ML18283A775

Attachments 1 & 2: Summary of Changes to ANO Emergency Plan Implementing Document and Procedure OP-1903.010, Rev. 57, Emergency Action Level Classification

ML18283A775
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Site:	Arkansas Nuclear
Issue date:	10/04/2018
From:	Entergy Operations
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
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ML18283A773	List: 0CAN101801, Submittal of Emergency Plan Implementing Procedure OP-1903.010, Rev. 57 ML18283A775
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0CAN101801
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ATTACHMENT 1 TO 0CAN101801

SUMMARY

OF CHANGES TO ANO EMERGENCY PLAN IMPLEMENTING DOCUMENT to 0CAN101801 Page 1 of 3

SUMMARY

OF CHANGES TO ANO EMERGENCY PLAN IMPLEMENTING DOCUMENT The following table provides a brief description or summary of changes made to an Arkansas Nuclear One (ANO) Emergency Plan implementing document included in Attachment 2 of this submittal.

Procedure OP-1903.010, Revision 57, Emergency Action Level Classification Section Revised Description of Change Where referenced, removed reference to the Post Accident Sampling System (PASS)

Super Particulate Iodine and Noble Gas (SPING) monitor (2RX-9840) and the Low Level Radwaste (LLRW) Building SPING monitor (2RX-9850), including indicated readings.

In 2000, an amendment to the ANO-1 and ANO-2 Technical Specifications approved elimination of the PASS. The PASS was subsequently abandoned in place with all sources of Reactor Coolant System and containment system sample lines being isolated from the plant systems. Isolation of the PASS has eliminated any source of radioactive material from entering the PASS building. Therefore, the continuous monitoring of the PASS building effluent is no longer required. The primary function of the SPING is to monitor the vent effluent, actuate alarms within the Control Room when predetermined release limits are met, and to be a source of release data when performing dose assessment. With the elimination of any source term from the PASS building, the utilization of an effluent monitor is no longer needed for this pathway.

The ANO-2 Safety Analysis Report (SAR), Section 11.5.6.1, states that the calculated dose rates and radioactive energies conservatively assumed the High Specific Activity Waste area of the LLRW Building is full of resin containers. The Curie content was calculated using the isotopic content in order to determine expected dose rates. An estimation of facility dose rates is provided in SAR Figure 12.1-13 for informational purposes. The total estimated Curie content in the facility is 1.96E3 Ci. The dose rate at the Exclusion Area Boundary (EAB) per Curie of stored material is estimated at 8.8E-10 mR/hr per Curie. Thus if all contents of the building were released to the environment simultaneously, the resulting EAB dose rate would be 1.72E-6 mR/hr, much AU-1, AA-1, AS-1, AG-1, less than an approximate 1.14E-1 mR/hr value for 2 times the Offsite Dose Calculation CNB6 (Pages 24, 25, 41, Manual (ODCM) limit. The ANO-2 SAR also states in the same section that "The only 74, 76, 80, 86, 88, 128) potential release of radioactivity would occur during compacting operations; however, this process is not currently used. There are no plans to ever use the compaction system.

Radiation Protection performs a Category 1 and 2 inventory of the LLRW Building radioactivity once per week to ensure associated information contained in the SAR remains valid. The inventory is performed in accordance with procedure EN-RP-121, "Radioactive Material Control". ANO-2 SAR, Table 11.5-1, lists the radioactive isotope inventory of the LLRW Building based on capacity. This table shows that the majority of the isotopes are particulates with one iodine isotope (I-129) and no gaseous activity other than H-3 (tritium).

The most probable event for a significant release would be fire in the building which would most likely bypass the monitoring system. With the radioisotope content consisting of particulate isotopes, the use of a gas channel set point would not be the ideal detector for monitoring the pathway. The pathway is sampled on a weekly basis for particulate, iodine, and noble gases. The removal of the LLRW SPING set points is acceptable because the potential for a release requiring an emergency declaration cannot be exceeded based on the radio-isotopic makeup of the contents of the building.

The elimination of the PASS and LLRW Building SPINGs continue to meet the NEI 99-01, Methodology for Development of Emergency Action Levels, Revision 5, guidance because these areas do not constitute release pathways (either routine or non-routine) relevant to the EAL condition. These changes do not eliminate an Initiating Condition or EAL, but eliminate two thresholds that are not potential sources of a relevant offsite radiological release.

to 0CAN101801 Page 2 of 3 Procedure OP-1903.010, Revision 57, Emergency Action Level Classification Section Revised Description of Change Where referenced, deleted and/or replaced reference to ANO-2 SPING Channels 7 and 9 to reference the SPING gas channel.

The existing Eberline SPING radiation monitoring systems are being replaced with new equivalent models provided by Mirion Technologies. The Eberline SPING monitoring system is an obsolete system that is no longer supported by the vendor. The Mirion Technology replacements monitors are Regulatory Guide (RG) 1.97, Revision 3, compliant.

The replacement high range monitor is similar to the Eberline SPING in that the replacement high range gas detector high range limit is the same as the high range detector of the Eberline SPING (1E5 µCi/cc). The overall gas activity range for the combination of the Eberline low range monitor and the high range monitor is 1E-7 µCi/cc to 1E5 µCi/cc with the low range being 1E-7 µCi/cc to 1E-1 µCi/cc and the high range monitor being 1E-4 µCi/cc to 1E5 µCi/cc. The replacement high range monitor does not have a detector for the iodine or particulate channel as does the Eberline SPING. This requires obtaining iodine and particulate samples from the inline sample assemblies to determine actual iodine and particulate µCi/cc data.

For dose assessment purposes, the current practice is to input the iodine and particulate AU-1, AA-1, AA-2, AS-1, channel data into the dose assessment software if the data is available. With the AG-1 (Pages 24, 25, 26, implementation of the replacement SPINGS, the iodine and particulate channel are not 76, 80, 81, 83, 86, 88) available on the high range monitor and, therefore, this data is not available via a detector. To complete the dose projection without these channels, the input to the dose assessment software consists of only the gas channel data and the use of a standard source term for the current core/plant conditions for the remainder of the isotopes. This is a current option in the dose assessment software. To maintain the accuracy of dose assessment, procedures are in place for the Emergency Response Organization staff to determine the core status and to communicate this data to the Dose Assessor for determination of the appropriate source term. Therefore, the use of the standard source term will not affect the projections of the dose assessment software. The high range monitor does contain an iodine and particulate sample apparatus that permits sampling of the effluent stream and radio-isotopic analysis for verification of the dose assessment inputs as does the current SPINGs.

The Emergency Plan does not specify that an iodine and particulate online monitoring system is required for dose assessment. RG 1.97 specifies in Table 2, Note 12, that grab sample capability, associated with personnel protection conditions, is required for iodine and particulate along with analysis capability. Both the low range monitor and high range monitor have the capability to sample iodine and particulates in a sample assembly. Therefore, the replacement system continues to meet the criteria for the EALs and the determination of all Emergency Classes.

Added reference to the ANO-1 Emergency Penetration Room Ventilation SPING monitor (RX-9835).

AU-1, AA-1 (Pages 75, 76,

81) This change aligns the procedure with correct equipment designation, including the addition of equipment that was listed in other sections of the procedure. This change does not add new equipment. This change does not change the intent of the EAL.

Change Regenerative Waste Discharge Monitor System reference to LRW Discharge Monitor and changed procedure title from Eberline Radiation Monitoring System to AU-1, AA-1, AS-1, AG-1 Ventilation Radiation Monitoring System.

(Pages 76, 77, 81, 82, 87,

88) This change aligns the procedure with correct equipment designation. This change does not add new equipment or remove/replace old equipment, but only corrects nomenclature. This change does not change the intent of the EAL.

to 0CAN101801 Page 3 of 3 Procedure OP-1903.010, Revision 57, Emergency Action Level Classification Section Revised Description of Change Administrative / human factor changes:

Corrected nomenclature of process radiation monitors from RX to RE in AU-1 and AA-1 Changed MR/hr to mR/hr in FCB1 Added > sign after Containment pressure in CNB1, 3.a (ANO-2).

Added (8.6 psig) to CNB1 Pages 25, 38, 112, 126, Changed Control Room and open release path to Control Room with an open 180 release path in CNB4 basis Replaced through with into and added alone in CNB4 basis Updated Wall Charts to accommodate the Revision 57 changes.

The above changes are associated with the display of engineering units or component nomenclature, a reference to the psig equivalent of the stated psia indication, enhancing/clarifying limits and wording, and updating the Wall Charts consistent with the changes made in Revision 57 of the procedure. The changes do not result in a change to the current application of the affected EALs.

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

CNB4 Basis (Page 126) Also added The subsequent leak of the interfacing liquid system to the environment would constitute a direct release.

These changes provide clarification to permit the user to better understand/interpret a "direct path" release. These changes do not change the intent of the EAL.

Bases for Acceptability of Changes The described changes do not change a meaning or the intent of a description, do not change emergency response facilities or equipment, and do not change a process. The above changes have been screened and/or evaluated in accordance with 10 CFR 50.54(q). The changes continue to meet the applicable planning standards outlined in 10 CFR 50.47(b)(4), 10 CFR 50.47(b)(8), and 10 CFR 50.47(b)(9). This revision does not require a change to the Emergency Plan or represent a reduction in the effectiveness to the Emergency Plan.

List of Acronyms LRW Liquid Radwaste

ATTACHMENT 2 TO 0CAN101801 OP-1903.010, REVISION 57 EMERGENCY ACTION LEVEL CLASSIFICATION

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 1 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 TABLE OF CONTENTS SECTIONS PAGE NO.

1.0 Purpose ...................................................... 2 2.0 Scope ........................................................ 2 3.0 References ................................................... 2 4.0 Definitions .................................................. 4 5.0 Responsibility and Authority ................................. 12 6.0 Instructions ................................................. 13 7.0 Attachments / Tabs and Forms ................................. 17 7.1 Attachment 1 - Index of Emergency Action Levels ....... 19 7.1.1 Tab A Abnormal Radiation Levels / Radiological Effluents ............................... 23 7.1.2 Tab C Cold Shutdown / Refueling System Malfunction ............................. 28 7.1.3 Tab E Independent Spent Fuel Storage Installation (ISFSI) Malfunction ........ 35 7.1.4 Tab F Fission Product Barrier Degradation ..... 37 7.1.5 Tab H Hazards and Other Conditions Affecting Plant Safety ............................ 42 7.1.6 Tab S System Malfunction ...................... 55 7.2 Attachment 2 - ANO EAL Basis Document ................. 64 7.3 Attachment 3 - EAL Matrix Chart ....................... 179

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 2 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 1.0 PURPOSE This procedure establishes criteria for detection and classification of plant events into the four standard Emergency Classes.

2.0 SCOPE This procedure is applicable to Units 1 and 2 in all modes; it does not include specific plant casualty procedures or systems operations requirements, but rather provides administrative processes only.

3.1 REFERENCES

USED IN PROCEDURE PREPARATION:

3.1.1 ANO Emergency Plan 3.1.2 NUREG-0654/FEMA-REP-1, Rev. 1 3.1.3 10 CFR 50 3.1.4 NRC Branch Position on Acceptable Deviations to Appendix 1 to NUREG-0654/FEMA-REP-1, July 11, 1994 3.1.5 NEI 99 Methodology for Development of Emergency Action Levels 3.1.6 NEI Industry White Paper - Enhancements to Emergency Preparedness Programs for Hostile Action, dated November 18, 2005 3.1.7 NRC Bulletin 2005-02, Emergency Preparedness and Response Actions for Security-Based Events 3.1.8 NRC Information Notice No. 97-45, Supp. 1 - Environmental Qualification Deficiency for Cables and Containment Penetration Pigtails 3.2 References Used in Conjunction with this Procedure:

3.2.1 EN-LI-102, Corrective Action Process 3.2.2 1903.011, "Emergency Response/Notifications" 3.2.3 1903.064, "Emergency Response Facility - Control Room" 3.2.4 1903.081, "Technical Support Center (TSC) Activation" 3.2.5 1903.082, "Operational Support Center (OSC) Activation" 3.2.6 1903.080, "Emergency Operations Facility (EOF) Activation" 3.2.7 1203.025, "Natural Emergencies" 3.2.8 2203.008, "Natural Emergencies"

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 3 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 3.2.9 1202.XXX, "Emergency Operating Procedures" 3.2.10 2202.XXX, "Emergency Operating Procedures" 3.2.11 1404.052, "Post Earthquake Seismic Data Retrieval" 3.2.12 1904.002, "Offsite Dose Projections" 3.2.13 NRC Position Paper on "Timeliness of Classification of Emergency Conditions" dated August 17, 1995 3.2.14 1607.001, "Reactor Coolant System Sampling" 3.2.15 2607.001, "Unit 2 Reactor Coolant System Sampling" 3.2.16 1203.048, Security Event 3.2.17 1903.069, Equipment Important to Emergency Preparedness 3.2.18 EN-EP-609, Emergency Operations Facility (EOF) Operations 3.2.19 EN-EP-610, Technical Support Center (TSC) Operations 3.2.20 EN-EP-611, Operations Support Center (OSC) Operations 3.3 Related ANO Procedures:

3.3.1 1043.042, "Response to Security Contingencies" 3.3.2 1502.004, Attachment H 3.3.3 1903.023, "Personnel Emergency" 3.3.4 ANO Security Plan/Security Procedures 3.3.5 1015.007, "Fire Brigade Organization and Responsibilities" 3.3.6 1903.042, "Duties of the Emergency Medical Team" 3.3.7 1903.043, "Duties of the Emergency Radiation Team" 3.3.8 1302.022, "Core Damage Assessment" 3.4 Regulatory correspondence containing NRC commitments which are implemented in this procedure are DENOTED in left hand margin:

3.4.1 CNRO-2005-044 (NRC Bulletin 2005-02) - Definition Section of EAL Basis Document associated with EAL classifications, Hostile Action, Hostile Force and applicable security related EALs.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 4 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 4.0 DEFINITIONS 4.1 AFFECTING SAFE SHUTDOWN:

Event in progress has adversely affected functions that are necessary to bring the plant to and maintain it in the applicable HOT or COLD SHUTDOWN condition. Plant condition applicability is determined by Technical Specification LCOs in effect.

Example 1: Event causes damage that results in entry into an LCO that requires the plant to be placed in HOT SHUTDOWN. HOT SHUTDOWN is achievable, but COLD SHUTDOWN is not. This event is not AFFECTING SAFE SHUTDOWN.

Example 2: Event causes damage that results in entry into an LCO that requires the plant to be placed in COLD SHUTDOWN. HOT SHUTDOWN is achievable, but COLD SHUTDOWN is not. This event is AFFECTING SAFE SHUTDOWN.

4.2 ALERT

Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION.

Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline (PAG) exposure levels.

4.3 BOMB:

Refers to an explosive device suspected of having sufficient force to damage plant systems or structures.

4.4 CIVIL DISTURBANCE:

A group of persons violently protesting station operations or activities at the site 4.5 CONFINEMENT BOUNDARY:

The barrier(s) between areas containing radioactive substances and the environment 4.6 CONTAINMENT CLOSURE:

The actions to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. Containment closure must be capable of being set within 30 minutes. Containment Closure is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 5 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 4.7 CORE DAMAGE:

A failure of fuel cladding integrity to the extent that any of the following happen:

4.7.1 Fission product activity in the coolant exceeds the limits in the technical specifications.

4.7.2 Fuel is no longer in the original geometry.

4.7.3 A major portion of the core cannot be operated for its design cycle length.

4.8 COURTESY CALL:

A notification to the Arkansas Department of Health and follow-up notification to the NRC for conditions/events other than those constituting an Emergency Class as listed in procedure 1903.11, "Emergency Response/Notifications", Section 6.3.

4.9 EMERGENCY ACTION LEVEL (EAL):

A pre-determined, site specific, observable threshold for a plant IC that places the plant in a given emergency classification level. An EAL can be: an instrument reading; an equipment status indicator; a measurable parameter (on-site or off-site); a discrete, observable event; results of analyses; entry into specific emergency operating procedures; or another phenomenon which, if it occurs, indicates entry into a particular emergency classification level.

4.10 EMERGENCY CLASSIFICATION LEVEL:

One of a minimum set of names or titles established by the NRC for grouping off normal nuclear power plant conditions according to (1) their relative radiological seriousness, and (2) the time sensitive on-site and off-site radiological emergency preparedness actions necessary to respond to such conditions. The existing radiological emergency classification levels, in ascending order of seriousness, are called:

Notification of Unusual Event (NUE)

Alert Site Area Emergency (SAE)

General Emergency (GE)

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 6 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 4.11 EMERGENCY DIRECTION AND CONTROL:

Overall direction of facility response which must include the non-delegable responsibilities for the decision to notify and to recommend protective actions to Arkansas Department of Health personnel and other authorities responsible for offsite emergency measures. With activation of the EOF, the Emergency Director (ED) typically assumes the responsibility for Emergency Direction and Control. The management of on-site facility activities to mitigate accident consequences remains with the Emergency Plant Manager (EPM) in the Technical Support Center. The Shift Manager retains responsibility for the Control Room and plant systems operation.

4.12 EMERGENCY OPERATIONS FACILITY (EOF):

A near-site emergency response facility located approximately 0.65 miles northeast of the reactor buildings (the ANO Training Center).

4.13 EMERGENCY PLANNING ZONE (EPZ):

The EPZ considered by this procedure is the inhalation zone and is that area within approximately a 10 mile radius of ANO.

4.14 EMERGENCY RESPONSE ORGANIZATION (ERO):

The organization which is composed of the Initial Response Staff (IRS), the EOF staff, the TSC staff, the OSC staff, and the Emergency Team members. It has the capability to provide manpower and other resources necessary for immediate and long-term response to an emergency situation.

4.15 EPA PROTECTIVE ACTION GUIDELINE (PAG) Exposure Levels:

The projected dose to reference man, or other defined individual, from an unplanned release of radioactive material at which a specific protective action to reduce or avoid that dose is recommended (i.e., 1 Rem TEDE or 5 Rem Child Thyroid (CDE)).

4.16 EXCLUSION AREA:

That area surrounding ANO within a minimum radius of 0.65 miles of the reactor buildings, but outside the protected area and controlled to the extent necessary by ANO during periods of emergency.

4.17 EXPLOSION:

A rapid, violent, unconfined combustion or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 7 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 4.18 EXTORTION:

An attempt to cause an action at the station by threat of force.

4.19 FAULTED:

In a steam generator, the existence of secondary side leakage that results in an uncontrolled drop in steam generator pressure or the steam generator being completely depressurized.

4.20 FIRE:

Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIREs.

Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

4.21 FUEL OVERHEAT:

Condition in which fission products trapped within the fuel pellet are released at an accelerated rate due to increasing temperature. Fuel overheating temperatures typically range from 1600 F to 3600 F cladding temperature.

4.22 GENERAL EMERGENCY (GE):

Events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA PAG exposure levels off-site for more than the immediate site area.

4.23 HOSTAGE:

A person(s) held as leverage against the station to ensure that demands will be met by the station.

4.24 HOSTILE ACTION:

An act toward a Nuclear Power Plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 8 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 4.25 HOSTILE FORCE:

One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

4.26 IMMINENT:

Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur. Where IMMINENT timeframes are specified, they shall apply.

4.27 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI):

A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

4.28 INITIAL RESPONSE STAFF (IRS): The emergency organization composed of plant personnel which must be able to respond to the site in accordance with Table B-1 of the Emergency Plan.

4.29 INITIATING CONDITION (IC):

One of a predetermined subset of nuclear power plant conditions where either the potential exists for a radiological emergency, or such an emergency has occurred.

4.30 INTRUSION:

A person(s) present in a specified area without authorization.

Discovery of a BOMB in a specified area is indication of INTRUSION into that area by a HOSTILE FORCE.

4.31 LOSS OF PHYSICAL CONTROL OF THE PLANT:

Plant personnel are unable to operate equipment required to maintain safety functions to:

Shutdown the reactor and maintain it in a safe shutdown condition Remove residual heat Control the release of radioactive material Mitigate the consequences of an accident; or Cool irradiated fuel assemblies in the Spent Fuel Pool.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 9 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 4.32 NORMAL MAKEUP (MU) CAPACITY:

Unit 1: Normal makeup capacity is defined as 50 gpm. 50 gpm approximates a leak size for which the ability to make additions to the makeup tank is no longer adequate to maintain makeup tank level.

Unit 2: Normal makeup capacity is defined as 44 gpm. 44 gpm is the capacity of a single charging pump.

4.33 NORMAL PLANT OPERATIONS:

Activities at the plant site associated with routine testing, maintenance, or equipment operations, in accordance with normal operating or administrative procedures. Entry into off-normal or emergency operating procedures, or deviation from normal security or radiological controls posture, is a departure from NORMAL PLANT OPERATIONS.

4.34 NOTIFICATION OF UNUSUAL EVENT (NUE):

Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring off-site response or monitoring are expected unless further degradation of safety systems occurs.

4.35 OFFSITE:

Those areas not covered by Section 4.36.

4.36 ONSITE:

The area within the Exclusion Area Boundary 4.37 OPERATIONAL SUPPORT CENTER (OSC):

Emergency response center within the ANO Maintenance Facility where support is coordinated for the following functions:

Onsite Radiological Monitoring Maintenance Chemistry Emergency Medical Support Fire Fighting Support The OSC also serves as the briefing area for repair and damage control teams and is located in the Maintenance Facility.

4.38 OWNER CONTROLLED AREA (OCA):

The external area contiguous to the designated reactor site Protected Area over which site Security exercises control. The OCA extends outward to the Entergy site property lines.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 10 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 4.39 PLANT TRANSIENT:

4.39.1 Any unplanned reactor trip from criticality.

4.39.2 A planned reactor trip in which the expected post-trip response did not occur.

4.39.3 Any event resulting in an automatic ESAS (Unit 1) or ESF (Unit 2) actuation or any event requiring manual initiation of these systems where automatic initiation would likely have occurred 4.39.4 Any turbine-generator power change in excess of 100 MWe in less than one (1) minute other than a momentary spike due to a grid disturbance or a manually initiated runback.

4.39.5 Any unplanned main turbine or main feedwater pump turbine trip which results in a significant plant transient (change in excess of 100 MWe).

4.40 PROJECTILE:

An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

4.41 PROTECTED AREA:

An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

4.42 REACTOR COOLANT SYSTEM (RCS) LEAKAGE:

Loss of RCS inventory due to a leak in the RCS or a supporting system that is not or cannot be isolated within 10 minutes 4.43 RUPTURED:

In a steam generator, existence of primary-to-secondary leakage of a magnitude sufficient to require or cause a reactor trip and safety injection 4.44 SABOTAGE:

Deliberate damage, mis-alignment, or mis-operation of plant equipment with the intent to render the equipment inoperable. Equipment found tampered with or damaged due to malicious mischief may not meet the definition of SABOTAGE until this determination is made by security supervision.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 11 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 4.45 SECURITY CONDITION:

Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.

4.46 SIGNIFICANT TRANSIENT:

An UNPLANNED event involving one or more of the following: (1) automatic turbine runback > 25% thermal reactor power, (2) electrical load rejection > 25% full electrical load, (3) Reactor Trip, (4)

Safety Injection Activation, or (5) thermal power oscillations > 10%.

4.47 SITE AREA EMERGENCY (SAE):

Events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; 1) toward site personnel or equipment that could lead to the likely failure of or; 2) that prevent effective access to, equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA PAG exposure levels beyond the site boundary.

4.48 STRIKE ACTION:

A work stoppage within the PROTECTED AREA by a body of workers to enforce compliance with demands made on Entergy or its affiliates.

The STRIKE ACTION must threaten to interrupt NORMAL PLANT OPERATIONS.

4.49 TECHNICAL SUPPORT CENTER (TSC):

The location within the ANO Administration Building equipped with instrumentation and communication systems and facilities useful in monitoring the course of an accident; this center is located in the 3rd Floor of the ANO Administration Building.

4.50 UNISOLABLE:

A breach or leak that cannot be promptly isolated 4.51 UNPLANNED:

A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 12 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 4.52 VALID:

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

4.53 VISIBLE DAMAGE:

Damage to equipment or structures that is readily observable without measurement, testing, or analysis. Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or component. Example damage includes:

deformation due to heat or impact, denting, penetration, rupture, cracking, paint blistering. Surface blemishes (e.g., paint chipping, scratches) should not be included.

4.54 VITAL AREAS:

Any area within a protected area containing any equipment, system or device which, by result of failure, destruction or associated release, could directly or indirectly endanger the health and safety of the public.

5.0 RESPONSIBILITY AND AUTHORITY 5.1 The responsibility for event classification is assigned to the individual with responsibility for Emergency Direction and Control (i.e., The Shift Manager or Emergency Director).

5.2 The Control Room Supervisor (CRS) will assume Emergency Direction and Control responsibilities whenever the SM is not available to assume this responsibility (e.g. the SM becomes incapacitated and a replacement has not yet arrived).

5.3 Any individual who observes an initiating condition which warrants an emergency class declaration, as described in Attachment 1, shall immediately notify the person with current responsibility for Emergency Direction and Control (i.e. SM/ED).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 13 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 6.0 INSTRUCTIONS NOTE On emergencies that affect both units such as earthquakes, tornadoes, etc.,

the unit with the highest Emergency Action Level Classification should declare the emergency. IF the Emergency Action Level Classification is the same, THEN the Shift Managers should determine which unit has Emergency Direction and Control based on plant conditions, manpower, etc.

6.1 CLASSIFYING EMERGENCIES:

NOTE NRC 10CFR50 Appendix E IV. C.2 requires the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and SHALL PROMPTLY declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.

NOTE The emergency action levels described in this procedure are not intended to be used during maintenance and/or testing situations where abnormal temperature, pressure, equipment status, etc., is expected. In addition, each EAL contains information on the mode(s) of operation during which it is applicable.

NOTE When determining EAL classifications the EAL bases should be referred to if needed.

6.1.1 When indications of abnormal occurrences are received by the Control Room staff, the SM/ED shall:

A. Verify the indications of the off-normal event or reported sighting.

B. Ensure that the immediate actions (e.g., use of Emergency and Abnormal Operating Procedures) are taken for the safe and proper operation of the plant.

NOTE When plant conditions satisfy multiple EAL classifications then declare the HIGHEST level classification.

C. IF EAL classification is known, THEN proceed to appropriate tab.

D. IF EAL classification is NOT known, THEN compare the abnormal conditions with those listed in Attachment 1 "Index of Emergency Action Levels".

1. Turn to the appropriate tab which corresponds to the condition picked from the Index of EALs.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 14 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 (Step 6.1.1.D cont.)

2. Assess the information available from valid indications or reports, then:

Compare information to criteria given for EAL.

Review related EALs to determine if plant conditions meet their criteria.

Declare the emergency classification that is indicated.

E. IF the indications or reports do not match the given EALs, THEN refer to Tab H Hazards and Other Conditions Affecting Plant Safety and using appropriate judgment, determine if the plant status warrants an emergency declaration.

NOTE NRC Emergency Preparedness Position (EPPOS) 2 states that, The staff position is that 15-minutes is a reasonable period of time for assessing and classifying an emergency once indications are available to control room operators that an EAL has been exceeded.

EPPOS 2 goes on to state that the 15-minute period should not be interpreted as providing a grace period in which corrective actions can be taken to avoid classifying the emergency. Classification is expected to be made upon completion of the assessment without delay.

This 15-minute period is the assessment period referred to below.

6.1.2 In some cases, the conditions requiring an Emergency Class declaration are discovered and recognized after the conditions requiring such a declaration no longer exist. The discovery could come in a matter of minutes (in the case of a rapidly concluded event), days, or even weeks (as might occur during the review of the response to an abnormal plant condition).

The following guidance should be used to determine the proper notification method for a transient event:

A. Situation 1 It is discovered that plant conditions previously existed that would have warranted the declaration of an Emergency Class.

However, at the time of discovery, those conditions were no longer present and there is no current basis for an Emergency Class declaration.

In this case, an actual Emergency Class declaration is not necessary; however, an ENS notification must be made to the NRC within one hour of the discovery reporting that an undeclared Emergency Class previously existed. A Courtesy Call must also be performed in accordance with procedure 1903.011, Emergency Response/Notifications.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 15 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 (Step 6.1.2 cont.)

B. Situation 2 An event occurs in the plant during which conditions are present that would result in an Emergency Class declaration.

The conditions are discovered while they still exist.

However, before the completion of the allowed assessment period and before an Emergency Class is declared, the conditions clear.

In this case, the conditions cleared before completion of the assessment and prior to an Emergency Class declaration.

Therefore, an actual Emergency Class declaration is not necessary; however, an ENS notification must be made to the NRC within one hour of the discovery reporting that an undeclared Emergency Class previously existed. A Courtesy Call must also be performed in accordance with procedure 1903.011, Emergency Response/Notifications.

C. Situation 3 An event occurs in the plant during which the conditions are present that would result in an Emergency Class declaration.

At the time of discovery, these conditions still exist. Upon the completion of the allowed assessment period, the appropriate Emergency Class is declared. However, before offsite notifications are performed, the conditions requiring the Emergency Class declaration clear.

In this case, an Initial Notification (within 15 minutes) to State and local authorities shall be performed in accordance with procedure 1903.011, Emergency Response/Notifications.

This notification is to inform State and local authorities that the station was briefly in a declared Emergency Class but the conditions meeting the criteria for that Emergency Class no longer exist.

Notification to the NRC should follow immediately after notification of State and local authorities and not later than one hour of the event.

Activation of the Emergency Response Organization should be based on current plant conditions. Offsite organizations should be informed that the conditions requiring an emergency class declaration no longer exist and State and local authorities should activate their emergency response organizations based on the current plant conditions.

6.1.3 IF NO emergency declaration is required, THEN refer to procedure 1903.011, "Emergency Response /

Notifications", Section 6.4 to determine if the event warrants a "For Information Only" notification to Entergy Management, NRC Resident Inspector and/or the Arkansas Department of Health.

6.1.4 Upon declaration of an emergency classification implement procedure, 1903.011, "Emergency Response / Notifications", to ensure that immediate notification requirements are met and the proper Emergency Plan response is taken.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 16 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 6.1.5 Upgrade the emergency classification if plant conditions degrade per steps 6.1.1.A through E.

6.1.6 Downgrade the emergency classification when plant conditions have improved and step 6.2 is applicable.

6.2 DOWNGRADING THE EMERGENCY CLASSIFICATION:

6.2.1 Assess the current plant conditions, then perform the following:

A. Compare the abnormal conditions with those listed in the "Index Of Emergency Action Levels".

B. Turn to the appropriate tab which corresponds to the condition picked from the Index of EALs.

C. Assess the information available from valid indications or reports, compare it to the given EALs. Obtain concurrence from NRC and State officials that downgrading is appropriate (if their emergency response organizations have been activated as a result of this event). Downgrade to the emergency classification that is indicated.

D. If the indications or reports do not match the given EALs, then refer to Tab H Hazards and Other Conditions Affecting Plant Safety and using appropriate judgment, determine if the plant status warrants downgrading the emergency classification.

6.2.2 Perform notifications to downgrade the emergency classification if appropriate per procedure 1903.011, "Emergency Response/Notifications".

6.2.3 IF NO emergency classification appears necessary, THEN TERMINATE the emergency per step 6.3.

6.2.4 IF the emergency classification is still REQUIRED, THEN repeat steps 6.2.1 through 6.2.3 whenever plant conditions again appear to have improved.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 17 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 6.3 TERMINATING THE EMERGENCY:

6.3.1 Compare the existing plant conditions with the following:

A. Plant conditions no longer meet the emergency action level criteria AND it appears unlikely that current conditions will degrade further requiring reinstitution of an emergency classification.

B. Non-routine releases of radioactive material to the environment are under control or terminated.

C. Any fire, flood, earthquake, or similar emergency condition is controlled or has ceased.

D. All specified corrective actions have occurred OR the plant has been placed in the appropriate operational mode.

E. All required notifications have been completed.

F. NRC and State officials are in agreement that termination or transition to the recovery phase is appropriate (if their emergency response organizations have been activated as a result of this event).

6.3.2 IF the conditions of 6.3.1 A-F are met, THEN TERMINATE the emergency or proceed to the recovery phase.

7.0 ATTACHMENTS / TABS AND FORMS 7.1 Attachment 1 - Index of Emergency Action Levels 7.1.1 TAB A: Abnormal Radiation Levels / Radiological Effluents 7.1.2 TAB C: Cold Shutdown / Refueling System Malfunction 7.1.3 TAB E: Independent Spent Fuel Storage Installation (ISFSI)

Malfunction 7.1.4 TAB F: Fission Product Barrier Degradation 7.1.5 TAB H: Hazards and Other Conditions Affecting Plant Safety 7.1.6 TAB S: System Malfunction 7.2 Attachment 2 - ANO EAL Basis Document 7.3 Attachment 3 - EAL Matrix Chart

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/WORK PLAN TITLE: PAGE: 18 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ATTACHMENT 1 INDEX OF EMERGENCY ACTION LEVELS

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 19 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 INDEX OF EMERGENCY ACTION LEVELS SECTION PAGE TAB A: Abnormal Radiation Levels / Radiological Effluents AU1 Any release of gaseous or liquid radioactivity to the environment > 2 times the 24 ODCM limits for 60 minutes AA1 Any release of gaseous or liquid radioactivity to the environment > 200 times the 24 ODCM limits for 15 minutes AS1 Offsite dose resulting from an actual or IMMINENT release of gaseous 24 radioactivity > 100 mR TEDE or 500 mR child thyroid CDE for the actual or projected duration of the release AG1 Offsite dose resulting from an actual or IMMINENT release of gaseous 24 radioactivity >1000 mR TEDE or 5000 mR child thyroid CDE for the actual or projected duration of the release using actual meteorology AU2 UNPLANNED rise in plant radiation levels 26 AA2 Damage to irradiated fuel or loss of water level that has resulted or will result in 26 the uncovering of irradiated fuel outside the reactor vessel AA3 Rise in radiation levels within the facility that impedes operation of systems 27 required to maintain plant safety functions TAB C: Cold Shutdown / Refueling System Malfunction CU1 RCS leakage 29 CA1 Loss of RCS / reactor vessel inventory 29 CS1 Loss of RCS / reactor vessel inventory affecting core decay heat removal 29 capability CG1 Loss of RCS / reactor vessel inventory affecting fuel clad integrity with 29 containment challenged CU2 UNPLANNED loss of RCS / reactor vessel inventory 29 CU3 UNPLANNED loss of decay heat removal capability with irradiated fuel in the 31 reactor vessel CA3 Inability to maintain plant in Cold Shutdown 31 CU5 AC power capability to Vital 4.16 KV busses reduced to a single power source 32 15 minutes such that any additional single power source failure would result in station blackout CA5 Loss of all offsite and all onsite AC power to Vital 4.16KV busses 15 minutes 32

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 20 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 TABLE OF CONTENTS SECTION PAGE CU6 Loss of required DC power 15 minutes 33 CU7 Inadvertent criticality 33 CU8 Loss of all onsite or offsite communications capabilities 34 TAB E: Independent Spent Fuel Storage Installation (ISFSI) Malfunction E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY 36 TAB F: Fission Product Barrier Degradation General Bases 38 Fuel Clad Barrier EALs (FCB) 38 RCS Barrier EALs (RCB) 38 Containment Barrier EALS (CNB) 38 TAB H: Hazards and Other Conditions Affecting Plant Safety HU1 Confirmed SECURITY CONDITION or threat which indicates a potential 43 degradation in the level of safety of the plant HA1 HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack 43 threat HS1 HOSTILE ACTION within the PROTECTED AREA 42 HG1 HOSTILE ACTION resulting in loss of physical control of the facility 43 HU2 Other conditions exist which in the judgment of the SM warrant declaration of an 44 NUE HA2 Other conditions exist which in the judgment of the SM / ED warrant declaration of 44 an Alert HS2 Other conditions exist which in the judgment of the SM / ED warrant declaration of 44 a Site Area Emergency HG2 Other conditions exist which in the judgment of the SM / ED warrant declaration of 44 a General Emergency HA3 Control room evacuation has been initiated 45 HS3 Control Room evacuation has been initiated and plant control cannot be 45 established

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 21 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 TABLE OF CONTENTS SECTION PAGE HU4 FIRE within the PROTECTED AREA not extinguished within 15 minutes of 46 detection or EXPLOSION within the PROTECTED AREA HA4 FIRE or EXPLOSION affecting the operability of plant safety systems required to 46 establish or maintain safe shutdown HU5 Release of toxic, corrosive, asphyxiant, or flammable gases deemed detrimental 49 to NORMAL PLANT OPERATIONS HA5 Access to a VITAL AREA is prohibited due to toxic, corrosive, asphyxiant or 49 flammable gases which jeopardize operation of operable equipment required to maintain safe operations or safely shutdown the reactor.

HU6 Natural or destructive phenomena affecting the PROTECTED AREA 51 HA6 Natural or destructive phenomena affecting VITAL AREAS 51 TAB S : System Malfunction SU1 Loss of all offsite AC power to Vital 4.16 KV busses 15 minutes 56 SA1 AC power capability to Vital 4.16 KV busses reduced to a single power source 56 15 minutes such that any additional single power source failure would result in station blackout SS1 Loss of all offsite and all onsite AC power to Vital 4.16 KV busses 15 minutes 56 SG1 Prolonged loss of all offsite and all onsite AC power to Vital 4.16 KV busses 56 SA3 Automatic trip fails to shutdown the reactor and the manual actions taken from the 57 reactor control console are successful in shutting down the reactor SS3 Automatic trip fails to shutdown the reactor and manual actions taken from the 55 reactor control console are not successful in shutting down the reactor SG3 Automatic trip and all manual actions fail to shutdown the reactor and indication of 57 an extreme challenge to the ability to cool the core exists SS4 Loss of all vital DC power 15 minutes 58 SU6 UNPLANNED loss of safety system annunciation or indication in the Control 59 Room 15 minutes SA6 UNPLANNED loss of safety system annunciation or indication in the Control 59 Room with either (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable SS6 Inability to monitor a SIGNIFICANT TRANSIENT in progress 59 SU7 RCS leakage 60

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 22 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 TABLE OF CONTENTS SECTION PAGE SU8 Loss of all onsite or offsite communications capabilities 61 SU9 Fuel clad degradation 62 SU10 Inadvertent criticality 63 SU11 Inability to reach required operating mode within Technical Specification limits 63

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/WORK PLAN TITLE: PAGE: 23 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 TAB A Abnormal Radiation Levels /

Radiological Effluents

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 24 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT ABNORMAL RADIOLOGICAL EFFLUENTS AG1 1 2 3 4 5 6 D AS1 1 2 3 4 5 6 D AA1 1 2 3 4 5 6 D AU1 1 2 3 4 5 6 D Offsite dose resulting from an actual Offsite dose resulting from an actual Any release of gaseous or liquid Any release of gaseous or liquid or IMMINENT release of gaseous or IMMINENT release of gaseous radioactivity to the environment radioactivity to the environment radioactivity > 1000 mR TEDE or radioactivity > 100 mR TEDE or > 200 times the ODCM limits for > 2 times the ODCM limits for 5000 mR child thyroid CDE for the 500 mR child thyroid CDE for the 15 minutes 60 minutes actual or projected duration of the actual or projected duration of the Emergency Action Level(s): Emergency Action Level(s):

release using actual meteorology release NOTE: NOTE:

Emergency Action Level(s): Emergency Action Level(s):

The SM / ED should not wait until the The SM should not wait until the applicable NOTE: NOTE: applicable time has elapsed, but should time has elapsed, but should declare the declare the event as soon as it is determined event as soon as it is determined that the The SM / ED should not wait until the The SM / ED should not wait until the that the release duration has exceeded, or release duration has exceeded, or will likely applicable time has elapsed, but should declare applicable time has elapsed, but should declare will likely exceed, the applicable time. In the exceed, the applicable time. In the absence the event as soon as it is determined that the the event as soon as it is determined that the absence of data to the contrary, assume that of data to the contrary, assume that the condition will likely exceed the applicable time. condition will likely exceed the applicable time.

the release duration has exceeded the release duration has exceeded the If dose assessment results are available, the If dose assessment results are available, the applicable time if an ongoing release is applicable time if an ongoing release is classification should be based on EAL #2 classification should be based on EAL #2 detected and the release start time is detected and the release start time is instead of EAL #1. Do not delay declaration instead of EAL #1. Do not delay declaration unknown. unknown.

awaiting dose assessment results. awaiting dose assessment results.

1. VALID reading on SPING Gas 1. VALID reading on SPING Gas 1. VALID reading on SPING Gas 1. VALID reading on SPING Gas Channel on any of the following Channel on any of the following Channel on any of the following Channel on any of the following radiation monitors > the reading radiation monitors > the reading radiation monitors > the reading radiation monitors > the reading shown for 15 minutes: shown for 15 minutes: shown for 15 minutes: shown for 60 minutes:

MONITORS - Unit 1 LIMIT MONITORS - Unit 1 LIMIT MONITORS - Unit 1 LIMIT MONITORS - Unit 1 LIMIT RX-9820 Containment Purge 1.18E0 µCi/cc RX-9820 Containment Purge 1.18E-02 µCi/cc RX-9820 Containment Purge 1.18E+2 µCi/cc RX-9820 Containment Purge 1.18E+1 µCi/cc RX-9825 Radwaste Area 1.07E0 µCi/cc RX-9825 Radwaste Area 1.07E-02 µCi/cc RX-9825 Radwaste Area 1.07E+2 µCi/cc RX-9825 Radwaste Area 1.07E+1 µCi/cc RX-9830 Fuel Handling Area 9.08E-1 µCi/cc RX-9830 Fuel Handling Area 9.08E-03 µCi/cc RX-9830 Fuel Handling Area 9.08E+1 µCi/cc RX-9830 Fuel Handling Area 9.08E0 µCi/cc RX-9835 Emerg. Penetration Room 1.91E+1 µCi/cc RX-9835 Emerg. Penetration Room 1.91E-01 µCi/cc RX-9835 Emerg. Penetration Room 1.91E+3 µCi/cc RX-9835 Emerg. Penetration Room 1.91E+2 µCi/cc MONITORS - Unit 2 LIMIT MONITORS - Unit 2 LIMIT MONITORS - Unit 2 LIMIT MONITORS - Unit 2 LIMIT 2RX-9820 Containment Purge 8.92E-1 µCi/cc 2RX-9820 Containment Purge 8.92E-3 µCi/cc 2RX-9820 Containment Purge 8.92E+1 µCi/cc 2RX-9820 Containment Purge 8.92E0 µCi/cc 2RX-9825 Radwaste Area 6.64E-1 µCi/cc 2RX-9825 Radwaste Area 6.64E-3 µCi/cc 2RX-9825 Radwaste Area 6.64E+1 µCi/cc 2RX-9825 Radwaste Area 6.64E0 µCi/cc 2RX-9830 Fuel Handling Area 8.92E-1 µCi/cc 2RX-9830 Fuel Handling Area 8.92E-3 µCi/cc 2RX-9830 Fuel Handling Area 8.92E+1 µCi/cc 2RX-9830 Fuel Handling Area 8.92E0 µCi/cc 2RX-9835 Emerg. Penetration Room 1.77E+1 µCi/cc 2RX-9835 Emerg. Penetration Room 1.77E-1 µCi/cc 2RX-9835 Emerg. Penetration Room 1.77E+3 µCi/cc 2RX-9835 Emerg. Penetration Room 1.77E+2 µCi/cc 2RX-9845 Aux. Building Extension 2.53E0 µCi/cc 2RX-9845 Aux. Building Extension 2.53E-2 µCi/cc 2RX-9845 Aux. Building Extension 2.53E+2 µCi/cc 2RX-9845 Aux. Building Extension 2.53E+1 µCi/cc OR OR OR OR

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 25 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT ABNORMAL RADIOLOGICAL EFFLUENTS AG1 (continued) AS1 (continued) AA1 (continued) AU1 (continued)

2. Dose assessment using actual 2. Dose assessment using actual 2. EITHER VALID reading on any 2. VALID reading on any of the meteorology indicates doses meteorology indicates doses > 100 of the following radiation following radiation monitors

> 1000 mR TEDE or 5000 mR mR TEDE or 500 mR child thyroid monitors > 200 times the alarm > 2 times the alarm setpoint child thyroid CDE at or beyond the CDE at or beyond the site setpoint established by a current established by a current release site boundary. boundary. release permit for 15 minutes permit for 60 minutes:

OR VALID reading greater than OR OR MONITORS - Unit 1 the value listed for 15 minutes:

3. Field survey results indicate closed 3. Field survey results indicate closed Cont. Purge (SPING Gas RX-9820 MONITORS - Unit 1 LIMIT Ch) window dose rates > 1000 mR/hr window dose rates > 100 mR/hr Cont. Purge (SPING Gas expected to continue for 60 expected to continue for 60 RX-9820 Ch)

N/A RE-4830 Waste Gas Monitor minutes; or analyses of field minutes; or analyses of field RE-4830 Waste Gas Monitor 9.5E7 cpm RE-4642 Liquid Radwaste Monitor survey samples indicate child survey samples indicate child RE-4642 Liquid Radwaste Monitor 9.5E7 cpm RX-9835 Emerg. Penetration Room thyroid CDE > 5000 mR for one thyroid CDE > 500 mR for one RX-9835 Emerg. Penetration Room N/A MONITORS - Unit 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of inhalation, at or beyond the hour of inhalation, at or beyond the MONITORS - Unit 2 LIMIT Cont. Purge (SPING Gas site boundary. site boundary. 2RX-9820 Cont. Purge (SPING Gas N/A 2RX-9820 Ch)

Ch) 2RE-2429 Waste Gas Monitor 9.5E5 cpm 2RE-2429 Waste Gas Monitor 2RE-2330 BMS Discharge Monitor 9.5E5 cpm 2RE-2330 BMS Discharge Monitor 2RE-4423 LRW Discharge Monitor 9.5E5 cpm 2RE-4423 LRW Discharge Monitor 2RE-4425 SG BD to Flume Monitor 9.5E5 cpm 2RE-4425 SG BD to Flume Monitor OR OR

3. Confirmed grab sample analyses for gaseous or liquid releases 3. Confirmed grab sample analyses indicates concentrations or for gaseous or liquid releases release rates > 200 times the indicates concentrations or applicable values of the ODCM release rates > 2 times the for 15 minutes. applicable values of the ODCM for 60 minutes.

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/WORK PLAN TITLE: PAGE: 26 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT ABNORMAL RADIATION LEVELS AA2 1 2 3 4 5 6 D AU2 1 2 3 4 5 6 D Damage to irradiated fuel or loss of UNPLANNED rise in plant radiation water level that has resulted or will levels result in the uncovering of irradiated Emergency Action Level(s):

fuel outside the reactor vessel

1. a. UNPLANNED lowering of Emergency Action Level(s):

water level in the refueling

1. A water level drop in the canal or spent fuel pool as refueling canal or spent fuel pool indicated by:

that will result in irradiated fuel becoming uncovered. Personnel observation, refueling crew report, OR indication on area security camera, borated water

2. VALID alarm on any of the source (BWST or RWT) following radiation monitors due level drop due to makeup to damage to irradiated fuel or demands.

loss of water level:

MONITORS - Unit 1 AND RX-9820 Containment Purge (SPING Gas Ch) b. VALID Area Radiation Monitor RX-9825 Radwaste Area (SPING Gas Ch) reading rise on any of the RX-9830 Fuel Handling Area (SPING Gas Ch) following:

RE-8060 Containment High Range Monitor MONITORS - Unit 1 RE-8061 Containment High Range Monitor RE-8009 Spent Fuel Area RE-8009 Spent Fuel Area RE-8017 Fuel Handling Area RE-8017 Fuel Handling Area MONITORS - Unit 2 MONITORS - Unit 2 2RE-8914 Spent Fuel Area 2RX-9820 Containment Purge (SPING Gas Ch) 2RE-8915 Spent Fuel Area 2RX-9825 Radwaste Area (SPING Gas Ch) 2RE-8916 Spent Fuel Area 2RX-9830 Fuel Handling Area (SPING Gas Ch) 2RE-8912 Containment Incore Instrumentation 2RE-8905 Containment Equipment Hatch Area 2RE-8909 Containment Personnel Hatch Area 2RE-8925-1/2 Containment High Range Monitors 2RE-8914/15/16 Spent Fuel Area Monitors 2RE-8912 Containment Incore Instruments

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/WORK PLAN TITLE: PAGE: 27 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT ABNORMAL RADIATION LEVELS OR AU2 (continued)

AA3 1 2 3 4 5 6 D

2. UNPLANNED VALID Area Rise in radiation levels within the Radiation Monitor readings or facility that impedes operation of survey results indicate a rise by systems required to maintain plant a factor of 1000 over normal*

safety functions.

levels.

Emergency Action Level(s): NOTE:

1. Dose rate > 15 mR/hr in any of For area radiation monitors with ranges the following areas requiring incapable of measuring 1000 times normal*

continuous occupancy to levels, classification shall be based on VALID full scale indication unless surveys maintain plant safety functions: confirm that area radiation levels are below 1000 times normal* within 15 minutes of the Unit 1 Control Room Area Radiation Monitor indications going to Unit 2 Control Room full scale indication.

Central Alarm Station

• Normal can be considered as the highest reading in the past twenty-four hours excluding the current peak value.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 28 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 TAB C Cold Shutdown / Refueling System Malfunction

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 29 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION - Loss of RCS / Reactor Vessel Inventory CG1 5 6 CS1 5 6 CA1 5 6 CU1 5 Loss of RCS / reactor vessel Loss of RCS / reactor vessel Loss of RCS / reactor vessel RCS leakage inventory affecting fuel clad integrity inventory affecting core decay heat inventory Emergency Action Level(s):

with containment challenged removal capability Emergency Action Level(s):

NOTE:

Emergency Action Level(s): Emergency Action Level(s): NOTE:

The SM should not wait until the applicable NOTE: NOTE: The SM / ED should not wait until the time has elapsed, but should declare the applicable time has elapsed, but should event as soon as it is determined that the The SM / ED should not wait until the The SM / ED should not wait until the declare the event as soon as it is determined condition will likely exceed the applicable applicable time has elapsed, but should declare applicable time has elapsed, but should declare that the condition will likely exceed the time.

the event as soon as it is determined that the the event as soon as it is determined that the applicable time.

condition will likely exceed the applicable time. condition will likely exceed the applicable time. 1. RCS leakage results in the

1. Loss of RCS / reactor vessel inability to maintain or restore

1. a. Core exit thermocouples 1. With CONTAINMENT CLOSURE inventory as indicated by: level within Pressurizer or RCS indicate superheat for not established:

30 minutes. Unit 1: RVLMS Levels 1 through level target band for Loss of RCS / reactor vessel level 8 indicate DRY 15 minutes.

AND as indicated by:

Unit 2: RVLMS Levels 1 through

b. Any of the following Unit 1: RVLMS Levels 1 through 5 indicate DRY containment challenge 9 indicate DRY OR indications: Unit 2: RVLMS Levels 1 through 6 indicate DRY Unit 1: Reactor vessel level CU2 6 CONTAINMENT CLOSURE <368 ft., 6 in. (bottom of not established OR UNPLANNED loss of RCS / reactor the hot leg)

Explosive mixture inside 2. With CONTAINMENT CLOSURE Unit 2: Reactor vessel level vessel Inventory containment established, core exit < 369 ft., 1.5 in. (bottom Emergency Action Level(s):

UNPLANNED rise in thermocouples indicate superheat. of the hot leg)

NOTE:

containment pressure OR OR The SM should not wait until the applicable OR time has elapsed, but should declare the event as soon as it is determined that the

2. a. RCS / reactor vessel level condition will likely exceed the applicable cannot be monitored for 30 time.

minutes with a loss of RCS/ 1. UNPLANNED RCS / reactor reactor vessel inventory as vessel level drop as indicated by indicated by any of the either of the following:

following:

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 30 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION - Loss of RCS / Reactor Vessel Inventory CG1 (continued)

Containment High Range CS1 (continued)

CA1 (continued) CU2 (continued)

Radiation Monitor reading

3. RCS / reactor vessel level cannot

>10 R/hr a. RCS / reactor vessel water be monitored for 30 minutes with 2. RCS / reactor vessel level cannot Erratic source range monitor level drop below the reactor a loss of RCS / reactor vessel be monitored for 15 minutes with indication vessel flange for 15 minutes inventory as indicated by any of a loss of RCS / reactor vessel when the RCS / reactor Unexplained level rise in the following: inventory as indicated by an vessel level band is Reactor Building Sump, unexplained level rise in the Containment High Range Reactor Building Sump, Reactor established above the reactor Reactor Drain Tank, Quench Radiation Monitor reading vessel flange.

Tank, Aux. Building Drain Tank, Aux. Building

> 10 R/hr Equipment Drain Tank, Aux.

Equipment Drain Tank, or OR Aux. Building Sump Erratic source range monitor Building Sump, or Quench Tank.

indication b. RCS / reactor vessel water AND level drop below the RCS /

Unexplained level rise in Reactor reactor vessel level band for

b. Any of the following Building Sump, Reactor Drain 15 minutes when the RCS /

containment challenge Tank, Quench Tank, Aux. reactor vessel level band is indications: Building Equipment Drain Tank, established below the reactor or Aux. Building Sump vessel flange.

CONTAINMENT CLOSURE not established OR Explosive mixture inside containment 2. RCS / reactor vessel level UNPLANNED rise in cannot be monitored with a loss containment pressure of RCS / reactor vessel inventory as indicated by an unexplained level rise in (as applicable) the Reactor Building Sump, Reactor Drain Tank, Aux. Building Equipment Drain Tank, Aux.

Building Sump, or Quench Tank.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 31 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION - Loss of Decay Heat Removal CA3 5 6 CU3 5 6 Inability to maintain plant in Cold UNPLANNED loss of decay heat Shutdown removal capability with irradiated fuel in the reactor vessel Emergency Action Level(s):

Emergency Action Level(s):

1. An UNPLANNED event results in RCS temperature > 200 °F > NOTE:

the specified duration in The SM should not wait until the applicable Table C1. time has elapsed, but should declare the event as soon as it is determined that the Table C1 condition will likely exceed the applicable RCS Reheat Duration Thresholds time.

Containment RCS Duration Closure 1. UNPLANNED event results in Intact (but not RCS lowered inventory)

N/A 60 minutes* RCS temperature exceeding Established 20 minutes*

200 °F.

Not intact or RCS lowered inventory Not Established 0 minutes OR

• If an RCS heat removal system is in operation within 2. Loss of all RCS temperature this time frame and RCS temperature is being reduced, the EAL is not applicable. and RCS / reactor vessel level indication for 15 minutes.

OR NOTE: EAL #2 does not apply in solid plant conditions.

2. An UNPLANNED event results in RCS pressure rise > 10 psi due to a loss of RCS cooling.

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/WORK PLAN TITLE: PAGE: 32 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION - Loss of AC Power CA5 5 6 D CU5 5 6 Loss of all offsite and all onsite AC AC power capability to Vital 4.16 power to Vital 4.16 KV busses KV busses reduced to a single 15 minutes power source 15 minutes such that any additional single power Emergency Action Level(s):

source failure would result in NOTE: station blackout The SM / ED should not wait until the Emergency Action Level(s):

applicable time has elapsed, but should declare the event as soon as it is NOTE:

determined that the condition will likely exceed the applicable time. The SM should not wait until the applicable time has elapsed, but should declare the

1. Loss of all offsite and all onsite event as soon as it is determined that the AC power to Vital 4.16KV condition will likely exceed the applicable time.

busses 15 minutes.

1. a. AC power capability to Vital 4.16 KV busses reduced to a single power source 15 minutes.

AND

b. Any additional single power source failure will result in station blackout.

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/WORK PLAN TITLE: PAGE: 33 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION - Loss of DC Power CU6 5 6 Loss of required DC power 15 minutes Emergency Action Level(s):

NOTE:

The SM should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. < 105 volts on required Vital DC bus 15 minutes.

GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION - Inadvertant Criticality CU7 5 6 Inadvertent criticality Emergency Action Level(s):

1. UNPLANNED sustained positive startup rate observed on nuclear instrumentation.

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/WORK PLAN TITLE: PAGE: 34 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION - Loss of Communications CU8 5 6 D Loss of all onsite or offsite communications capabilities Emergency Action Level(s):

1. Loss of all Table C2 onsite communication methods affecting the ability to perform routine operations.

Table C2 Onsite Communications Equipment Station radio system Plant paging system In-plant telephones Gaitronics OR

2. Loss of all Table C3 offsite communication methods affecting the ability to perform offsite notifications.

Table C3 Offsite Communications Equipment All telephone lines (commercial and microwave)

ENS

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/WORK PLAN TITLE: PAGE: 35 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 TAB E Independent Spent Fuel Storage Installation (ISFSI)

Malfunction

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/WORK PLAN TITLE: PAGE: 36 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT ISFSI MALFUNCTION - Cask Damage E-HU1 1 2 3 4 5 6 D Note: Security Events are bounded by the Hazards EALs.

Damage to a loaded cask CONFINEMENT BOUNDARY Emergency Action Level(s):

1. Damage to a loaded cask CONFINEMENT BOUNDARY.

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/WORK PLAN TITLE: PAGE: 37 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 TAB F Fission Product Barrier Degradation

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 38 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT FISSION PRODUCT BARRIER DEGRADATION - Barriers FG1 1 2 3 4 FS1 1 2 3 4 FA1 1 2 3 4 FU1 1 2 3 4 Loss of ANY two barriers AND loss Loss or potential loss of ANY two ANY loss or ANY potential loss of ANY loss or ANY potential loss of or potential loss of third barrier barriers EITHER fuel clad or RCS containment Note: Determine which combination of the three barriers are lost or have a potential loss and use the above key to classify the event. Also, multiple events could occur which result in the conclusion that exceeding the loss or potential loss EALs is IMMINENT. In this IMMINENT loss situation use judgment and classify as if the EALs are exceeded.

Fuel Clad Barrier EALs RCS Barrier EALs Containment Barrier EALs LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS

1. Primary Coolant Activity Level (FCB1) 1. RCS Leak Rate (RCB1) 1. Containment Pressure (CNB1)

1. Coolant activity None RCS leak rate > available Unit 1: UNISOLABLE 1. Rapid unexplained drop 1. Unit 1: Containment

> 300 µCi/gm dose makeup capacity as RCS leak in containment pressure >

equivalent I-131 activity indicated by: > 50 gpm with pressure following an 73.7 PSIA by Chemistry sample Letdown isolated initial rise in (59 PSIG) and Unit 1: Loss of adequate containment pressure rising OR subcooling margin Unit 2: UNISOLABLE RCS leak > 44 OR Unit 2: Containment

2. Radiation levels Unit 2: RCS subcooling gpm with Letdown pressure >

> 1000 mR/hr (MTS) can NOT isolated 2. Containment pressure 73.7 PSIA and be maintained at or sump level response rising Unit 1: at SA-229 least 30 °F not consistent with Unit 2: at 2TCD-19 LOCA conditions OR

2. Explosive mixture exists inside Containment OR

3. a. Containment Pressure >

containment spray actuation setpoint Unit 1: 44.7 PSIA (30 PSIG)

Unit 2: 23.3 PSIA (8.6 PSIG)

AND

b. LESS THAN one full train of spray operating

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 39 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 Fuel Clad Barrier EALs RCS Barrier EALs Containment Barrier EALs LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS

2. Core Exit Thermocouple Readings 2. SG Tube Rupture (RCB2) 2. Core Exit Thermocouple Readings (CNB2)

(FCB2)

> 1200 °F CET Unit 1: ICC exists as SGTR that results in an None None 1. a. CETs indicate >

temperature evidenced by ECCS (SI) actuation 1200 °F CETs indicating AND superheated b. Restoration conditions procedures not effective within Unit 2: Average CETs 15 minutes indicate OR superheat for current RCS 2. a. CETs indicate >

pressure 700 °F AND

b. RVLMS indicates Unit 1: Levels 1 through 9 DRY Unit 2: Levels 1 through 7 DRY AND

c. Restoration procedures not effective within 15 minutes

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 40 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 Fuel Clad Barrier EALs RCS Barrier EALs Containment Barrier EALs LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS

3. Containment Radiation Monitoring 3. SG Secondary Side Release With

3. Reactor Vessel Water Level (FCB3)

(RCB3) Primary-to-Secondary Leakage (CNB3)

None Unit 1: RVLMS Levels 1 Containment high range None 1. RUPTURED steam None through 9 indicate radiation monitor reading > generator is also DRY 100 R/hr FAULTED outside of containment Unit 2: RVLMS Levels 1 OR through 7 indicate DRY

2. a. Primary to secondary leakrate

> 10 gpm AND

b. UNISOLABLE steam release from affected steam generator to the environment

4. Containment Radiation Monitoring 4. Containment Isolation Failure or Bypass

4. Emergency Director Judgment (RCB4)

(FCB4) (CNB4)

Containment high range None Any condition in the opinion of the SM / ED that indicates 1. UNISOLABLE breach None radiation monitor reading > Loss or Potential Loss of the RCS barrier of containment 1000 R/hr AND

2. Direct downstream pathway to the environment exists after containment isolation signal

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 41 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 Fuel Clad Barrier EALs RCS Barrier EALs Containment Barrier EALs LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS

5. Containment Radiation Monitoring

5. Core Damage Assessment (FCB5)

(CNB5)

At least 5% fuel clad None None Containment high range damage as determined radiation monitor reading >

from core damage 4000 R/hr assessment

6. Emergency Director Judgment (FCB6) 6. Other Indications (CNB6)

Any condition in the opinion of the SM/ED that indicates Elevated readings on the following radiation monitors that Loss or Potential Loss of the fuel clad barrier indicate loss or potential loss of the Containment barrier:

MONITORS - Unit 1 RX-9820 Containment Purge RX-9825 Radwaste Area RX-9830 Fuel Handling Area RX-9835 Emergency Penetration Room MONITORS - Unit 2 2RX-9820 Containment Purge 2RX-9825 Radwaste Area 2RX-9830 Fuel Handling Area 2RX-9835 Emergency Penetration Room 2RX-9845 Auxiliary Building Extension

7. Emergency Director Judgment (CNB7)

Any condition in the opinion of the SM / ED that indicates Loss or Potential Loss of the containment barrier

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/WORK PLAN TITLE: PAGE: 42 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 TAB H Hazards and Other Conditions Affecting Plant Safety

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 43 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY - Security HG1 1 2 3 4 5 6 D HS1 1 2 3 4 5 6 D HA1 1 2 3 4 5 6 D HU1 1 2 3 4 5 6 D HOSTILE ACTION resulting in loss HOSTILE ACTION within the HOSTILE ACTION within the Confirmed SECURITY CONDITION of physical control of the facility PROTECTED AREA OWNER CONTROLLED AREA or or threat which indicates a potential airborne attack threat degradation in the level of safety of Emergency Action Level(s): Emergency Action Level(s):

the plant Emergency Action Level(s):

1. A HOSTILE ACTION has 1. A HOSTILE ACTION is occurring Emergency Action Level(s):

occurred such that plant or has occurred within the 1. A HOSTILE ACTION is occurring personnel are unable to operate PROTECTED AREA as reported or has occurred within the 1. A SECURITY CONDITION that equipment required to maintain by ANO Security Shift OWNER CONTROLLED AREA does not involve a HOSTILE safety functions. Supervision. as reported by ANO Security Shift ACTION as reported by ANO Supervision. Security Shift Supervision.

OR OR OR

2. A HOSTILE ACTION has caused failure of Spent Fuel Cooling 2. A validated notification from NRC 2. A credible site specific security Systems and IMMINENT fuel of an airliner attack threat within threat notification.

damage is likely for a freshly off- 30 minutes of the site.

OR loaded reactor core in pool.

3. A validated notification from NRC providing information of an aircraft threat.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 44 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY - Discretionary HG2 1 2 3 4 5 6 D HS2 1 2 3 4 5 6 D HA2 1 2 3 4 5 6 D HU2 1 2 3 4 5 6 D Other conditions exist which in the Other conditions exist which in the Other conditions exist which in the Other conditions exist which in the judgment of the SM / ED warrant judgment of the SM / ED warrant judgment of the SM / ED warrant judgment of the SM warrant declaration of General declaration of a Site Area declaration of an Alert declaration of an NUE Emergency Emergency Emergency Action Level(s): Emergency Action Level(s):

Emergency Action Level(s): Emergency Action Level(s):

1. Other conditions exist which in 1. Other conditions exist which in

1. Other conditions exist which in 1. Other conditions exist which in the judgment of the SM / ED the judgment of the SM indicate the judgment of the SM / ED the judgment of the SM / ED indicate that events are in that events are in progress or indicate that events are in indicate that events are in progress or have occurred have occurred which indicate a progress or have occurred progress or have occurred which involve an actual or potential degradation of the which involve actual or which involve actual or likely potential substantial level of safety of the plant or IMMINENT substantial core major failures of plant functions degradation of the level of indicate a security threat to degradation or melting with needed for protection of the safety of the plant or a security facility protection has been potential for loss of public or HOSTILE ACTION event that involves probable life initiated. No releases of containment integrity or that results in intentional threatening risk to site radioactive material requiring HOSTILE ACTION that results damage or malicious acts; (1) personnel or damage to site offsite response or monitoring in an actual loss of physical toward site personnel or equipment because of are expected unless further control of the facility. Releases equipment that could lead to HOSTILE ACTION. Any degradation of safety systems can be reasonably expected to the likely failure of or; (2) that releases are expected to be occurs.

exceed EPA Protective Action prevent effective access to limited to small fractions of the Guideline exposure levels equipment needed for the EPA Protective Action Guideline offsite for more than the protection of the public. Any exposure levels.

immediate site area. releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 45 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY - Control Room Evacuation HS3 1 2 3 4 5 6 D HA3 1 2 3 4 5 6 D Control Room evacuation has been Control Room evacuation has been initiated and plant control cannot be initiated established Emergency Action Level(s):

Emergency Action Level(s):

1. Alternate Shutdown procedure

1. a. Control Room evacuation has requires Control Room been initiated. evacuation:

AND Unit 1: 1203.002, Alternate Shutdown

b. Control of the plant cannot be established in accordance Unit 2: 2203.014, Alternate with the following procedures Shutdown within 15 minutes:

Unit 1: 1203.002, Alternate Shutdown Unit 2: 2203.014, Alternate Shutdown

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 46 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Fire 1 1 HA4 1 2 3 4 5 6 D HU4 1 2 3 4 5 6 D FIRE or EXPLOSION affecting the FIRE within the PROTECTED operability of plant safety systems AREA not extinguished within 15 required to establish or maintain minutes of detection safe shutdown OR EXPLOSION within the Emergency Action Level(s):

PROTECTED AREA

1. FIRE or EXPLOSION resulting Emergency Action Level(s):

in VISIBLE DAMAGE to any Table H1 structure or area NOTE:

containing safety systems or The SM should not wait until the applicable components or Control Room time has elapsed, but should declare the indication of degraded event as soon as it is determined that the condition has exceeded, or will likely performance of those safety exceed, the applicable time.

systems:

1. FIRE in any Table H1 structure or area not extinguished:

a. within 15 minutes of Control Room notification OR

b. within 15 minutes of 2

verification of a Control Room FIRE alarm (i.e.

Alarm valid until disproved)

OR

2. EXPLOSION within the PROTECTED AREA.

1 The HA4 and HU4 EALs apply to any Table H1 structure or area whether in service or tagged out for maintenance.

2 Verification of a fire detection system alarm/actuation includes actions that can be taken within the Control Room or other nearby site specific location to ensure that it is not spurious.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 47 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 Table H1 Unit 1 Reactor Building All Elevations Aux Building All Elevations Including Penthouse/MSIV Room Exceptions: Boric Acid Mix Tank Room (Chem Add Area) 404 (157-B)

EDG Exhaust Fan area on 386 (1-E and 2-E)

Turbine Building All Elevations Including:

Pipechase under ICW Coolers CRD Pump Pit / T-28 Room / Area under ICW Pumps Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)

Manholes adjacent to Intake Structure (MH-05/MH-06)

Intake Structure (354 and 366)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes MH-09 and MH-10 (Manhole, MH-09, is located approximately 15 feet northeast of the Unit 1 QCST , Manhole, MH-10, is located approximately 5 feet west of Unit 2 Condensate Storage Tank, 2T-41A)

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/WORK PLAN TITLE: PAGE: 48 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 Table H1 Unit 2 Reactor Building All Elevations Aux Building All Elevations including Aux Extensions Turbine Building All Elevations Outside Areas Intake Structure (354 and 366)

Concrete Manhole East, NE of intake Concrete Manhole East of Turbine building next to train bay Diesel Fuel Vault Diesel Fuel Vault Pump Manholes MH-09 and MH-10 (Manhole, MH-09, is located approximately 15 feet northeast of the Unit 1 QCST , Manhole, MH-10, is located approximately 5 feet west of Unit 2 Condensate Storage Tank, 2T-41A)

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 49 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Toxic Gas HA5 1 2 3 4 5 6 D HU5 1 2 3 4 5 6 D Access to a VITAL AREA is Release of toxic, corrosive, prohibited due to toxic, corrosive, asphyxiant, or flammable gases asphyxiant, or flammable gases deemed detrimental to NORMAL which jeopardize operation of PLANT OPERATIONS operable equipment required to Emergency Action Level(s):

maintain safe operations or safely shutdown the reactor 1. Toxic, corrosive, asphyxiant, or flammable gases in amounts Emergency Action Level(s):

that have or could adversely NOTE: affect NORMAL PLANT If the equipment in the stated area was OPERATIONS.

already inoperable, or out of service, before the event occurred, then this EAL OR should not be declared as it will have no adverse impact on the ability of the plant to 2. Report by Local, County or State safely operate or safely shutdown beyond officials for evacuation or that already allowed by Technical sheltering of site personnel based Specifications at the time of the event. on an offsite event.

1. Access to a VITAL AREA is prohibited due to toxic, corrosive, asphyxiant, or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 50 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Toxic Gas HA5 (continued) 1 2 3 4 5 6 D Unit 1 APPLICABLE VITAL AREA MODES A-4 Switchgear Room 3, 4 Upper North Electrical 3, 4 Penetration Room Lower South Electrical 3, 4 Equipment Room Control Room ALL Unit 2 APPLICABLE VITAL AREA MODES Auxiliary Building 317 Emergency Core 3, 4 Cooling Rooms Auxiliary Building 317 3, 4 Tendon Gallery Access Auxiliary Building 335 Charging Pumps/ 2B- 3, 4 52 Auxiliary Building 354 3, 4 2B-62 Area Emergency Diesel 3, 4 Generator Corridor Lower South Piping 3, 4 Penetration Room Auxiliary Building 386 3, 4 Containment Hatch Control Room ALL

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 51 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Natural or Destructive Phenomena HA6 1 2 3 4 5 6 D HU6 1 2 3 4 5 6 D Natural or destructive phenomena Natural or destructive phenomena affecting VITAL AREAS affecting the PROTECTED AREA Emergency Action Level(s): Emergency Action Level(s):

1. a. Seismic event > Operating 1. Seismic event identified by any Basis Earthquake (OBE) as 2 of the following:

indicated by annunciation of Seismic event confirmed by the 0.1g acceleration alarm. annunciation of the 0.01g AND acceleration alarm

b. Earthquake confirmed by ANY Earthquake felt in plant of the following: National Earthquake Center Earthquake felt in plant OR National Earthquake 2. Tornado striking within Center PROTECTED AREA boundary Control Room indication of or high winds > 67 mph.

degraded performance of (2 minute average) systems required for the OR safe shutdown of the plant

3. Internal flooding that has the OR potential to affect safety related equipment required by Technical Specifications for the current operating mode in any of the structures or areas in Table H1. (Page 47)

OR

4. Turbine failure resulting in casing penetration or damage to turbine or generator seals.

OR

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 52 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Natural or Destructive Phenomena HA6 (continued) HU6 (continued)

2. Tornado striking or winds > 67 5. Lake Dardanelle level < 335 feet.

mph (2 minute average) resulting in VISIBLE DAMAGE to any of OR the following

6. Lake Dardanelle level > 345 feet.

structures/equipment containing safety systems or components or Control Room indication of degraded performance of those safety systems:

Reactor Building Intake Structure Ultimate Heat Sink BWST/RWT Auxiliary Building Turbine Building QCST Control Room Startup Transformers Diesel Fuel Vault OR

3. Internal flooding in any of the following areas resulting in an electrical shock hazard that precludes access to operate or monitor safety equipment or Control Room indication of degraded performance of those safety systems:

Intake Structure Auxiliary Building Turbine Building

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 53 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Natural or Destructive Phenomena HA6 (continued)

OR

4. Turbine failure-generated PROJECTILES resulting in VISIBLE DAMAGE to or penetration of any of the structures/equipment containing safety systems or components or Control Room indication of degraded performance of those safety systems:

Auxiliary Building Turbine Building Control Room Startup Transformers OR

5. Lake Dardanelle level < 335 feet and Emergency Cooling Pond inoperable.

OR

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 54 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Natural or Destructive Phenomena HA6 (continued)

6. Vehicle crash resulting in VISIBLE DAMAGE to any of the structures/equipment containing safety systems or components or Control Room indication of degraded performance of those safety systems:

Reactor Building Intake Structure Ultimate Heat Sink BWST/RWT Auxiliary Building Turbine Building QCST Startup Transformers Diesel Fuel Vault

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 55 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 TAB S System Malfunction

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 56 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SYSTEM MALFUNCTION - Loss of AC Power SG1 1 2 3 4 SS1 1 2 3 4 SA1 1 2 3 4 SU1 1 2 3 4 Prolonged loss of all offsite and all Loss of all offsite and all onsite AC AC power capability to Vital 4.16 Loss of all offsite AC power to onsite AC power to Vital 4.16 KV power to Vital 4.16 KV busses KV busses reduced to a single Vital 4.16 KV busses 15 minutes busses 15 minutes power source 15 minutes such Emergency Action Level(s):

that any additional single power Emergency Action Level(s): Emergency Action Level(s):

source failure would result in NOTE:

1. a. Loss of all offsite and all NOTE: station blackout The SM / ED should not wait until the onsite AC power to Vital The SM / ED should not wait until the applicable time has elapsed, but should Emergency Action Level(s): declare the event as soon as it is 4.16 KV busses. applicable time has elapsed, but should declare the event as soon as it is NOTE: determined that the condition has AND determined that the condition has exceeded, or will likely exceed, the exceeded, or will likely exceed, the The SM / ED should not wait until the applicable time.

b. Either of the following: applicable time. applicable time has elapsed, but should declare the event as soon as it is 1. Loss of all offsite AC power to Restoration of at least one 1. Loss of all offsite and all onsite determined that the condition has Vital 4.16 KV busses Vital 4.16 KV bus in AC power to Vital 4.16 KV exceeded, or will likely exceed, the 15 minutes.

< 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely. applicable time.

busses 15 minutes.

OR 1. a. AC power capability to Vital 4.16 KV busses reduced to Continuing degradation of a single power source core cooling based on 15 minutes.

Fission Product Barrier monitoring as indicated by AND CETs 700 °F. b. Any additional single power source failure will result in station blackout.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 57 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SYSTEM MALFUNCTION - Failure of Reactor Protection System SG3 1 2 SS3 1 2 SA3 1 2 Automatic trip and all manual Automatic trip fails to shutdown Automatic trip fails to shutdown actions fail to shutdown the reactor the reactor and manual actions the reactor and the manual and indication of an extreme taken from the reactor control actions taken from the reactor challenge to the ability to cool the console are not successful in control console are successful in core exists shutting down the reactor shutting down the reactor Emergency Action Level(s): Emergency Action Level(s): Emergency Action Level(s):

1. a. An automatic trip failed to 1. a. An automatic trip failed to 1. a. An automatic trip failed to shutdown the reactor. shutdown the reactor. shutdown the reactor as indicated by reactor power AND AND 5%.

b. All manual actions do not b. Manual actions taken at AND shutdown the reactor as panel C03 (Unit 1) or panels indicated by reactor power 2C03/2C14 (Unit 2) do not b. Manual actions taken at 5%. shutdown the reactor as panel C03 (Unit 1) or panels indicated by reactor power 2C03/2C14 (Unit 2)

AND 5%. successfully shutdown the

c. Either of the following exist or reactor as indicated by have occurred due to reactor power < 5%.

continued power generation:

CET temperatures at or approaching 1200 °F.

OR Feedwater flow rate less than:

Unit 1: 430 gpm Unit 2: 485 gpm

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/WORK PLAN TITLE: PAGE: 58 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SYSTEM MALFUNCTION - Loss of DC Power SS4 1 2 3 4 Loss of all Vital DC power 15 minutes Emergency Action Level(s):

NOTE:

The SM / ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

1. < 105 volts on all Vital DC busses 15 minutes.

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/WORK PLAN TITLE: PAGE: 59 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SYSTEM MALFUNCTION - Loss of Annunciators SS6 1 2 3 4 SA6 1 2 3 4 SU6 1 2 3 4 Inability to monitor a UNPLANNED loss of safety UNPLANNED loss of safety SIGNIFICANT TRANSIENT in system annunciation or indication system annunciation or indication progress in the Control Room with either (1) in the Control Room for 15 a SIGNIFICANT TRANSIENT in minutes Emergency Action Level(s):

progress, or (2) compensatory Emergency Action Level(s):

NOTE: indicators unavailable The SM / ED should not wait until the NOTE:

Emergency Action Level(s):

applicable time has elapsed, but should The SM / ED should not wait until the declare the event as soon as it is NOTE: applicable time has elapsed, but should determined that the condition has declare the event as soon as it is exceeded, or will likely exceed, the The SM / ED should not wait until the determined that the condition has applicable time. applicable time has elapsed, but should exceeded, or will likely exceed, the declare the event as soon as it is determined applicable time.

1. a. UNPLANNED loss of > that the condition has exceeded, or will likely approximately 75% of the exceed, the applicable time. 1. UNPLANNED loss of >

following 15 minutes: 1. a. UNPLANNED loss of > approximately 75% of the Control Room approximately 75% of the following 15 minutes:

annunciators associated following 15 minutes: a. Control Room annunciators with safety systems. Control Room annunciators associated with safety OR associated with safety systems.

systems.

Control Room safety OR system indication. OR

b. Control Room safety system AND Control Room safety indication.

system indication.

b. A SIGNIFICANT TRANSIENT in progress. AND AND b. Either of the following:

A SIGNIFICANT

c. Compensatory indications TRANSIENT is in progress are unavailable.

OR Compensatory indications are unavailable

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/WORK PLAN TITLE: PAGE: 60 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SYSTEM MALFUNCTION - RCS Leakage SU7 1 2 3 4 RCS leakage Emergency Action Level(s):

1. Unidentified or pressure boundary leakage > 10 gpm.

OR

2. Identified leakage > 25 gpm.

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/WORK PLAN TITLE: PAGE: 61 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SYSTEM MALFUNCTION - Loss of Communications SU8 1 2 3 4 Loss of all onsite or offsite communications capabilities Emergency Action Level(s):

1. Loss of all Table M1 onsite communications methods affecting the ability to perform routine operations.

Table M1 Onsite Communications Methods Station radio system Plant paging system In-plant telephones Gaitronics OR

2. Loss of all Table M2 offsite communications methods affecting the ability to perform offsite notifications.

Table M2 Offsite Communications Methods All telephone lines (commercial and microwave)

ENS

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/WORK PLAN TITLE: PAGE: 62 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SYSTEM MALFUNCTION - Fuel Clad Degradation SU9 1 2 3 4 Fuel clad degradation Emergency Action Level(s):

1. Failed Fuel Iodine radiation monitor reading indicates fuel clad degradation > Technical Specification allowable limits:

Unit 1: RI-1237S reads

> 1.3 x 105 cpm Unit 2: 2RITS-4806B reads

> .65 x 105 cpm OR

2. RCS sample activity value indicating fuel clad degradation

> Technical Specification allowable limits:

> 1.0 uCi/gm Dose Equivalent I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> OR Unit 1: 60 uCi/gm Dose Equivalent I-131 Unit 2: > 60 uCi/gm Dose Equivalent I-131 OR

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/WORK PLAN TITLE: PAGE: 63 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SYSTEM MALFUNCTION - Fuel Clad Degradation SU9 (continued)

Unit 1: > 2200 µCi/gm Dose Equivalent Xe-133 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Unit 2: > 3100 µCi/gm Dose Equivalent Xe-133 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> SYSTEM MALFUNCTION - Inadvertant Criticality SU10 3 4 Inadvertent criticality Emergency Action Level(s):

1. An UNPLANNED sustained positive startup rate observed on nuclear instrumentation.

SYSTEM MALFUNCTION - Failure to Shutdown SU11 1 2 3 4 Inability to reach required operating mode within Technical Specification limits Emergency Action Level(s):

1. A Plant is not brought to required operating mode within Technical Specifications LCO action statement time.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 64 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 Attachment 2 Arkansas Nuclear One EAL Basis Document

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 65 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 TABLE OF CONTENTS SECTION PAGE General Notes on Basis Document Use ......................................................................................... 69 Overview......................................................................................................................................... 70 Abnormal Radiation Levels / Radiological Effluents ................................................................ 74 AU1 Any release of gaseous or liquid radioactivity to the environment >2 times the 75 ODCM limits for 60 minutes AA1 Any release of gaseous or liquid radioactivity to the environment >200 times the 80 ODCM limits for 15 minutes AS1 Offsite dose resulting from an actual or IMMINENT release of gaseous 86 radioactivity >100 mR TEDE or 500 mR child thyroid CDE for the actual or projected duration of the release AG1 Offsite dose resulting from an actual or IMMINENT release of gaseous 88 radioactivity >1000 mR TEDE or 5000 mR child thyroid CDE for the actual or projected duration of the release using actual meteorology AU2 UNPLANNED rise in plant radiation levels 78 AA2 Damage to irradiated fuel or loss of water level that has resulted or will result in 83 the uncovering of irradiated fuel outside the reactor vessel AA3 Rise in radiation levels within the facility that impedes operation of systems 85 required to maintain plant safety functions Cold Shutdown / Refueling System Malfunction 90 CU1 RCS leakage 91 CA1 Loss of RCS / reactor vessel inventory 99 CS1 Loss of RCS / reactor vessel inventory affecting core decay heat removal 104 capability CG1 Loss of RCS / reactor vessel inventory affecting fuel clad integrity with 106 containment challenged CU2 UNPLANNED loss of RCS / reactor vessel inventory 92 CU3 UNPLANNED loss of decay heat removal capability with irradiated fuel in the 94 reactor vessel CA3 Inability to maintain plant in Cold Shutdown 101 CU5 AC power capability to Vital 4.16 KV busses reduced to a single power source 95 15 minutes such that any additional single power source failure would result in station blackout

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 66 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 TABLE OF CONTENTS SECTION PAGE Cold Shutdown / Refueling System Malfunction (continued)

CA5 Loss of all offsite and all onsite AC power to Vital 4.16KV busses 15 minutes 103 CU6 Loss of required DC power 15 minutes 96 CU7 Inadvertent criticality 97 CU8 Loss of all onsite or offsite communications capabilities 98 Independent Spent Fuel Storage Installation (ISFSI) Malfunction 108 E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY 109 Fission Product Barrier Degradation........................................................................................110 General Bases 111 Fuel Clad Barrier EALs (FCB) 112 RCS Barrier EALs (RCB) 117 Containment Barrier EALS (CNB) 120 Hazards and Other Conditions Affecting Plant Safety ...........................................................128 HU1 Confirmed SECURITY CONDITION or threat which indicates a potential 129 degradation in the level of safety of the plant HA1 HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack 140 threat HS1 HOSTILE ACTION within the PROTECTED AREA 152 HG1 HOSTILE ACTION resulting in loss of physical control of the facility 155 HU2 Other conditions exist which in the judgment of the SM warrant declaration of an 131 NUE HA2 Other conditions exist which in the judgment of the SM / ED warrant declaration of 142 an Alert HS2 Other conditions exist which in the judgment of the SM / ED warrant declaration of 153 a Site Area Emergency HG2 Other conditions exist which in the judgment of the SM / ED warrant declaration of 156 a General Emergency

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 67 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 TABLE OF CONTENTS SECTION PAGE HA3 Control room evacuation has been initiated 143 HS3 Control Room evacuation has been initiated and plant control cannot be 154 established HU4 FIRE within the PROTECTED AREA not extinguished within 15 minutes of 132 detection or EXPLOSION within the PROTECTED AREA HA4 FIRE or EXPLOSION affecting the operability of plant safety systems required to 144 establish or maintain safe shutdown HU5 Release of toxic, corrosive, asphyxiant, or flammable gases deemed detrimental 136 to NORMAL PLANT OPERATIONS HA5 Access to a VITAL AREA is prohibited due to toxic, corrosive, asphyxiant or 147 flammable gases which jeopardize operation of operable equipment required to maintain safe operations or safely shutdown the reactor.

HU6 Natural or destructive phenomena affecting the PROTECTED AREA 137 HA6 Natural or destructive phenomena affecting VITAL AREAS 149 System Malfunction ...................................................................................................................157 SU1 Loss of all offsite AC power to Vital 4.16 KV busses 15 minutes 158 SA1 AC power capability to Vital 4.16 KV busses reduced to a single power source 167 15 minutes such that any additional single power source failure would result in station blackout SS1 Loss of all offsite and all onsite AC power to Vital 4.16 KV busses 15 minutes 171 SG1 Prolonged loss of all offsite and all onsite AC power to Vital 4.16 KV busses 176 SA3 Automatic trip fails to shutdown the reactor and the manual actions taken from the 168 reactor control console are successful in shutting down the reactor SS3 Automatic trip fails to shutdown the reactor and manual actions taken from the 172 reactor control console are not successful in shutting down the reactor SG3 Automatic trip and all manual actions fail to shutdown the reactor and indication of 178 an extreme challenge to the ability to cool the core exists SS4 Loss of all vital DC power 15 minutes 173

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 68 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 TABLE OF CONTENTS SECTION PAGE SU6 UNPLANNED loss of safety system annunciation or indication in the Control 159 Room 15 minutes SA6 UNPLANNED loss of safety system annunciation or indication in the Control 169 Room with either (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable SS6 Inability to monitor a SIGNIFICANT TRANSIENT in progress 174 SU7 RCS leakage 161 SU8 Loss of all onsite or offsite communications capabilities 162 SU9 Fuel clad degradation 163 SU10 Inadvertent criticality 165 SU11 Inability to reach required operating mode within Technical Specification limits 166

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 69 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 GENERAL NOTES ON BASIS DOCUMENT USE Plant Operating Mode Usage for ANO EALs:

UNIT 1:

Mode 1 = Power Operation - Keff 0.99, Reactor Power > 5%

Mode 2 = Startup - Keff .99, Reactor Power 5%

Mode 3 = Hot Standby - Keff < .99, RCS 280 °F Mode 4 = Hot Shutdown - Keff < .99, 280 °F > RCS >200 °F Mode 5 = Cold Shutdown - Keff < .99, RCS 200 °F Mode 6 = Refueling - One or more reactor vessel head closure bolts less than fully tensioned Defueled (D) - All reactor fuel removed from reactor pressure vessel (full core offload during refueling or extended outage). This is not an operating mode designation by Technical Specifications.

UNIT 2:

Mode 1 = Power Operation - Keff 0.99, Reactor Power > 5%, RCS 300 °F Mode 2 = Startup - Keff .99, Reactor Power 5%, RCS 300 °F Mode 3 = Hot Standby - Keff < .99, Reactor Power 0, RCS 300 °F Mode 4 = Hot Shutdown - Keff < .99, Reactor Power 0, 300 °F > RCS > 200 °F Mode 5 = Cold Shutdown - Keff < .99, Reactor Power 0, RCS 200 °F Mode 6 = Refueling - Keff .95, Reactor Power 0, RCS 140 °F Reactor vessel head unbolted or removed and fuel in the vessel Defueled (D) - All reactor fuel removed from reactor pressure vessel (full core offload during refueling or extended outage). This is not an operating mode designation by Technical Specifications.

This basis document serves two basic functions:

It provides background and explanatory information based on NEI 99-01 to present a basis for the origination of the ANO EALs for reviewers and users.

The second function this basis document may provide is an aid to decision makers when making a determination to classify an emergency event. It is intended that decision makers have all the information in Attachment 7.1 of this procedure that they need to make a sound classification decision. Information that may be useful to a decision maker in classifying emergency events is also contained in the Basis section for each IC in the Basis Document.

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

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 70 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 OVERVIEW Emergency Action Levels Planned evolutions involve preplanning to address the limitations imposed by the condition, the performance of required surveillance testing, and the implementation of specific controls prior to knowingly entering the condition in accordance with the specific requirements of the ANO Technical Specifications (TSs). Activities which cause the site to operate beyond that allowed by the TSs, planned or unplanned, may result in an EAL threshold being met or exceeded. Planned evolutions to test, manipulate, repair, perform maintenance or modifications to systems and equipment that result in an EAL value being met or exceeded are not subject to classification and activation requirements as long as the evolution proceeds as planned and is within the operational limitations imposed by the ANO operating license. However, these conditions may be subject to the reporting requirements of 10 CFR 50.72.

Classifications are based on evaluation of each Unit. All classifications are to be based upon valid indications, reports or conditions. Indications, reports or conditions are considered valid when they are verified by (1) an instrument channel check, or (2) indications on related or redundant indications, or (3) by direct observation by plant personnel, such that doubt related to the indications operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

With the emergency classification levels defined, the thresholds that must be met for each EAL to be placed under the EAL can be determined. There are two basic approaches to determining these EALs.

EALs and emergency classification level boundaries coincide for those continuously measurable, instrumented ICs, such as radioactivity, core temperature, coolant levels, etc. For these ICs, the EAL will be the threshold reading that most closely corresponds to the EAL description using the best available information.

For discrete (discontinuous) events, the approach will have to be somewhat different. Typically, in this category are internal and external hazards such as fire or earthquake. The purpose for including hazards in EALs is to assure that station personnel and off-site emergency response organizations are prepared to deal with consequential damage these hazards may cause. If, indeed, hazards have caused damage to safety functions or fission product barriers, this should be confirmed by symptoms or by observation of such failures. Therefore, it may be appropriate to enter an Alert status for events approaching or exceeding design basis limits such as Operating Basis Earthquake (OBE), design basis wind loads, Fire within Vital Areas, etc. This would give the operating staff additional support and improved ability to determine the extent of plant damage. If damage to barriers or challenges to Safety Functions (SFs) have occurred or are identified, then the additional support can be used to escalate or terminate the emergency classification level based on what has been found. Of course, security events must reflect potential for increasing security threat levels.

Plant emergency operating procedures (EOPs) are designed to maintain and/or restore a set of SFs which are listed in the order of priority for restoration efforts during accident conditions.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 71 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 The PWR CSF set includes:

Subcriticality Core cooling Heat sink Pressure-temperature-stress (RCS integrity)

Containment RCS inventory There are diverse and redundant plant systems to support each SF. By monitoring the SFs instead of the individual system component status, the impact of multiple events is inherently addressed, e.g., the number of operable components available to maintain the SF.

The EOPs contain detailed instructions regarding the monitoring of these functions and provides a scheme for classifying the significance of the challenge to the functions. In providing EALs based on these schemes, the emergency classification level can flow from the EOP assessment rather than being based on a separate EAL assessment. This is desirable as it reduces ambiguity and the time necessary to classify the event.

Although the majority of the EALs provide very specific thresholds, the Emergency Director must remain alert to events or conditions that lead to the conclusion that exceeding the EAL is imminent. If, in the judgment of the Emergency Director, an imminent situation is at hand, the classification should be made as if the threshold has been exceeded. While this is particularly prudent at the higher emergency classification levels (as the early classification may provide for more effective implementation of protective measures), it is nonetheless applicable to all emergency classification levels.

Treatment of Multiple Events and Classification Level Upgrading The above discussion deals primarily with simpler emergencies and events that may not escalate rapidly. However, usable EAL guidance must also consider rapidly evolving and complex events.

Hence, emergency classification level upgrading and consideration of multiple events must be addressed.

When multiple simultaneous events occur, the emergency classification level is based on the highest EAL reached. For example, two Alerts remain in the Alert category. Or, an Alert and a SAE is a SAE.

Further guidance is provided in RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events.

Emergency classification level upgrading must also consider the effects of a loss of a common system on more than one unit (e.g. potential for radioactive release from more than one core at the same site).

This must be considered in the emergency classification level declaration and in the development of appropriate site specific ICs and EALs based on the generic EAL guidance.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 72 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 Although the majority of the EALs provide very specific thresholds, the Emergency Director must remain alert to events or conditions that lead to the conclusion that exceeding the EAL is imminent. If, in the judgment of the Emergency Director, an imminent situation is at hand, the classification should be made as if the threshold has been exceeded. While this is particularly prudent at the higher emergency classification levels (as the early classification may provide for more effective implementation of protective measures), it is nonetheless applicable to all emergency classification levels.

Emergency Classification Level Downgrading Another important aspect of usable EAL guidance is the consideration of what to do when the risk posed by an emergency is clearly decreasing. A combination approach involving recovery from GEs and some SAEs, and termination from NUEs, Alerts, and certain SAEs causing no long term plant damage appears to be the best choice. Downgrading to lower emergency classification levels adds notifications, but may have merit under certain circumstances.

Classifying Transient Events For some events, the condition may be corrected before a declaration has been made. The key consideration in this situation is to determine whether or not further plant damage occurred while the corrective actions were being taken. In some situations, this can be readily determined, in other situations, further analyses (e.g., coolant radiochemistry sampling, may be necessary). Classify the event as indicated and terminate the emergency once assessment shows that there were no consequences from the event and other termination criteria are met.

Existing guidance for classifying transient events addresses the period of time of event recognition and classification (15 minutes). However, in cases when EAL declaration criteria may be met momentarily during the normal expected response of the plant, declaration requirements should not be considered to be met when the conditions are a part of the designed plant response, or result from appropriate Operator actions.

There may be cases in which a plant condition that exceeded an EAL was not recognized at the time of occurrence but is identified well after the condition has occurred (e.g., as a result of routine log or record review), and the condition no longer exists. In these cases, an emergency should not be declared.

Reporting requirements of 10 CFR 50.72 are applicable and the guidance of NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73, should be applied.

Operating Mode Applicability The plant operating mode that existed at the time that the event occurred, prior to any protective system or operator action initiated in response to the condition, is compared to the mode applicability of the EALs. If an event occurs, and a lower or higher plant operating mode is reached before the emergency classification level can be declared, the emergency classification level shall be based on the mode that existed at the time the event occurred.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 73 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 For events that occur in Cold Shutdown or Refueling, escalation is via EALs that have Cold Shutdown or Refueling for mode applicability, even if Hot Shutdown (or a higher mode) is entered during any subsequent heat-up. In particular, the fission product barrier EALs are applicable only to events that initiate in Hot Shutdown or higher.

Summary ANO has established an EAL Basis Document including basis information with the IC/EALs. This information may assist the Emergency Director in making classifications, particularly those involving judgment or multiple events. The basis information may also be useful in training, for explaining event classifications to off-site officials, and for facilitating regulatory review and approval of the classification scheme.

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/WORK PLAN TITLE: PAGE: 74 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS /

RADIOLOGICAL EFFLUENTS

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 75 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AU1 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT Any release of gaseous or liquid radioactivity to the environment >2 times the ODCM limits for 60 minutes Operating Mode Applicability: All Example Emergency Action Level(s): (1 or 2 or 3)

Note: The SM should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown.

1. VALID reading on SPING Gas Channel on any of the following radiation monitors > the reading shown for 60 minutes:

MONITORS - UNIT 1 LIMIT RX-9820 Containment Purge 1.18E-02 µCi/cc RX-9825 Radwaste Area 1.07E-02 µCi/cc RX-9830 Fuel Handling Area 9.08E-03 µCi/cc RX-9835 Emergency Penetration Room 1.91E-01 µCi/cc MONITORS - UNIT 2 LIMIT 2RX-9820 Containment Purge 8.92E-03 µCi/cc 2RX-9825 Radwaste Area 6.64E-03 µCi/cc 2RX-9830 Fuel Handling Area 8.92E-03 µCi/cc 2RX-9835 Emergency Penetration Room 1.77E-01 µCi/cc 2RX-9845 Aux. Building Extension 2.53E-02 µCi/cc OR

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 76 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AU1

2. VALID reading on any of the following radiation monitors >2 times the alarm setpoint established by a current release permit for 60 minutes.

EFFLUENT MONITORS - Unit 1 RX-9820 Containment Purge (SPING Gas Channel)

RE-4830 Waste Gas Radiation Monitor RE-4642 Liquid Radwaste Monitor RX-9835 Emerg Penetration Room EFFLUENT MONITORS - Unit 2 2RX-9820 Containment Purge (SPING Gas Channel) 2RE-2429 Waste Gas Decay Tank Vent Line Radiation Monitor 2RE-2330 BMS Liquid Discharge Monitor 2RE-4423 LRW Discharge Monitor 2RE-4425 SG Blowdown to Flume Radiation Monitor OR

3. Confirmed grab sample analyses for gaseous or liquid releases indicates concentrations or release rates >2 times the applicable values of the ODCM for 60 minutes.

Basis: The SM should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

This IC addresses a potential reduction in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time.

ANO incorporates features intended to control the release of radioactive effluents to the environment.

Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls.

The ODCM multiples are specified in AU1 and AA1 only to distinguish between non-emergency conditions, and from each other. While these multiples obviously correspond to an offsite dose or dose rate, the emphasis in classifying these events is the degradation in the level of safety of the plant, NOT the magnitude of the associated dose or dose rate.

Releases should not be prorated or averaged over 60 minutes. For example, a release exceeding 4 times ODCM limits for 30 minutes does not meet the threshold for this IC.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 77 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AU1 This Initiating Condition includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit.

EAL #1 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in the EAL.

This EAL is intended for sites that have established effluent monitoring on non-routine release pathways for which a discharge permit would not normally be prepared.

EAL #2 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in this Initiating Condition established by the release permit.

This value may be associated with a planned batch release, or a continuous release path.

EAL #3 This EAL addresses uncontrolled releases that are detected by sample analyses, particularly on unmonitored pathways, e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, lake, etc.

EAL #1 and #2 directly correlate with the IC since annual average meteorology is required to be used in showing compliance with the ODCM and is used in calculating the alarm setpoints.

Reference Documents:

1. 1604.051, Ventilation Radiation Monitoring System

2. Offsite Dose Calculation Manual

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 78 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AU2 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT UNPLANNED rise in plant radiation levels Operating Mode Applicability: All Example Emergency Action Level(s): (1 or 2)

1. a. UNPLANNED lowering of water level in the refueling canal or spent fuel pool as indicated by:

Personnel observation, refueling crew report, indication on area security camera, borated water source (BWST or RWT) level drop due to makeup demands.

AND

b. VALID Area Radiation Monitor reading rise on any of the following:

Unit 1 RE-8009 Spent Fuel Area RE-8017 Fuel Handling Area Unit 2 2RE-8914 Spent Fuel Area 2RE-8915 Spent Fuel Area 2RE-8916 Spent Fuel Area 2RE-8912 Containment Incore Instrumentation OR

2. UNPLANNED VALID Area Radiation Monitor readings or survey results indicate a rise by a factor of 1000 over normal* levels.

Note: For area radiation monitors with ranges incapable of measuring 1000 times normal*

levels, classification shall be based on VALID full scale indication unless surveys confirm that area radiation levels are below 1000 times normal* within 15 minutes of the Area Radiation Monitor indications going to full scale indication.

• Normal can be considered as the highest reading in the past twenty-four hours excluding the current peak value.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 79 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AU2 Basis:

This IC addresses elevated radiation levels as a result of lowered water level above irradiated fuel or events that have resulted, or may result, in UNPLANNED rises in radiation dose rates within plant buildings. These radiation rises represent a loss of control over radioactive material and represent a potential degradation in the level of safety of the plant.

EAL #1 The refueling pathway is a site specific combination of cavities, tubes, canals and pools. While a radiation monitor could detect a rise in dose rate due to a drop in the water level, it might not be a reliable indication of whether or not the fuel is covered. For example, a refueling bridge ARM reading may rise due to planned evolutions such as head lift, or even a fuel assembly being raised in the manipulator mast. Also, a monitor could in fact be properly responding to a known event involving transfer or relocation of a source, stored in or near the fuel pool or responding to a planned evolution such as removal of the reactor head. Generally, elevated radiation monitor indications will need to be combined with another indicator (or personnel report) of water loss.

For refueling events where the water level drops below the RPV flange classification would be via CU2.

This event escalates to an Alert per AA2 if irradiated fuel outside the reactor vessel is uncovered. For events involving irradiated fuel in the reactor vessel, escalation would be via the Fission Product Barrier Matrix for events in operating Modes 1-4.

EAL #2 This EAL addresses rises in plant radiation levels that represent a loss of control of radioactive material resulting in a potential degradation in the level of safety of the plant.

This EAL excludes radiation level rises that result from planned activities such as use of radiographic sources and movement of radioactive waste materials. A specific list of ARMs is not required as it would restrict the applicability of the Threshold. The intent is to identify loss of control of radioactive material in any monitored area.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 80 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AA1 Initiating Condition - ALERT Any release of gaseous or liquid radioactivity to the environment >200 times the ODCM limits for 15 minutes Operating Mode Applicability: All Example Emergency Action Level(s): (1 or 2 or 3)

Note: The SM / ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown.

1. VALID reading on SPING Gas Channel on any of the following radiation monitors > the reading shown for 15 minutes:

MONITORS - UNIT 1 LIMIT RX-9820 Containment Purge 1.18E+00 µCi/cc RX-9825 Radwaste Area 1.07E+00 µCi/cc RX-9830 Fuel Handling Area 9.08E-01 µCi/cc RX-9835 Emergency Penetration Room 1.91E+01 µCi/cc MONITORS - UNIT 2 LIMIT 2RX-9820 Containment Purge 8.92E-01 µCi/cc 2RX-9825 Radwaste Area 6.64E-01 µCi/cc 2RX-9830 Fuel Handling Area 8.92E-01 µCi/cc 2RX-9835 Emergency Penetration Room 1.77E+01 µCi/cc 2RX-9845 Aux. Building Extension 2.53E+00 µCi/cc OR

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 81 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AA1

2. EITHER VALID reading on any of the following radiation monitors > 200 times the alarm setpoint established by a current release permit for 15 minutes OR VALID reading greater than the value listed for 15 minutes.

MONITORS - UNIT 1 LIMIT RX-9820 Containment Purge (SPING Gas Channel) N/A RE-4830 Waste Gas Radiation Monitor 9.5E7 cpm RE-4642 Liquid Radwaste Monitor 9.5E7 cpm RX-9835 Emerg Penetration Room MONITORS - UNIT 2 LIMIT 2RX-9820 Containment Purge (SPING Gas Channel) N/A 2RE-2429 Waste Gas Monitoring System 9.5E5 cpm 2RE-2330 BMS Liquid Discharge Monitor 9.5E5 cpm 2RE-4423 LRW Discharge Monitor 9.5E5 cpm 2RE-4425 SG Blowdown to Flume Radiation Monitor 9.5E5 cpm OR

3. Confirmed grab sample analyses for gaseous or liquid releases indicates concentrations or release rates > 200 times the applicable values of the ODCM for 15 minutes.

Basis: The SM / ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

This IC addresses an actual or substantial potential reduction in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time.

ANO incorporates features intended to control the release of radioactive effluents to the environment.

Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls.

The ODCM multiples are specified in AU1 and AA1 only to distinguish between non-emergency conditions, and from each other. While these multiples obviously correspond to an offsite dose or dose rate, the emphasis in classifying these events is the degradation in the level of safety of the plant, NOT the magnitude of the associated dose or dose rate.

Releases should not be prorated or averaged. For example, a release exceeding 600 times ODCM limits for 5 minutes does not meet the threshold for this IC.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 82 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AA1 This Initiating Condition includes any release for which a release permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.)

on the applicable permit.

EAL #1 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in the Initiating Condition.

This EAL is intended for sites that have established effluent monitoring on non-routine release pathways for which a discharge permit would not normally be prepared.

EAL #2 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in this Initiating Condition established by the radioactivity discharge permit. This value may be associated with a planned batch release, or a continuous release path. The limit values provided are for those cases in which the maximum monitor range is less than the release permit value multiplied by 200.

EAL #3 This EAL addresses uncontrolled releases that are detected by sample analyses, particularly on unmonitored pathways, e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, lake, etc.

EAL #1 and #2 directly correlate with the IC since annual average meteorology is required to be used in showing compliance with the ODCM and is used in calculating the alarm setpoints.

Reference Documents:

1. 1604.051, Ventilation Radiation Monitoring System

2. Offsite Dose Calculation Manual

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 83 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AA2 Initiating Condition - ALERT Damage to irradiated fuel or loss of water level that has resulted or will result in the uncovering of irradiated fuel outside the reactor vessel Operating Mode Applicability: All Example Emergency Action Level(s): (1 or 2)

1. A water level drop in the refueling canal or spent fuel pool that will result in irradiated fuel becoming uncovered.

OR

2. VALID alarm on any of the following radiation monitors due to damage to irradiated fuel or loss of water level.

Unit 1 RX-9820 Containment Purge (SPING Gas Channel)

RX-9825 Radwaste Area (SPING Gas Channel)

RX-9830 Fuel Handling Area (SPING Gas Channel)

RE-8060 Containment High Range Radiation Monitors RE-8061 Containment High Range Radiation Monitors RE-8009 Spent Fuel Area RE-8017 Fuel Handling Area Unit 2 2RX-9820 Containment Purge (SPING Gas Channel) 2RX-9825 Radwaste Area (SPING Gas Channel) 2RX-9830 Fuel Handling Area (SPING Gas Channel) 2RE-8905 Containment Equipment Hatch Area 2RE-8909 Containment Personnel Access Area 2RE-8925-1 Containment High Range Radiation Monitors 2RE-8925-2 Containment High Range Radiation Monitors 2RE-8914 Spent Fuel Area 2RE-8915 Spent Fuel Area 2RE-8916 Spent Fuel Area 2RE-8912 Containment Incore Inst.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 84 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AA2 Basis:

This IC addresses rises in radiation dose rates within plant buildings, and may be a precursor to a radioactivity release to the environment. These events represent a loss of control over radioactive material and represent an actual or substantial potential degradation in the level of safety of the plant.

These events escalate from AU2 in that fuel activity has been released, or is anticipated due to fuel heatup. This IC applies to spent fuel requiring water coverage and is not intended to address spent fuel which is licensed for dry storage.

EAL #1 Indications may include instrumentation such as water level and local area radiation monitors, and personnel (e.g., refueling crew) reports. Depending on available level indication, the declaration may be based on indications of water makeup rate or drop in applicable borated water storage tank level. Video cameras (Security or outage-related) may allow remote observation of level.

EAL #2 This EAL addresses radiation monitor indications of fuel uncovery and/or fuel damage.

Elevated ventilation monitor readings may be indication of a radioactivity release from the fuel, confirming that damage has occurred. Elevated background at the ventilation monitor due to water level drop may mask elevated ventilation exhaust airborne activity and needs to be considered.

While a radiation monitor could detect a rise in dose rate due to a drop in the water level, it might not be a reliable indication of whether or not the fuel is covered.

For example, a refueling bridge ARM reading may rise due to planned evolutions such as head lift, or even a fuel assembly being raised in the manipulator mast. Also, a monitor could in fact be properly responding to a known event involving transfer or relocation of a source, stored in or near the fuel pool or responding to a planned evolution such as removal of the reactor head. Generally, elevated radiation monitor indications will need to be combined with another indicator (or personnel report) of water loss.

Escalation of this emergency classification level, if appropriate, would be based on AS1 or AG1.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 85 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AA3 Initiating Condition - ALERT Rise in radiation levels within the facility that impedes operation of systems required to maintain plant safety functions Operating Mode Applicability: All Example Emergency Action Level(s):

Dose rate > 15 mR/hr in any of the following areas requiring continuous occupancy to maintain plant safety functions:

Unit 1 Control Room Unit 2 Control Room Central Alarm Station Basis:

This IC addresses elevated radiation levels that impact continued operation in areas requiring continuous occupancy to maintain safe operation or to perform a safe shutdown.

The cause and/or magnitude of the rise in radiation levels is not a concern of this IC. The SM/ED must consider the source or cause of the elevated radiation levels and determine if any other IC may be involved.

This IC is not meant to apply to rises in the containment dome radiation monitors as these are events which are addressed in the fission product barrier matrix EALs.

Areas requiring continuous occupancy include the Control Rooms and the Central Alarm Station.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 86 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AS1 Initiating Condition -- SITE AREA EMERGENCY Offsite dose resulting from an actual or IMMINENT release of gaseous radioactivity >100 mR TEDE or 500 mR child thyroid CDE for the actual or projected duration of the release Operating Mode Applicability: All Example Emergency Action Level(s): (1 or 2 or 3)

Note: The SM / ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. If dose assessment results are available, the classification should be based on EAL #2 instead of EAL #1. Do not delay declaration awaiting dose assessment results.

1. VALID reading on SPING Gas Channel on any of the following radiation monitors > the reading shown for 15 minutes:

MONITORS - UNIT 1 LIMIT RX-9820 Containment Purge 1.18E+01 µCi/cc RX-9825 Radwaste Area 1.07E+01 µCi/cc RX-9830 Fuel Handling Area 9.08E+00 µCi/cc RX-9835 Emergency Penetration Room 1.91E+02 µCi/cc MONITORS - UNIT 2 LIMIT 2RX-9820 Containment Purge 8.92E+00 µCi/cc 2RX-9825 Radwaste Area 6.64E+00 µCi/cc 2RX-9830 Fuel Handling Area 8.92E+00 µCi/cc 2RX-9835 Emergency Penetration Room 1.77E+02 µCi/cc 2RX-9845 Aux. Building Extension 2.53E+01 µCi/cc OR

2. Dose assessment using actual meteorology indicates doses > 100 mR TEDE or 500 mR child thyroid CDE at or beyond the site boundary.

OR

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 87 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AS1

3. Field survey results indicate closed window dose rates >100 mR/hr expected to continue for 60 minutes; or analyses of field survey samples indicate child thyroid CDE >500 mR for one hour of inhalation, at or beyond the site boundary.

Basis:

This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

EAL #1 The monitor list in EAL #1 includes monitors on all potential release pathways (plant stack, primary-secondary leak, fuel handling accident).

EAL #2 Since dose assessment in EAL #2 is based on actual meteorology, whereas the monitor readings in EAL #1 are not, the results from these assessments may indicate that the classification is not warranted, or may indicate that a higher classification is warranted. For this reason, emergency implementing procedures should call for the timely performance of dose assessments using actual meteorology and release information. If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor reading EALs.

EAL #3 Field team surveys in EAL #3 should be performed at or beyond the SITE BOUNDARY and at the most accurate indicator of the condition. Field data are independent of release elevation and meteorology.

The assumed release duration is one hour. Expected post accident source terms would be dominated by noble gases providing the dose rate value. Sampling of radioiodine by adsorption on a charcoal cartridge should determine the iodine value.

Reference Documents:

1. 1604.051, Ventilation Radiation Monitoring System

2. Offsite Dose Calculation Manual

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 88 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AG1 Initiating Condition -- GENERAL EMERGENCY Offsite dose resulting from an actual or IMMINENT release of gaseous radioactivity >1000 mR TEDE or 5000 mR child thyroid CDE for the actual or projected duration of the release using actual meteorology Operating Mode Applicability: All Example Emergency Action Level(s): (1 or 2 or 3)

Note: The SM / ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

If dose assessment results are available, the classification should be based on EAL #2 instead of EAL #1. Do not delay declaration awaiting dose assessment results.

1. VALID reading on SPING Gas Channel on any of the following radiation monitors > the reading shown for 15 minutes:

MONITORS - UNIT 1 LIMIT RX-9820 Containment Purge 1.18E+02 (Ci/cc)

RX-9825 Radwaste Area 1.07E+02 (Ci/cc)

RX-9830 Fuel Handling Area 9.08E+01 (Ci/cc)

RX-9835 Emergency Penetration Room 1.91E+03 (Ci/cc)

MONITORS - UNIT 2 LIMIT 2RX-9820 Containment Purge 8.92E+01 (Ci/cc) 2RX-9825 Radwaste Area 6.64E+01 (Ci/cc) 2RX-9830 Fuel Handling Area 8.92E+01 (Ci/cc) 2RX-9835 Emergency Penetration Room 1.77E+03 (Ci/cc) 2RX-9845 Aux. Building Extension 2.53E+02 (Ci/cc)

OR

2. Dose assessment using actual meteorology indicates doses >1000 mR TEDE or 5000 mR child thyroid CDE at or beyond the site boundary.

OR

3. Field survey results indicate closed window dose rates >1000 mR/hr expected to continue for 60 minutes; or analyses of field survey samples indicate child thyroid CDE >5000 mR for one hour of inhalation, at or beyond the site boundary.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 89 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENTS AG1 Basis:

This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed the EPA Protective Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and likely involve fuel damage.

EAL #1 The monitor list in EAL #1 includes monitors on all potential release pathways (plant stack, primary-secondary leak, fuel handling accident).

EAL #2 Since dose assessment in EAL #2 is based on actual meteorology, whereas the monitor readings in EAL #1 are not, the results from these assessments may indicate that the classification is not warranted.

For this reason, emergency implementing procedures should call for the timely performance of dose assessments using actual meteorology and release information. If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level),

the dose assessment results override the monitor reading EALs.

EAL #3 Field team surveys in EAL #3 should be performed at or beyond the SITE BOUNDARY and at the most accurate indicator of the condition. Field data are independent of release elevation and meteorology.

The assumed release duration is one hour. Expected post accident source terms would be dominated by noble gases providing the dose rate value. Sampling of radioiodine by adsorption on a charcoal cartridge should determine the iodine value.

Reference Documents:

1. 1604.051, Ventilation Radiation Monitoring System

2. Offsite Dose Calculation Manual

PROC./WORK PLAN N

O. PROCEDURE

/WORK PLAN TITLE: PAGE: 90 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 Cold Shutdown / Refueling System Malfunction

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 91 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CU1 Initiating Condition -- NOTIFICATION OF UNUSUAL EVENT RCS leakage Operating Mode Applicability: Cold Shutdown (Mode 5)

Example Emergency Action Level(s):

Note: The SM should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. RCS leakage results in the inability to maintain or restore level within Pressurizer or RCS level target band for 15 minutes.

Basis:

This IC is considered to be a potential degradation of the level of safety of the plant. The inability to maintain or restore level is indicative of loss of RCS inventory.

Relief valve normal operation should be excluded from this IC. However, a relief valve that operates and fails to close per design should be considered applicable to this IC if the relief valve cannot be isolated.

Prolonged loss of RCS Inventory may result in escalation to the Alert emergency classification level via either CA1 or CA3.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 92 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CU2 Initiating Condition -- NOTIFICATION OF UNUSUAL EVENT UNPLANNED loss of RCS / reactor vessel inventory Operating Mode Applicability: Refueling (Mode 6)

Example Emergency Action Level(s): (1 or 2)

Note: The SM should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. UNPLANNED RCS / reactor vessel level drop as indicated by either of the following:

a. RCS / reactor vessel water level drop below the reactor vessel flange for 15 minutes when the RCS / reactor vessel level band is established above the reactor vessel flange OR

b. RCS / reactor vessel water level drop below the RCS / reactor vessel level band for 15 minutes or longer when the RCS / reactor vessel level band is established below the reactor vessel flange.

OR

2. RCS / reactor vessel level cannot be monitored with a loss of RCS / reactor vessel inventory as indicated by an unexplained level rise in (as applicable) the Reactor Building Sump, Reactor Drain Tank, Aux. Building Equipment Drain Tank, Aux. Building Sump, or Quench Tank.

Basis:

This IC is a precursor of more serious conditions and considered to be a potential degradation of the level of safety of the plant.

Refueling evolutions that lower RCS water level below the reactor vessel flange are carefully planned and procedurally controlled. An UNPLANNED event that results in water level dropping below the reactor vessel flange, or below the planned RCS water level for the given evolution (if the planned RCS water level is already below the reactor vessel flange), warrants declaration of an NUE due to the lowered RCS inventory that is available to keep the core covered.

The allowance of 15 minutes was chosen because it is reasonable to assume that level can be restored within this time frame using one or more of the redundant means of refill that should be available. If level cannot be restored in this time frame then it may indicate a more serious condition exists.

Continued loss of RCS Inventory will result in escalation to the Alert emergency classification level via either CA1 or CA3.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 93 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CU2 EAL #1 This EAL involves a drop in RCS level below the top of the reactor vessel flange that continues for 15 minutes due to an UNPLANNED event. This EAL is not applicable to drops in flooded reactor cavity level, which is addressed by AU2 EAL1, until such time as the level drops to the level of the vessel flange.

If reactor vessel level continues to drop and reaches the Bottom ID of the RCS Loop then escalation to CA1 would be appropriate.

EAL #2 This EAL addresses conditions in the refueling mode when normal means of core temperature indication and RCS level indication may not be available. Redundant means of reactor vessel level indication will normally be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted. However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that reactor vessel inventory loss was occurring by observing sump and tank level changes. Sump and tank level rises must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.

Escalation to the Alert emergency classification level would be via either CA1 or CA3.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 94 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CU3 Initiating Condition -- NOTIFICATION OF UNUSUAL EVENT UNPLANNED loss of decay heat removal capability with irradiated fuel in the reactor vessel Operating Mode Applicability: Cold Shutdown (Mode 5)

Refueling (Mode 6)

Example Emergency Action Level(s): (1 or 2)

Note: The SM should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. UNPLANNED event results in RCS temperature exceeding 200 °F.

OR

2. Loss of all RCS temperature and RCS/reactor vessel level indication for 15 minutes.

Basis:

This IC is 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. In cold shutdown the ability to remove decay heat relies primarily on forced cooling flow. Operation of the systems that provide this forced cooling may be jeopardized due to the unlikely loss of electrical power or RCS inventory. Since the RCS usually remains intact in the cold shutdown mode a large inventory of water is available to keep the core covered.

During refueling the level in the reactor vessel will normally be maintained above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and procedurally controlled. Loss of forced decay heat removal at lowered inventory may result in more rapid rises in RCS/reactor vessel temperatures depending on the time since shutdown.

Normal means of core temperature indication and RCS level indication may not be available in the refueling mode. Redundant means of reactor vessel level indication are therefore procedurally installed to assure that the ability to monitor level will not be interrupted. However, if all level and temperature indication were to be lost in either the cold shutdown of refueling modes, EAL 2 would result in declaration of an NUE if both temperature and level indication cannot be restored within 15 minutes from the loss of both means of indication.

Escalation to Alert would be via CA1 based on an inventory loss or CA3 based on exceeding its temperature criteria.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 95 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CU5 Initiating Condition -- NOTIFICATION OF UNUSUAL EVENT AC power capability to Vital 4.16 KV busses reduced to a single power source 15 minutes such that any additional single power source failure would result in station blackout Operating Mode Applicability: Cold Shutdown (Mode 5)

Refueling (Mode 6)

Example Emergency Action Level(s):

Note: The SM should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. a. AC power capability to Vital 4.16 KV busses reduced to a single power source 15 minutes.

AND

b. Any additional single power source failure will result in station blackout.

Basis:

The condition indicated by this IC is the degradation of the offsite and onsite AC power systems such that any additional single power source failure would result in a station blackout. This condition could occur due to a loss of offsite power with a concurrent failure of all but one emergency generator to supply power to its emergency busses. The subsequent loss of this single power source would escalate the event to an Alert in accordance with CA5.

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

The EAL allows credit for operation of the Alternate AC Diesel Generator.

Reference Documents:

1. 1202.007, Degraded Power

2. 1202.008, Blackout

3. 2202.007, Loss of Off-Site Power

4. 2202.008, Station Blackout

5. 2104.037, Alternate AC Diesel Generator Operations

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 96 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CU6 Initiating Condition -- NOTIFICATION OF UNUSUAL EVENT Loss of required DC power 15 minutes Operating Mode Applicability: Cold Shutdown (Mode 5)

Refueling (Mode 6)

Example Emergency Action Level(s):

Note: The SM should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. < 105 volts on required Vital DC bus 15 minutes.

Basis:

The purpose of this IC and its associated EALs 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.

It is intended that the loss of the operating (operable) train is to be considered. If this loss results in the inability to maintain cold shutdown, the escalation to an Alert will be per CA3.

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

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 97 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CU7 Initiating Condition -- NOTIFICATION OF UNUSUAL EVENT Inadvertent criticality Operating Mode Applicability: Cold Shutdown (Mode 5)

Refueling (Mode 6)

Example Emergency Action Level(s):

1. UNPLANNED sustained positive startup rate observed on nuclear instrumentation.

Basis:

This IC addresses criticality events that occur in Cold Shutdown or Refueling modes such as fuel mis-loading events and inadvertent dilution events. This IC indicates a potential degradation of the level of safety of the plant, warranting an NUE classification.

This condition can be identified using the startup rate meter. The term sustained is used in order to allow exclusion of expected short term positive startup rates from planned fuel bundle or control rod movements during core alteration. These short term positive startup rates are the result of the rise in neutron population due to subcritical multiplication.

Escalation would be by SM judgment.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 98 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CU8 Initiating Condition -- NOTIFICATION OF UNUSUAL EVENT Loss of all onsite or offsite communications capabilities Operating Mode Applicability: Cold Shutdown (Mode 5)

Refueling (Mode 6)

Defueled Example Emergency Action Level(s): (1 or 2)

1. Loss of all Table C2 onsite communication methods affecting the ability to perform routine operations.

OR

2. Loss of all Table C3 offsite communication methods affecting the ability to perform offsite notifications.

Table C2 Table C3 Onsite Communications Methods Offsite Communications Methods Station radio system All telephone lines (commercial and microwave)

Plant paging system ENS In-plant telephones Gaitronics Basis:

The purpose of this IC and its associated EALs 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 issues with offsite authorities. The loss of off-site communications ability is expected to be significantly more comprehensive than the condition addressed by 10 CFR 50.72.

The availability of one method of ordinary offsite communications is sufficient to inform federal, state, and local authorities of plant issues. This EAL is intended to be used only when extraordinary means (e.g., relaying of information from radio transmissions, individuals being sent to offsite locations, etc.)

are being utilized to make communications possible.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 99 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CA1 Initiating Condition - ALERT Loss of RCS / reactor vessel inventory Operating Mode Applicability: Cold Shutdown (Mode 5)

Refueling (Mode 6)

Example Emergency Action Level(s): (1 or 2)

Note: The SM / ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. Loss of RCS / reactor vessel inventory as indicated by:

Unit 1: RVLMS Levels 1 through 8 indicate DRY Unit 2: RVLMS Levels 1 through 5 indicate DRY OR Unit 1: Reactor vessel level < 368 ft., 6 in. (bottom of the hot leg)

Unit 2: Reactor vessel level < 369 ft., 1.5 in. (bottom of the hot leg)

OR

2. RCS / reactor vessel level cannot be monitored for 15 minutes with a loss of RCS / reactor vessel inventory as indicated by an unexplained level rise in (as applicable) the Reactor Building Sump, Reactor Drain Tank, Aux. Building Equipment Drain Tank, Aux. Building Sump, or Quench Tank.

Basis:

These EALs serve as precursors to a loss of ability to adequately cool the fuel. The magnitude of this loss of water indicates that makeup systems have not been effective and may not be capable of preventing further reactor vessel level lowering and potential core uncovery. This condition will result in a minimum emergency classification level of an Alert.

EAL #1 The bottom of the RCS hot leg penetration into the reactor vessel is approximately RLVMS Level 8 (Unit

1) or RVLMS Level 5 (Unit 2). However, RVLMS may not be available in mode 6. Redundant means level indication is provided in this mode and included in EAL #1. The bottom of the RCS hot leg penetration into the reactor vessel is 368 ft., 6 in. (Unit 1) or 369 ft., 1.5 in. (Unit 2). Below this level, reactor vessel level indication will be lost and loss of suction to decay heat removal systems will occur.

The inability to restore and maintain level after reaching this setpoint would be indicative of a failure of the RCS barrier.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 100 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CA1 EAL #2 In the cold shutdown mode, normal RCS level and reactor vessel level instrumentation systems will usually be available. In the refueling mode, normal means of reactor vessel level indication may not be available. Redundant means of reactor vessel level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted.

However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that reactor vessel inventory loss was occurring by observing sump and tank level changes. Sump and tank level rises must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.

If reactor vessel level continues to lower then escalation to Site Area Emergency will be via CS1.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 101 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CA3 Initiating Condition - ALERT Inability to maintain plant in Cold Shutdown Operating Mode Applicability: Cold Shutdown (Mode 5)

Refueling (Mode 6)

Example Emergency Action Level(s): (1 or 2)

1. An UNPLANNED event results in RCS temperature >200 °F > the specified duration in Table C1.

Table C1 RCS Reheat Duration Thresholds RCS Containment Closure Duration Intact (but not RCS Lowered Inventory) N/A 60 minutes*

Established 20 minutes*

Not intact or RCS Lowered Inventory Not Established 0 minutes

• If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.

OR Note: EAL #2 does not apply in solid plant conditions.

2. An UNPLANNED event results in RCS pressure rise >10 psi due to a loss of RCS cooling.

Basis:

EAL #1 The RCS Reheat Duration Threshold table addresses complete loss of functions required for core cooling for greater than 60 minutes during refueling and cold shutdown modes when RCS integrity is established. RCS integrity should be considered to be in place when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams).

The 60 minute time frame should allow sufficient time to restore cooling without there being a substantial degradation in plant safety.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 102 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CA3 The RCS Reheat Duration Threshold table also addresses the complete loss of functions required for core cooling for greater than 20 minutes during refueling and cold shutdown modes when CONTAINMENT CLOSURE is established but RCS integrity is not established or RCS inventory is lowered (e.g., mid-loop operation ). As discussed above, RCS integrity should be assumed to be in place when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams). The allowed 20 minute time frame was included to allow operator action to restore the heat removal function, if possible.

Finally, the EAL addresses complete loss of functions required for core cooling during refueling and cold shutdown modes when neither CONTAINMENT CLOSURE nor RCS integrity are established.

The (*) indicates that this EAL is not applicable if actions are successful in restoring an RCS heat removal system to operation and RCS temperature is being reduced within the specified time frame.

EAL #2 The 10 psi pressure rise addresses situations where, due to high decay heat loads, the time provided to restore temperature control, should be less than 60 minutes. The RCS pressure setpoint chosen should be 10 psi or the lowest pressure that the site can read on installed Control Board instrumentation that is equal to or greater than 10 psi.

Escalation to Site Area Emergency would be via CS1 should boiling result in significant reactor vessel level loss leading to core uncovery.

A loss of Technical Specification components alone is not intended to constitute an Alert. The same is true of a momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available.

The SM / ED must remain alert to events or conditions that lead to the conclusion that exceeding the EAL is IMMINENT. If, in the judgment of the SM / ED, an IMMINENT situation is at hand, the classification should be made as if the threshold has been exceeded.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 103 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CA5 Initiating Condition - ALERT Loss of all offsite and all onsite AC power to Vital 4.16KV busses 15 minutes Operating Mode Applicability: Cold Shutdown (Mode 5)

Refueling (Mode 6)

Defueled Example Emergency Action Level(s):

Note: The SM / ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. Loss of all offsite and all on-site AC power to Vital 4.16KV busses 15 minutes.

Basis:

Loss of all AC power compromises all plant safety systems requiring electric power including DHR/shutdown cooling, emergency core cooling, containment cooling, spent fuel pool cooling and the ultimate heat sink.

The event can be classified as an Alert when in cold shutdown, refueling, or defueled mode because of the significantly reduced decay heat and lower temperature and pressure, which allow raising the time to restore one of the emergency busses, relative to that specified for the Site Area Emergency EAL.

Escalating to Site Area Emergency, if appropriate, is by Abnormal Radiation Levels/ Radiological Effluent (TAB A) ICs.

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

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 104 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CS1 Initiating Condition - SITE AREA EMERGENCY Loss of RCS / reactor vessel inventory affecting core decay heat removal capability Operating Mode Applicability: Cold Shutdown (Mode 5)

Refueling (Mode 6)

Example Emergency Action Level(s): (1 or 2)

Note: The SM / ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. With CONTAINMENT CLOSURE not established:

Unit 1: RVLMS Levels 1 through 9 indicate DRY Unit 2: RVLMS Levels 1 through 6 indicate DRY OR

2. With CONTAINMENT CLOSURE established, core exit thermocouples indicate superheat.

OR

3. RCS / reactor vessel level cannot be monitored for 30 minutes with a loss of RCS / reactor vessel inventory as indicated by any of the following:

Containment High Range Radiation Monitor reading > 10 R/hr Erratic source range monitor indication Unexplained level rise in Reactor Building Sump, Reactor Drain Tank, Quench Tank, Aux.

Building Equipment Drain Tank, or Aux. Building Sump.

Basis:

Under the conditions specified by this IC, continued lowering in RCS / reactor vessel level is indicative of a loss of inventory control. Inventory loss may be due to an RCS breach, pressure boundary leakage, or continued boiling in the RPV. Thus, declaration of a Site Area Emergency is warranted.

Escalation to a General Emergency is via CG1 or AG1.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 105 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CS1 EAL #3 In the cold shutdown mode, normal RCS level and reactor vessel level instrumentation systems will usually be available. In the refueling mode, normal means of reactor vessel level indication may not be available. Redundant means of reactor vessel level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted.

However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that reactor vessel inventory loss was occurring by observing sump and tank level changes. Sump and tank level rises must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.

The 30-minute duration allows sufficient time for actions to be performed to recover inventory control equipment.

As water level in the reactor vessel lowers, the dose rate above the core will rise. The dose rate due to this core shine should result in site specific monitor indication and possible alarm.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 106 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CG1 Initiating Condition - GENERAL EMERGENCY Loss of RCS / reactor vessel inventory affecting fuel clad integrity with containment challenged Operating Mode Applicability: Cold Shutdown (Mode 5)

Refueling (Mode 6)

Example Emergency Action Level(s):

Note: The SM / ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. a. Core exit thermocouples indicate superheat for 30 minutes.

AND

b. Any of the following containment challenge indications:

CONTAINMENT CLOSURE not established Explosive mixture inside containment UNPLANNED rise in containment pressure OR

2. a. RCS / reactor vessel level cannot be monitored for 30 minutes with a loss of RCS / reactor vessel inventory as indicated by any of the following:

Containment High Range Radiation Monitor reading > 10 R/hr Erratic source range monitor indication Unexplained level rise in Reactor Building Sump, Reactor Drain Tank, Quench Tank, Aux.

Building Equipment Drain Tank, or Aux. Building Sump AND

b. Any of the following containment challenge indications:

CONTAINMENT CLOSURE not established Explosive mixture inside containment UNPLANNED rise in containment pressure

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 107 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION CG1 Basis:

This IC represents the inability to restore and maintain reactor vessel level to above the top of active fuel with containment challenged. Fuel damage is probable if reactor vessel level cannot be restored, as available decay heat will cause boiling, further reducing the reactor vessel level. With the CONTAINMENT breached or challenged then the potential for unmonitored fission product release to the environment is high. This represents a direct path for radioactive inventory to be released to the environment. This is consistent with the definition of a GE. The GE is declared on the occurrence of the loss or IMMINENT loss of function of all three barriers.

A number of variables can have a significant impact on heat removal capability challenging the fuel clad barrier. Examples include mid-loop, reduced level / flange level, head in place, cavity flooded, RCS venting strategy, decay heat removal system design, vortexing pre-disposition, and steam generator U-tube draining.

Analysis indicates that core damage may occur within an hour following continued core uncovery therefore, 30 minutes was conservatively chosen.

If CONTAINMENT CLOSURE is re-established prior to exceeding the 30 minute core uncovery time limit then escalation to GE would not occur.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive mixture of dissolved gasses in Containment. However, Containment monitoring and/or sampling should be performed to verify this assumption and a General Emergency declared if it is determined that an explosive mixture exists.

Sump and tank level rises must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.

In the cold shutdown mode, normal RCS level and reactor vessel level instrumentation systems will usually be available. In the refueling mode, normal means of reactor vessel level indication may not be available. Redundant means of reactor vessel level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted.

However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that reactor vessel inventory loss was occurring by observing sump and tank level changes. Sump and tank level rises must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.

As water level in the reactor vessel lowers, the dose rate above the core will rise. The dose rate due to this core shine should result in site specific monitor indication and possible alarm.

Reference Documents:

1. ULD-1-SYS-24, Unit 1 Inadequate Core Cooling

2. ULD-2-SYS-24, Unit 2 Inadequate Core Cooling

PROC./WORK PLAN N

O. PROCEDURE

/WORK PLAN TITLE: PAGE: 108 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) MALFUNCTION

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 109 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 ISFSI MALFUNCTION E-HU1 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT Note: Security Events are bounded by the Hazards EALs.

Damage to a loaded cask CONFINEMENT BOUNDARY Operating Mode Applicability: All Example Emergency Action Level(s):

1. Damage to a loaded cask CONFINEMENT BOUNDARY.

Basis:

An NUE in this IC is categorized on the basis of the occurrence of an event of sufficient magnitude that a loaded cask CONFINEMENT BOUNDARY is damaged or violated. This includes classification based on a loaded fuel storage cask CONFINEMENT BOUNDARY loss leading to the degradation of the fuel during storage or posing an operational safety problem with respect to its removal from storage.

This EAL addresses a dropped cask, a tipped over cask, EXPLOSION, PROJECTILE damage, FIRE damage or natural phenomena affecting a cask (e.g., seismic event, tornado, etc.).

PROC./WORK PLAN N

O. PROCEDURE

/WORK PLAN TITLE: PAGE: 110 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER DEGRADATION

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 111 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 General Bases The logic used for these initiating conditions reflects the following considerations:

The Fuel Clad Barrier and the RCS Barrier are weighted more heavily than the Containment Barrier (See Sections 3.4 and 3.8). NUE ICs associated with RCS and Fuel Clad Barriers are addressed under System Malfunction (S) ICs.

At the Site Area Emergency level, there must be some ability to dynamically assess how far present conditions are from the threshold for a General Emergency. For example, if Fuel Clad and RCS Barrier Loss EALs existed, that, in addition to off-site dose assessments, would require continual assessments of radioactive inventory and containment integrity. Alternatively, if both Fuel Clad and RCS Barrier Potential Loss EALs existed, the SM / ED 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 deteriorates must be maintained. For example, RCS leakage steadily increasing would represent an increasing risk to public health and safety.

The Containment Barrier should not be declared lost or potentially lost based on exceeding Technical Specification action statement criteria, unless there is an event in progress requiring mitigation by the Containment barrier. When no event is in progress (Loss or Potential Loss of either Fuel Clad and/or RCS) the Containment Barrier status is addressed by Technical Specifications.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 112 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER FUEL CLAD Fuel Clad Barrier Emergency Action Levels: FCB1 OR FCB2 OR FCB3 OR FCB4 OR FCB5 OR FCB6 The Fuel Clad barrier consists of the zircalloy or stainless steel fuel bundle tubes that contain the fuel pellets.

1. Primary Coolant Activity Level (FCB1)

Loss:

1. Coolant activity > 300 µCi/gm dose equivalent I-131 activity by Chemistry sample OR

2. Radiation levels > 1000 mR/hr Unit 1: at SA-229 Unit 2: at 2TCD-19 Potential Loss: None Basis:

Loss The site specific value corresponds to 300 Ci/gm I-131 equivalent. Assessment by the EAL Task Force indicates that this amount of coolant activity is well above that expected for iodine spikes and corresponds to less than 5% fuel clad damage. This amount of radioactivity indicates significant clad damage and thus the Fuel Clad Barrier is considered lost.

A reading of greater than 1000 mR/hr within at one foot from the RCS sample lines (SA-229 for Unit 1, 2TCD-19 for Unit 2) has been determined to correspond to fuel clad failure of approximately 2-5%, and thus the fuel clad barrier is considered lost. This reading is well above that expected for iodine spikes and thus indicates significant clad damage and thus the fuel clad barrier is considered lost.

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

Reference Documents

1. ANO Calculation 03-E-0002-01, Radiation Monitor EAL Setpoints for Fission Product Barrier Degradation

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 113 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER FUEL CLAD

2. Core Exit Thermocouple Readings (FCB2)

Loss: > 1200 °F CET temperature.

Potential Loss:

Unit 1: ICC exists as evidenced by CETs indicating superheated conditions Unit 2: Average CETs indicate superheat for current RCS pressure Basis:

Loss The Loss EAL of > 1200 °F is consistent with NEI 99-01 and corresponds to significant superheating of the coolant.

Potential Loss The Potential Loss EAL corresponds to a loss of subcooling margin.

Note that the loss or potential loss EAL for this category will occur after a loss of adequate sub-cooling margin, which represents a loss of the RCS barrier in EAL RCB1, and therefore represents the loss of two barriers, resulting in a Site Area Emergency per FS1. Any loss or potential loss of the containment barrier at that point would escalate to a General Emergency.

Reference Documents

1. Unit 1 EOP 1202.005, Inadequate Core Cooling

2. Unit 1 EOP 1202.013, EOP Figures

3. Unit 2 OP 2202.009, Functional Recovery

4. ANO Procedure OP 1302.022, Core Damage Assessment

5. CE-NPSD-241, Development of the Comprehensive Procedure Guideline for Core Damage Assessment, Task 467

6. BWOG EOP Technical Bases Document, Vol. 3, Chapter III.F

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 114 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER FUEL CLAD

3. Reactor Vessel Water Level (FCB3)

Loss: None Potential Loss:

Unit 1: RVLMS Levels 1 through 9 indicate DRY Unit 2: RVLMS Levels 1 through 7 indicate DRY Basis:

Loss There is no Loss EAL associated with this item.

Potential Loss The Reactor Vessel Level Monitoring Systems at ANO do not provide positive indication of core uncovery. The above core level indication provided is used to monitor the approach to and recovery from ICC conditions, but the CETs are used to identify core uncovery, and are the only positive indication of core uncovery.

Per reference document #1, the reactor vessel level indicators installed in Unit 1 extend from the top of the reactor vessel to the fuel alignment plate, and information in reference document #2 indicates that the lowest sensor is greater than 2 feet above the top of active fuel. If any of the 4 RCPs are running, flow induced turbulence produced by the pumps renders the reactor vessel level indicator readings invalid.

Per reference document #3, only the reactor vessel level indicators above the core are considered part of the ICC monitoring system. Per reference document #4, the lowest sensor above the core, RVLMS LVL 6 on the ICC monitoring panel 2C388, is 47 inches above the top of the core. If any of the 4 RCPs are running, flow induced turbulence produced by the pumps renders the reactor vessel level indicator readings invalid.

For either unit then, should CET indication be unavailable and reactor vessel level indication be unavailable due to RCP operation or any other cause, a degraded ability to monitor the barrier would exist.

Reference Documents:

1. ULD-1-SYS-24, Unit 1 Inadequate Core Cooling System

2. Calculation 84-EQ-0080-02, Loop Error Analysis for Reactor Vessel Level Monitoring System

3. ULD-2-SYS-24, Unit 2 Inadequate Core Cooling Monitoring System

4. Calculation 90-E-0116-01, Unit 2 EOP Setpoint Document, Setpoint R.3

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 115 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER FUEL CLAD

4. Containment Radiation Monitoring (FCB4)

Loss: Containment high range radiation monitor reading > 1000 R/hr Potential Loss: None Basis:

Loss The 1000 R/hr reading on the containment high range radiation monitors (RE-8060 or RE-8061 for Unit 1, 2RE-8925-1 or 2RE-8925-2 for Unit 2) is a value which indicates the release of reactor coolant, with elevated activity indicative of fuel damage, into the containment.

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.

This radiation monitor value is higher than that specified for RCS barrier Loss EAL RCB3. Thus, this EAL indicates a loss of both the Fuel Clad barrier and RCS barrier that appropriately escalates the emergency classification to a Site Area Emergency per FS1.

NRC Information Notice 97-045 Supplement 1 identifies the potential for erratic indications from the high range radiation monitors (HRRMs) as a result of thermally induced currents (TIC) which may cause the HRRM to read falsely high (for approximately 15 minutes) on a rapid temperature increase, and fail low intermittently on a rapid temperature decrease. Because of this phenomenon, any trends or alarms on the HRRMs should be validated by comparison to the containment low range/area radiation monitors and Air Monitoring Systems trends before actions are taken.

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

Reference Documents:

1. NUREG 1228, Source Term Estimation During Incident Response to Severe Nuclear Power Plant Accidents

2. ANO Calculation 03-E-0002-01, Radiation Monitor EAL Setpoints for Fission Product Barrier Degradation

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 116 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER FUEL CLAD

5. Core Damage Assessment (FCB5)

Loss: At least 5% fuel clad damage as determined from core damage assessment Potential Loss: None Basis:

Loss This level is consistent with other fuel clad barrier loss EALs indicative of significant fuel clad damage, but uses core damage assessment evaluations by Technical Support personnel. The fuel clad barrier is considered lost.

If this determination is made from the high range containment radiation monitor readings, or if accompanied by other indications of a loss or potential loss of the RCS barrier, this EAL condition represents a Site Area Emergency per FS1.

Potential Loss There is no potential loss EAL associated with this item.

Reference Documents:

1. ANO Procedure OP-1302.022, Core Damage Assessment

6. Emergency Director Judgment (FCB6)

Any condition in the opinion of the SM / ED that indicates Loss or Potential Loss of the Fuel Clad barrier.

Basis:

This EAL addresses any other factors that are to be used by the SM / ED in determining whether the Fuel Clad 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 SM / ED judgment that the barrier may be considered lost or potentially lost.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 117 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER RCS RCS Barrier EALs: RCB1 OR RCB2 OR RCB3 OR RCB4 The RCS Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.

1. RCS Leak Rate (RCB1)

Loss: RCS leak rate > available makeup capacity as indicated by:

Unit 1: Loss of adequate subcooling margin Unit 2: RCS subcooling (MTS) can NOT be maintained at least 30 °F Potential Loss:

Unit 1: UNISOLABLE RCS leak > 50 gpm with Letdown isolated Unit 2: UNISOLABLE RCS leak > 44 gpm with Letdown isolated Basis:

Loss 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.

Potential Loss This EAL is based on the apparent inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) by normal operation of the Makeup and Purification System (Unit 1) or the Chemical and Volume Control System (Unit 2).

Isolating letdown is a standard abnormal operating procedure action and may prevent unnecessary classifications when a non-RCS leakage path such as a Makeup and Purification System or CVCS leak exists. The intent of this condition is met if attempts to isolate Letdown are NOT successful. Additional charging pumps being required is indicative of a substantial RCS leak.

Reference Documents:

1. Unit 1 EOP 1202.013, Figure 1, Saturation and Adequate SCM

2. Unit 1 EOP Setpoint Document, Calculation 90-E-0116-07, Setpoint B.19

3. Unit 2 EOP 2202.009, Functional Recovery

4. Unit 2 EOP Setpoint Document, Calculation 90-E-0116-01

5. Unit 2 SAR Table 9.3-14, Charging Pumps Design Data

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 118 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER RCS

2. SG Tube Rupture (RCB2)

Loss: SGTR that results in an ECCS (SI) actuation Potential Loss: None Basis:

Loss This EAL addresses the full spectrum of Steam Generator (SG) tube rupture events in conjunction with Containment barrier Loss EALs. It addresses RUPTURED SG(s) for which the leakage is large enough to cause actuation (either automatic or manual) of ECCS (SI). This is consistent to the RCS leak rate barrier Potential Loss EAL.

By itself, this EAL will result in the declaration of an Alert. However, if the SG is also FAULTED (i.e., two barriers failed), the declaration escalates to a Site Area Emergency per Containment barrier Loss EAL CNB3.

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

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 119 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER RCS

3. Containment Radiation Monitoring (RCB3)

Loss: Containment high range radiation monitor reading > 100 R/hr.

Potential Loss: None Basis Loss The 100 R/hr reading on the containment high range radiation monitors (RE-8060 or RE-8061 for Unit 1, 2RE-8925-1 or 2RE-8925-2 for Unit 2) is a value which indicates the release of reactor coolant to the containment.

This reading is less than that specified for Fuel Clad barrier EAL FCB4. Thus, this EAL is indicative of a RCS leak only. If the radiation monitor reading rose to that specified by Fuel Clad barrier EAL, fuel damage would also be indicated.

NRC Information Notice 97-045 Supplement 1 identifies the potential for erratic indications from the high range radiation monitors (HRRMs) as a result of thermally induced currents (TIC) which may cause the HRRM to read falsely high (for approximately 15 minutes) on a rapid temperature increase, and fail low intermittently on a rapid temperature decrease. Because of this phenomenon, any trends or alarms on the HRRMs should be validated by comparison to the containment low range/area radiation monitors and Air Monitoring Systems trends before actions are taken.

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

Reference Documents:

1. ANO Calculation 03-E-0002-01, Radiation Monitor EAL Setpoints for Fission Product Barrier Degradation

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 120 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER RCS

4. Emergency Director Judgment (RCB4)

Any condition in the opinion of the SM / ED that indicates Loss or Potential Loss of the RCS Barrier.

Basis:

This EAL addresses any other factors that are to be used by the SM / ED in determining whether the RCS 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 SM / ED judgment that the barrier may be considered lost or potentially lost.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 121 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER CONTAINMENT Containment Barrier EALs: CNB1 OR CNB2 OR CNB3 OR CNB4 OR CNB5 OR CNB6 OR CNB7 The Containment Barrier includes the containment building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the containment building up to and including the outermost secondary side isolation valve.

1. Containment Pressure (CNB1)

Loss:

1. Rapid unexplained drop in containment pressure following an initial rise in containment pressure OR

2. Containment pressure or sump level response not consistent with LOCA conditions Potential Loss:

1. Unit 1: Containment pressure > 73.7 PSIA (59 PSIG) and rising Unit 2: Containment pressure > 73.7 PSIA (59 PSIG) and rising OR

2. Explosive mixture exists inside containment.

OR

3. a. Containment Pressure > containment spray actuation setpoint UNIT 1: 44.7 PSIA (30 PSIG)

UNIT 2: 23.3 PSIA (8.6 PSIG)

AND

b. LESS THAN one full train of spray operating

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 122 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER CONTAINMENT Basis:

Loss Rapid unexplained loss of pressure (i.e., not attributable to containment spray or condensation effects) following an initial pressure rise from a primary or secondary high energy line break indicates a loss of containment integrity. Containment pressure and sump levels should rise as a result of mass and energy release into containment from a LOCA. Thus, sump level or pressure not rising indicates containment bypass and a loss of containment integrity.

This indicator relies on operator recognition of an unexpected response for the condition and therefore, does not have a specific value associated with it. The unexpected response is important because it is the indicator for a containment bypass condition.

Potential Loss 1.

The site specific pressure is based on the containment design pressure.

Potential Loss 2.

Existence of an explosive mixture means a hydrogen and oxygen concentration of at least the lower deflagration limit curve exists. The hydrogen concentration of 4% has been recognized by the NRC staff as a well-established lower flammability limit in air or steam-air atmospheres that is adequately conservative for protecting against an H2 explosion. Hydrogen control systems at ANO are designed and operated as to maintain the containment hydrogen concentration below this level, so that indications of hydrogen concentrations above this are considered a potential challenge to the containment integrity.

Potential Loss 3.

This EAL represents a potential loss of containment in that the containment heat removal/depressurization system (e.g., containment sprays, ice condenser fans, etc., but not including containment venting strategies) are either lost or performing in a degraded manner, as indicated by containment pressure greater than the setpoint at which the equipment was supposed to have actuated.

Reference Documents:

1. Unit 1 OP-1105.003, Engineering Safeguards Actuation System

2. Unit 1 SAR Sections 1.4.43, 5.2.1.2.1, 14.2.2.5.5.1 (reactor building design pressure)

3. Unit 1 SAR Section 6.6 (Post-Loss of Coolant Accident Hydrogen Control)

4. Unit 1 TS Table 3.3.5-1

5. Unit 2 SAR Section 6.2.5 (Combustible Gas Control In Containment)

6. Unit 2 SAR Section 3.8.1.3.1.D (Containment Design Pressure)

7. Unit 2 TS Table 3.3-4

8. Regulatory Guide 1.7, Control of Combustible Gas Concentrations in Containment Following a Loss-of-Coolant Accident, Rev. 2 1978

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 123 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER CONTAINMENT

2. Core Exit Thermocouple Readings (CNB2)

Loss: None Potential Loss:

1. a. CETs indicate > 1200 °F AND

b. Restoration procedures not effective within 15 minutes.

OR

2. a. CETs indicate > 700 °F AND

b. RVLMS indicates:

Unit 1: Levels 1 through 9 DRY Unit 2: Levels 1 through 7 DRY AND

c. Restoration procedures not effective within 15 minutes.

Basis:

Loss There is no Loss EAL associated with this item.

Potential Loss The conditions in these EALs represent an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and a higher potential for containment failure. In conjunction with the Core Cooling and RCS Leakage criteria in the Fuel and RCS barrier columns, this threshold would result in the declaration of a General Emergency, i.e., loss of two barriers and the potential loss of a third. If the function restoration procedures are ineffective, there is no "success" path.

The function restoration procedures are those emergency operating procedures that address the recovery of the core cooling critical safety functions. The procedure is considered effective if the temperature is dropping or if the vessel water level is rising.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 124 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER CONTAINMENT Whether or not the procedures will be effective should be apparent within 15 minutes. The SM / ED should make the declaration as soon as it is determined that the procedures have been, or will be ineffective.

3. SG Secondary Side Release With Primary-to-Secondary Leakage (CNB3)

Loss:

1. RUPTURED steam generator is also FAULTED outside of containment OR

2. a. Primary-to-secondary leakrate > 10 gpm AND

b. UNISOLABLE steam release from affected steam generator to the environment Potential Loss: None Basis:

This loss EAL recognizes that SG tube leakage can represent a bypass of the containment barrier as well as a loss of the RCS barrier.

This EAL results in a NUE for smaller breaks that; (1) do not exceed the Normal Makeup Capacity for Unit 1 or the capacity of one charging pump in the normal charging lineup for Unit 2 EAL in RCS leak rate barrier Potential Loss , or (2) do not result in ECCS actuation in RCS SG tube rupture barrier Loss.

For larger breaks, RCS barrier threshold criteria would result in an Alert. For SG tube ruptures which may involve multiple steam generators or UNISOLABLE secondary line breaks, this condition would exist in conjunction with RCS barrier conditions and would result in a Site Area Emergency. Escalation to General Emergency would be based on "Potential Loss" of the Fuel Clad Barrier.

Loss 1.

This EAL addresses the condition in which a RUPTURED steam generator is also FAULTED. This condition represents a bypass of the RCS and containment barriers and is a subset of the second threshold. In conjunction with RCS leak rate barrier loss EAL RCB2, this would always result in the declaration of a Site Area Emergency.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 125 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER CONTAINMENT Loss 2.

This EAL addresses SG tube leaks that exceed 10 gpm in conjunction with an UNISOLABLE release path to the environment from the affected steam generator. The threshold for establishing the UNISOLABLE secondary side release is intended to be a prolonged release of radioactivity from the RUPTURED steam generator directly to the environment. This could be expected to occur when the main condenser is unavailable to accept the contaminated steam (i.e., SG tube rupture with concurrent loss of off-site power and the RUPTURED steam generator is required for plant cooldown or a stuck open relief valve). The time it takes to isolate a SG with tube leakage > 10 gpm in accordance with plant specific EOPs is not considered a prolonged release. In this case the SG with tube leakage > 10 gpm with a concurrent loss of offsite power is normally steamed to the environment in a controlled manner to achieve and maintain a RCS Hot Leg temperature below that which corresponds to the Main Steam Safety Valve relief settings. However, if the SG cannot be isolated or if both SGs have tube leakage > 10 gpm, a prolonged release will likely be necessary to support plant cooldown. If the main condenser is available, there may be releases via air ejectors, gland seal exhausters, and other similar controlled, and often monitored, pathways. These pathways do not meet the intent of an UNISOLABLE release path to the environment. These minor releases are assessed using Abnormal Radiation Levels

/ Radiological Effluent ICs (TAB A).

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

4. Containment Isolation Failure or Bypass (CNB4)

Loss:

1. UNISOLABLE breach of containment AND

2. Direct downstream pathway to the environment exists after containment isolation signal Potential Loss: None

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 126 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER CONTAINMENT Basis:

Loss This EAL addresses incomplete containment isolation that allows a direct release to the environment. As used here the term environment includes the atmosphere of a room or area, outside the containment, that may in turn communicate with the outside-the-plant atmosphere (e.g., through discharge of a ventilation system or atmospheric leakage).

A breach of containment has also occurred if an inboard and outboard pair of isolation valves fails to close on an automatic actuation signal or from a manual action in the Control Room with an open release path to the environment.

The breach is not isolable from the Control Room if an attempt for isolation from the Control Room has been made and was unsuccessful. An attempt for isolation should be made prior to the accident classification. If isolable upon identification, then this Initiating Condition is not applicable.

The use of the modifier direct in defining the release path discriminates against release paths into interfacing liquid systems alone. The subsequent leak of the interfacing liquid system to the environment would constitute a direct release. The existence of an in-line charcoal filter does not make a release path indirect since the filter is not effective at removing fission product noble gases. Typical filters have an efficiency of 95-99% removal of iodine. Given the magnitude of the core inventory of iodine, significant releases could still occur.

In addition, since the fission product release would be driven by boiling in the reactor vessel, the high humidity in the release stream can be expected to render the filters ineffective in a short period.

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

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 127 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER CONTAINMENT

5. Containment Radiation Monitoring (CNB5)

Loss: None Potential Loss:

Containment high range radiation monitor reading > 4000 R/hr Basis:

Loss There is no Loss EAL associated with this item.

Potential Loss The 4000 R/hr reading on the containment high range radiation monitors (RE-8060 or RE-8061 for Unit 1, 2RE-8925-1 or 2RE-8925-2 for Unit 2) 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. A major release of radioactivity requiring off-site 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, 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 declaration is warranted.

Because the monitor reading exceeds the readings for Fuel Clad Barrier loss in FCB4 and RCS Barrier loss in RCB3, the SM/ED should declare a General Emergency when this value on the Containment High Range Rad Monitor is exceeded as a loss of two barriers (fuel clad and RCS) and potential loss of the third (containment).

NRC Information Notice 97-045 Supplement 1 identifies the potential for erratic indications from the high range radiation monitors (HRRMs) as a result of thermally induced currents (TIC) which may cause the HRRM to read falsely high (for approximately 15 minutes) on a rapid temperature increase, and fail low intermittently on a rapid temperature decrease. Because of this phenomenon, any trends or alarms on the HRRMs should be validated by comparison to the containment low range/area radiation monitors and Air Monitoring Systems trends before actions are taken.

Reference Documents:

1. ANO Calculation 03-E-0002-01, Radiation Monitor EAL Setpoints for Fission Product Barrier Degradation

2. NUREG 1228, Source Term Estimation During Incident Response to Severe Nuclear Power Plant Accidents

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 128 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 FISSION PRODUCT BARRIER CONTAINMENT

6. Other Indications (CNB6)

Elevated readings on the following radiation monitors that indicate loss or potential loss of the Containment barrier:

MONITORS - UNIT 1 RX-9820 Containment Purge RX-9825 Radwaste Area RX-9830 Fuel Handling Area RX-9835 Emergency Penetration Room MONITORS - UNIT 2 2RX-9820 Containment Purge 2RX-9825 Radwaste Area 2RX-9830 Fuel Handling Area 2RX-9835 Emergency Penetration Room 2RX-9845 Aux. Building Extension Basis:

This EAL covers other indications that may unambiguously indicate the loss or potential loss of the containment barrier.

7. Emergency Director Judgment (CNB7)

Any condition in the opinion of the SM / ED that indicates Loss or Potential Loss of the Containment Barrier.

Basis:

This EAL addresses any other factors that are to be used by the SM / ED 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 SM / ED judgment that the barrier may be considered lost or potentially lost.

The Containment barrier should not be declared lost or potentially lost based on exceeding Technical Specification action statement criteria, unless there is an event in progress requiring mitigation by the Containment barrier. When no event is in progress (Loss or Potential Loss of either Fuel Clad and/or RCS) the Containment barrier status is addressed by Technical Specifications

PROC./WORK PLAN N

O. PROCEDURE

/WORK PLAN TITLE: PAGE: 129 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 130 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU1 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT Confirmed SECURITY CONDITION or threat which indicates a potential degradation in the level of safety of the plant Operating Mode Applicability: All Example Emergency Action Level(s): (1 or 2 or 3)

1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by ANO Security Shift Supervision.

OR

2. A credible site specific security threat notification.

OR

3. A validated notification from NRC providing information of an aircraft threat.

Basis:

NOTE: Timely and accurate communication between Security Shift Supervision and the Control Room is crucial for the implementation of effective Security EALs.

Security events which do not represent a potential degradation in the level of safety of the plant are reported under 10 CFR 73.71 or in some cases under 10 CFR 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under HA1, HS1 and HG1.

A higher initial classification could be made based upon the nature and timing of the security threat and potential consequences. Consideration shall be given to upgrading the emergency response status and emergency classification in accordance with the Safeguards Contingency Plan and Emergency Plan.

EAL #1 The Security Shift Supervisor is the designated individual on-site qualified and trained to confirm that a security event is occurring or has occurred. Training on security event classification confirmation is closely controlled due to the strict secrecy controls placed on the plant Safeguards Contingency Plan.

This EAL is based on the Safeguards Contingency Plan. The Safeguards Contingency Plan is based on guidance provided in NEI 03-12.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 131 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU1 EAL #2 This EAL is included to ensure that appropriate notifications for the security threat are made in a timely manner. This includes information of a credible threat. Only the plant to which the specific threat is made need declare the NUE.

The determination of credible is made through use of information found in the Safeguards Contingency Plan.

EAL #3 The intent of this EAL is to ensure that notifications for the aircraft threat are made in a timely manner and that Offsite Response Organizations and plant personnel are at a state of heightened awareness regarding the credible threat. It is not the intent of this EAL to replace existing non-hostile related EALs involving aircraft.

This EAL is met when a plant receives information regarding an aircraft threat from NRC. Validation is performed by calling the NRC or by other approved methods of authentication. Only the plant to which the specific threat is made need declare the NUE.

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an airliner (airliner is meant to be a large aircraft with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC.

Escalation to Alert via HA1 would be appropriate if the threat involves an airliner within 30 minutes of the plant.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 132 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU2 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT Other conditions exist which in the judgment of the SM warrant declaration of an NUE Operating Mode Applicability: All Example Emergency Action Level(s):

1. Other conditions exist which in the judgment of the SM indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Basis:

This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the SM to fall under the NUE emergency classification level.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 133 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA Operating Mode Applicability: All Example Emergency Action Level(s): (1 or 2)

Note: The SM should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the duration has exceeded, or will likely exceed, the applicable time.

1. FIRE in any Table H1 structure or area not extinguished:

1) within 15 minutes of Control Room notification OR

2) within 15 minutes of verification of a Control Room FIRE alarm (i.e. Alarm valid until disproved).

OR

2. EXPLOSION within the PROTECTED AREA.

Basis:

This IC addresses the magnitude and extent of FIRES or EXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the FIRE / EXPLOSION, and not the degradation in performance of affected systems that may result.

As used here, detection is visual observation and report by plant personnel or sensor alarm indication.

EAL #1 The 15-minute time period begins with a credible notification that a FIRE is occurring or indication of a fire detection system alarm/actuation. Verification of a fire detection system alarm/actuation includes actions that can be taken within the Control Room or other nearby site specific location to ensure that it is not spurious. An alarm is assumed to be an indication of a FIRE unless it is disproved within the 15-minute period by personnel dispatched to the scene. In other words, a personnel report from the scene may be used to disprove a sensor alarm if received within 15 minutes of the alarm, but shall not be required to verify the alarm.

The intent of this 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 134 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 EAL #2 This EAL addresses only those EXPLOSIONS of sufficient force to damage permanent structures or equipment within the PROTECTED AREA.

No attempt is made to assess the actual magnitude of the damage. The occurrence of the EXPLOSION is sufficient for declaration.

The SM also needs to consider any security aspects of the EXPLOSION, if applicable.

Escalation of this emergency classification level, if appropriate, would be based on HA4.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 135 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 Table H1 Unit 1 Reactor Building All Elevations Aux Building All Elevations Including Penthouse/MSIV Room Exceptions: Boric Acid Mix Tank Room (Chem Add Area) 404 (157-B)

EDG Exhaust Fan area on 386 (1-E and 2-E)

Turbine Building All Elevations Including:

Pipechase under ICW Coolers CRD Pump Pit / T-28 Room / Area under ICW Pumps Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)

Manholes adjacent to Intake Structure (MH-05/MH-06)

Intake Structure (354 and 366)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes MH-09 and MH-10 (Manhole, MH-09, is located approximately 15 feet northeast of the Unit 1 QCST , Manhole, MH-10, is located approximately 5 feet west of Unit 2 Condensate Storage Tank, 2T-41A)

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 136 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 Table H1 Unit 2 Reactor Building All Elevations Aux Building All Elevations including Aux Extensions Turbine Building All Elevations Outside Areas Intake Structure (354 and 366)

Concrete Manhole East, NE of intake Concrete Manhole East of Turbine building next to train bay Diesel Fuel Vault Diesel Fuel Vault Pump Manholes MH-09 and MH-10 (Manhole, MH-09, is located approximately 15 feet northeast of the Unit 1 QCST , Manhole, MH-10, is located approximately 5 feet west of Unit 2 Condensate Storage Tank, 2T-41A)

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 137 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU5 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT Release of toxic, corrosive, asphyxiant, or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS.

Operating Mode Applicability: All Example Emergency Action Level(s): (1 or 2)

1. Toxic, corrosive, asphyxiant or flammable gases in amounts that have or could adversely affect NORMAL PLANT OPERATIONS.

OR

2. Report by Local, County or State officials for evacuation or sheltering of site personnel based on an offsite event.

Basis:

This IC is based on the release of toxic, corrosive, asphyxiant or flammable gases of sufficient quantity to affect NORMAL PLANT OPERATIONS.

The fact that SCBAs may be worn does not eliminate the need to declare the event.

This IC is not intended to require significant assessment or quantification. It assumes an uncontrolled process that has the potential to affect plant operations. This would preclude small or incidental releases, or releases that do not impact structures needed for plant operation.

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

Escalation of this emergency classification level, if appropriate, would be based on HA5.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 138 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT Natural or destructive phenomena affecting the PROTECTED AREA Operating Mode Applicability: All Example Emergency Action Level: (1 or 2 or 3 or 4 or 5 or 6)

1. Seismic event identified by any 2 of the following:

Seismic event confirmed by annunciation of the 0.01g acceleration alarm Earthquake felt in plant National Earthquake Center OR

2. Tornado striking within PROTECTED AREA boundary or high winds > 67 mph (2 minute average).

OR

3. Internal flooding that has the potential to affect safety related equipment required by Technical Specifications for the current operating mode in any of the structures or areas in Table H1 (see Table H1 located in HU4).

OR

4. Turbine failure resulting in casing penetration or damage to turbine or generator seals.

OR

5. Lake Dardanelle level < 335 feet.

OR

6. Lake Dardanelle level > 345 feet.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 139 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 Basis:

These EALs are categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators.

EAL #1 Damage may be caused to some portions of the site, but should not affect ability of safety functions to operate.

As defined 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 the vibratory 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.

The National Earthquake Center can confirm if an earthquake has occurred in the area of the plant.

EAL #2 This EAL is based on a tornado striking (touching down) or high winds within the PROTECTED AREA.

The high wind value in EAL #2 is conservatively based on the SAR design basis for Unit 1 of 67 mph.

Unit 2 Design basis is 80 mph.

Escalation of this emergency classification level, if appropriate, would be based on VISIBLE DAMAGE, or by other in plant conditions, via HA6.

EAL #3 This EAL addresses the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps.

Escalation of this emergency classification level, if appropriate, would be via HA6, or by other plant conditions.

EAL #4 This EAL addresses main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator. Generator seal damage observed after generator purge does not meet the intent of this EAL because it did not impact normal operation of the plant.

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 HU4 and HU5.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 140 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 This EAL is consistent with the definition of an NUE while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment.

Escalation of this emergency classification level, if appropriate, would be to HA6 based on damage done by PROJECTILES generated by the failure or in conjunction with a steam generator tube rupture.

These latter events would be classified by the radiological (A) ICs or Fission Product Barrier (F) ICs.

EALs #5 and #6 EALs #5 and #6 are based on the levels of Lake Dardanelle at which the site will take specific action to reduce the impact of the lake level on plant safety by initiating plant shutdown.

Reference Documents:

1. OP-1203.025, Natural Emergencies

2. OP-2203.008, Natural Emergencies

3. Unit 1 FSAR

4. Unit 2 FSAR

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 141 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 Initiating Condition - ALERT HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat Operating Mode Applicability: All Example Emergency Action Level(s): (1 or 2)

1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by ANO Security Shift Supervision.

OR

2. A validated notification from NRC of an airliner attack threat within 30 minutes of the site.

Basis:

NOTE: Timely and accurate communication between Security Shift Supervision and the Control Room is crucial for the implementation of effective Security EALs.

These EALs address the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. They are not premised solely on the potential for a radiological release.

Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements.

The fact that the site is under serious attack or is an identified attack target with minimal time available for further preparation or additional assistance to arrive requires a heightened state of readiness and implementation of protective measures that can be effective (such as on-site evacuation, dispersal or sheltering).

EAL #1 This EAL addresses the potential for a very rapid progression of events due to a HOSTILE ACTION. It is not intended to address incidents that are accidental events or acts of civil disobedience, such as small aircraft impact, hunters, or physical disputes between employees within the OWNER CONTROLLED AREA. Those events are adequately addressed by other EALs.

Note that this EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes Independent Spent Fuel Storage Installations that may be outside the PROTECTED AREA but still in the OWNER CONTROLLED AREA.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 142 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 EAL #2 This EAL addresses the immediacy of an expected threat arrival or impact on the site within a relatively short time.

The intent of this EAL is to ensure that notifications for the airliner attack threat are made in a timely manner and that Offsite Response Organizations and plant personnel are at a state of heightened awareness regarding the credible threat. Airliner is meant to be a large aircraft with the potential for causing significant damage to the plant.

This EAL is met when a plant receives information regarding an airliner attack threat from NRC and the airliner is within 30 minutes of the plant. Only the plant to which the specific threat is made need declare the Alert.

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an airliner (airliner is meant to be a large aircraft with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 143 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA2 Initiating Condition - ALERT Other conditions exist which in the judgment of the SM / ED warrant declaration of an Alert Operating Mode Applicability: All Example Emergency Action Level(s):

1. Other conditions exist which in the judgment of the SM / ED indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Basis:

This EAL addresses unanticipated conditions not addressed explicitly elsewhere, but that warrant declaration of an emergency because conditions exist which are believed by the SM / ED to fall under the Alert emergency classification level.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 144 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA3 Initiating Condition - ALERT Control room evacuation has been initiated Operating Mode Applicability: All Example Emergency Action Level(s):

1. Alternate Shutdown procedure requires Control Room evacuation:

Unit 1: 1203.002, Alternate Shutdown Unit 2: 2203.014, Alternate Shutdown Basis:

With the Control Room evacuated, additional support, monitoring and direction through the Technical Support Center and/or other emergency response facilities may be necessary.

Inability to establish plant control from outside the Control Room will escalate this event to a Site Area Emergency.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 145 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA4 Initiating Condition - ALERT FIRE or EXPLOSION affecting the operability of plant safety systems required to establish or maintain safe shutdown Operating Mode Applicability: All Example Emergency Action Level(s):

1. FIRE or EXPLOSION resulting in VISIBLE DAMAGE to any Table H1 structure or area containing safety systems or components or Control Room indication of degraded performance of those safety systems.

Basis:

VISIBLE DAMAGE is used to identify the magnitude of the FIRE or EXPLOSION and to discriminate against minor FIRES and EXPLOSIONS.

The reference to structures or areas containing safety systems or components is included to discriminate against FIRES or EXPLOSIONS in areas having a low probability of affecting safe operation. The significance here is not that a safety system was degraded but the fact that the FIRE or EXPLOSION was large enough to cause damage to these systems.

The use of VISIBLE DAMAGE should not be interpreted as mandating a lengthy damage assessment prior to classification. The declaration of an Alert and the activation of the Technical Support Center will provide the SM/ED with the resources needed to perform detailed damage assessments.

The SM / ED also needs to consider any security aspects of the EXPLOSION.

Escalation of this emergency classification level, if appropriate, will be based on System Malfunction (S),

Fission Product Barrier Degradation (F) or Abnormal Radiation Levels / Radiological Effluent (A) ICs.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 146 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA4 Table H1 Unit 1 Reactor Building All Elevations Aux Building All Elevations Including Penthouse/MSIV Room Exceptions: Boric Acid Mix Tank Room (Chem Add Area) 404 (157-B)

EDG Exhaust Fan area on 386 (1-E and 2-E)

Turbine Building All Elevations Including:

Pipechase under ICW Coolers CRD Pump Pit / T-28 Room / Area under ICW Pumps Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)

Manholes adjacent to Intake Structure (MH-05/MH-06)

Intake Structure (354 and 366)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes MH-09 and MH-10 (Manhole, MH-09, is located approximately 15 feet northeast of the Unit 1 QCST , Manhole, MH-10, is located approximately 5 feet west of Unit 2 Condensate Storage Tank, 2T-41A)

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 147 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA4 Table H1 Unit 2 Reactor Building All Elevations Aux Building All Elevations including Aux Extensions Turbine Building All Elevations Outside Areas Intake Structure (354 and 366)

Concrete Manhole East, NE of intake Concrete Manhole East of Turbine building next to train bay Diesel Fuel Vault Diesel Fuel Vault Pump Manholes MH-09 and MH-10 (Manhole, MH-09, is located approximately 15 feet northeast of the Unit 1 QCST , Manhole, MH-10, is located approximately 5 feet west of Unit 2 Condensate Storage Tank, 2T-41A)

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 148 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 Initiating Condition - ALERT Access to a VITAL AREA is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of operable equipment required to maintain safe operations or safely shutdown the reactor.

Unit 1 VITAL AREA APPLICABLE MODES A-4 Switchgear Room 3, 4 Upper North Electrical Penetration Room 3, 4 Lower South Electrical Equipment Room 3, 4 Control Room ALL Unit 2 VITAL AREA APPLICABLE MODES Auxiliary Building 317 Emergency Core Cooling 3, 4 Rooms Auxiliary Building 317 Tendon Gallery Access 3, 4 Auxiliary Building 335 Charging Pumps / 2B-52 3, 4 Auxiliary Building 354 2B-62 Area 3, 4 Emergency Diesel Generator Corridor 3, 4 Lower South Piping Penetration Room 3, 4 Auxiliary Building 386 Containment Hatch 3, 4 Control Room ALL Operating Mode Applicability: As stated in above tables.

Example Emergency Action Level(s):

Note: If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.

1. Access to a VITAL AREA is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 149 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 Basis:

Gases in a VITAL AREA can affect the ability to safely operate or safely shutdown the reactor. The fact that SCBAs may be worn does not eliminate the need to declare the event.

Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere poses an immediate threat to life and health or an immediate threat of severe exposure to gases. This could be based upon documented analysis, indication of personal ill effects from exposure, or operating experience with the hazards.

If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

An uncontrolled release of flammable gasses within a facility structure has the potential to affect safe operation of the plant by limiting either operator or equipment operations due to the potential for ignition and resulting equipment damage/personnel injury. Flammable gasses, such as hydrogen and acetylene, are routinely used to maintain plant systems (hydrogen) or to repair equipment/components (acetylene - used in welding). This EAL assumes concentrations of flammable gasses which can ignite/support combustion.

Escalation of this emergency classification level, if appropriate, will be based on System Malfunction (S),

Fission Product Barrier Degradation (F) or Abnormal Radiation Levels / Radioactive Effluent (A) ICs.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 150 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA6 Initiating Condition - ALERT Natural or destructive phenomena affecting VITAL AREAS Operating Mode Applicability: All Example Emergency Action Level(s): (1 or 2 or 3 or 4 or 5 or 6)

1. a. Seismic event > Operating Basis Earthquake (OBE) as indicated by annunciation of the 0.1g acceleration alarm.

AND

b. Earthquake confirmed by any of the following:

Earthquake felt in plant National Earthquake Center Control Room indication of degraded performance of systems required for the safe shutdown of the plant OR

2. Tornado striking or high winds > 67 mph (2 minute average) resulting in VISIBLE DAMAGE to any of the following structures/equipment containing safety systems or components or Control Room indication of degraded performance of those safety systems:

Reactor Building Turbine Building Intake Structure Q Condensate Storage Tank (QCST)

Ultimate Heat Sink Control Room Startup Transformers Auxiliary Building Diesel Fuel Vault Borated Water Storage Tank (BWST)

Refueling Water Tank (RWT)

OR

3. Internal flooding in any of the following areas resulting in an electrical shock hazard that precludes access to operate or monitor safety equipment or Control Room indication of degraded performance of those safety systems:

Intake Structure Turbine Building Auxiliary Building OR

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 151 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA6

4. Turbine failure-generated PROJECTILES resulting in VISIBLE DAMAGE to or penetration of any of the structures/equipment containing safety systems or components or Control Room indication of degraded performance of those safety systems:

Control Room Turbine Building Startup Transformers Auxiliary Building OR

5. Lake Dardanelle level < 335 feet and Emergency Cooling Pond inoperable.

OR

6. Vehicle crash resulting in VISIBLE DAMAGE to any of the structures/equipment containing safety systems or components or Control Room indication of degraded performance of those safety systems:

Reactor Building Turbine Building Intake Structure QCST Ultimate Heat Sink RWT Startup Transformers Auxiliary Building Diesel Fuel Vault BWST Basis:

These EALs escalate from HU6 in that the occurrence of the event has resulted in VISIBLE DAMAGE to plant structures or areas containing equipment necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by Control Room indications of degraded system response or performance. The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discriminate against lesser events. 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. The significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation.

Escalation of this emergency classification level, if appropriate, would be based on System Malfunction (S) ICs.

EAL #1 Seismic events of this magnitude can result in a VITAL AREA being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems.

The National Earthquake Center can confirm if an earthquake has occurred in the area of the plant.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 152 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA6 EAL #2 This EAL is based on a tornado striking (touching down) or high winds that have caused VISIBLE DAMAGE to structures containing functions or systems required for safe shutdown of the plant. The high wind value in EAL #2 is conservatively based on the SAR design basis for Unit 1 of 67 mph. Unit 2 Design basis is 80 mph.

EAL #3 This EAL addresses the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps. It is based on the degraded performance of systems, or has created industrial safety hazards (e.g., electrical shock) that preclude necessary access to operate or monitor safety equipment. The inability to access, operate or monitor safety equipment represents an actual or substantial potential degradation of the level of safety of the plant.

Flooding as used in this EAL describes a condition where water is entering the room faster than installed equipment is capable of removal, resulting in a rise of water level within the room. Classification of this EAL should not be delayed while corrective actions are being taken to isolate the water source.

EAL #4 This EAL addresses the threat to safety related equipment imposed by PROJECTILEs generated by main turbine rotating component failures. Therefore, this EAL is consistent with the definition of an ALERT in that the potential exists for actual or substantial potential degradation of the level of safety of the plant.

EAL #5 EAL #5 addresses site specific phenomena which has the potential for the loss of primary and secondary heat sink.

EAL #6 This EAL addresses vehicle crashes within the PROTECTED AREA that result in VISIBLE DAMAGE to VITAL AREAS or indication of damage to safety structures, systems, or components containing functions and systems required for safe shutdown of the plant.

Reference Documents:

1. OP-1203.025, Natural Emergencies

2. OP-2203.008, Natural Emergencies

3. Unit 1 FSAR

4. Unit 2 FSAR

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 153 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 Initiating Condition - SITE AREA EMERGENCY HOSTILE ACTION within the PROTECTED AREA Operating Mode Applicability: All Example Emergency Action Level(s):

1. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by ANO Security Shift Supervision.

Basis:

This condition represents an escalated threat to plant safety above that contained in the Alert in that a HOSTILE FORCE has progressed from the OWNER CONTROLLED AREA to the PROTECTED AREA.

This EAL addresses the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. It is not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements.

The fact that the site is under serious attack with minimal time available for further preparation or additional assistance to arrive requires Offsite Response Organization readiness and preparation for the implementation of protective measures.

This EAL addresses the potential for a very rapid progression of events due to a HOSTILE ACTION. It is not intended to address incidents that are accidental events or acts of civil disobedience, such as small aircraft impact, hunters, or physical disputes between employees within the PROTECTED AREA.

Those events are adequately addressed by other EALs.

Escalation of this emergency classification level, if appropriate, would be based on actual plant status after impact or progression of attack.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 154 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 Initiating Condition - SITE AREA EMERGENCY Other conditions exist which in the judgment of the SM / ED warrant declaration of a Site Area Emergency Operating Mode Applicability: All Example Emergency Action Level(s):

1. Other conditions exist which in the judgment of the SM / ED indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

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 SM / ED to fall under the emergency classification level description for Site Area Emergency.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 155 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS3 Initiating Condition - SITE AREA EMERGENCY Control Room evacuation has been initiated and plant control cannot be established Operating Mode Applicability: All Example Emergency Action Level(s):

1. a. Control room evacuation has been initiated AND

b. Control of the plant cannot be established in accordance with the following procedures within 15 minutes:

Unit 1: 1203.002, Alternate Shutdown Unit 2: 2203.014, Alternate Shutdown Basis:

The intent of this IC is to capture those events where control of the plant cannot be reestablished in a timely manner. In this case, expeditious transfer of control of safety systems has not occurred (although fission product barrier damage may not yet be indicated).

The intent of the EAL is to establish control of important plant equipment and knowledge of important plant parameters in a timely manner. Primary emphasis should be placed on those components and instruments that supply protection for and information about safety functions such as reactivity control (ability to shutdown the reactor and maintain it shutdown), RCS inventory (ability to cool the core), and decay heat removal (ability to maintain a heat sink).

The determination of whether or not control is established is based on SM / ED judgment. The SM / ED is expected to make a reasonable, informed judgment within 15 minutes that the plant staff has control of the plant .

Escalation of this emergency classification level, if appropriate, would be by Fission Product Barrier Degradation (F) or Abnormal Radiation Levels/Radiological Effluent (A) EALs.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 156 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG1 Initiating Condition - GENERAL EMERGENCY HOSTILE ACTION resulting in loss of physical control of the facility Operating Mode Applicability: All Example Emergency Action Level(s): (1 or 2)

1. A HOSTILE ACTION has occurred such that plant personnel are unable to operate equipment required to maintain safety functions.

OR

2. A HOSTILE ACTION has caused failure of Spent Fuel Cooling Systems and IMMINENT fuel damage is likely for a freshly off-loaded reactor core in pool.

Basis:

EAL #1 This EAL encompasses conditions under which a HOSTILE ACTION has resulted in a loss of physical control of VITAL AREAS (containing vital equipment or controls of vital equipment) required to maintain safety functions and control of that equipment cannot be transferred to and operated from another location. These safety functions are reactivity control (ability to shut down the reactor and keep it shutdown) RCS inventory (ability to cool the core), and secondary heat removal (ability to maintain a heat sink).

Loss of physical control of the Control Room or remote shutdown/alternate shutdown capability alone may not prevent the ability to maintain safety functions per se. Design of the remote shutdown/alternate shutdown capability and the location of the transfer switches should be taken into account. Primary emphasis should be placed on those components and instruments that supply protection for and information about safety functions.

If control of the plant equipment necessary to maintain safety functions can be transferred to another location, then the threshold is not met.

EAL #2 This EAL addresses failure of spent fuel cooling systems as a result of HOSTILE ACTION if IMMINENT fuel damage is likely, such as when a freshly off-loaded reactor core is in the spent fuel pool. At ANO, the term freshly off-loaded reactor core refers to fuel that has been discharged from the core and stored in the spent fuel pool for a period of LESS THAN one year.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 157 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG2 Initiating Condition - GENERAL EMERGENCY Other conditions exist which in the judgment of the SM / ED warrant declaration of a General Emergency Operating Mode Applicability: All Example Emergency Action Level(s):

1. Other conditions exist which in the judgment of the SM / ED indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

Basis:

This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the SM / ED to fall under the emergency classification level description for General Emergency.

PROC./WORK PLAN N

O. PROCEDURE

/WORK PLAN TITLE: PAGE: 158 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 159 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SU1 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT Loss of all offsite AC power to Vital 4.16 KV busses 15 minutes Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Hot Standby (Mode 3)

Hot Shutdown (Mode 4)

Example Emergency Action Level(s):

Note: The SM should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

1. Loss of all offsite AC power to Vital 4.16 KV busses 15 minutes.

Basis:

Prolonged loss of 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 to emergency busses.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of off-site power.

Reference Documents:

1. 1202.007, Degraded Power

2. 1202.008, Blackout

3. 2202.007, Loss of Off-Site Power

4. 2202.008, Station Blackout

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 160 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SU6 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT UNPLANNED loss of safety system annunciation or indication in the Control Room 15 minutes Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Hot Standby (Mode 3)

Hot Shutdown (Mode 4)

Example Emergency Action Level(s):

Note: The SM should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

1. UNPLANNED Loss of > approximately 75% of the following > 15 minutes:

a. Control Room annunciators associated with safety systems.

OR

b. Control Room safety system indication.

Basis:

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 e.g., SPDS, plant computer, etc.

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

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible 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 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 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the NUE is based on SU11 "Inability to reach required operating mode within Technical Specification limits."

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 161 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SU6 Indicators associated with safety systems are those indicators for reactivity control, core cooling, maintaining reactor coolant system integrity or maintaining containment integrity.

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

This NUE will be escalated to an Alert based on a concurrent loss of compensatory indications or if a SIGNIFICANT TRANSIENT is in progress during the loss of annunciation or indication (SA6).

Reference Documents:

1. 1203.043, Loss Control Room Annunciators

2. 2203.042, Loss of Control Room Annunciators

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 162 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SU7 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT RCS leakage Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Hot Standby (Mode 3)

Hot Shutdown (Mode 4)

Example Emergency Action Level(s): (1 or 2)

1. Unidentified or pressure boundary leakage > 10 gpm.

OR

2. Identified leakage > 25 gpm.

Basis:

With respect to this IC, RCS leakage is defined as a loss of RCS inventory due to a leak in the RCS or a supporting system that is not or cannot be isolated within 10 minutes. For example, isolation of the RCS Letdown (purification) system is a standard abnormal operating procedure action and may prevent unnecessary classifications when a non-RCS leakage path leak exists. However, the intent of this condition is met if attempts to isolate the RCS leak are NOT successful.

This IC is included as an NUE because it may be a precursor of more serious conditions and, as result, is considered to be a potential degradation of the level of safety of the plant. The 10 gpm value for the unidentified or pressure boundary leakage was selected as it is observable with normal Control Room indications. Lesser values must generally be determined through time-consuming surveillance tests (e.g., mass balances).

Relief valve normal operation should be excluded from this IC. However, a relief valve that operates and fails to close per design should be considered applicable to this IC if the relief valve cannot be isolated.

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. Steam generator tube leakage is identified leakage. In either case, escalation of this IC to the Alert level is via Fission Product Barrier Degradation (F) ICs.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 163 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SU8 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT Loss of all onsite or offsite communications capabilities Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Hot Standby (Mode 3)

Hot Shutdown (Mode 4)

Example Emergency Action Level(s): (1 or 2)

1. Loss of all Table M1 onsite communications methods affecting the ability to perform routine operations.

OR

2. Loss of all Table M2 offsite communications methods affecting the ability to perform offsite notifications.

Table M1 Table M2 Onsite Communications Offsite Communications Methods Methods Station radio system All telephone lines (commercial and microwave)

Plant paging system ENS In-plant telephones Gaitronics Basis:

The purpose of this IC and its associated EALs 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 issues with offsite authorities.

The availability of one method of ordinary offsite communications is sufficient to inform federal, state, and local authorities of plant problems. This EAL is intended to be used only when extraordinary means (e.g., relaying of information from non-routine radio transmissions, individuals being sent to off-site locations, etc.) are being used to make communications possible.

Reference Documents:

1. 1903.062, Communications System Operating Procedure

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 164 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SU9 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT Fuel clad degradation Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Hot Standby (Mode 3)

Hot Shutdown (Mode 4)

Example Emergency Action Level(s): (1 or 2)

1. Failed Fuel Iodine radiation monitor reading indicates fuel clad degradation > Technical Specification allowable limits:

Unit 1:

RI-1237S reads > 1.3 x 105 counts per minute Unit 2:

2RITS-4806B reads > .65 x 105 counts per minute OR

2. RCS sample activity value indicating fuel clad degradation > Technical Specification allowable limits:

> 1.0 uCi/gm Dose Equivalent I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> OR Unit 1:

60 uCi/gm Dose Equivalent I-131 Unit 2:

> 60 uCi/gm Dose Equivalent I-131 OR Unit 1:

> 2200 µCi/gm Dose Equivalent Xe-133 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Unit 2:

> 3100 µCi/gm Dose Equivalent Xe-133 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 165 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SU9 Basis:

This IC is included because it is a precursor of more serious conditions and, as result, is considered to be a potential degradation of the level of safety of the plant.

EAL #1 This threshold addresses the Letdown Radiation Monitor readings that provide indication of a degradation of fuel clad integrity.

EAL #2 This EAL addresses coolant samples exceeding coolant technical specifications for transient iodine spiking limits and coolant samples exceeding coolant Technical Specifications for nominal operating limits for the time period specified in the Technical Specifications.

Escalation of this IC to the Alert level is via the Fission Product Barriers (F).

Reference Documents:

1. ANO1 Technical Specifications

2. ANO2 Technical Specifications

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 166 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SU10 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT Inadvertent criticality Operating Mode Applicability: Hot Standby (Mode 3)

Hot Shutdown (Mode 4)

Example Emergency Action Level(s):

1. UNPLANNED sustained positive startup rate observed on nuclear instrumentation.

Basis:

This IC addresses inadvertent criticality events. This IC indicates a potential degradation of the level of safety of the plant, warranting an NUE classification. This IC excludes inadvertent criticalities that occur during planned reactivity changes associated with reactor startups (e.g., criticality earlier than estimated).

This condition can be identified using the startup rate meter. The term sustained is used in order to allow exclusion of expected short term positive startup rates from planned control rod movements for (such as shutdown bank withdrawal). These short term positive startup rates are the result of the rise in neutron population due to subcritical multiplication.

Escalation would be by the Fission Product Barrier Table (F), as appropriate to the operating mode at the time of the event.

Reference Documents:

1. 1203.012G, Annunciator K08 Corrective Action

2. 2203.012D, Annunciator 2K04 Corrective Action

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 167 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SU11 Initiating Condition - NOTIFICATION OF UNUSUAL EVENT Inability to reach required operating mode within Technical Specification limits Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Hot Standby (Mode 3)

Hot Shutdown (Mode 4)

Example Emergency Action Level(s):

1. Plant is not brought to required operating mode within Technical Specifications LCO Action Statement time.

Basis:

Limiting Conditions of Operation (LCOs) require the plant to be brought to a required operating 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 Specifications requires a four hour report under 10 CFR 50.72 (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 NUE 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 NUE 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 long a condition may have existed.

Reference Documents:

1. ANO2 Technical Specifications

2. ANO1 Technical Specifications

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 168 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SA1 Initiating Condition - ALERT AC power capability to Vital 4.16 KV busses reduced to a single power source 15 minutes such that any additional single power source failure would result in station blackout Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Hot Standby (Mode 3)

Hot Shutdown (Mode 4)

Example Emergency Action Level(s):

Note: The SM / ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

1. a. AC power capability to Vital 4.16 KV busses reduced to a single power source 15 minutes.

AND

b. Any additional single power source failure will result in station blackout.

Basis:

The condition indicated by this IC is the degradation of the offsite and onsite AC power systems such that any additional single power source failure would result in a station blackout. This condition could occur due to a loss of offsite power with a concurrent failure of all but 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 generators with only one train of emergency busses being backfed from the unit main generator, or the loss of onsite emergency generators 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 SS1.

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

The EAL allows credit for operation of the Alternate AC Diesel Generator.

Reference Documents:

1. 1202.007, Degraded Power

2. 1202.008, Blackout

3. 2202.007, Loss of Off-Site Power

4. 2202.008, Station Blackout

5. 2104.037, Alternate AC Diesel Generator Operations

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 169 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SA3 Initiating Condition - ALERT Automatic trip fails to shutdown the reactor and the manual actions taken from the reactor control console are successful in shutting down the reactor Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Example Emergency Action Level(s):

1. a. An automatic trip failed to shutdown the reactor as indicated by reactor power 5%.

AND

b. Manual actions taken at the reactor control console successfully shutdown the reactor as indicated by reactor power < 5%.

Basis:

Manual trip actions taken at the reactor control console are any set of actions by the Reactor Operator(s) which causes or should cause control rods to be rapidly inserted into the core and shuts down the reactor. Any action taken to trip the reactor from any location other than panel C03 (Unit 1) or 2C03/2C14 (Unit 2) constitutes a failure of the manual trip function. Failure of manual trip would escalate the event to a Site Area Emergency (SS3).

This condition indicates failure of the automatic protection system to trip the reactor. 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. Thus the plant safety has been compromised because design limits of the fuel may have been exceeded. An Alert is indicated because conditions may exist that lead to potential loss of fuel clad or RCS and because of the failure of the Reactor Protection System to automatically shutdown the plant. This EAL applies whether or not a mode change has occurred. (Reference Operating Mode Applicability page 72)

If manual actions taken at the reactor control console fail to shutdown the reactor, the event would escalate to a Site Area Emergency.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 170 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SA6 Initiating Condition - ALERT UNPLANNED loss of safety system annunciation or indication in the Control Room with either (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Hot Standby (Mode 3)

Hot Shutdown (Mode 4)

Example Emergency Action Level(s):

Note: The SM/ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

1. a. UNPLANNED loss of > approximately 75% of the following 15 minutes:

Control Room annunciators associated with safety systems OR Control Room safety system indication AND

b. Either of the following:

A SIGNIFICANT TRANSIENT is in progress OR Compensatory indications are unavailable.

Basis:

This IC is 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 SIGNIFICANT TRANSIENT.

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

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

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 171 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SA6 Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible 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 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 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the NUE is based on SU11 "Inability to reach required operating mode within Technical Specification limits."

Indicators associated with safety systems are those indicators for reactivity control, core cooling, maintaining reactor coolant system integrity or maintaining containment integrity.

"Compensatory indications" in this context includes computer based information such as SPDS, QSPDS, COLSS, etc. If both a major portion of the annunciation system and all computer monitoring are unavailable, the Alert is required.

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

This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor the transient in progress due to a concurrent loss of compensatory indications with a SIGNIFICANT TRANSIENT in progress during the loss of annunciation or indication.

Reference Documents:

1. 1015.037, Post Transient Review

2. 1203.043, Loss of Control Room Annunciators

3. 2203.042, Loss of Control Room Annunciators

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 172 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SS1 Initiating Condition - SITE AREA EMERGENCY Loss of all offsite and all onsite AC power to Vital 4.16 KV busses 15 minutes Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Hot Standby (Mode 3)

Hot Shutdown (Mode 4)

Example Emergency Action Level(s):

Note: The SM / ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

1. Loss of all offsite and all onsite AC power to Vital 4.16 KV busses 15 minutes.

Basis:

Loss of all AC power to emergency busses compromises all plant safety systems requiring electric power including Shutdown Cooling, ECCS, Containment Heat Removal and the Ultimate Heat Sink.

Prolonged loss of all AC power to emergency busses will lead to loss of Fuel Clad, RCS, and Containment, thus this event can escalate to a General Emergency.

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

Escalation to General Emergency is via Fission Product Barrier Degradation (F) or IC SG1, "Prolonged loss of all offsite and all onsite AC power to Vital 4.16 KV busses."

Reference Documents:

1. 1202.007, Degraded Power

2. 1202.008, Blackout

3. 2202.007, Loss of Off-Site Power

4. 2202.008, Station Blackout

5. 2104.037, Alternate AC Diesel Generator Operations

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 173 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SS3 Initiating Condition - SITE AREA EMERGENCY Automatic trip fails to shutdown the reactor and manual actions taken from the reactor control console are not successful in shutting down the reactor Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Example Emergency Action Level(s):

1. a. An automatic trip failed to shutdown the reactor.

AND

b. Manual actions taken at the reactor control console do not shutdown the reactor as indicated by reactor power 5%.

Basis:

Under these conditions, the reactor is producing more heat than the maximum decay heat load for which the safety systems are designed and efforts to bring the reactor subcritical are unsuccessful. A Site Area Emergency is warranted because conditions exist that lead to IMMINENT loss or potential loss of both fuel clad and RCS.

Manual trip actions taken at the reactor control console are any set of actions by the Reactor Operator(s) which causes or should cause control rods to be rapidly inserted into the core and shuts down the reactor.

Manual trip actions are not considered successful if action away from panel C03 (Unit 1) or panels 2C03/2C14 (Unit 2) is required to trip the reactor. This EAL is still applicable even if actions taken away from panel C03 (Unit 1) or panels 2C03/2C14 (Unit 2) are successful in shutting the reactor down because the design limits of the fuel may have been exceeded or because of the gross failure of the Reactor Protection System to shutdown the plant. This EAL applies whether or not a mode change has occurred. (Reference Operating Mode Applicability page 72)

Escalation of this event to a General Emergency would be due to a prolonged condition leading to an extreme challenge to either core-cooling or heat removal.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 174 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SS4 Initiating Condition - SITE AREA EMERGENCY Loss of all vital DC power 15 minutes Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Hot Standby (Mode 3)

Hot Shutdown (Mode 4)

Example Emergency Action Level(s):

Note: The SM / ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

1. <105 volts on all Vital DC busses 15 minutes.

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.

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

Escalation to a General Emergency would occur by Abnormal Radiation Levels/Radiological Effluent (A), Fission Product Barrier Degradation (F).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 175 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SS6 Initiating Condition - SITE AREA EMERGENCY Inability to monitor a SIGNIFICANT TRANSIENT in progress Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Hot Standby (Mode 3)

Hot Shutdown (Mode 4)

Example Emergency Action Level(s):

Note: The SM / ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

1. a. Loss of > approximately 75% of the following 15 minutes:

Control Room annunciators associated with safety systems OR Control Room safety system indication AND

b. A SIGNIFICANT TRANSIENT is in progress.

AND

c. Compensatory indications are unavailable.

Basis:

This IC is intended to recognize the threat to plant safety associated with the complete loss of capability of the control room staff to monitor plant response to a SIGNIFICANT TRANSIENT.

"Planned" and UNPLANNED actions are not differentiated since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 176 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SS6 It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible 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 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 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the NUE is based on SU11 "Inability to reach required operating mode within Technical Specification limits."

A Site Area Emergency is considered to exist if the Control Room staff cannot monitor safety functions needed for protection of the public while a significant transient is in progress.

Site specific indications needed to monitor safety functions necessary for protection of the public must include Control Room indications, computer generated indications and dedicated annunciation capability.

Indicators associated with safety systems are those indicators for reactivity control, core cooling, maintaining reactor coolant system integrity or maintaining containment integrity.

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

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

Reference Documents:

1. 015.037, Post Transient Review

2. 1203.043, Loss of Control Room Annunciators

3. 2203.042, Loss of Control Room Annunciators

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 177 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SG1 Initiating Condition - GENERAL EMERGENCY Prolonged loss of all offsite and all onsite AC power to Vital 4.16 KV busses Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Hot Standby (Mode 3)

Hot Shutdown (Mode 4)

Example Emergency Action Level(s):

1. a. Loss of all offsite and all onsite AC power to Vital 4.16 KV busses.

AND

b. Either of the following:

Restoration of at least one Vital 4.16 KV bus in <4 hours is not likely.

OR Continuing degradation of core cooling based on Fission Product Barrier monitoring as indicated by CETs 700 °F.

Basis:

Loss of all AC power to Vital 4.16 KV busses compromises all plant safety systems requiring electric power including Shutdown Cooling, ECCS, Containment Heat Removal and the Ultimate Heat Sink.

Prolonged loss of all AC power to Vital 4.16 KV busses will lead to loss of fuel clad, RCS, and containment, thus warranting declaration of a General Emergency.

This IC is specified to assure that in the unlikely event of a 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 Vital 4.16 KV 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.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 178 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SG1 Although it may be difficult to predict when power can be restored, it is necessary to give the SM / ED a reasonable idea of how quickly (s)he may need to 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?

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 SM / ED judgment as it relates to IMMINENT loss or potential loss of fission product barriers and degraded ability to monitor fission product barriers.

Reference Documents:

1. Unit 1 Calculation 85-E-0072-02, Time from Loss of All AC Power to Loss of Subcooling

2. Unit 2 Calculation 85-E-0072-01, Time from Loss of All AC Power to Loss of Subcooling

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 179 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 SYSTEM MALFUNCTION SG3 Initiating Condition - GENERAL EMERGENCY Automatic trip and all manual actions fail to shutdown the reactor and indication of an extreme challenge to the ability to cool the core exists Operating Mode Applicability: Power Operations (Mode 1)

Startup (Mode 2)

Example Emergency Action Level(s):

1. a. An automatic trip failed to shutdown the reactor AND

b. All manual actions do not shutdown the reactor as indicated by reactor power 5%.

AND

c. Either of the following exist or have occurred due to continued power generation:

CET temperatures at or approaching 1200 °F OR Feedwater flow rate less than:

Unit 1: 430 gpm Unit 2: 485 gpm Basis:

Under these conditions, the reactor is producing more heat than the maximum decay heat load for which the safety systems are designed and efforts to bring the reactor subcritical are unsuccessful.

In the event either of these challenges exists at a time that the reactor has not been brought below the power associated with the safety system design a core melt sequence exists. 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 table declaration to permit maximum off-site intervention time.

PROC./WORK PLAN N

O. PROCEDURE

/WORK PLAN TITLE: PAGE: 180 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 Attachment 3 EAL Matrix Chart

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 181 of 181 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 057 Attachment 3 EAL Matrix Chart Attachment 3 EAL Matrix Chart Procedure 1903.010 Rev 057 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION - Loss of RCS / Reactor Vessel Inventory ISFSI MALFUNCTION - Cask Damage CG1 5 6 CS1 5 6 CA1 5 6 CU1 5 E-HU1 1 2 3 4 5 6 D Loss of RCS / reactor vessel inventory affecting fuel clad Loss of RCS / reactor vessel inventory affecting core Loss of RCS / reactor vessel inventory RCS leakage Note: Security Events are bounded by the Hazards integrity with containment challenged decay heat removal capability EALs.

Emergency Action Level(s): Emergency Action Level(s): Emergency Action Level(s): Emergency Action Level(s): Damage to a loaded cask CONFINEMENT BOUNDARY NOTE: NOTE: NOTE: NOTE:

The SM / ED should not wait until the applicable time has The SM / ED should not wait until the applicable time has The SM / ED should not wait until the applicable time has The SM should not wait until the applicable time has Emergency Action Level(s):

elapsed, but should declare the event as soon as it is elapsed, but should declare the event as soon as it is elapsed, but should declare the event as soon as it is elapsed, but should declare the event as soon as it is 1. Damage to a loaded cask CONFINEMENT determined that the condition will likely exceed the determined that the condition will likely exceed the determined that the condition will likely exceed the determined that the condition will likely exceed the BOUNDARY.

applicable time. applicable time. applicable time. applicable time.

1. a. Core exit thermocouples indicate superheat for 1. With CONTAINMENT CLOSURE not established: 1. Loss of RCS / reactor vessel inventory as indicated 1. RCS leakage results in the inability to maintain or 30 minutes. by: restore level within Pressurizer or RCS level target Loss of RCS / reactor vessel level as indicated by: Unit 1: RVLMS Levels 1 through 8 indicate DRY band for 15 minutes.

AND Unit 1: RVLMS Levels 1 through 9 indicate DRY Unit 2: RVLMS Levels 1 through 6 indicate DRY Unit 2: RVLMS Levels 1 through 5 indicate DRY

b. Any of the following containment challenge indications: OR OR CONTAINMENT CLOSURE not established Explosive mixture inside containment 2. With CONTAINMENT CLOSURE established, core Unit 1: Reactor vessel level < 368 ft., 6 in.

UNPLANNED rise in containment pressure exit thermocouples indicate superheat. (bottom of the hot leg)

OR OR Unit 2: Reactor vessel level < 369 ft., 1.5 in.

Definitions (bottom of the hot leg)

2. a. RCS / reactor vessel level cannot be monitored for 3. RCS / reactor vessel level cannot be monitored for OR CONFINEMENT BOUNDARY: The barrier(s) between areas containing radioactive substances and the environment 30 minutes with a loss of RCS/ reactor vessel 30 minutes with a loss of RCS / reactor vessel inventory as indicated by any of the following: inventory as indicated by any of the following: 2. RCS / reactor vessel level cannot be monitored for CONTAINMENT CLOSURE: The actions to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing Containment High Range Radiation Monitor 15 minutes with a loss of RCS / reactor vessel Containment High Range Radiation Monitor reading > 10 R/hr inventory as indicated by an unexplained level rise in plant conditions. Containment closure must be capable of being set within 30 minutes. Containment Closure is Set when the penetrations are isolated by manual or automatic isolation valve, reading >10 R/hr Erratic source range monitor indication the Reactor Building Sump, Reactor Drain Tank, Aux. blind flange, or equivalent.

Erratic source range monitor indication Unexplained level rise in Reactor Building Sump, Building Equipment Drain Tank, Aux. Building Sump, Unexplained level rise in Reactor Building Sump, Reactor Drain Tank, Quench Tank, Aux. Building or Quench Tank.

EXPLOSION: A rapid, violent, unconfined combustion or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent Reactor Drain Tank, Quench Tank, Aux. Building Equipment Drain Tank, or Aux. Building Sump Equipment Drain Tank, or Aux. Building Sump structures, systems, or components.

AND FAULTED: In a steam generator, the existence of secondary side leakage that results in an uncontrolled drop in steam generator pressure or the steam generator being completely depressurized.

b. Any of the following containment challenge indications:

CONTAINMENT CLOSURE not established FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIREs.

Explosive mixture inside containment UNPLANNED rise in containment pressure HOSTILE ACTION: An act toward a Nuclear Power Plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be CU2 6 included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

UNPLANNED loss of RCS / reactor vessel Inventory HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or Emergency Action Level(s): causing destruction.

NOTE:

The SM should not wait until the applicable time has IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur. Where elapsed, but should declare the event as soon as it is IMMINENT timeframes are specified, they shall apply.

determined that the condition will likely exceed the applicable time.

PROTECTED AREA: An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

1. UNPLANNED RCS / reactor vessel level drop as RUPTURED: In a steam generator, existence of primary-to-secondary leakage of a magnitude sufficient to require or cause a reactor trip and safety injection indicated by either of the following:

a. RCS / reactor vessel water level drop below the SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential reactor vessel flange for 15 minutes when the degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.\

RCS / reactor vessel level band is established above the reactor vessel flange. SIGNIFICANT TRANSIENT: An UNPLANNED event involving one or more of the following: (1) automatic turbine runback > 25% thermal reactor power, (2) electrical load rejection > 25% full OR electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal power oscillations > 10%.

b. RCS / reactor vessel water level drop below the UNISOLABLE: A breach or leak that cannot be promptly isolated RCS / reactor vessel level band for 15 minutes when the RCS / reactor vessel level band is established below the reactor vessel flange. UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions OR VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for

2. RCS / reactor vessel level cannot be monitored with a loss of RCS / reactor vessel inventory as indicated by timely assessment.

an unexplained level rise in (as applicable) the Reactor Building Sump, Reactor Drain Tank, Aux. Building VISIBLE DAMAGE: Damage to equipment or structures that is readily observable without measurement, testing, or analysis. Damage is sufficient to cause concern regarding the continued Equipment Drain Tank, Aux. Building Sump, or Quench operability or reliability of affected structure, system, or component. Example damage includes: deformation due to heat or impact, denting, penetration, rupture, cracking, paint blistering.

Tank.

Surface blemishes (e.g., paint chipping, scratches) should not be included.

COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION - Loss of Decay Heat Removal CA3 5 6 CU3 5 6 LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS Inability to maintain plant in Cold Shutdown UNPLANNED loss of decay heat removal capability with FUEL CLAD RCS CONTAINMENT irradiated fuel in the reactor vessel Emergency Action Level(s):

1. An UNPLANNED event results in RCS temperature Emergency Action Level(s):

> 200 °F > the specified duration in Table C1. NOTE:

The SM should not wait until the applicable time has GENERAL EMERGENCY Table - C1 elapsed, but should declare the event as soon as it is RCS Reheat Duration Threshold BARRIERS AFFECTED FG1 1 2 3 4 determined that the condition will likely exceed the Containment applicable time.

RCS Closure Duration 3 LOSS OR 2 LOSS / 1 POTENTIAL LOSS Loss of ANY two barriers AND loss or potential loss of Intact (but not RCS 1. UNPLANNED event results in RCS temperature third barrier lowered inventory) N/A 60 minutes* exceeding 200 °F.

OR Not intact or RCS Established 20 minutes*

2. Loss of all RCS temperature and RCS / reactor vessel lowered inventory Not Established 0 minutes level indication for 15 minutes. LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS

• If an RCS heat removal system is in operation within FUEL CLAD RCS CONTAINMENT this time frame and RCS temperature is being reduced, the EAL is not applicable OR NOTE: EAL #2 does not apply in solid plant conditions. SITE AREA EMERGENCY BARRIERS AFFECTED

2. An UNPLANNED event results in RCS pressure rise FS1 1 2 3 4

> 10 psi due to a loss of RCS cooling. 2 LOSS OR 1 LOSS / 1 POTENTIAL LOSS Loss or potential loss of ANY two barriers COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION - Loss of AC Power CA5 5 6 D CU5 5 6 LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS Loss of all offsite and all onsite AC power to Vital 4.16 KV AC power capability to Vital 4.16 KV busses reduced to a FUEL CLAD RCS busses 15 minutes single power source 15 minutes such that any additional single power source failure would result in station blackout Emergency Action Level(s): Emergency Action Level(s): ALERT BARRIERS AFFECTED NOTE: NOTE: FA1 1 2 3 4 The SM / ED should not wait until the applicable time has The SM should not wait until the applicable time has 1 LOSS OR 1 POTENTIAL LOSS elapsed, but should declare the event as soon as it is elapsed, but should declare the event as soon as it is ANY loss or ANY potential loss of EITHER fuel clad or determined that the condition will likely exceed the determined that the condition will likely exceed the RCS applicable time. applicable time.

1. Loss of all offsite and all onsite AC power to Vital 1. a. AC power capability to Vital 4.16 KV busses 4.16KV busses 15 minutes. reduced to a single power source 15 minutes.

LOSS POTENTIAL LOSS AND CONTAINMENT

b. Any additional single power source failure will result in station blackout.

COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION - Loss of DC Power UNUSUAL EVENT BARRIERS AFFECTED CU6 5 6 FU1 1 2 3 4 1 LOSS OR 1 POTENTIAL LOSS ANY loss or ANY potential loss of containment Loss of required DC power 15 minutes Emergency Action Level(s):

NOTE:

The SM should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the Plant Operating Mode Usage for ANO EALs:

applicable time.

1. < 105 volts on required Vital DC bus 15 minutes. UNIT 1:

Mode 1 = Power Operation - Keff 0.99, Reactor Power > 5%

COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION - Inadvertant Criticality Mode 2 = Startup - Keff .99, Reactor Power 5%

CU7 5 6 Mode 3 = Hot Standby - Keff < .99, RCS 280 °F Inadvertent criticality Mode 4 = Hot Shutdown - Keff < .99, 280 °F > RCS >200 °F Emergency Action Level(s): Mode 5 = Cold Shutdown - Keff < .99, RCS 200 °F

1. UNPLANNED sustained positive startup rate observed Mode 6 = Refueling - One or more reactor vessel head closure bolts less than fully tensioned on nuclear instrumentation.

Defueled (D) - All reactor fuel removed from reactor pressure vessel (full core offload during refueling or extended outage). This is not an operating mode designation by Technical Specifications.

Plant Operating Mode Usage for ANO EALs:

COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION - Loss of Communications UNIT 2:

CU8 5 6 D Mode 1 = Power Operation - Keff 0.99, Reactor Power > 5%, RCS 300 °F Loss of all onsite or offsite communications capabilities Mode 2 = Startup - Keff .99, Reactor Power 5%, RCS 300 °F Emergency Action Level(s):

1. Loss of all Table C2 onsite communication methods Mode 3 = Hot Standby - Keff < .99, Reactor Power 0, RCS 300 °F affecting the ability to perform routine operations.

Table C2 Mode 4 = Hot Shutdown - Keff < .99, Reactor Power 0, 300 °F > RCS > 200 °F Onsite Communications Equipment Station radio system Mode 5 = Cold Shutdown - Keff < .99, Reactor Power 0, RCS 200 °F Plant paging system In-plant telephones Mode 6 = Refueling - Keff .95, Reactor Power 0, RCS 140 °F Reactor vessel head unbolted or removed and fuel in the vessel Gaitronics Defueled (D) - All reactor fuel removed from reactor pressure vessel (full core offload during refueling or extended outage). This is not an operating mode OR designation by Technical Specifications.

2. Loss of all Table C3 offsite communication methods affecting the ability to perform offsite notifications.

Table C3 Offsite Communications Equipment All telephone lines (commercial and microwave)

ENS