuation area of an offsite event (i. e.,

tanker truck accident releasing toxic gases, etc.). The evacuation area is as determined &om the DOT Evacuation Tables for Selected Hazardous Materials, in the DOT Emergency Response Guide for Hazardous Materials.

Should an explosion occur within a specified plant area, an Alert would be declared based on EAL 8.2.2.

PEG

Reference:

HU3.1 HU3.2 Basis Reference(s):

None 8-12

0SSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.3 Man-Made Events-8.3.4 Alert Vehicle crash or projectile impact which precludes personnel access to or damages equipment in plant vital areas, Table 8.3 Table 8.3 Plant Vital Areas

~ Control Building

~ Reactor Containment Building

~ Auxiliary Building

~ Intermediate Building

~ Emergency Diesel Building

~ Standby Auxiliary Feedwater Building

~ Screen House Mode Applicability:

Basis:

This EAL addresses events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage.

This EAL addresses such items as plane, helicopter, train, barge, car or truck crash, or impact of projectiles into a plant vital area.

PEG

Reference:

HA1.5 Basis Reference(s):

None 8-13

OSSI-92-402A~-REG Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.3 Man-Made Events 8.3.6 Alert Report or detection of toxic or Qammable gases within a plant area, Table 8.3, in concentrations that will be life threatening,to plant personnel or preclude access to equipment needed for safe plant operation Table 8.3 Plant Vital Areas

~ Control Building

~ Reactor Containment Building

~ AuxiliaryBuilding

~ Intermediate Building

~ Emergency Diesel Building

~ Standby Auxiliary Feedwater Building

~ Screen House Mode Applicability:

All Basis:

This EAL is based on gases that have entered a plant structure precluding access to equipment necessary for the safe operation of the plant. This EAL applies to buildings and areas contiguous to plant vital areas or other signi6cant buildings or areas. The intent of this EAL is not to include buildings (i. e., warehouses) or other areas that are not contiguous or immediately adjacent to plant vital areas. It is appropriate that increased monitoring be done to ascertain whether consequential damage has occurred.

PEG

Reference:

HA3.1 HA3.2 Basis Reference(s):

None 8- 14

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.4 Natural Events 8.4.1 Unusual Event Earthquake felt inplant by any operator AND Con6rmation of earthquake of an intensity > 0.01 g per SC-5 "Earthquake Emergency Plan".

Mode Applicability:

Basis:

REGNPS seismic instrumentation actuates at 0.01 g.

Damage to some portions of the site may occur but it should not afFect ability of safety functions to operate. Methods of detection can be based on instrumentation validated by a reliable source, operator assessment, or indication received from outside agencies. As de6ned in the EPRI-sponsored "Guidelines for Nuclear Plant Response to an Earthquake", dated October 1989, a "felt earthquake" is:

"An earthquake of sufFicient intensity such that: (a) the inventory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of Control Room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated. For most plants with seismic instrumentation, the seismic switches are set at an acceleration of about 0.01 g."

PEG

Reference:

HU1.1 Basis Reference(s):

1. SC-5 Earthquake Emergency Plan

2. EPRI document, "Guidelines for Nuclear Plant Response to an Earthquake", dated October 1989 8-15

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.4 Natural Events 8.4.2 Unusual Event Report by plant personnel of tornado within plant Protected Area boundary Mode Applicability:

Basis:

This EAL is based on the assumption that a tornado striking (touching down) within the Protected Area boundary may have potentially damaged plant structures containing functions or systems required for safe shutdown of the plant. Ifsuch damage is confirmed visually or by other in-plant indications, the event may be escalated to Alert.

PEG

Reference:

HU1.2 Basis Reference(s):

None 8-16

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.4 Natural Events 8.4.8 Unusual Event Assessment by Control Room personnel that a natural event has occurred precluding access to a plant vital area, Table 8.3 Table 8.3 Plant Vital Areas

~ Control Building

~ Reactor Containment Building

~ Auxiliary Building

~ Intermediate Building

~ Emergency Diesel Building

~ Standby Auxiliary Feedwater Building

~ Screen House Mode Applicability:

Basis:

This EAL allows for the Control Room to determine that an event has occurred and take appropriate action based on personal assessment as opposed to verification (i. e., an earthquake is felt but does not register on any plant-specific instrumentation, etc.).

PEG

Reference:

HU1.3 Basis Reference(s):

None 8-17

OSSI-92-402A-4-REG . Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.4 Natural Events

~

8.4.4 Unusual Event Deer Creek flooding over entrance road bridge OR

)

Lake level 252 ft OR Screen House Suction Bay water level < 16 ft Oow-low level alarm)

Mode Applicability:

Basis:

This covers high and low lake water level conditions that could be precursors of more serious events. Deer creek flooding over entrance road bridge may preclude emergency response personnel access and egress. Lake water level

) 252 ft. corresponds to plant design levels. Screen House Suction Bay level (

15 K corresponds to the low-low level alarm point and which requires load reduction below 50%.

PEG

Reference:

HU1.7 Basis Reference(s):

1. SC-4 High Water (Flood) Emergency Plan

2. SC-4.1 Low Screenhouse Water Level

3. InterofBce Memo" Screenhouse Pump Bay Water Level" dated V24/94 to Terry White from William Rapin and Jeffrey Wayland 8-18

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.4 Natural Events 8.4.5 Alert Earthquake felt inplant by any plant operations personnel AND Confirmation of earthquake of an intensity > 0.08 g per SC-5 "Earthquake Emergency Plan" Mode Applicability:

Basis:

This EAL addresses events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage.

This EAL is based on the FSAR design basis operating earthquake of 0.08 g.

Seismic events of this magnitude can cause damage to plant safety functions.

PEG

Reference:

HA1.1 Basis Reference(s):

1. SC-5 "Earthquake Emergency Plan" 8-19

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.4 Natural Events 8.4.6 Alert Sustained winds > 75 mph OR Tornado strikes a plant vital area, Table 8.3 Table 8.3 Plant Vital Areas Control Building

~ Reactor Containment Building

~ Auxiliary Building

~ Intermediate Building

~ Emergency Diesel Building

~ Standby Auxiliary Feedwater Building

~ Screen House Mode Applicability:

Basis:

This EAL addresses events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage.

This EAL is based on the FSAR assumed "severe environmental loading" condition of 75 mph. Wind loads of this magnitude can cause damage to safety functions.

PEG

Reference:

HA1.2 Basis Reference(s):

1. RGE FSAR Section 3.3.2.1.4 8-20

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 8.0 Hazards 8.4 Natural Events 8.4.7 Alert Assessment by the Control Room personnel that a natural event has resulted in damage to equipment needed for safe plant operation, Table 8.3 Table 8.3 Plant Vital Areas

~ Control Building

~ Reactor Containment Building

~ Auxiliary Building

~ Intermediate Building

~ Emergency Diesel Building

~ Standby AuxiliaryFeedwater Building

~ Screen House Mode Applicability:

Basis:

This EAL addresses events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage.

This EAL specifies areas in which structures containing systems and functions required for safe shutdown of the plant are located.

PEG

Reference:

HA1.3 Basis Reference(s):

None 8-21

OSSI-92-402A-4-REG Ginna EAL Technical Baees Document, Rev 0 8.0 Hazards 8.4 Natural Events 8.4.8 Alert Flood water accumulating on screen house operating floor OR Lake level > 253 ft OR

(

Screen House Suction Bay water level 13 ft Mode Applicability:

Basis:

This EAL addresses events that may have resulted in a plant vital area being subjected to levels beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage.

This EAL covers high and low lake water level conditions that exceed levels which threaten vital equipment. Flood water accumulating on the screen house operating floor or lake levels > 253 ft. corresponds to levels threatening vital equipment. Screen House Suction Bay level < 13 ft. corresponds to the level below which the motor driven firewater pump suction bowls are uncovered.

PEG

Reference:

HA1.7 Basis Reference(s):

1. SC-4 High Water (Flood) Emergency Plan

2. SC-4.1 Low Screenhouse Water Level

3. Interof6ce Memo" Screenhouse Pump Bay Water Level" dated V24/94 to Terry White from William Rapin and Jeffrey Wayland 8-22

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 The EALs defined in categories 1.0 through 8.0 specify the predetermined symptoms or events which are indicative of emergency or potential emergency conditions, and which warrant classification. While these EALs have been developed to address the full spectrum of possible emergency conditions which may warrant classification and subsequent implementation of the Emergency Plan, a provision for classification of emergencies based on operator/management experience and judgment is still necessary. The EALs of this category provide the Shift Supervisor or Emergency Coordinator the latitude to classify emergency conditions consistent with the established classification criteria, based upon their judgment.

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0

=9.0 Other Unusual Event

'.1.1 Any event, as determined by the Shift Supervisor or Emergency Coordinator, that could lead to or has led to a potential degradation of the level of safety of the plant.

Mode Applicability:

Basis:

This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the Unusual Event emergency class.

From a broad perspective, one area that may warrant Emergency Coordinator judgment is related to likely or actual breakdown of site specific event mitigating actions. Examples to consider include inadequate emergency response procedures, transient response either unexpected or not understood, failure or unavailability of emergency systems during an accident in excess of that assumed in accident analysis, or insufBcient availability of equipment and/or support personnel.

PEG

Reference:

HU5.1 Basis Reference(s):

None

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 9.0 Other 9.1.2 Unusual Event Any event, as determined by the Shift Supervisor or Emergency Coordinator, that could lead to or has led to a loss or potential loss of containment.

Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses any other factors that are to be used by the Emergency Coordinator in determining whether the containment barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this EAL as a factor in Emergency Coordinator judgment that the barrier may be considered lost or potentially lost. l PEG

Reference:

PCS.1 Basis Reference(s):

None

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 9.0 Other 9.1.3 Alert Any event, as determined by the Shift Supervisor or Emergency Coordinator, that could cause or has caused actual substantial degradation of the level of safety of the plant.

Mode Applicability:

Basis:

This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the Alert emergency class.

PEG

Reference:

HA6.1 Basis Reference(s):

None

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 9.0 Other 9.1.4 Alert Any event, as determined by the Shift Supervisor or Emergency Coordinator, that could lead or has led to a loss or potential loss of either fuel clad or RCS barrier.

Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses any other factors that are to be used by the Emergency Coordinator in determining whether the fuel clad or RCS barriers are lost or potentially lost. In addition, the inability to monitor the barriers should also be considered in this EAL as a factor in Emergency Coordinator judgment that the barriers may be considered lost or potentially lost.

PEG

Reference:

FC7.1 RCS6.1 Basis Reference(s):

None

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 9.0 Other 9.1.6 Site Area Emergency As determined by the Shift Supervisor or Emergency Coordinator, events are in progress which indicate actual or likely failures of plant systems needed to protect the public. Any releases are not expected to result in exposures which exceed EPA PAGs.

Mode Applicability:

Basis.

This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the emergency class description for Site Area Emergency.

PEG

Reference:

HS8.1 Basis Reference(s):

None

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 9.0 Other 9.1.6 Site Area Emergency Any event, as determined by the Shift Supervisor or Emergency Coordinator, that could lead or has led to either:

Loss or potential loss of both fuel clad and RCS barrier OR Loss or potential loss of either fuel clad or RCS barrier in conjunction with a loss of containment Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses unanticipated conditions affecting fission product barriers which are not addressed explicitly elsewhere. Declaration of an emergency is warranted because conditions exist which are believed by the Emergency Coordinator to fall under the emergency class description for Site Area Emergency.

PEG

Reference:

FC7.1 RCS6,1 PC8.1 Basis Reference(s):

None

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 9.0 Other 9.1.V General Emergency As determined by the Shift Supervisor or Emergency Coordinator, events are in progress which indicate actual or imminent core damage and the potential for a large release of radioactive material in excess of EPA PAGs outside the site boundary.

Mode Applicability:

Basis:

This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the General Emergency class.

Releases can reasonably be expected to exceed EPA PAG plume exposure levels outside the site boundary.

PEG

Reference:

HG2.1 Basis Reference(s):

None

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 9.0 Other 9.1.8 General Emergency Any event, as determined by the Shift Supervisor or Emergency Coordinator, that could lead or has led to a loss of any two fission product barriers and loss or potential loss of the third.

Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses unanticipated conditions affecting fission product barriers which are not addressed explicitly elsewhere, Declaration of an emergency is warranted because conditions exist which are believed by the Emergency Coordinator to fall under the emergency class description for the General Emergency class.

PEG

Reference:

FC7.1 RCS6.1 PC8.1 Basis Reference(s):

None

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 ATTA HIKE

%ORD LIST/DEFINITIONS

OSSI-92-402A-4-REG ~

Ginna EAL Technical Bases Document, Rev 0 Actuate To put into operation; to move to action; commonly used to refer to automated, multi-faceted operations. "Actuate ECCS".

Adversary As applied to security EALs, an individual whose intent is to commit sabotage, disrupt Station operations or otherwise commit a crime on station property.

Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Available The state or condition of being ready and able to be used (placed into operation) to accomplish the stated (or implied) action or function. As applied to a system, this requires the operability of necessary support systems (electrical power supplies, cooling water, lubrication, etc.).

Can/Cannot be determined (c/>)

The current value or status of an identified parameter relative to that specified can/cannot be ascertained using all available indications (direct and indirect, singly or in combination).

Can/Cannot be maintained above/below (c/>)

The value of the identified parameter(s) is/is not able to be kept above /below specified limits. This determination includes making an evaluation that considers both current and future system performance in relation to the current value and trend of the parameter(s). Neither implies that the parameter must actually exceed the limit before the action is taken nor that the action must be taken before the limit is reached.

A-2

OSSI-92<02A-4-REG Ginna EAL Technical Bases Document, Rev 0

,. Can/Cannot be restored above/below (c/>)

The value of the identified parameter(s) is/is not able to be returned to above/below specified limits after having passed those limits. This determination includes making an evaluation that considers both current and future systems performances in relation to the current value and trend of the parameter(s). Does not imply any specific time interval but does not permit prolonged operation beyond a limit without taking the specified action.

As applied to loss of electrical power sources (ex.: Power cannot be restored to any vital bus in 5 4 hrs) the specified power source cannot be returned to service within the specified time. This determination includes making an evaluation that considers both current and future restoration capabilities.

Implies that the declaration should be made as soon as the determination is made that the power source cannot be restored within the specified time.

Close To position a valve or damper so as to prevent flow of the process fluid.

To make an electrical connection to supply power.

Confirm / ConGrmation To validate, through visual observation or physical inspection, that an assumed condition is as expected or required, without taking action to alter the "as found" configuration.

Control Take action, as necessary, to maintain the value of a specified parameter within applicable limits; to fix or adjust the time, amount, or rate of; to regulate or restrict.

Decrease To become progressively less in size, amount, number, or intensity.

Discharge Removal of a fluid/gas from a volume or system.

A-3

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Enter To go into.

Establish To perform actions necessary to meet a stated condition. "Establish communication with the Control Room."

Evacuate To remove the contents of; to remove personnel from an area.

Exceeds To go or be'beyond a stated or implied limit, measure, or degree.

Exist To have being with respect to understood limitations or conditions.

Failure A state of inability to perform a normal function.

General Emergency Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

If I

Logic term which indicates that taking the action prescribed is contingent upon the current existence of the stated condition(s). Ifthe identified conditions do not exist, the prescribed action is not to be taken and execution of operator actions must proceed promptly in accordance with subsequent instructions.

A-4

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Increase To become progressively greater in size, amount, number or intensity.

Indicate To point out or point to; to display the value of a process variable; to be a sign or symbol.

Initiate The act of placing equipment or a system into service, either manually or automatically, Activation of a function or protective feature (i.e. initiate a manual trip).

Iajection The act of forcing a fluid into a volume or vessel.

Inoperable Not able to perform it's intended function Intrusion The act of entering without authorization Failure of operability or lack of access to.

Maintain Take action, as necessary, to keep the value of the specified parameter within the applicable limits.

Monitor Observe and evaluate at a frequency sufBcient to remain apprised of the value, trend, and rate of change of the specified parameter.

A-5

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Notify To give notice of or report the occurrence of; to.make known to; to inform specifled personnel; to advise; to communicate; to contact; to relay.

Open To position a valve or damper so as to allow Qow of the process Quid.

To break an electrical connection which removes a power supply from an electrical device.

To make available for entry or passage by turning back, removing, or clearing away.

Operable Able to perform it's intended function Perform To carry outan action; to accomplish; to afFect; toreachanobjective.

Primary System The pipes, valves, and other equipment which connect directly to the reactor vessel or reactor coolant system such that a reduction in reactor coolant system pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system.

Remove To change the location or position of.

Report To describe as being in a specific state.

Require To demand as necessary or essential.

A-6

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0

~

Take the appropriate action requires to return the value of an identified parameter to within applicable limits.

Rise Describes an increase in a parameter as the result of an operator or automatic action.

Sample To perform an analysis on a specified media to determine its properties.

Shut down To perform operations necessary to cause equipment to cease or suspend operation; to stop. "Shut down unnecessary equipment."

Site Area Emergency Events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels except near the site boundary.

Sustained Prolonged. Not intermittent or of transitory nature Trip To de-energize a pump or fan motor; to position a breaker so as to interrupt or prevent the flow of current in the associated circuit; to manually activate a semi-automatic feature.

To take action to cause shutdown of the reactor by rapidly inserting a control rod or control rods (PWR).

A-7

OSSI-92-402A-4-REG Ginna EAL Technical Bases Document, Rev 0 Uncontrolled An evolution lacking control but is not the result of operator action.

Unplanned Not as an expected result of deliberate action.

Until Indicates that the associated prescribed action is to proceed only so long as the identified condition does not exist.

Unusual Event Events are in process or have occurred which indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Valid Supported or corroborated on a sound basis.

Vent To open an effluent (exhaust) flowpath from an enclosed volume; to reduce pressure in an enclosed volume.

Verify To confirm a condition and take action to establish that condition ifrequired.

"Verifyreactor trip, verify SI pumps running."

A-8

R. E. Ginna Emergency Action Levels Category 1.0 CSFST Status Category 2.0 Reactor Fuel Category 3.0 Reactor Coolant System Category 4.0 Containment Category 5.0 Radioactivity Release Category 6.0 Elecrtical Failures Category 7.0 Equipment Failures Category 8.0 Hazards Category 9.0 Other 3/23/94

Category 1.0 CSFST Status 1.0 CSFST Status 1.0 CSFST Status 1.1 Subcriticality 12 Core Cooling 1.1.1 Alert 1.2.1 Site Area Emergency ORANGE or RED path F-0.1 SUBCRITICALITY ORANGE or RED path in F-0.2, CORE COOLING AND Emergency boration is required Power Operations, Hot Shutdown Power Operations, Hot Shutdown 1.2.2 General Emergency 1.1.2 Site Area Emergency RED path in F-0.2, CORE COOLING AND RED path in F-0.1 SUBCRITICALITY Functional restoration procedures not effective within AND either: 15 min.

Emergency boration is inoperable OR Power Operations, Hot Shutdown Power range not < 6% within 15 min. of initiation of emergency boration Power Operations, Hot Shutdown 1-2

Category 1.0 CSFST Status 1.0 CSFST Status 1.0 CSFST Status 18 Heat Sink 1.4 Integrity 1.8.1 Site Area Emergency 1.4.1 Alert RED path in F-0.3, HEAT SINK RED path on F-0.4, INTEGRITY Power Operations, Hot Shutdown Power Operations, Hot Shutdown 1.8.2 General Emergency RED path in F-0.3, HEAT SINK AND RED path in F-0.1, SUBCRITICALITY Power Operations 1-3

Category 1.0 CSFST Status 1.0 CSFST Status 1.5 Containment 1.6.1 General Emergency RED path F-0.5, CONTAINiMENT

.Power Operations, Hot Shutdown 1-4

Category 2.0 Reactor Fuel 2.0 Reactor Fuel 2.0 Reactor Fuel 2.1 Coolant Activity 2.2 Failed Fuel Detectors 2.1.1 Unusual Event 2.2.1 Unusual Event Coolant sample activity: Letdown Line Monitor R-9 > 2 R/hr

>100% of 84/E bar pCi/cc total specific activity OR

> 02 pCi/cc I-131 equivalent and the conditions of Technical Specifications 3.1.4.3.b are exceeded 2.2.2 Alert Letdown Line Monitor R-9 ) 10 8/hr 2.1.2 Alert Power operation, hot shutdown Coolant activity > 300 pCi/cc I-131 equivalent 2.2.3 Site Area Emergency Power operation, hot shutdown Letdown Line Monitor R-9 > 10 R/hr and any of the following:

~ RED path on F-0.4, INTEGRITY

~ Primary system leakage > 46 gym

~ RCS subcooling < EOP Fig. MIN SUBCOOLING Power operation, hot shutdown 2-1

Category 2.0 Reactor Fuel 2.0 Reactor Fuel 2.0 Reactor Fuel 2.3 Containment Radiation 2.4 Refu'cling Accidents or Other Radiation Monitors 2.3.1 Alert 2.4.1 Unusual Event Containment radiation monitor R-29/R-30 reading > 10 Rlhr Spent fuel pool (reactor cavity during refueling) water level cannot be restored and maintained above the Power operation, hot shutdown spent fuel pool low water level alarm setpoint 2.3.2 Site Area Emergency Containment radiation monitor R-29/R-30 reading > 2.4.2 Alert 100 R/hr Confirmed sustained alarm on any of the following Power operation, hot shutdown radiation monitors resulting from an uncontrolled fuel handling process:

~ R-2 Containment Area Monitor 2.3.3 General Emergency ~ R-5 Spent Fuel Pit

~ R-12 Containment Noble Gas Containment radiation monitor R-29/R-30 reading >

1000 R/hr All Power operation, hot shutdown 2.4.3 Alert Report of visual observation of irradiated fuel uncovered 2-2

Category 3.0 Reactor Coolant System 3.0 Reactor Coolant System 3.0 Reactor Coolant System 8.1 RCS Leakage 3.2 Primary to Secondary Leakage 8.1.1 Unusual Event 8.2.1 Unusual Event Unidentified or pressure boundary leakage > 10 gpm Release of secondary side to atmosphere with primary OR to secondary leakage > 0.1 gpm per steam generator Identified leakage > 26 gpm Power operation, hot shutdown Power operation, hot shutdown 3.2.2 Site Area Emergency 3.1.2 Alert Unisolable release of secondary side to atmosphere Primary system leakage > 46 gpm with primary to secondary leakage > 46 gym Power operation, hot shutdown Power operation, hot shutdown 8.1.3 Site Area Emergency RVLIS cannot be maintained > 43% with no RCPs running OR With the reactor vessel head removed, it is reported that water level in the reactor vessel is dropping in an uncontrolled manner and core uncovery is likely 3-1

Category 8.0 Reactor Coolant System 8.0 Reactor Coolant System 8.3 RCS Subcooling 3.3.1 Alert RCS subcooling < EOP Fig. MIN SUBCOOLING Power operation, hot shutdown 3-2

Category 4.0 Containment 4.0 Containment 4.0 Containxnent 4.1 Containment Integrity Status 4.1 Containment Integrity Status 4.1.1 Unusual Event 4.1.3 Site Area Emergency Both doors open on containment airlock Either:

OR CI or CVI valve(s) not closed when required

.Inability to close containment pressure relief or purge following confirmed LOCA valves which results in a radiological release pathway OR to the environment Inability to isolate any primary system discharging outside containment Poujer operation, hot shutdown AND Radiological release pathway to the environment exists 4.12 Site Area Emergency Poujer operation, hot shutdown Rapid uncontrolled decrease in containment pressure following initial increase OR 4.1.4 General Emergency Loss of primary coolant inside containment with containment pressure or sump level response not Safety injection signal due to LOCA with less than consistent with LOCA conditions minimum operable containment heat removal equipment, Table 4.3 Poujer operation, hot shutdown AND Any indicators of fuel clad loss, Table 4.1 Power operation, hot shutdown 4-1

Category 4.0 Containment 4.0 Containment 4.0 Containment 4.1 Containment Integrity Status 4.2 SG Tube Rupture w/ Secondary Release 4.1.5 General Emergency 4.2.1 Site Area Emergency Either: Unisolable secondary side line break with SG tube Rapid uncontrolled decrease in containment rupture as identified in E-3 "Steam Generator Tube pressure following initial increase Rupture" OR Loss of primary coolant inside containment with Power operation, hot shutdown containment pressure or sump level response not consistent with LOCA conditions AND 4.2.2 General Emergency Any indicators of fuel clad damage, Table 4.2 Release of secondary side to atmosphere with primary Power operation, hot shutdown to secondary leakage > 0.1 gpm per steam generator AND Any indicators of fuel clad damage, Table 4.2 4.1.6 General Emergency Power operation, hot shutdown Either:

CI or CVI valve(s) not closed when required following confirmed LOCA OR Inability to isolate any primary system discharging outside containment AND Radiological release pathway to the environment exists AND Any indicators of fuel clad damage, Table 4.2 Power operation, hot shutdown

Category 4.0 Containment Table 4.3 Minimum Operable Containment Heat 4.0 Containment RemovalE ui ment 4.3 Combustible Gas Concentrations CNMT Pressure Recirc Fans Operable Spray Pumps Re uired 4.3.1 General Emergency

<28 psig N/A

> 4% hydrogen concentration in containment Power operation, hot shutdown >%8 psig Table 4.1 Fuel Clad Loss Indicators

1. Coolant activity > 300 pCi/cc of I-131

2. Containment rad monitor R-29/R-30 reading

>100 R/hr

3. Letdown Monitor R-9 reading > 10 R/hr Table 4.2 Fuel Clad Dama e Indicators

~ ORANGE or RED path in F-0.2, CORE COOLING

~ RED path in F-0.3, HEAT SINK

~ Coolant activity > 300 pCi/cc of I-131

~ Containment rad monitor R-29/R-30 reading

>100 R/hr

~ Letdown Monitor R-9 reading > 10 R/hr 4-3

Category 6.0 Radioactivity Release 6.0 Radioactivity Release / Area Radiation 6.0 Radioactivity Release /Area Radiation 6.1 EfQuent Monitors 6.2 Dose Projections/ Environmental Measurements/ Release Rates 6.1.1 Unusual Event 5.2.1 Unusual Event A valid reading on any monitors Table 5.1 column "NUE" for > 60 min. Confirmed sample analyses for gaseous or liquid release rates > 2 x technical specifications limits for >

60 min.

6.12 Alert A valid reading on any monitors Table 5.1 column 5.2.2 Alert "Alert" for > 15 min.

Confirmed sample analyses for gaseous or liquid release rates > 200 x technical specifications limits for

> 15 min.

6.1.3 Site Area Emergency

~

A valid reading on any monitors Table 5.1 column "SAE" for > 15 min. 5.2.3 Alert Dose projections or field surveys which indicate doses /

dose rates > Table 5.2 column "Alert" at the site boundary or beyond.

5.1.4 General Emergency All A valid reading on any monitors Table 5.1 column "GE" for > 15 min.

All 5-1

Category 6.0 Radioactivity Release 6.0 Radioactivity Release / Area Radiation 6.0 Radioactivity Release / Area Radiation 6.2 Dose Projections/ Environmental 5.8 Area Radiation Levels Measurements/ Release Rates 6.3.1 Unusual Event 6.2.4 Site Area Emergency Any sustained direct ARM readings > 100 x alarm or Dose projections or field surveys which indicate doses / offscale hi resulting from an uncontrolled process dose rates > Table 5.2 column "SAE" at the site boundary or beyond. All 5.8.2 Alert 6.2.5 General Emergency Sustained area radiation levels > 16 mR/hr in either:

Control Room Dose projections or field surveys which indicate doses / OR dose rates > Table 5.2 column "GE" at the site Central Alarm Station and Secondary Alarm boundary or beyond. Station 5.8.3 Alert Sustained abnormal area radiation levels > 8 R/hr within any areas, Table 5.3 AND Access is required for safe operation or shutdown All 5-2

Category 5.0 Radioactivity Release Table 5.1 EfHuent Monitor Classification Thresholds Monitor R-11 1.62E6 cpm N/A N/A N/A R-12 V.SOE6 cpm 1.07E7 cpm N/A N/A R-13 2.20E4 cpm N/A N/A N/A R-14 6.40E5 cpm 1.61E6 cpm N/A N/A R-15 4.00E5 cpm 2.31EV cpm N/A N/A R-18 3.60E5 cpm oFscale hi N/A N/A R-12A(7/9) N/A N/A 6.00 pCi/cc 60.00 pCi/cc R-14 A(7/9) N/A N/A 5.33E-1 pCi/cc 5.33 pCi/cc R-15A(7/9) N/A N/A 11.50 pCi/cc 115.00 pCi/cc Table 5.2 Dose Pro ection/Env. Measurement Classification Thresholds GE TEDE 10 mR 100 mR 1000 mR CDE Thyroid N/A 500 mR 5000 mR TEDE rate 10 mR/hr 100 mR/hr 1000 mR/hr CDE Thyroid rate N/A 500 mH/hr 5000 mR/hr 5-3

Category 6.0 Electrical Failures 6.0 Electrical Failures 6.0 Electrical Failures 6.1 Loss of AC Power Sources 6.1 Loss of AC Power Sources 6.1.1 Unusual Event 6.1.4 Site Area Emergency Loss of ability to supply power to the safeguard buses Loss of all safeguards bus AC power for > 15 min.

from offsite circuits 751 and 767 for > 15 min.

Power operation, hot shutdown 6.1.5 General Emergency 6.12 Alert Loss of all safeguards bus AC power Loss of all safeguards bus AC power for > 15 min. AND either:

Power cannot be restored to any safeguards bus in Cold Shutdown, Refueling, Defueled <4 hrs OR ORANGE or RED path on F-0.2, "CORE 6.1.3 Alert COOLING" Available safeguard train AC power reduced to only Power operation, hot shutdown one of the following for > 15 min.:

~ EDG 1A (14/18)

~ EDG 1B (16/17)

~ Station AuxiliaryTransformer 12A

~ Station AuxiliaryTransformer 12B Power operation, hot shutdown

Category 6.0 Electrical Failures 6.0 Electrical Failures 6.2 Loss of DC Power Sources 6.2.1 Unusual Event

< 106 vdc bus voltage indications on 125 vdc batteries 1A and 1B for > 15 min.

Cold Shutdown, Refueling 6.2.2 Site Area Emergency

> 106 vdc bus voltage indications on 125 vdc batteries 1A and 1B for > 15 min.

Power operation, hot shutdown

Category V.O Equipment Failures V.O Equipment Failures 7.0 Equipment Failures V.1 Technical Speci6cationXRequirements 7.2 System Failures or Control Room Evacuation V.1.1 Unusual Event 7.2.1 Unusual Event Plant is not brought to required operating mode within Technical Specifications LCO Action Statement Time. Report of main turbine failure resulting in casing penetration or damage to turbine seals or generator Power operation, hot shutdown seals.

Power Operations 7.2.2 Alert Turbine failure generated missiles result in any visible structural damage to plant vital equipment Power Operat'ions, Hot Shutdown 7.2.3 Alert Control Room evacuation All V.2.4 Alert Reactor coolant temperature cannot be maintained <

200 'F Cold Shutdown, Refueling 7-1

Category 7.0 Equipment Failures V.O Equipment Failures V.O Equipment Failures 7.2 System Failures or Control Room V.3 Loss of Indications /Alarms /

Evacuation Communication Capability V.2.5 Site Area Emergency 7.3.1 Unusual Event Control Room evacuation Unplanned loss of annunciators or indications on any AND Control Room Panels, Table 7.3 for > 15 min.

Core cooling cannot be established per AP-CR.1 AND "Control Room Inaccessibility" in < 20 min. Increased surveillance is required for safe plant operation Power operation, hot shutdown V.3.2 Unusual Event Loss of all communications capability affecting the ability to either:

Perform routine operations OR Notify offsite agencies or personnel 7-2

Category V.O Equipment Failures 7.0 Equipment Failures 7.3 Loss of Indications /Alarms /

Communication Capability Table 7.3 Vital Control Room Panels V.8.8 Alert B C D E F 0 Unplanned loss of annunciators or indications on any

.Control Room Panels, Table 7.3 for > 15 min.

AND Increased surveillance is required for safe plant operation AND either:

A plant transient in progress OR PPCS and SAS are unavailable Power operation, hot shutdown 7.3.4 Site Area Emergency Loss of annunciators or indications on any Control Room Panels, Table 7.3 AND Complete loss of ability to monitor all critical safety function status AND A plant transient in progress Power operation, hot shutdown

Category 8.0 Hazards 8.0 Hazards 8.0 Hazards 8.1 Security Threats 8.2 Fire or Explosion 8.1.1 Unusual Event 8.2.1 Unusual Event Bomb device or other indication of attempted sabotage Confirmed fire in any plant area, Table 8.2 or Table discovered within plant Protected Area. 8.3 not extinguished in < 15 min. of Control Room notification:

8.1.2 Alert 8.2.2 Alert Intrusion into plant Protected Area by an adversary.

Fire or explosion in any plant area, Table 8.2 or 8.3 which results in damage to plant equipment or structures needed for safe plant operation 8.1.3 Site Area Emergency All Intrusion into a plant security vital area by an adversary.

8.1.4 General Emergency Security event which results in:

Loss of plant control from the Control-Room AND Loss of remote shutdown capability

Category 8.0 Hazards 8.0 Hazards 8.0 Hazards 8.3 Man-Made Events 8.3 Man-Made Events 8.3.1 Unusual Event 8.3.4 Alert Vehicle crash into or projectile which impacts plant Vehicle crash or projectile impact which precludes structures or systems within Protected Area boundary personnel access to or damages equipment in plant vital areas, Table 8.3 8.3.2 Unusual Event 8.3.5 Alert Report by plant personnel of an explosion within Protected Area boundary resulting in visible damage Report or detection of toxic or flammable gases within to permanent structures or equipment a plant area, Table 8.3, in concentrations that will be life threatening to plant personnel or preclude access to equipment needed for safe plant operation 8.3.3 Unusual Event Report or detection of toxic or flammable gases that could enter or have entered within the Protected Area boundary in amounts that could affect the health of plant personnel or safe plant operation OR Report by local, county or state officials for potential evacuation of site personnel based on offsite event 8-2

4 Category 8.0 Hazards 8.0 Hazards 8.0 Hazards 8.4 Natural Events 8.4 Natural Events 8.4.1 Unusual Event 8.4.4 Unusual Event Earthquake felt inplant by any operator Deer Creek flooding over entrance road bridge AND OR Confirmation of earthquake of an intensity ) 0.01 g Lake level ) 262 f't per SC-5 "Earthquake Emergency Plan". OR Screen House Suction Bay water level < 16 ft (low-low level alarm)

All 8.4.2 Unusual Event Report by plant personnel of tornado within plant 8.4.6 Alert Protected Area boundary Earthquake felt inplant by any plant operations personnel AND Confirmation of earthquake of an intensity > 0.08 g 8.4.3 Unusual Event per SC-5 "Earthquake Emergency Plan" Assessment by Control Room personnel that a natural All event has occurred precluding access to a plant vital area, Table 8.3 8.4.6 Alert Sustained winds ) 75 mph OR Tornado strikes a plant vital area, Table 8.3 All 8-3

Category 8.0 Hazards 8.0 Hazards Table 8.2 Plant Areas 8.4 Natural Events ~ Turbine Building 8.4.7 Alert

~ TSC Service Building Assessment by the Control Room personnel that a

~ Contaminated Storage Building natural event has resulted in damage to equipment needed for safe plant operation, Table 8.3 Table 8.3 Plant Vital Areas

~ Control Building

~ Reactor Containment Building 8.4.8 Alert ~ AuxiliaryBuilding

~ Intermediate Building Flood water accumulating on screen house operating ~ Emergency Diesel Building floor ~ Standby Auxiliary Feedwater Building OR ~ Screen House Lake level > 253 ft OR Screen House Suction Bay water level < 13 ft 8-4

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Category 9.0 Other 9.0 Other 9.0 Other 9.1.1 Unusual Event 9.1.4 Alert Any event, as determined by the Shift Supervisor or Any event, as determined by the Shik Supervisor Emergency Coordinator, that could lead to or has led Coordinator, that could lead or has led to a or'mergency to a potential degradation of the level of safety of the loss or potential loss of either fuel clad or RCS barrier.

plant.

Power operation, hot shutdown 9.1.5 Site Area Emergency 9.12 Unusual Event As determined by the Shift Supervisor or Emergency Any event, as determined by the Shik Supervisor or Coordinator, events are in progress which indicate Emergency Coordinator, that could lead to or has led actual or likely failures of plant systems needed to to a loss or potential loss of containment. protect the public. Any releases are not expected to result in exposures which exceed EPA PAGs.

Power operation, hot shutdown 9.1.3 Alert 9.1.6 Site Area Emergency Any event, as determined by the Shift Supervisor or Emergency Coordinator, that could cause or has Any event, as determined by the Shift Supervisor or caused actual substantial degradation of the level of Emergency Coordinator, that could lead or has led to safety of the plant. either:

Loss or potential loss of both fuel clad and RCS barrier OR Loss or potential loss of either fuel clad or RCS barrier in conjunction with a loss of containment Power operation, hot shutdown

Category 9.0 Other 9.0 Other 9.1.7 General Emergency As determined by the Shik Supervisor or Emergency Coordinator, events are in progress which indicate actual or imminent core damage and the potential for a large release of radioactive material in excess of EPA PAGs outside the site boundary.

9.1.8 General Emergency Any event, as determined by the Shik Supervisor or Emergency Coordinator, that could lead or has led to a loss of any two fission product barriers and loss or potential loss of the third.

Power operation, hot shutdown

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