ML18361A679
| ML18361A679 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point, 07201036  |
| Issue date: | 12/20/2018 |
| From: | Exelon Generation Co |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18361A739 | List: |
| References | |
| NMP1L3254 | |
| Download: ML18361A679 (337) | |
Text
{{#Wiki_filter:ATTACHMENT 1 10 CFR 50.54(q)(5) Procedure Change Summary Analysis Page 1 of 2 10 CFR so~54(g)(5) Procedure Change Summary Analysis Procedures/Titles Exelon Generation Company, LLC (Exelon) is submitting the following Emergency Plan Addendum revisions for the Nine Mile Point Nuclear Station (NMP):
- EP-AA-1013, Addendum 3, Revision 4, "Nine Mile Point Nuclear Station Unit 1 Emergency Classification Technical Bases"
- EP-AA-1013, Addendum 4, Revision 3, "Nine Mile Point Nuclear Station Unit 2 Emergency Classification Technical Bases" Description of Procedures EP-AA-1013, Addendums 3 and 4, describe the Emergency Action Levels (EALs) implemented at NMP for entering Emergency Classification Levels (ECLs).
Description of Changes The changes to Emergency Plan Addendums 3 and 4 addressed in these revisions reflect aspects of the implementation of the NEI 99-01, Revision 6, EAL schemes for NMP that were approved by the NRC. As documented in a letter and supporting Safety Evaluation Report (SER) dated June 26, 2018, the NRC issued Amendment No. 230 to Renewed Facility Operating License No. DPR-63 and Amendment No. 171 to Renewed Facility Operating License No. NPF-69 for the Nine Mile Point Nuclear Station, Units 1 and 2, respectively, permitting the adoption of the NEI 99-01, Revision 6, EAL schemes at NMP. In support of the implementation efforts, EAL Wallboards were revised to reflect the updated schemes. The Wallboards were implemented as EP-AA-1013, Addendum 3, Appendix 1, Revision O for NMP, Unit 1 and EP-AA-1013, Addendum 4, Appendix 1, Revision O for NMP Unit 2. These new Appendix documents replace Emergency Plan Implementing Procedures EPIP-EPP EAL, Revision 25, "Emergency Action Level Matrix Unit 1," and EPIP-EPP-02-EAL, Revision 24, "Emergency Action Level Matrix Unit 2." Description of How the Changes Still Comply with Regulations The revisions to EP-AA-1013, Addendums 3 and 4, involve implementing changes based on the NRC issuance of Amendment Nos. 230 and 171 for NMP, Units 1 and 2, respectively. A new Appendix 1 was added to each of the Addendums that replace the previous Unit 1 and Unit 2 Wallboards (i.e., EPIP-EPP-01-EAL, Revision 25 and EPIP-EPP-02-EAL, Revision 24). . Implementing a change based on an NRG-approved amendment and supporting Safety Evaluation Report (SER) does not alter the meaning or intent of the basis of the approved EALs, and applicable emergency planning regulations and commitments to the NRC continue to be met. Page 2 of 2 Description of Why the Changes are Not a Reduction in Effectiveness (RIE) Revising EP-AA-1013, Addendums 3 and 4, as described above does not alter the meaning or intent of the EALs as approved by the NRG. Applicable emergency planning regulations and commitments to the NRG continue to be met. The changes do not alter the capability of the ERO to implement required Emergency Plan functions, and do not affect the timeliness of the performance of these functions. Therefore, the changes do not result in a reduction in the effectiveness of the Emergency Plan for NMP.
ATTACHMENT 2 Radiological Emergency Addendum Revision EP-AA-1013, Addendum 3, Revision 4, "Nine Mile Point Nuclear Station Unit 1 Emergency Classification Technical Bases"
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EP-AA-1013 Addendum 3 =?Exelon Generation Revision 4 Nine Mile Point Nuclear Station Unit 1
- Emergency Classification Technical Bases
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear REVISION HISTORY Rev. 0 February 2015 Rev. 1 October 2016 Rev. 2 May 2017 Rev. 3 July 2017 Rev. 4 December 2018 I December 2018 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear Section 1: Classification of Emergencies 1.1 General Section D of the Exelon Nuclear Standardized Emergency Plan divides the types of emergencies into four EMERGENCY CLASSIFICATION LEVELS (ECLs). The first four are the UNUSUAL EVENT (UE), ALERT, SITE AREA EMERGENCY (SAE), and GENERAL EMERGENCY (GE). These ECLs are entered by satisfying the Initiating Condition (IC) through meeting an Emergency Action Level (EAL) of the IC provided in this section of the Annex. The ECLs are escalated from least severe to most severe according to relative threat to the health and safety of the public and emergency workers. Depending on the severity of an event, prior to returning to a standard day-to-day organization, a state or phase called Recovery may be entered to provide dedicated resources and organization in support of restoration and communication activities following the termination of the emergency. Unusual Event (UE): 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. 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 exposure levels. Site Area Emergency (SAE): Events are in progress or have occurred which involve an 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. 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 ofthe facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area. Recovery: Recovery can be considered as a phase of the emergency and is entered by meeting emergency termination criteria provided in EP-CE-111 Emergency Classification and Protective Action Recommendations. December 2018 NMP 1-1 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear Emergency Classification Level (ECL): One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The Emergency Classification Levels, in ascending order of severity, are:
- UNUSUAL EVENT (UE)
- ALERT
- SITE AREA EMERGENCY (SAE)
- GENERAL EMERGENCY (GE)
Initiating Condition (IC): An event or condition that aligns with the definitiory of one of the four Emergency Classification Levels by virtue of the potential or actual effects or consequences. Emergency Action Level (EAL): A pre-determined, site-specific, observable threshold for an Initiating Condition that, when met or exceeded, places the plant in a given Emergency Classification Level. December 2018 NMP 1-2 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear An emergency is classified by assessing plant conditions and comparing abnormal conditions to ICs and EALs, based on the designated Operational Condition (MODE). Modes 1 through 4 are based on Reactor Mode Switch Position and average reactor coolant temperature. "Defueled" Mode was established for classification purposes under NEI 99-01 to reflect conditions where all fuel has been removed from the Reactor Pressure Vessel. MODE TITLE CONDITION 1 Power Reactor mode switch is in startup or Operation run position. Reactor is critical criticality is possible due to control rod motion. 2 Hot Shutdown Reactor mode switch is in shutdown position. No core alterations leading to an addition of reactivity are being performed. Reactor coolant temperature is greater than 212°F 3 Cold Shutdown Reactor mode switch is in shutdown or refuel position. No core alterations leading to an addition of reactivity are being performed. Reactor coolant temperature is less than 212°F. 4 Refueling Reactor mode switch is in the refuel position. Reactor coolant temperature is less than 212°F. Fuel may be loaded or unloaded. No more than one operable control rod may be witrhdrawn. D Defueled No fuel is in the reactor. Hot Matrix - applies in modes (1) and (2) Cold Matrix - applies in modes (3), (4), and (D) Individuals responsible for the classification of events will refer to the Initiating Condition and EALs on the matrix of the appropriate station Standardized Emergency Plan Annex (this document). This matrix will contain ICs, EALs, Mode Applicability Designators, appropriate EAL numbering system, and additional guidance necessary to classify events. It may be provided as a user aid. December 2018 NMP 1-3 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear The matrix is set up in six Recognition Categories. The first is designated as "R" and relates to Abnormal Radiological Conditions I Abnormal Radiological Effluent Releases. The second is designated as "F" and relates to Fission Product Barrier Degradation. The third is designated as "M" and relates to hot condition System Malfunctions. The fourth is designated as "C" and relates to Cold Shutdown I Refueling System Malfunctions. The fifth is designated as "H" and relates to Hazards and Other Conditions Affecting Plant Safety. The sixth is designated "E-H" and relates to ISFSI Malfunctions. The matrix is designed to provide an evaluation of the Initiating Conditions from the worst conditions (General Emergencies) on the left to the relatively less severe conditions on the right (Unusual Events). Evaluating conditions from left to right will reduce the possibility that an event will be under classified. All Recognition Categories should be reviewed for applicability prior to classification. The Initiating Conditions are coded with a two letter and one number code. The first letter is the Recognition Category designator, the second letter is the classification Level, "U" for (NOTIFICATION OF) UNUSUAL EVENT, "A" for ALERT, "S" for SITE AREA EMERGENCY and "G" for GENERAL EMERGENCY. The EAL number is a sequential number for that Recognition Category series. All ICs that are describing the severity of a common condition (series) will have the same number. The EAL number may then be used to reference a corresponding page(s), which provides the basis information pertaining to the IC:
- EAL
- Mode Applicability
- Basis Classification is not to be made without referencing, comparing and satisfying the specified Emergency Action Levels.
A list of definitions is provided as part of this document for terms having specific meaning to the EALs. Site specific definitions are provided for terms with the intent to be used for a particular IC/EAL and may not be applicable to other uses of that term at other sites, the Emergency Plan or procedures. References are also included to documents that were used to develop the EALs. References to the Emergency Director means the person in Command and Control as defined in the Emergency Plan. Classification of emergencies is a non-delegable responsibility of Command and Control assigned to the Shift Emergency Director (Control Room Shift Manager) or the Corporate Emergency Director (Emergency Operations Facility). December 2018 NMP 1-4 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear 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 EAL has been exceeded. While this is particularly prudent at the higher ECL (as the early classification may provide for more effective implementation of protective me~sures), it is nonetheless applicable to all ECLs. 1.2 Classification, Instrumentation and Transient Events 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 indication's operability, the condition's existence, or the report's accuracy is removed. Implicit in this is the need for timely assessment. Indications used for monitoring and evaluation of plant conditions include the normally used instrumentation, backup or redundant instrumentation, and the use of other parameters that provide information that supports determination if an EAL has been reached. When an EAL refers to a specific instrument or indication that is determined to be inaccurate or unavailable, then alternate indications shall be used to monitor the specified condition. During an event that results in changing parameters trending towards an EAL classification, and instrumentation that was available to monitor this parameter becomes unavailable or the parameter goes off scale, the parameter should be assumed to have been exceeded consistent with the trend and the classification made if there are no other direct or indirect means available to determine if the EAL has not been exceeded. The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL has been exceeded (e.g., dose assessments, chemistry sampling, RCS leak rate calculation, etc.); the EAL and/or the associated basis discussion will identify the necessary analysis. In these cases, the 15-minute declaration period starts with the availability of the analysis results that show the EAL to be exceeded (i.e., this is the time that the EAL information is first available). 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 site's Technical Specifications. Activities which cause the site to operate beyond that allowed by the site's Technical Specifications, planned or unplanned, may result in an EAL being met December 2018 NMP 1-5 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear or exceeded. Planned evolutions to test, manipulate, repair, perform maintenance or modifications to systems and equipment that result in an EAL 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 specific operating license. However, these conditions may be subject to the reporting requirements of 10 CFR 50.72. When two or more EALs are determined, declaration will be made on the highest classification level for the unit. When both units are affected, the highest classification for the Station will be used for notification purposes and bot.h units' ECLs will be noted. Concerning EGL Downgrading, Exelon Nuclear policy is that ECLs shall not be downgraded to a lower classification. Once declared, the event shall remain in effect until no classification is warranted or until such time as conditions warrant classification to Recovery. 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, the guidance of NUREG-1022, Event Reporting Guidelines 10 CFR 50. 72 and 50. 73 and the Reportability Reference Manual, should be applied. 1.3 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 can be made, the declaration shall be based on the mode that existed at the time the event occurred. 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 Shutdow,n (or a higher mode) is entered during any subsequent heat-up. In particular, the Fission Product Barrier Matrix EALs are applicable only to events that initiate in Hot Shutdown or higher. If there is a change in Mode following an event declaration, any subsequent events involving EALs outside of the current declaration escalation path will be evaluated on the Mode of the plant at the time the subsequent events occur. December 2018 NMP 1-6 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear 1.4 Emergency Director Judgment Emergency Director (ED) Judgment EALs are provided in the Hazards and Other Condition Affecting Plant Safety section and on the Fission Product Barrier (FPB) Matrix. Both of the ED Judgment EALs have specific criteria for when they should be applied. The Hazards Section ED Judgment EALs are intended to address unanticipated conditions which are not addressed explicitly by other EALs but warrant declaration of an emergency because conditions exist which are believed by the ED to fall under specific emergency classifications (UE, Alert, SAE or GE). The FPB Matrix ED Judgment EALs are intended to include unanticipated conditions, which are not addressed explicitly by any of the other FPB threshold values, but warrant determination because conditions exist that fall under the broader definition for a significant Loss or Potential Loss of the fission product barrier (equal to or greater than the defined FPB threshold values). 1.5
- Fission Product Barrier (FPB) Threshold A fission product barrier threshold is a pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier.
FPB thresholds represent threats to the defense in depth design concept that precludes the release of radioactive fission products to the environment. This concept relies on multiple physical barriers, any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment. The primary FPBs are: Fuel Clad (FC) Reactor Coolant System (RCS) Containment (CT) Upon determination that one or more FPB thresholds have been exceeded, the combination of barrier loss and/or potential loss thresholds is compared to the FPB IC/EAL criteria to determine the appropriate ECL. In some accident sequences, the ICs and EALs presented in the Abnormal Radiation Levels/ Radiological Effluent (R) Recognition Category will be exceeded at the same time, or shortly after, the loss of one or more fission product barriers. This redundancy is intentional as the former ICs address radioactivity releases that result in certain offsite doses from whatever cause, including events that might not be fully encompassed by fission product barriers (e.g., spent fuel pool accidents, design containment leakage following a LOCA, etc.). December 2018 NMP 1-7 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear 1.6 Fission Product Barrier Restoration Fission Product Barriers are not treated the same as EAL threshold values. Conditions warranting declaration of the loss or potential loss of a FPB may occur resulting in a specific classification. The condition that caused the loss or potential loss declaration could be rectified as the result of Operator action, automatic actions, or designed plant response. Barriers will be considered re-established when there are direct verifiable indications (containment penetration or open valve has been isolated, coolant sample results, etc) that the barrier has been restored and is capable of mitigating future events. The reestablishment of a FPB does not alter or lower the existing classification. Termination and entry into Recovery phase is still required for exiting the present classification. However the reestablishment of the barrier should be considered in determining future classifications should plant conditions or events change.
- 1. 7 Definitions CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.
CONTAINMENT CLOSURE: The procedurally defined actions taken to secure containment (primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment" due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events may require a post-event inspection to determine if the attributes of an explosion are present. FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fire. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed. FISSION PRODUCT BARRIER (FPB) THRESHOLD: A pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. December 2018 NMP 1-8 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear HOSTILE ACTION: An act toward a Nuclear Power Plant (NPP) 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). HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction. IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions. 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. NORMAL LEVELS: As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value. OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons entering for official business. PROJECTILE: An object directed toward a Nuclear Power Plant (NPP) that could cause concern for its continued operability, reliability, or personnel safety. PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence. REFUELING PATHWAY: All the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange. SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. 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. December 2018 NMP 1-9 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon-Nuclear UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally. UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. VISIBLE DAMAGE: Damage to a SAFETY SYSTEM train that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected SAFETY SYSTEM train. December 2018 NMP 1-10 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear EMERGENCY ACTION LEVEL TECHNICAL BASIS PAGE INDEX General Site Area Alert Unusual Event EAL Pg. EAL Pg. EAL Pg. EAL Pg. RG1 2-24 RS1 2-26 RA1 2-28 RU1 2-30 RG2 2-33 RS2 2-34 RA2 2-35 RU2 2-38 RA3 2-40 RU3 2-43 FG1 2-44 FS1 2-45 FA1 2-46 Fuel Clad RCS Containment FC1 2-47 FC2 2-48 RC2 2-52 CT2 2-60. RC3 2-54 CT3 2-61 RC4 2-55 FCS 2-50 RCS 2-58 CTS 2-63 CT6 2-64 FC7 2-51 RC? 2-59 CT? 2-67 MG1 2-68 MS1 2-70 MA1 2-72 MU1 2-74 MG2 2-75 MS2 2-77 MS3 . 2-78 MA3 2-80 MU3 2-82 MA4 2-85 MU4 2-87 MAS 2-89 MU6 2-92 MU? 2-94 CA1 2-96 CU1 2-98 CA2 2-100 CU3 2-103 CU4 2-104 CAS 2-106 cus 2-108 CG6 2-110 CS6 2-114 CA6 2-117 CU6 2-119 HS1 2-121 HA1 2-123 HU1 2-126 HS2 2-128 HA2 2-130 HU3 2-131 HU4 2-135
- HAS 2-137 HU6 2-140 HG? 2-143 HS7 2-144 HA? 2-145 HU? 2-146 E-HU1 2-147 December 2018 NMP 1-11 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Abnormal Rad Levels / Radiological Effluents RG1 mrnrmm [Q] RS1 mrnrmm IT:l RA1 mrn@m[Q] RU1 mrnrmm [Q] Release of gaseous radioactivity resulting in offsite dose greater Release of gaseous radioactivity resulting in offsite dose greater Release of gaseous or liquid radioactivity resulting in offsite Release of gaseous or liquid radioactivity greater than 2 times than 1,000 mRem TEDE or 5,000 mRem COE Thyroid. than 100 mRem TEDE or 500 mRem COE Thyroid. dose greater than 10 mRem TEDE or50 mRem COE Thyroid. the ODCM limits for 60 minutes or longer. Emergency Action Level (EAL): Emergency Action Level (EAL): Emergency Action Level (EAL): Emergency Action Level (EAL): Notes: Notes: Notes: Notes:
. The Emergency Director should declare the event promptly upon determining that the applicable time has been
. The Emergency Director should declare the event promptly upon determining that the applicable lime has been
. The Emergency Director should declare the event promptly upon determining that the applicable lime has
. The Emergency Director should declare the event promptly upon determining that the applicable lime has 1.
exceeded, or will likely be exceeded. Dose assessment using actual meteorology indicates doses al 1. exceeded, or will likely be exceeded. Dose assessment using actual meteorology indicates doses at been exceeded, or will likely be exceeded. If an ongoing release is detected and the release start lime is unknown, assume that the release duration has
. been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes. exceeded 60 minutes. or beyond the site boundary of EITHER:
- a. > 1000 mRem TEDE or beyond the site boundary of EITHER:
- a. > 100 mRem TEDE
. Classification based on effluent monitor readings assumes that a release path to the environment is
. Classification based on effluent monitor readings assumes that a release path to the environment is established. If OR DR established. If the effluent flow past an effluent monitor is the effluent flow past an effluent monitor is known to have known to have stopped due to actions to isolate the stopped due to actions to isolate the release path, then
- b. > 5000 mRem COE Thyroid b. > 500 mRem COE Thyroid release path, then the effluent monitor reading is no the effluent monitor reading is no longer valid for longer valid for classification purposes. classification purposes.
J!! C 2. OR Field survey results at or beyond the site boundary indicate EITHER: 2. OR Field survey results al or beyond the site boundary indicate EITHER:
. The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification CII 1. Reading on the Rad Waste Discharge effluent monitor assessments until the results from a dose assessment > 2x.alarm setpolnt established by a current radioactive
- I a. Gamma (dosed window) dose rates a. Gamma (dosed window) dose rates using actual meteorology are available.
ii: > 1000 mR/hr are expected to continue > 100 mR/hr are expected to continue release discharge permit for c?: 60 minutes. w for?, 60 minutes. for?, 60 minutes. OR iii OR OR
- 1. Reading on Stack (RN 1o A/B) Effluent Monitor
- 2. Reading on Stack (RN 10 A/B) Effluent Monitor "c, > 1.5 E+OS cps for?. 15 minutes. > 2.85 E+o2 cps (285 cpsl for?. 60 minutes.
0 b. Analyses of field survey samples indicate b. Analyses offield survey samples indicate
> 5000 mRem COE Thyroid for 60 minutes > 500 mRem COE Thyroid for 60 minutes OR 0 OR
'c of inhalation. of inhalation. 2. Dose assessment using actual meteorology indicates doses at ca or beyond the site boundary of EITHER: 3. Confirmed sample analyses for gaseous or liquid releases ir: a. > 10 mRem TEDE indicate concentrations or release rates > 2x ODCM Limit with a release duration of?, 60 minutes. OR
- b. > SO mRem COE Thyroid OR
- 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary:
- a. 10 mRem TEDE for 60 minutes of exposure.
OR
- b. 50 mRem COE Thyroid for 60 minutes of exposure.
OR
- 4. Field survey results at or beyond the site boundary indicate EITHER:
- a. Gamma (dosed window) dose rates
> 10 mR/hr are expected to continue for?. 60 minutes.
OR
- b. Analyses offield survey samples indicate
> 50 mRem COE Thyroid for 60 minutes of inhalation.
Modes: 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4-Refuehng D-Defueled December 2018 HOT MATRIX NMP2-1 HOT MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Abnormal Rad Levels / Radiological Effluents RG2 RS2 RA2 Spent fuel pool level cannot be restored to at least 316 feet Spent fuel pool level at 316 feet. Significant lowering of water level above, or damage to, UNPLANNED loss of water level above irradiated fuel. for 60 minutes or longer. irradiated fuel. Emergency Action Levels {EAU: Emergency Action Level (EAU: Emergency Action Level IEALl: Emergency Action Level (EAL): Note: The Emergency Director should declare the event Lowering of spent fuel pool level to 316 feet as indicated on promptly upon determining that the applicable lime Ll-54-65A or Ll-54-65B on SFP monitoring panel 1. Uncovery of irradiated fuel in the REFUELING 1. a. UNPLANNED water level drop in the REFUELING has been exceeded, or w!ll likely be exceeded. (PNL-54-65H). PATHWAY. PATHWAY as indicated by; OR
- SFP water level < low water level alarm.
Spent fuel pool level cannot be restored to at least 316 feet as indicated on Ll-54-65A or Ll-54-65B on SFP monitoring 2. Damage to irradiated fuel resulting in a release of OR panel (PNL-54-65H) for::_ 60 minutes. radioactivity from the fuel as indicated by ANY
- Indication or report of a drop in water level in Table R1 Radiation Monitor Alarm.
the REFUELING PATHWAY. OR AND
- 3. Lowering of spent fuel pool level to 326 feet as indicated on Ll-54-65A or Ll-54-65B on SFP b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitor in Table R1.
monitoring panel (PNL-54-65H). RA3 RU3 Radiation levels that impede access to equipment Reactor coolant activity greater than Technical necessary for normal plant operations, cooldown or Specification allowable limits. shutdown. Table R2 Emergency Action Level (EAL): Emergency Action Level (EAL): Areas Requiring Continuous Occupancy Note: If the equipment in the room or area listed in Table
- Main Control Room 1 Offgas radiation monitor RN-12A or RN-12B R3 was already inoperable, or not available, before
- !e UPSCL alarm.
the event occurred, then no emergency classification
- Central Alarm Station - (by survey) is warranted. OR
- 2. Specific coolant activity> 4.011Ci/gm 1-131
- 1. Dose rate > 15 mR/hr in ANY of the areas equivalent.
in Table R2. Table R1 Refuel Floor ARM's Table R3 OR Areas with Entry Related Mode Applicability
- 2. UNPLANNED event results in radiation levels that Entry Related prohibit or significantly impede access to ANY
- ARM 18 (West end of shield wall) Area Mode Applicability of the areas in Table R3.
- ARM 25 (Reactor Building - east wall)
Reactor Building
- ARM 29 Refuel Bridge (Low Range) 198' Northeast comer
- Refuel Bridge (High Range) 261' North and Shutdown
- Reactor Building Vent Radiation Monitor Cooling Room Modes 2, 3 and 4 281' North Turbine Building 291' North Modes. 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4- Refueling D-Defueled December 2018 HOT MATRIX NMP2-2 HOT MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
FC - Fuel Clad RC - Reactor Coolant System CT- Containment Sub-Category Loss Potential Loss Loss Potential Loss Loss Potential Loss Coolant acUvity > 300 uCi/gm 1-131 equivalent. None
- 1. RCS Activity None None None None 1.SAP entry required 2. RPV water level cannot be restored and 1. RPV water level!:!!!!!!!! be restored and SAP entry required.
maintained> -84 inches. maintained > -84 inches.
- 2. RPV Water Level OR OR None None
- 3. RPV water level cannot be determined. 2. RPV water level £!.!!!!.Q! be detennlned.
- 1. a. Primary Containment pressure> 3.~ psig. 1. UNPLANNED rapid drop in Primary 3. Torus pressure > 35 psig.
AND Containment pressure following Primary OR
- b. Primary Containment pressure rise is due Containment pressure rise. 4. a. Primary Containment hydrogen
- 3. Primary to RCS leakage. OR concentration?. 6%.
Containment 2. Primary Containment pressure response !!Q! AND None None None consistent with LOCA conditions. b. Primary Containment oxygen Pressure/ Conditions concentration 2, 5%. OR
- 5. Heat Capacity Temperature Limit (N1-EOP-4 Figure M) exceeded.
- 1. UNISOLABLE Main Steam line, EC steam 3. UNISOLABLE primary system leakage line, Feedwater, or RWCU line break. that results in EITHER of the following:
OR a. ANY area temperature> N1-EOP-S
- 4. RCS Leak Rate None None 2. RPV Slowdown is required. Detail T alarm set point. None None OR
- b. ANY area radiation revel> N1-EOP-S Detail R alarm set point.
Drywell radiation reading> 1.1 E+03 R/hr Drywel1 radiation reading> 100 R/hr. Drywell radiation reading> 1.1 E+04 R/hr 5.Primary 11100 R/hr). (11,000 R/hr). Containment None None None Radiation
- 1. UNISOLABLE direct downstream pathway to the environment exists following automatic or manual isolation signal.
OR
- 2. Intentional Primary Containment venting/purging per EOPs or SAPs due to accident conditions.
6.Primary OR Containment None None None None 3. UNISOL.ABLE primary system leakage that None Isolation Failure results in EITHER of the following:
- a. Maximum safe general area temperature> 135°F.
OR
- b. Maximum safe area radiation level
> 8 R/hr.
- 1. ANY Condition in the opinion of the 2. ANY Condition In the opinion of the 1. ANY Condition In the opinion of the 2. ANY Condition In the opinion of the 1. ANY Condition In the opinion of the 2. ANY Condition in the opinion of the Emergency Director that indicates Emergency Director that indicates Emergency Director that indicates Loss of Emergency Director that indicates Potential Emergency Director that indicates Loss of Emergency Director that indicates Potential
- 7. Emergency Loss of the Fuel Clad Barrier. Potential Loss of the Fuel Clad Barrier. the RCS Barrier. Loss ofthe RCS Barrier. the Containment Barrier. Loss of the Containment Barrier.
Director Judgment Modes: 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4 - Refueling D-Defueled December 201 B HOT MATRIX NMP2-3 HOT MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT System Malfunction MG1 [Im MS1 MA1 [Im MU1 Prolonged loss of all offsite and all onsite AC power to Loss of all offsite and onsite AC power to emergency buses Loss of all but one AC power source to emergency Loss of all offsite AC power capability to emergency buses emergency buses. for 15 minutes or longer. buses for 15 minutes or longer. for 15 minutes or longer. Emergency Action Level (EAU: Emergency Action Level (EAL}: Emergency Action Level (EAL}: Emergency Action Level (EAL}: Note: The Emergency Director should declare the event Note: The Emergency Director should declare the event Note: The Emergency Director should declare the event Note: The Emergency Director should declare the event promptly upon determining that the applicable time has promptly upon determining that the applicable time promptly upon dete~mining that the applicable time promptly upon determining that the applicable time 0 I
- a. 1 been exceeded, or will likely be exceeded.
Loss of ALL offsite and onsite AC power to 4.16 kV Emergency Buses. has been exceeded, or will likely be exceeded. ,
- 1. Loss of ALL offsite and onsite AC Power to 4.16 kV has been exceeded, or will likely be exceeded.
- 1. AC power capability to 4.16 kV Emergency Buses has been exceeded, or will likely be exceeded.
Loss of ALL offsite AC power capability to 4.16 kV ...<C 0 2. AND EITHER of the following: Emergency Buses. AND reduced to only one of the following power sources for?. 15 minutes: Emergency Buses for::. 15 minutes:
- T-101 N UI 2. Failure to restore power to at least one 4.16 kV UI a. Restoration of at least one 4.16 kV Emergency Bus
- T-101 N 0 in < 4 hours is not likely. Emergency Bus from the time of loss of both offsite and
- T-101 S
...I
- T-101 S onsite AC power in< 15 minutes.
OR
- b. RPV water level cannot be restored and
- DG-102 Emergency Diesel Generator maintained> -109 inches.
- DG-103 Emergency Diesel Generator AND
- 2. ANY additional single power source failure will result in a loss of all AC power to SAFETY SYSTEMS.
MG2 [Im MS2 Loss of all AC and Vital DC power sources for 15 minutes or Loss of all Vital DC power for 15 minutes or longer. longer. Emergency Action Level (EAL}: Emergency Action Level (EAL}: Note: The Emergency Director should declare the event Note: The Emergency Director should declare the event promptly upon determining that the applicable time has promptly upon determining that the applicable time I a. 0 1. been exceeded, or will likely be exceeded. Loss of ALL offsite and onsite AC power to 4.16 kV has been exceeded, or will likely be exceeded. Voltage is< 106 VDC on 125 voe Battery Boards 11 and 12 for::_ 15 minutes. C 0 Emergency Buses. AND ll! 2. Voltage is < 106 VDC on 125 voe 0 Battery Boards 11 and 12 . ...I AND
- 3. ALL AC and Vital DC power sources have been lost for::. 15 minutes.
Modes. 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4-Refueling D-Defueled December 2018 HOT MATRIX NMP2-4 HOT MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT System Malfunction MS3 ill MA3 ill MU3 Inability to shutdown the reactor causing a challenge to RPV Automalic or manual scram fails to shutdown !he Automatic or manual scram fails to shutdown the reactor. Water Level or RCS heat removal. reactor, and subsequent manual actions taken at the Emergency Action Level (EALI: Reactor Control Console are not successful in shutting down !he reactor. Note: A manual aclion is any operator action, or set of Emergency Action Level (EAL): actions, which causes the control rods to be rapidly Emergency Action Level (EAL):
- 1. Automalic scram did not shutdown the reactor as inserted into the core, and does not include manually indicated by ReactorPower> 6%. Note: A manual action is any operator action, or set of driving in control rods or implementalion of boron actions, which causes the control rods to be rapidly injeclion strategies.
AND inserted into the core, and does not include manually
- 1. a. Automalic scram did not shutdown the reactor
- 2. ALL manual / ARI actions to shutdown the reactor have driving in control rods or implementation of boron as indicated by ReactorPower > 6%.
been unsuccessful as indicated by Reaclor Power> 6%. injection strategies. AND AND 1. Automatic or manual scram did not shutdown the reactor as indicated by Reactor Power> 6%. b. Subsequent manual / ARI aclion taken at the
- 3. EITHER of the following conditions exist: Reactor Control Console is successful in AND shutting down !he reactor as indicated by
- RPV water level cannot be restored and maintained
> -109 inches. - - - 2. Manual / ARI actions taken at the Reactor Control Reactor Power.::; 6%.
Console are not successful in shutting down !he reactor OR OR as indicated by Reactor Power> 6%. 2. a. Manual scram did not shutdown the reactor as
- Heat Capacity Temperature Limit (N1-EOP-4 Figure M) indicated by Reactor Power> 6%.
exceeded. AND
- b. EITHER of the following:
- 1. Subsequent manual I ARI action taken at !he Reactor Control Console is successful in shutting down the reactor as indicated by Reactor Power .::; 6%.
OR
- 2. Subsequent automatic scram / ARI is successful in shutting down !he reactor as indicated by Reactor Power!, 6%.
MA4 I!]~ MU4 . Ill C 0 Table M1 Control Room Parameters Table M2 Significant Transients UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress. UNPLANNED loss of Control Room indications for 15 minutes or longer. I'll u
. Emergency Action Level (EAL): Emergency Action Level (EAL):
=ti
-=E 0
.. Reactor Power RPV Water Level RPV Pressure Turbine runback > 25% thermal reactor power Electrical Load rejeclion > 35% full electrical load Note: The Emergency Director should declare the event promptly upon determining !hat the applicable lime has been exceeded, or will likely be exceeded.
Note: The Emergency Director should declare !he event promptly upon determining !hat the applicable lime has been exceeded, or will likely be exceeded.
- Reactor scram 0
n:: e.. . Primary Containment Pressure
- ADS or Core Spray actuation 1. UNPLANNED event results in !he inability to monitor UNPLANNED event results in the inability to monitor
. Torus Water Level ANY Table M1 parameter from within the Control Room ANY Table M1 parameter from within the Control Room for
- . 15 minutes .
0 C 0
. Torus Water Temperature
- Thermal power oscillalions > 10% for:::. 15 minutes.
AND
- 2. ANY Table M2 transient in progress.
Modes. 1 - Power Operation 2 - Ho! Shutdown 3 - Cold Shutdown 4-Refuehng D-Defueled December 2018 HOT MATRIX NMP2-5 HOT MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT System Malfunction MAS l!ll~ Hazardous event affecting a SAFETY SYSTEM required for the current operating mode. EmergencJ! Action Level (EAL): Note:
. This EAL is only applicable to SAFETY SYSTEMs
. having two (2) or more trains.
If the affected SAFETY SYSTEM train was already inoperable before the hazardous event occurred,
. then this emergency classification is not warranted.
If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not E GI UI
. warranted.
If a hazardous event occurs and it is determined that the conditions of MA5 are not met then assess en the event via HU3, HU4, or HUS. ~ 1. a. The occurrence of ANY of the following hazardous J!! nl events: en . Cl C u
.. Seismic event (earthquake)
Internal or external flooding event ! .. High winds or tornado strike FIRE "C nl 1,1
. EXPLOSION other events with similar hazard characteristics as determined by the Shift
- c Manager AND
- b. Event damage has caused indications of degraded performance to one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.
AND C. EITHER of the following:
. Event damage has caused indications of degraded performance to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.
. OR Event damage has resulted in VISIBLE DAMAGE to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.
Modes: 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4-Refuehng D- Defueled December 2018 HOT MATRIX NMP2-6 HOT MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT System Malfunction MUS ITirn RCS leakage for 15 minutes or longer. Emergencll Action Level (EAL}: Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded. .:a:: I'll
- 1. RCS unidentified or pressure boundary leakage in the CII
...I Drywell > 10 gpm for::, 15 minutes . U) u a: OR
- 2. RCS identified leakage in the Drywell > 25 gpm for::, 15 minutes.
OR
- 3. Leakage from the RCS to a location outside the Primary Containment> 25 gpm for::, 15 minutes.
Table M3 Communication Caoabilities MU7 ITirn Loss of all onsite or offsite communication capabilities. System Onsite Offsite NRC Gaitronics X Emergencll Action Level (EAL}: Hand Held Portable 1. Loss of all Table M3 onsite communication Radio (Station Radio) X capabilities affecting the ability to perform routine (II operations. C PBX (Conventional 0 Telechone lines) X X X OR I'll 2. Loss of all Table M3 offsite communication u Control Room installed capabilities affecting the ability to perform offsite 'i: satellite phone (non X X
- s cortablel notifications.
E OR E ENS X X 0 3. Loss of all Table M3 NRG communication u capabilities affecting the ability to perform NRG RECS X notifications. Modes: 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4-Refuehng D- Defueled December 201 B HOT MATRIX NMP 2-7 HOT MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Plant Safety HS1 ffl~@l@l[Q] HA1 ffl~@l@l[Q] HU1 ffl~@l@l[Q] HOSTILE ACTION within lhe PROTECTED AREA. HOSTILE ACTION within the OWNER CONTROLLED Confirmed SECURITY CONDITION or threat. AREA or airborne attack threat within 30 minutes. C 0 Ememencl£ Action Level (EAL): Emergencl£ Action Level (EALJ: Emergencl£ Action Level (EALJ: t; A notification from the Security Supervisor that a HOSTILE 1. A validated notification from NRG of an aircraft 1. Notification of a credible security threat directed at c( ,S! UI 0
- r:
ACTION is occurring or has occurred within the PROTECTED AREA. attack threat< 30 minutes from the site. OR
- 2. Notification by the Security Supervisor that a the site as determined per SY-AA-101-132, Security Assessment and Response to Unusual Activities.
OR HOSTILE ACTION is occurring or has occurred 2. A validated notification from the NRG providing within the OWNER CONTROLLED AREA. information of an aircraft threat. OR
- 3. Notification by the Security Supervisor of a SECURITY CONDITION that does not involve a HOSTILE ACTION ..
HS2 ffl~@l@l[Q] HA2 ffl~@l@l[Q] Inability to control a key safely function from outside !he Control Room evacuation resulting in transfer of plant Table H1 Safety Functions Control Room. control to alternate locations.
. Reactivity Control (ability to shutdown the reactor and keep it shutdown)
Emergencll Action Level (EAL): Note: The Emergency Director should declare the event Ememencll Action Level (EALJ: A Control Room evacuation has resulted in plant control
. RPV Water Level (ability to cool the core) promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
being transferred from the Control Room to alternate locations per N1-SOP-21.2, Control Room Evacuation. 0... . RCS Heat Removal (ability to maintain a heat sink)
- 1. A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per N1-SOP-21.2, Control Room Evacuation.
c0 0 C I'll 2. AND Control of ANY Table H1 key safely function is.!!!!! reestablished in < 15 minutes. ...ii:
...0 UI C
I! I-Modes. 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4-Refuehng D-Defueled December 2018 HOT MATRIX NMP2-8 HOT MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other conditions Affecting Plant Safety HU3 FIRE potentially degrading the level of safety of the plant. Emergency AcHon Level (EAL): Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- Escalation of the emergency classification level would be via IC CA2 or MA5.
- 1. A FIRE in ANY Table H2 area is not extinguished in
< 15 minutes of ANY of the following FIRE detection indications:
- Report from the field (i.e., visual observation)
- Receipt of multiple (more than 1) fire alarms or indications Table H2 Areas
- Field verification of a single fire alarm
- Reactor Building (when inerted the Drywall is OR exempt) 2. a. Receipt of a single fire alarm in ANY Table H2 area
- Control Room (i.e., no other indications of a FIRE).
- Screenhouse AND
- Turbine Building
- 11 and 12 Battery Rooms b. The existence of a FIRE is not verified in
- 11 and 12 Battery Board Rooms < 30 minutes of alarm receipt.
- Cable Spreading Room OR
- 291' North
- Diesel Generator Engine and Board 3. A FIRE within the plant PROTECTED AREA.!!.!!!
Rooms extinguished in < 60 minutes of the initial report, alarm or indication .
. OR
- 4. A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.
Modes: 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4- Refueling D-Defueled December 2018 HOT MATRIX NMP2-9 HOT MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other conditions Affecting Plant Safety HU4 ij]~@IHl@I
. Seismic event greater than OBE levels Emergencl£ Action Level (EAL):
Note: For emergency classification if EAL #2 is not able to be confirmed, then the occurrence of a seismic event is confirmed in a manner deemed appropriate by the Shift Manager or Emergency Director in~ 15 minutes Cl)
. of the event.
Escalation of the emergency classification level would be via IC CA2 or MAS. I'll \
- i Seismic event as indicated by:
C" .c 1. Control Room personnel feel an actual or potential seismic t:: I'll event. w AND
- 2. ANY one of the following confirmed in ~ 15 minutes of the event:
. The earthquake resulted in Modified Mercalli Intensity
.. (MMI)::. VI and occurred~ 3.5 miles of the plant.
The earthquake was magnitude::. 6.0 The earthquake was magnitude::. 5.0 and occurred
.. ~ 125 miles from the plant.
NMP-2 seismic instrumentation indicates > 0.075g If the above bullets are not able to be confirmed, then the occurrence of a seismic event is confinned in a manner deemed appropriate by the Shift Manager or Emergency Director. HAS lfil@:111 Table H3 Gaseous release impeding access to.equipment
\ Areas with Entry Related Mode Applicability necessary for normal plant operations, cooldown or shutdown.
Entry Related Area Emergencl£ Action Level (EAU: Ill Mode Applicability I'll Note: If the equipment in the listed room or area was t!) Reactor Building u already inoperable, or not available, before the "ic 198' Northeast comer event occurred, then no emergency classification 0 261' North and Shutdown is warranted. I-Cooling Room
- 1. Release of a toxic, corrosive, asphyxiant or 281' North Modes 2, 3, and 4 flammable gas in ANY Table H3 area.
Turbine Building AND
- 2. Entry into the room or area is prohibited or 291' North impeded.
Modes: 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4- Refuehng D-Defueled December 2018 HOT MATRIX NMP2-10 HOT MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other conditions Affecting Plant Safety HU6 Hazardous Event Emergency Action Level !EAL): Note:
- EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.
- Escalation of the emergency classification level would be via IC CA2 or MA5.
C lUI
- 1. Tornado strike within the PROTECTED AREA.
OR 0 2. Internal room or area flooding of a magnitude sufficient to 'E require manual or automatic electrical isolation of a
~
SAFETY SYSTEM component required by Technical Specifications for the current operating mode.
- c OR
- 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).
OR
- 4. A hazardous event that results in onsite conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.
OR
- 5. Intake water level< 238.8 feet.
-C GI E HG7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a GENERAL HS7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a SITE AREA HA7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT. HU7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of an UNUSUAL ,g' EMERGENCY. EMERGENCY. EVENT. ~ Emergency Action Level !EAL): Emergency Action Level !EAL): Emergency Action Level !EAL): Emergency Action Level !EAL): Other conditions exist which in the judgment of the Other conditions exist which in the judgment of the Other conditions exist which, in the judgment of the Other conditions exist which in the judgment of the Emergency I!! Emergency Director indicate that events are in progress or Emergency Director indicate that events are in progress or Emergency Director, indicate that events are in progress or Director indicate that events are in progress or.have occurred i5 have occurred which involve actual or IMMINENT substantial have occurred which involve actual or likely major failures of have occurred which involve an actual or potential 'which indicate a potential degradation of the level of safety of (i' core degradation or melting with potential for loss of plant functions needed for protection of the public or HOSTILE substantial degradation of the level of safety of the plant or a the plant or indicate a security threat to facility protection has c containment integrity or HOSTILE ACTION that results in an ACTION that results in intentional damage or malicious acts, security event that involves probable life threatening risk to been initiated. No releases of radioactive material requiring E1 actual loss of physical control of the facility. Releases can be (1) toward site personnel or equipment that could lead to the site personnel or damage to site equipment because of offsite response or monitoring are expected unless further GI reasonably expected to exceed EPA Protective Action likely failure of or, (2) that prevent effective access to HOSTILE ACTION. Any releases are expected to be limited degradation of safety systems occurs. E Guideline exposure levels offsite for more than the immediate equipment needed for the protection of the public. Any to small fractions of the EPA Protective Action Guideline W sitearea. releases are not expected to result in exposure levels which exposure levels. exceed EPA Protective Action Guideline exposure levels beyond the site boundary. Modes: 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4-Refuelmg D-Defueled December 2018 HOT MATRIX NMP 2,11 HOT MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT ISFSI Malfunction E-HU1 ITI~@l@l@J Damage to a loaded cask CONFINEMENT BOUNDARY. Emergencl! Action Level (EALl: Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading: For 61 BT DSC:
> 800 mrem/hr 3 feet from the HSM surface
. OR
> 200 mrem/hr outside the HSM door on centerline of DSC
. OR
> 40 mrem/hr end of shield wall exterior For 61 BTH DSC:
> 1400 mrem/hr on the HSM or HSM-H front surface
. OR
> 200 mrem/hr on the HSM or HSM-H door centertine
. OR
> 40 mrem/hr on the end shield wall exterior in u.
~
Modes: 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4-Refuehng D - Defueled December 201 B HOT MATRIX NMP 2-12 HOT MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex COLDSHUTD LI COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear ALERT Abnormal Rad Levels / Radiological Effluents RG1 mmOO@l@l RS1 ff@@l@l(Q] RA1 IJ:@00@1@1 RU1 mmOO@l@l Release of gaseous radioactivity resulting in offsite dose greater Release of gaseous radioactivity resulting in offsite dose greater Release of gaseous or liquid radioactivity resulting in offsite Release of gaseous or liquid radioactivity greater than 2 times than 1,000 mRem TEDE or 5,000 mRem CDE Thyroid. than 100 mRem TEDE or 500 mRem CDE Thyroid. dose greater than 1o mrem TEDE or 50 mrem COE Thyroid. the ODCM limits for 60 minutes or longer. Emergency Action Level (EAL): Emergency Action Level fEAL): Emergency Action Level (EAL): Emergency Action Level fEALl: Notes: Notes: Notes: Notes:
. The Emergency Director should declare the event promptly upon determining that the applicable time has been
. The Emergency Director should declare the event promptly upon determining that the applicable time has been The Emergency Director should declare the event promptly upon determining that the applicable time has The Emergency Director should declare the event promptly upon determining that the applicable time has exceeded, or will likely be exceeded. exceeded, or will likely be exceeded.
been exceeded, or will likely be exceeded. If an ongoing release is detected and the release start time is unknown, assume that the release duration has
. been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes. exceeded 60 minutes.
- 1. Dose assessment Using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- 1. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: Classification based on effluent monitor readings assumes that a release path to the environment is established. If
. Classification based on effluent monitor readings assumes that a release path to the environment is established. If
- a. > 1000 mRem TEDE a. > 100 mRem TEDE the effluent flow past an effluent monitor is known to have the effluent flow past an effluent monitor is known to have OR OR stopped due to actions to isolate the release path, then stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for the effluent monitor reading is no longer valid for
- b. > 5000 mRem CDE Thyroid b. > 500 mRem CDE Thyroid classification purposes. classification purposes.
OR OR The pre-calculated effluent monitor values presented in
- 2. Field survey results at or beyond the site boundary indicate 2. Field survey results at or beyond the site boundary indicate EAL #1 should be used for emergency classification
- 1. Reading on the Rad Waste Discharge effluent monitor J!l C
EITHER: EITHER: assessments until the results from a dose assessment
> 2x alarm setpoint established by a current radioactive using actual meteorology are available.
GI a. Gamma (closed window) dose rates a. Gamma (closed window) dose rates release discharge permit for~ 60 minutes.
=
- I
> 1000 mR/hr are expected to continue > 100 mR/hr are expected to continue OR w for?. 60 minutes. for::, 60 minutes. 1. Reading on Stack (RN 1 O A/8) Effluent Monitor
> 1.5 E+05 cps for?_ 15 minutes. 2. Reading on Stack (RN 1O A/8) Effluent Monitor iii OR OR > 2.85 E+02 cps (285 cps) for?. 60 minutes.
u OR
'ii, b. Analyses of field survey samples indicate b. Analyses offield survey samples indicate OR 0 > 5000 mRem COE Thyroid for 60 minutes > 500 mRem CDE Thyroid for 60 minutes 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
i5 of inhalation. of inhalation. 3. Confirmed sample analyses for gaseous or liquid releases
- aIll a. > 10 mRem TEDE indicate concentrations or release rates> 2x ODCM Limit with OR a release duration of?. 60 minutes.
0:::
- b. > 50 mRem CDE Thyroid OR
- 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary:
- a. 10 mRem TEDE for 60 minutes of exposure.
OR
- b. 50 mRem CDE Thyroid for 60 minutes of exposure.
OR
- 4. Field survey results at or beyond the site boundary indicate EITHER:
- a. Gamma (closed window) dose rates
> 10 mR/hr are expected to continue for?. 60 minutes.
OR
- b. Analyses of field survey samples indicate
> 50 mRem CDE Thyroid for 60 minutes of inhalation.
Modes. 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4 - Refueling D-Defueled December 201 B COLD SHUTDOWN/REFUELING MATRIX NMP 2-13 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Abnormal Rad Levels/ Radiological Effluents RG2 ITI~§@I[Q] RS2 RA2 RUZ Spent fuel pool level cannot be restored to at least 316 feet Spent fuel pool level at 316 feet. Significant lowering of water level above, or damage to, Unplanned loss of water level above irradiated fuel. for 60 minutes or longer. irradiated fuel. Emergency Action Levels !EAU: Emergency Action Level (EAL): Emergency Action Level !EAL): Emergency Action Level IEALl: Note: The Emergency Director should declare the event Lowering of spent fuel pool level to 316 feet as indicated on promptly upon determining that the applicable time 1. a. UNPLANNED water level drop in the REFUELING Ll-54-65A or Ll-54-65B on SFP monitoring panel 1. Uncovery of irradiated fuel in the REFUELING has been exceeded, or will likely be exceeded. PATHWAY as indicated by; (PNL-54-65H). PATHWAY. Spent fuel pool level cannot be restored to at least 316 feet
- SFP water level < low water level alarm.
OR as indicated on Ll-54-65A or Ll-54-65B on SFP monitoring OR panel (PNL-54-65H) for:::_ 60 minutes. 2. Damage to irradiated fuel resulfing in a release of radioactivity from the fuel as indicated by ANY
- Indication or report of a drop in water level in Table R1 Radiation Monitor Alarm. the REFUELING PATHWAY.
OR AND
- 3. Lowering of spent fuel pool level to 326 feet as b. UNPLANNED Area Radiation Monitor reading indicated on Ll-54-65A or Ll-54-65B on SFP rise on ANY radiation monitor in Table R1.
monitoring panel (PNL-54-65H). RA3
.l!!
C Radiation levels that impede access to. equipment CII
- I Table R2 necessary for normal plant operations, cooldown or ffi Areas Requiring Continuous Occupancy shutdown.
Emergency Action Level IEALl: iii
*s,
- Main Control Room Note: If the equipment in the room or area listed in Table 0 R3 was already inoperable, or not available, before
- Central Alarm Station - (by survey) c the event occurred, then no emergency classification
't'i is warranted. ~
Table R3 1. Dose rate > 15 mR/hr in ANY of the areas Areas with Entry Related Mode Applicability in Table R2. Entry Related OR Table R1 Refuel Floor ARM's Area Mode Applicability
- 2. UNPLANNED event results in radiation levels that Reactor Building prohibit or significantly impede access to ANY of the
- ARM 18 (West end of shield wall) areas in Table R3.
198' Northeast comer
- ARM 25 (Reactor Building - east wall) 261' North and Shutdown
- ARM 29 Refuel Bridge (Low Range) Cooling Room
- Refuel Bridge (High Range) Modes 2, 3 and 4 281' North
- Reactor Building Vent Radiation Monitor Turbine Building 291' North Modes. 1 - Power OperaUon 2 - Hot Shutdown 3 - Cold Shutdown 4-Refuelmg D-Defueled December 2018 COLD SHUTDOWN/REFUELING MATRIX NMP2-14 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex COLD SHUTDOWN/REFUELING MATRIX ==================C=O=L=D==SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY ALERT UNUSUAL EVENT Cold Shutdown/ Refueling System Malfunctions CA1 lfil@l[QJ CU1 lfil@l[QJ Loss of all offsite and onsite AC power to emergency buses Loss of all but one AC power source to emergency buses for 15 minutes or longer. for 15 minutes or longer. Emergencl£ Action Level (EAL}: Emergencl£ Action Level (EAL): Note: The Emergency Director should declare the event Note: The Emergency Director should declare the promptly upon detennining that the applicable time event promptly upon detennining that the has been exceeded, or will likely be exceeded. applicable time has been exceeded, or will likely be exceeded.
- 1. Loss of all offsite and onsite AC power to 4.16 kV Emergency Buses. 1. AC power capability to 4.16 kV Emergency Buses reduced to only one of the following power sources AND for.?. 15 minutes:
- 2. Failure to restore power to at least one 4.16 kV T-101 N Emergency Bus from the time of loss of both offsite T-101 S and onsite AC power in < 15 minutes.
AND
. DG-102 Emergency Diesel Generator DG-103 Emergency Diesel Generator
- 2. ANY additional single power source failure will result GI 3::
in a loss of all AC power to SAFETY SYSTEMS . 0 II. (.J <( 0
,n ,n 0
.J Modes: 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4 - Refueling D-Defueled December 2018 COLD SHUTDOWN/REFUELING MATRIX NMP2-15 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY Cold Shutdown / Refueling System Malfunctions CA2 Hazardous event affecting SAFETY SYSTEM required for the current operating mode. Emergency Action Level (EAL): Note:
. This EAL is only applicable to SAFETY SYSTEMs
. having two (2) or more trains.
If the affected SAFETY SYSTEM train was already inoperable before the hazardous event occurred, then
. this emergency classification is not warranted.
If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not E GI (II
. warranted.
If a hazardous event occurs and it is determined that the conditions of CA2 are not met then assess the U) event via HU3, HU4, or HUS.
~
J!! 1. a. The occurrence of ANY of the following hazardous Ill events: U) CD
- Seismic event (earthquake)
C
~
- Internal or external flooding event
!c(
- High winds or tornado strike
- FIRE "Cl Ill
- EXPLOSION N
- Other events with similar hazard characteristics Ill
- c as determined by the Shift Manager AND
- b. Event damage has caused indications of degraded performance to one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.
AND
- c. EITHER of the following:
- Event damage has caused indications of degraded performance to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.
OR
- Event damage has resulted in VISIBLE DAMAGE to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.
Modes. 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4 - Refueling D-Defueled December 201 B COLD SHUTDOWN/REFUELING MATRIX NMP 2-16 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex COLD SHUTDOWN/REFUELING MATRIX =========~---=====....:C;.,O;.,Le;D SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY ' UNUSUAL EVENT SITE AREA EMERGENCY ALERT Cold Shutdown / Refueling System Malfunctions CU3 lfilBI
...<II Loss of Vital DC power for 15 minutes or longer.
3: Emergency Action Level (EAL): 0 D. 0 Note: The Emergency Director should declare the event C promptly upon determining that the applicable time has been exceeded, or will likely be exceeded. Voltage is< 106 VDC on required 125 VDC Battery Boards 11 and 12 for~ 15 minutes. CU4 ~H][Q] Table C1 Communication Capabilities Loss of all onsite or offsite communication capabilities. Svstem Onsite Offsite NRC Emergency Action Level (EAL): Ill Gaitronics C X 1. Loss of all Table C1 onsite communication 0 capabilities affecting the ability to perform routine
~ Hand Held Portable operations.
(.I X
*c:s Radio /Station Radial OR PBX (Conventional E Telenhnne linesl X X X 2. Loss of all Table C1 offsite communication E capabilities affecting the ability to perform offsite 0 Control Room installed 0 notifications.
satellite phone (non X X nortablei OR ENS 3. Loss of all Table C1 NRG communication capabilities X X affecting the ability to perform NRG notifications. RECS X TableC2 RCS Heat-uo Duration Thresholds CAS ~Bl cus ~Bl Inability to maintain plant in cold shutdown. UNPLANNED rise in RCS temperature. RCS Containment Closure _Heat-up Status Status "Duration Emergency Action Level (EAL): Emergency Action Level (EAL): Intact Not Annlicable 60 minutes* Not Intact Established 20 minutes* Note:
. The Emergency Director should declare the event promptly upon determining that the applicable time Note:
The Emergency Director should declare the event promptly upon determining that the applicable time
.Iii: has been exceeded, or will likely be exceeded.
C iii I'll Not Established 0 minutes has been exceeded, or will. likely be exceeded. A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature
. A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature <II limit when heat removal function is available does not limit when heat removal function is available does not
- i:::
warrant classification. warrant classification.
- If an RCS heat removal system is in operation within this time frame and RCS temperature is being 1. UNPLANNED rise in RCS temperature to> 212'F.
reduced, then EAL #1 is not applicable.
- 1. UNPLANNED rise in RCS temperature to> 212'F for OR
> Table C2 duration. 2. Loss of the following for~ 15 minutes:
2. OR UNPLANNED RPV pressure rise> 10 psig as a
. ALL RCS temperature indications AND result of temperature rise.
. ALL RPV level indications Modes. 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4-Refuehng D- Defueled December 201 B COLD SHUTDOWN/REFUELING MATRIX NMP2-17 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Cold Shutdown / Refueling System Malfunctions CG& ~BJ CS& ~~ CA& ~~ CU& ~~ Loss of RPV inventory affecting fuel clad integrity with Loss of RPV inventory affecting core decay heat removal Loss of RPV inventory UNPLANNED loss of RPV inventory for 15 minutes or containment challenged. capabilities. longer. Emergency Action Level (EAU: Emergency Action Level (EAL): Emergency Action Level !EAU: Emergency Action Level !EAL): Note: The Emergency Director should declare the event Note: The Emergency Director should declare the event Note: The Emergency Director should declare the event Note: The Emergency Director should declare the event promptly upon determining that the applicable time promptly upon detenmining that the applicable time promptly upon determining that the applicable time promptly upon determining that the applicable time has has been exceeded, or will likely be exceeded. has been exceeded, or will likely be exceeded. has been exceeded, or will likely be exceeded. been exceeded, or will likely be exceeded.
- 1. a. RPV water level < - 84 inches for::, 30 minutes. 1. With CONTAINMENT CLOSURE!!!!! established, RPV 1. Loss .of RPV inventory as indicated by 1. UNPLANNED loss of reactor coolant results in the inability water level < - 10 inches. level < + 5 inches. to restore and maintain RPV level to above the AND OR procedurally established lower limit for?. 15 minutes.
- b. ANY Table C4 Containment Challenge Indication. OR
- 2. With CONTAINMENT CLOSURE established, RPV water OR OR 2. a. RPV water level £!!!!!l2! be monitored level < - 84 inches. for::, 15 minutes. 2. a. RPV level £!!!!!!2! be monitored.
- 2. a. RPV water level cannot be monitored OR AND AND for::, 30 minutes-.- -
- 3. a. RPV water level cannot be monitored for?. 30 minutes. b. Loss of RPV inventory per Table*C3 indication. b. Loss of RPVinventory per Table C3 indication.
AND AND
- b. Core uncovery is indicated by ANY of the following:
~ b. Core uncovery is indicated by ANY of the following:
- Table C3 indication of a sufficient magnitude to
.s C
indicate core uncovery.
- Table C3 indication of a sufficient magnitude to GI indicate core uncovery.
> OR GI CD ca .:,: AND
- Refuel Bridge High Range Radiation Monitor reading ::, 3 R/hr.
- OR Refuel Bridge High Range Radiation Monitor reading ::, 3 R/hr.
ca j c. ANY Table C4 Containment Challenge Indication. en
~
Table C3 Indications of RCS Leakage
- UNPLANNED Drywell equipment drain tank level rise* Table C4 Containment Challenge Indications
- UNPLANNED Drywell floor drain tank level rise*
- UNPLANNED Reactor Building equipment sump
- Primary Containment Hydrogen Concentration level rise* ?. 6% and Oxygen Concentration ::, 5%
- UNPLANNED Reactor Building floor drain sump
- UNPLANNED rise in containment pressure level rise*
- UNPLANNED Torus water level rise*
- CONTAINMENT CLOSURE!!!!! established*
- UNPLANNED RPV make up rate rise*
- Reactor Building area radiation > 8 R/hr.
- Observation of leakage or inventory loss
- If CONTAINMENT CLOSURE is re-established
*Rise in level is attributed to a loss of RPV inventory prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.
Modes: . 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4-Refuelmg D-Defueled December 201 B COLD SHUTDOWN/REFUELING MATRIX NMP2-18 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other conditions Affecting Plant Safety HS1 HA1 HU1 HOSTILE ACTION within the PROTECTED AREA. HOSTILE ACTION within the OWNER CONTROLLED Confirmed SECURITY CONDITION or threat. AREA or airborne attack threat within 30 minutes. C 0 Emergency Action Level (EAL): Emergency Action Level (EAL): Emergency Action Level (EAL): ~ A notification from the Security Supervisor that a HOSTILE ACTION is occurring or has occurred within the
- 1. A validated notification from NRG of an aircraft attack threat< 30 minutes from the site.
- 1. Notification of a credible security threat directed at the site as determined per SY-AA-101-132, Security
- E Ill PROTECTED AREA.
OR Assessment and Response to Unusual Activities. 0 OR
- c 2. Notification by the Security Supervisor that a HOSTILE ACTION is occurring or has occurred 2. A validated notification from the NRG providing within the OWNER CONTROLLED AREA. information of an aircraft threat.
OR
- 3. Notification by the Security Supervisor of a SECURITY CONDITION that does not involve a HOSTILE ACTION.
HS2 HA2 Inability to control a key safety function from outside the Control Room evacuation resulting in transfer of plant Table H1 Safety Functions Control Room. control to alternate locations.
- Reactivity Control Emergency Action Level (EAL): Emergency Action Level (EAL):
(ability to shutdown the reactor and keep it shutdown) Note: The Emergency Director should declare the event A Control Room evacuation has resulted in plant control promptly upon determining that the applicable time has being transferred from the Control Room to alternate
- RPV Water Level (ability to cool the core) been exceeded, or will likely be exceeded. locations per N1-SOP-21.2, Control Room Evacuation.
- RCS Heat Removal (ability to maintain a heat sink)
~C 1. A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate 0 locations per N1-SOP-21.2, Control Room Evacuation. 0 C I'll ii: 2. AND Control of ANY Table H1 key safety function is !!2! 0 J!! reestablished in < 15 minutes. Ill C I! I-Modes: 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4-Refuehng D- Defueled December 201 B COLD SHUTDOWN/REFUELING MATRIX NMP2-19 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
_N_in_e_M_ile_P_o_in_t_N_u_c_le_a_r_S_t_at_io_n_U_n_it_1_A_n_n_e_x_ _ _ _ _C_O_L_D_SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other conditions Affecting Plant Safety HU3 FIRE potentially degrading the level of safety of the plant. Emergency Action Level (EAL): Note:
- The Emergency Director should declare the event prompUy upon determining that the applicable time has been exceeded, or will likely be exceeded.
- Escalation of the emergency classification level would be via IC CA2 or MA5.
- 1. A FIRE in ANY Table H2 area is fill! extinguished in
< 15 minutes of ANY of the following FIRE detection indications:
- Report from the field (i.e., visual observation)
- Receipt of multiple (more than 1) fire alarms or indications
- Field verification of a single fire alarm Table H2 Areas OR
- Reactor Building (when inerted the Drywell is
- 2. a. Receipt of a single fire alarm in ANY Table H2 area exempt)
(i.e., no other indications of a FIRE).
- Control Room
- Screenhouse AND
- Turbine Building b. The existence of a FIRE is not verified
- 11 and 12 Battery Rooms in < 30 minutes of alarm receipt.
- 11 and 12 Battery Board Rooms
- Cable Spreading Room OR
- 291' North 3. A FIRE within the plant PROTECTED AREA fill!
- Diesel Generator Engine and Board extinguished in < 60 minutes of the initial report, alarm or Rooms indication.
OR
- 4. A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.
Modes. 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4-Refuehng D-Defueled December 201 B COLD SHUTDOWN/REFUELING MATRIX NMP2-20 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 3"(Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other conditions Affecting Plant Safety HU4 II]~@l@l@l Seismic event greater than OBE levels. Emergencll Action Level (EAL): Note: For emergency classification if EAL #2 is not able to be confirmed, then the occurrence of a seismic event is confirmed in a manner deemed appropriate by the Shift Manager or Emergency Director in S 15 minutes G)
. of the event.
Escalation of the emergency classification level would be via IC CA2 or MA5. I'll
- i Seismic event as indicated by:
er
.c 1. Control Room personnel feel an actual or potential seismic t::
I'll event. w AND
- 2. ANY one of the following confirmed in S 15 minutes of the event:
. The earthquake resulted in Modified Mercalli Intensity
.. (MMI) :! VI and occurred S 3.5 miles of the plant.
The earthquake was magnitude :! 6.0 The earthquake was magnitude :! 5.0 and occurred
.. S 125 miles from the plant.
NMP-2 seismic instrumentation indicates > 0.075g If the above bullets are not able to be confirmed. then the occurrence of a seismic event is confirmed in a manner deemed appropriate by the Shift Manager or Emergency Director. HAS lfil@l~ Gaseous release impeding access to equipment J necessary for normal plant operations, cooldown or shutdown. Table H3 Areas with Entry Related Mode Applicability Entry Related EmergencJl Action Level (EAL): Ill Area I'll Mode Applicability (!) Note: If the equipment in the listed room or area was u Reactor Building already inoperable. or not available, before the "i< event occurred, then no emergency classification 0 198' Northeast comer is warranted. I-261' North and Shutdown
- 1. Release of a toxic, corrosive, asphyxiant or Cooling Room flammable gas in ANY Table H3 area.
281' North Modes 2, 3, and 4 AND Turbine Building
- 2. Entry into the room or area is prohibited or impeded.
291' North Modes: 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4-Refuehng D-Defueled December 2018 COLD SHUTDOWN/REFUELING MATRIX NMP2-21 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex COLD S_H_U_T_DOW __N_/R__EF __U_E__ LING MATRIX ===================C==OLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other conditions Affecting Plant Safety HUS Hazardous Event Emergency Action Level (EAL): Note:
- EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.
- Escalation of the emergency classification level would be via IC CA2 or MA5.
- 1. Tornado strike within the PROTECTED AREA.
OR
- 2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrtcal isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating mode. '
OR
- 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).
OR
- 4. A hazardous event that results in onsite conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.
OR
- 5. Intake water level < 238.8 feet.
..5; HG7 Other conditions exist which in the judgment of the HS7 Other conditions exist which in the judgment of the HA7 Other conditions exist which in the judgment of the HU7 Other conditions exist which in the judgment of the E Emergency Director warrant declaration of a GENERAL Emergency Director warrant declaration of a SITE AREA Emergency Director warrant declaration of an ALERT. Emergency Director warrant declaration of an UNUSUAL .g> EMERGENCY. EMERGENCY. EVENT.
- I Emergency Action Level (EAL): Emergency Action Level (EAL): Emergency Action Level (EAL): Emergency Action Level (EAU:
~ I!! Other conditions exist which in the judgment of the Other conditions exist which in the judgment of the Emergency Other conditions exist which, in the judgment of the Other conditions exist which in the judgment of the Emergency c Emergency Director indicate that events are in progress or Director indicate that events are in progress or have occurred Emergency Director, indicate that events are in progress or Director indicate that events are in progress or have occurred
~ have occurred which involve actual or IMMINENT substantial which involve actual or likely major failures of plant functions have occurred which involve an actual or potential which indicate a potential degradation of the level of safety of c core degradation or melting with potential for loss of needed for protection of the public or HOSTILE ACTION that substantial degradation of the level of safety of the plant or a the plant or indicate a securtty threat to facility protection has ~ containment integrtty or HOSTILE ACTION that results in an results in intentional damage or malicious acts, (1) toward site security event that involves probable life threatening risk to been initiated. No releases of radioactive matertal requiring CD actual loss of physical control of the facility. Releases can be personnel or equipment that could lead to the likely failure of or, site personnel or damage to site equipment because of offsite response or monitortng are expected unless further E reasonably expected to exceed EPA Protective Action*- (2) that prevent effective access to equipment needed for the HOSTILE ACTION. Any releases are expected to be limited degradation of safety systems occurs.
W Guideline exposure levels offsite for more than the immediate protection of the public. Any releases are not expected to to small fractions of the EPA Protective Action Guideline site area. result in exposure levels which exceed EPA Protective Action exposure levels. Guideline exposure levels beyond the site boundary. Modes: 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4- Refueling D-Defueled December 201 B COLD SHUTDOWN/REl'UELING MATRIX NMP 2-22 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex COLD SHUTDOWN/REFUELING MATRIX ==================;;;C;;;;,;OLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY ALERT UNUSUAL EVENT ISFSI Malfunction E-HU1 II]§@l@J[Q] Damage to a loaded cask CONFINEMENT BOUNDARY. EmergencJl Action Level (EAL}: Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading: For 61BT DSC:
. > 800 mrem/hr 3 feet from the HSM surface OR
. > 200 mrem/hr outside the HSM door on centerline of DSC OR
. > 40 mrem/hr end of shield wall exterior For 61 BTH DSC:
. > 1400 mrem/hr on the HSM or HSM-H front surface OR
. > 200 mrem/hr on the HSM or HSM-H door centerline in II. OR
~
. > 40 mrem/hr on the end shield wall exterior Modes. 1 - Power Operation 2 - Hot Shutdown 3 - Cold Shutdown 4- Refueling D- Defueled December 201 B COLD SHUTDOWN/REFUELING MATRIX NMP2-23 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 3 (Rev. 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RG1 Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRem TEDE or 5000 mRem COE Thyroid.
- qpijj-~tiij_g_ M<icl.e APr:>_1-,c.~bJijfy~ -- :*:__ : - - ~ _- --~--~- -_- ~ ~-~ -- _~~--- -~~- _-~=--- -~-----:~-~~--~: _- ~--~:-~~--_~~~-~-- ~-
1, 2, 3, 4, D
- !;_!!19-rgen_~y -~c:tiQ_n __Ley_9-I (!;.A_~)_; ____ _
Notes:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- a. > 1000 mRem TEDE OR
- b. > 5000 mRem CDE Thyroid OR
- 2. Field survey results at or beyond the site boundary indicate EITHER:
- a. Gamma (closed window) dose rates> 1000 mR/hr are expected to continue for~ 60 minutes.
OR
- b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.
December 2018 NMP 2-24 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RG1 (cont)
- eas1s£ - --- - -- *- ---- --- - ------ -- -- --- -- --- ----------- -- - -- ---- --------- - - -- - ---- --- -- -----
This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public. Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at the EPA PAG of 1000 mRem while the 5000 mRem .thyroid COE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid COE. iB.~~l5- ~~f~r~.Q~~(~)_:__ ______________________________________ .. _ __ ___ __ __ ____________ _
- 1. EP-AA-112-500-F-55, NMP Offsite Monitoring Team Guidance
- 2. EP-AA-110-200, Dose Assessment
- 3. EP-AA-110-201, On-Shift Dose Assessment
- 4. CY-NM-170-301 Figure 5.1.3-1
- 5. NEI 99-01 Rev 6, AG1 December 2018 NMP 2-25 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RS1
- initiating_ Condition:__________ __ _______ _ ___ __ _______ _ ___ ___ ________ _ _____ _ __ __________________ _
Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDE or 500 mRem CDE Thyroid.
- QP~a:.~ti_11glVl_c;:,g~-A~PHC?~_bil_ity; _____________________________________________________________
- 1,2,3,4,D lt~itifgj!!ci~~-tfQn: ~~yeJ*(~A,j;:_~--~_-_:__~ ~~-- -_ ------ -_: ~=- -~----=-:-~ ~- ::*~ _-- -~-~ -_-:~---= ~- ~--:=~-- ~-~-~-- _::~
- Notes:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- a. > 100 mRem TEDE OR
- b. > 500 mRem CDE Thyroid OR
- 2. Field survey results at or beyond the site boundary indicate EITHER:
- a. Gamma (closed window) dose rates> 100 mR/hr are expected to continue for
~ 60 minutes.
OR
- b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.
December 2018 NMP 2-26 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RS1 (cont)
- Basis
This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at 10% of the EPA PAG of 1000 mRem while the 500 mRem thyroid COE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid COE. Escalation of the emergency classification level would be via IC RG1. ~~~iij t(~fe-r~nce(s):--~~ - - - - ~ _- - _ -- -- -- -- -- - -_ -- -- ----*--- ---
- 1. EP-AA-112-500-F-55, NMP Offsite Monitoring Team Guidance
- 2. EP-AA-110-200, Dose Assessment
- 3. EP-AA-110-201, On-Shift Dose Assessment
- 4. CY-NM-170-301 Figure 5.1.3-1
- 5. NEI 99-01 Rev 6, AS1 December 2018 NMP 2-27 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RA1 Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRem TEDE or 50 mRe.m COE Thyroid . .9P~r~,Jrig M9de)-\ppl_ic~~l.l_ity: . __ 1, 2, 3, 4, D E_r~u~rgE!ncy ~ct_lon bey~I (~~~)_:__ _ Notes:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
- Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
- The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. *
- 1. Reading on Stack (RN 10 A/8) Effluent Monitor> 1.50 E+05 cps for~ 15 minutes.
OR
- 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- a. > 10 mRem TEDE OR
- b. > 50 mRem CDE Thyroid OR
- 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary:
- a. 10 mRem TEDE for 60 minutes of exposure OR
- b. 50 mRem CDE Thyroid for 60 minutes of exposure OR December 2018 NMP 2-28 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RA1 (cont) ~Em~rgen_cy Act_ion __~~~eH!:;Ab)_ (~~nO: ____ ___ __ _ _____ __ __ ___ __ __ ___ _ ___ ____________ _
- 4. Field survey results at or beyond the site boundary indicate EITHER:
- a. Gamma (closed window) dose rates > 10 mR/hr are expected to continue for?. 60 minutes.
OR
- b. Analyses of field survey samples indicate > 50 mRem COE Thyroid for 60 minutes of inhalation.
- Basis:
This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release). Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at 1% of the EPA PAG of 1000 mRem while the 50 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE. Escalation of the emerg~ncy classification level would be via IC RS1.
- B.asJ~-Ref~ren_ce_(sj
- _":---- --- ----- -- ----- - -- - --------~-~----__-------- - -
- 1. CY-NM-170-301 Figure 5.1.3-1
- 2. EP-EAL-0633, Calculation of Nine Mile Point Unit 1 Table R-1 EAL Threshold Values
- 3. EP-AA-112-500-F-55, NMP Offsite Monitoring Team Guidance
- 4. NEI 99-01 Rev 6, AA1 December 2018 NMP 2-29 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RU1
- lf1i!i!l_ti_11_g C_Q_r,_ctiJiQ!I
- __ ___ __
Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.
- ------ --- --------- -- --~-------- *- --****
9PEm!~i11g_Mod_~-A~pl_i_c;:a~!ljfy: __ ______________________________ _ 1, 2, 3, 4, D J~n1erg~!l:~y_ ~c!iQ~1~v:~u~~~); __ _ Notes:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.
- Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
- 1. Reading on the Rad Waste Discharge effluent monitor > 2x alarm setpoint established by a current radioactive release discharge permit for~ 60 minutes.
OR
- 2. Reading on Stack (RN 10 A/8) Effluent Monitor> 2.85 E+02 cps (285 cps) for
~ 60 minutes OR
- 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2x ODCM Limit with a release duration of~ 60 minutes.
December 2018 NMP 2-30 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RU1 (cont}
- Basis:
I.:--*--*--*------------- --- - ---------------* *- ---*----*----**- - -- . --- *------ -- - - - - -**- --- *----------- -*---~- --------**-** This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared. Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls. Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL. EAL#1 Basis This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).
- EAL#2 Basis This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous effluent pathways.
EAL#3 Basis This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.). Escalation of the emergency classification level would be via IC RA 1. December 2018 NMP 2-31 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RU1 (cont)
- 1~-~!I~ -R~t~r~ii~e.(sj:~---~---~~- -~- ~:~- -_:=----~~ ~ -:-_----~ :_ -- *:~~~~:: __~--~ -_ ~~- -~:_:-:_:*--~:-_:~---~-~: ~ _: ~:-~~----:--~:~~
- 1. CY-NM-170-301 Figure 5.1.3-1
- 2. EP-EAL-0633, Calculation of Nine Mile Point Unit 1 Table R-1 EAL Threshold Values
- 3. NEI 99-01 Rev 6, AU1 December 2018 NMP 2-32 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RG2 J_r,_i~ia~~!'19 ~or,_~i_ti_on:__________ _____ ___ ____ ___ ____ _______ _ ___ __ __ __ ________ _ Spent fuel pool level cannot be restored to at least 316 feet for 60 minutes or longer.
- qper~tinsiiyi_~g~~Appiic;:a~OJti: ____ ~-:_:_~_::*: _=- *:*:- __ _ - - -_ --~- ---~ - -- - ---- -____ :-~ :___ -:*-~
1,2,3,4,D Note: The Emergency Dir_~ctor should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded. Spent fuel pool level cannot be restored to at least 316 feet as indicated on Ll-54-65A or Ll-54-658 on SFP monitoring panel (PNL-54-65H) for~ 60 minutes. 'Basis: This IC addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment. Level indicators Ll-54-65A and Ll-54-658 are located in the Aux Control Room. It is recognized that this IC would likely not be met until well after another General Emergency IC was met; however, it is included to provide classification diversity. Basis Referenc~(s)~ _______________ . ____ _ __ __ ____ ___ __ ____ __ ___ __ __ _ ____ _ ____
- 1. NEI 99-01 Rev 6, AG2
- 2. N1-EOP-5, Secondary Containment Control December 2018 NMP 2-33 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RS2 J_riitjc:1~_fn_g ~o_ij~:ff!_Qij:~ -- .-***- -- -* *-*. -*-* -- ~-~-~--:**_- ~-* :- Spent fuel pool level at 316 feet. 9P.~r!!.ting _!Vl_qct_e_ )\pp_lic;:c:1!Ji!i!Y: 1, 2, 3, 4, D
- ~m
- e~~g-~~~il~itrQ_11J~v~U1;AC)=~ *_ -_- ~~- .. _ __ : ~ ~ :_ -_-:-___ :* _ ______ ...
Lowering of spent fuel pool level to 316 feet as indicated on Ll-54-65A or Ll-54-65B on SFP monitoring panel (PNL-54-65H).
- easis:---- **- ---*--- --- -- ---*--
This IC addresses a significant loss of spent fuel pool inventory control and makeup capability leading to IMMINENT fuel damage. This condition entails major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration. Level indicators Ll-54-65A and Ll-54-65B are located in the Aux Control Room. It is recognized that this IC would likely not be met until well after another Site Area Emergency IC was met; however, it is included to provide classification diversity. Escalation of the emergency classification level would be via IC RG1 or RG2 . .B~sis R~f~-~e_n~_e(~}~ _
- 1. NEI 99-01 Rev 6, AS2
- 2. N1-EOP-5, Secondary Containment Control December 2018 NMP 2-34 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RA2
- 1!)-itlatfn-g c;c,~c1-.tJ9~=-.. :*. ~-- ~- ~-----*::.~- ------~_ :*::: *_-: *_--- ~------- --*~ _:_ -_ ~-- - -_ -~ _:_: -~~-- **: :*_ -~~-* . ----~~-~-: ~--: -_-
Significant lowering of water level above, or damage to, irradiated fuel. !Op~ra_t1ng M_o_d~ AP~Jic~~~l_(ty:: -~ ---~- **: : . _-- __ . _ :. _* .. : -** _. __ :-_ .. *- 1, 2, 3, 4, D i~rri-~rn~_ncyAc~ic;,ri_~~Y~U~A~)~ ___ . __ ______ . _______ *. ___ . _____ _
- 1. Uncovery of irradiated fuel in the REFUELING PATHWAY.
OR
- 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R1 Radiation Monitor Alarm.
OR
- 3. Lowering of spent fuel pool level to 326 feet as indicated on Ll-54-65A or Ll-54-65B on SFP monitoring panel (PNL-54-65H).
Table R1 Refuel Floor ARM's
- ARM 18 (West end of shield wall)
- ARM 25 (Reactor Building - east wall)
- ARM 29 Refuel Bridge (Low Range)
- Refuel Bridge (High Range)
- Reactor Building Vent Radiation Monitor
- J~~sls_: __ __________________________________________ ***-** ________ ... ___ .
REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange .. IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions. CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment. This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly or a significant lowering of water level within the spent fuel pool. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant. December 2018 NMP 2-35 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RA2 (cont)
- ~_,!~i§__(~9.'!~): ____ -------------- --------- ---- ----- --- - -- ------ --------- ---- __________-_- _____ _____ :
This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1. EAL#1 Basis This EAL escalates from RU2 in that the loss of level, in the affected portion of the REFUE;LING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations. - While an area radiation monitor could detect a rise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss. A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes. EAL #2 Basis This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident). _EAL #3 Basis: Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool. Level indicators Ll-54-65A and Ll-54-658 are located in the Aux Control Room. Escalation of the emergency would be based on either Recognition Category R or C ICs. December 2018 NMP 2-36 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RA2 (cont) ~Ba~f~)f~efer~~-~e~):_-_ ---- ------_: :-- _--__:: ---- --- ------~--~--~:- ___ -_:_*-:_-----_ -_: _-__-:_- : :-~- -_ -~:
- 1. N1-EOP-5, Secondary Containment Control
- 2. N1-0P-50A ARM System Attachment 2
- 3. N1-0P-50B Process Radiation Monitoring System
- 4. UFSAR Section X.J.2.1
- 5. N1-SOP-6.1 Loss of Rx Cavity Level/Decay Heat Removal
- 6. NEI 99-01 Rev 6, AA2 December 2018 NMP 2-37 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RU2
- 1~Ji"i~ffng-Gon~-lt10~=~----- _--__ --- ---- ---- -___-:~_- __ :-----~--~----~::---~----- --
UNPLANNED loss of water level above irradiated fuel.
- op~ra~~ng _Mi~~--~i:>P.ii~~b_mty:_ -_-:_- :- -- -- -
1,2,3,4, D
- l;rn~rnE!n_cy _A~~iga::i_~~vel (EA~)_;_ __ __ _ __ _
- 1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by;
- SFP water level < low water level alarm.
OR
- Indication or report of a drop in water level in the REFUELING PATHWAY.
AND
- b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R1.
Table R1 Refuel Floor ARM's
- ARM 18 0f\/est end of shield wall)
- ARM 25 (Reactor Building - east wall)
- ARM 29 Refuel Bridge (Low Range)
- Refuel Bridge (High Range)
- Reactor Building Vent Radiation Monitor December 2018 NMP 2-38 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RU2 (cont) Basis: UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. REFUELING PATHWAY: All the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange. This IC addresses a loss in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant. A water level loss will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available) or from any other temporarily installed monitoring instrumentation. A significant drop in the water level may also cause a rise in the radiation levels of adjacent areas that can be detected by monitors in those locations. The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may rise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level. A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes. Escalation of the emergency classification level would be via IC RA2.
- easJ~_~et~renc~
: * *** ___ --_-__ *:**----_- -______ ..:~
- _---~---- ___ : * * -__ --_-_-__ _
- 1. UFSAR Section X.J.2.1
- 2. N1-ARP-L 1 Annunciator L1-3-5
- 3. N1-SOP-6.1 Loss of Rx Cavity Level/Decay Heat Removal
- 4. N1-0P-50A ARM System Attachment 2
- 5. N1-EOP-5, Secondary Containment Control
- 6. NEI 99-01 Rev 6, AU2 December 2018 NMP 2-39 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RA3 Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.
- C~p~r~tirag ~~gE! ~ppli<;a!)ility:___ __ _ _ __
1, 2, 3, 4, D
- i;~~rg~ncy A~tt~~~ L~V:el _(E;A~)-~_-- :___ -_ ._
Note:
- If the equipment in the room or area listed in Table R3 was already inoperable, or not available, before the event occurred, then no emergency classification is warranted.
- 1. Dose rate> 15 mR/hr in ANY of the areas in Table R2.
Table R2 Areas Requiring Continuous Occupancy
- Main Control Room
- Central Alarm Station - (by survey)
OR
- 2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the areas in Table R3:
Table R3 Areas with Entry Related Mode Applicability Entry Related Mode Area Applicability Reactor Building 198' Northeast corner 261' North and Shutdown Cooling Room Modes 2, 3 and 4 281' North Turbine Building 291' North December 2018 NMP 2-40 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RA3 (cont) Basis: UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedures. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the increased radiation levels and determine if another IC may be applicable. Assuming all plant equipment is operating as designed, normal operation is capable from the Main Control Room (MCR). The plant is also able to transition into a hot shutdown condition from the.MGR, therefore Table R3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown. This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
- Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including the Control Room.
For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the elevated radiation levels preclude the ability to place shutdown cooling in service. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding beyond that required by procedures, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits). An emergency declaration is not warranted if any of the following conditions apply.
- The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation rise occurs, and the procedures. used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.
- The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.).
December 2018 NMP 2-41 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RA3 (cont) ~$a~i~-(co~t)_: - _-_- --__ - _ --- --:----- - _- -_--_ -- -- --~ --- -- -- - --- - - - -- - --- :- - -__ ----
- The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
- The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.
Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.
- -~-a~1~:R_~Je~~-"-~~(~)-: ~::- - -
- 1. N1-0P-50A ARM System
- 2. NEI 99-01 Rev 6, AA3 December 2018 NMP 2-42 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RU3 }n_fti~tfi:ig~c~9ri~OJ1on-:~_--_-_ :~:-- -~----~ _-:- -~-------- _-- - -- --~ ___________________ ---- -_-_- ~-----:- --- -- Reactor coolant activity greater than Technical Specification allowable limits.
- 9p~r~t_1~g _-iv!~de_~i>liH~~~1fif}i_:
1, 2
- E~erg~ijcy A~fiQO L9-y_~i-{l:_A1)~- -- -
- 1. Offgas radiation monitor RN-12A or RN-128 ~ UPSCL alarm.
OR
- 2. Specific coolant activity> 4.0 µCi/gm 1-131 equivalent.
This IC addresses a reactor coolant activity value that exceeds an allowable limit specified in Technical Specifications. This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant. This EAL addresses site-specific radiation monitor readings that provide indication of a degradation of fuel clad integrity. Escalation of the emergency classification level would be via ICs FA 1 or the Recognition Category R ICs.
- ~~siiij_~fej-~n_~e1~1~~--
- ~----~- .-:___ ~- ~:---_ -:__ : ~--- -~:: :- ____ ---_::~_-_- - -- . -- - ---- - - -- -*
- 1. CY-NM-170-301 3.6.14 & 15
- 2. N1-ARP-H1, Annunciator H1-2-7
- 3. N1-SOP-25.2 Fuel Failure or High Activity in RX Coolant or Off Gas
- 4. T~chnical Specification 3.2.4 Reactor Coolant System - RCS Specific Activity
- 5. NEI 99-01 Rev 6, SU3 December 2018 NMP 2-43 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FG1
- fo]ti_~ft11g_~~ng_ijio1J: ___ ________________________ -~ _ _ _ ____________________________________ ;
Loss of ANY two barriers AND Loss or Potential Loss of the third barrier. ~P~~~_tJ.rig_i\nc,~~:~pp1(c_~~Qiw_;_~~:~-~:~::_:*_-_-: _-_:_ *:___ -_ ------~_-_:--_:_~-~~=:_:_~~------_ -~---- ___ ~:_::* :=::~.-~:--~ 1, 2
- 1
- "-1~-~9!!_ncy~~tiQ.n__~~"~I (§_f'_L)_;__ ________ ___________________________________________________:
Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.
- Basis: _______ ---------------------------------------------- _____________
- _____________________________________ ----~
Fuel Cladding, RCS and Containment comprise the fission product barriers. At the General Emergency classification level each barrier is weighted equally.
- ~_a_~-i~-~~f~r~ri~~(~)_
- * _: _ :_-_-_-~~--~--~:~-_-:_-**:*_---__ _-*_::*_--- :.-=:*:-~:-~-~-~---*-::_-_- -~: :* :*_-~- - - _ -__ :-_-_- *_:~:-~:-
- 1. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-44 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FS1
- lrtiti~t,ng c_o~d_i~!OI}_: _ _____________________ _
Loss or Potential Loss of ANY two barriers. l~:iperal,rjgNfo_d_~-_Appijc~~jlJty:_~_:_-:~---:~~-: __ ______ --~-:------ - --- 1, 2
- Efl!erg_~~~i
- Act1~~J~~i~r (~A():_--- ~--_ __-___ :~ -_:_ -~-~ - _ ~- --~-~-- :__
Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.
- Basis:
Fuel Cladding, RCS and Containment comprise the fission product barriers. At the Site Area Emergency classification level, each barrier is weighted equally. ,ija~J~ _R~_f~reri~e(s)_~_ . _______ . __ _
- 1. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-45 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FA1
- 1ij}~f~tingj~~-ijf1Hi~ri; _~ --~-- *: *::_* __ - --- -- ~-- ---~~- --~--- _-_-_- -~ _:- ~:- __: ~ ::**_
ANY Loss or ANY Potential Loss of either Fuel Clad or RCS. ,bp~-rjti_f1i_Mc;i:ct~_A-RPffc~~Hity:*_ - _--_: -__ :*: _: :__--_ -~-- -- ___ -_ : _~-- __ : *_ - --- - -- -- 1, 2
- ~iji~_rgency"~~ti4n_ L~vel (~Ab5~--
- ~ -_~~-: - ~- ~ .:~~ -.-:-~*-.:*_---~ ~- -_-:* --~~- _:* _ __- - _
Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status. ~easis=*------------- - ------- ---- Fue1 Cladding, RCS and Containment comprise the fission product barriers. At the Alert classification level, Fuel Cladding and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability. Note that the loss or potential loss of Containment barrier in combination with loss or potential loss of either Fuel Cladding or RCS barrier results in declaration of a Site Area Emergency under EAL FS1 . .~a~.1~~~f~r~"'~i.fi1::_:__: .-.-:-__ :_ :~::_*:*---~---- :.- -~--~ --~:_*_:* :.--___:-.-:**- -: ___ -_: __ -__-_-----------
- 1. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-46 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC1
- t~i~Jatj_ng <;~~~itio~;
RCS Activity !Qpe_r~~ing IVI~~~ ~P~!l~c\b_ility:__ ___ _ 1, 2 fi~_!;!_~_l1 _PrQ~LJ_ct_ ~~rri~r (F_P~) ,:hr.e~hpJ~__; __ LOSS Coolant activity> 300 uCi/gm 1-131 equivalent.
- easis:
This threshold indicates that RCS radioactivity concentration is greater than 300 µCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier. It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications. There is no Potential Loss threshold associated with RCS Activity. B~~is ~~f~r~i,c~(s)_:-: :_ -_-__ --___ -
- 1. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-47 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2
- 111~Hatf~gJ:;~ci~-~1tlori: --~ :-:--
- RPV Water Level
.Qp_~ra~in_g_lV_lo~e A~Rllc_a_b~l_ity__;___ _ __ ___ ____ _ __________ _ 1; 2
- f:i~~ic;m -~rQcl~ct.__B~rrierJFl:'B) n,_res_hold: __
LOSS
- 1. SAP entry required.
POTENTIAL LOSS
- 2. RPV water level cannot be restored and maintained > -84 inches.
OR
- 3. RPV water level cannot be determined.
Loss Threshold #1 Basis The Loss threshold represents the EOP requirement for primary containment flooding. This is identified in the BWROG EPGs/SAGs when the phrase, "Primary Containment Flooding Is Required," appears. Since a site-specific RPV water level is not specified here, the Los.s threshold phrase, "SAP entry required" also accommodates the EOP need to flood the primary containment when RPV water level cannot be determined and core damage due to inadequate core cooling is believed to be occurring. Potential Loss Threshold #2 and #3 Basis This water level corresponds to the top of the active fuel and is used in the EOPs to indicate a challenge to core cooling. The RPV water level threshold is the same as RCS Barrier RC2 Loss threshold. Thus, this threshold indicates a Potential Loss of the Fuel Clad barrier and a Loss of the RCS barrier that appropriately escalates the emergency classification level to a Site Area Emergency. This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV water level cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization. EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this Fuel Clad barrier Potential Loss is met only after either: 1) the RPV has been depressurized, or required December 2018 NMP 2-48 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION
._____ . _____________________ .. _-* _______ . ______ . *-* _______ .______ FC2_ {co~t)_
~~a~ij_(~Q11t):_ _ __ *---- ___________________ . emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory. The term "cannot be restored and maintained above" means the value of RPV water level is not able to be brought above the specified limit .(top of active fuel). The determination requires an evaluation of system performance and availability in relation to the RPV water leve.1 value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation below the limit; the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained. In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level in order to reduce reactor power. Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority. For such events, ICs MA3 or MS3 will dictate the need for emergency classification. Since the loss of ability to determine if adequate core cooling is being provided presents a significant challenge to the fuel clad barrier, a potential loss of the fuel clad barrier is specified.
- ea~*~-~et~~~nce{~)=----=---*-- ---*-- --- --*--* - ------- -- -* -. ~-~-- _-_-___--~ ~~* - --
- 1. NER-1 M-095, NMP1 Emergency Operating Procedures (EOP) Basis Document
- 2. N1-EOP-2 RPV Control
- 3. N1-EOP-3 Failure to Scram
- 4. N1-EOP-7 RPV Flooding
- 5. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-49 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC5
- _tn_itj_~~ing C~11diti_o!1; _
Primary Containment Radiation
- 9p~f~tJiig IYl<>~~-~f'ppi}c~~Oity;_ - --
1, 2 'fi~~ic:>_n Pr<?_du_ct_B~rri~r (fP~t Thr~sti_QI~: _ __ __ _ __ LOSS Drywell radiation reading > 1.1 E+03 R/hr (1,100 R/hr). The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals 300 µCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier. The radiation monitor reading in this threshold is higher than that specified for RCS Barrier RC5 Loss Threshold since it indicates a loss of both the Fuel Clad Barrier and the RCS Barrier. Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency. There is no Fuel Clad Barrier Potential Loss threshold associated with Primary Containment Radiation.
- ~~sisJ~-~f~r_e11~~(~):__ ___ _ __
- 1. EP-EAL-0713, Criteria for Choosing Containment Radiation Values Indicating a Loss of Fuel Clad and a Potential Loss of Containment for Nine Mile Point Station Unit 1
- 2. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-50 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC7 Jri,t1~Ji_~_g _9_~n_di(fo.~:= - - . Emergency Director Judgment.
*9.i>~r~tlng)il~d~APi:>_itc~~i_(!ti; ~~~ _
1, 2
,fis_~!o_n_ Pro_~~-~t-~arrier <Fi:>~)_ TJ,r~~h_qLd_: __
LOSS
- 1. ANY condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.
POTENTIAL LOSS
- 2. ANY condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.
Basis: Loss Threshold #1 Basis This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad Barrier is lost. Potential Loss Threshold #2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored. B_a~i~ ~e-~E!r~nce(~):.
- 1. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-51 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC2 'lnl!ia{ing g~_n~i_tiQn: _____ _ RPV Water Level ~Qper~}hfg *MC?~~ Appf{~~~(ffty: 1, 2
- f_i~~ion_-P-fQ-~u~cf~arri~!'--(FPBf Thre~tjo(~-: _-:-: __ -*: -- - --- - -
LOSS
- 1. RPV water level cannot be restored and maintained > -84 inches.
OR
- 2. RPV water level cannot be determined.
- e~s_is_:__ _________________ _
This water level corresponds to the Top of Active Fuel (TAF) and is used in the EOPs to indicate challenge to core cooling. The RPV water level threshold is the same as Fuel Clad Barrier FC2 Potential Loss threshold. Thus, this threshold indicates a Loss of the RCS barrier and Potential Loss of the Fuel Clad barrier and that appropriately escalates the emergency classification level to a Site Area Emergency. This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV water level cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this RCS barrier Loss is met only after either: 1) the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure inj~ction sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory. The term, "cannot be restored and maintained above," means the value of RPV water level is not able to be brought above the specified limit (top of active fuel). The determination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation beyond the limit; the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained. December 2018 NMP 2-52 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION ___________________ RC2Jcont)
- BasJs._(ccmt): _ ___ ___ __ _ __ ____________ _
In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level in order to reduce reactor power. Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority. For such events, ICs MA3 or MS3 will dictate the need for emergency classification. There is no RCS Potential Loss threshold associated with RPV water level.
- _8-@~J~J~~f~rii1~i(jf: ___ ~ --_-_- --: ____ ~--- ___-_--::_ -~--- ~ -- .~--- ~ __ _-::- --~ ---::_ - --~--=~-- -_---- --- ---- --
- 1. NER-1 M-095, NMP1 Emergency Operating Procedures (EOP) Basis Document
- 2. N1-EOP-2 RPV Control
- 3. N1-EOP-3 Failure to Scram
- 4. N1-EOP-7 RPV Flooding
- 5. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-53 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC3
- lnitiating_C_<:>n~_i~i_Qn:__________ _________ _ --- - *- - -* --- -**---
/
Primary Containment Pressure cfo:Ei~~#n:siJvi_c,~~--APP*1~~~tiU1hi_:-- - ~ ~- __ ~--: _- 1, 2 fi~~iora PfQCh~~t~~rr~e_r _(f_P..~)_Itm~s_h<:>I~: __ _ LOSS
- 1. a. Primary Containment pressure > 3.5 psig.
AND
- b. Primary Containment pressure rise is due to RCS leakage
- . ----------- --- ----- ----- --**--- -------- --- .. ----- ---* --------- - - ~- ---- - -- . ***-- -- - --------***--- -----*--- ---- -- -
- Basis:
> 3.5 psig primary containment pressure is the Drywell high pressure setpoint which indicates a LOCA by automatically initiating ECCS.
The second threshold condition focuses the fission product barrier loss threshold on a failure of the RCS instead of the non-LOCA malfunctions that may adversely affect primary containment pressure. Pressures of this magnitude can be caused by non-LOCA events such as a loss of Drywell cooling or inability to control primary containment vent/purge. The release of mass from the RCS due to the as-designed/expected operation of any relief valve does not warrant an emergency classification. A stuck-open Electromatic Relief Valve (ERV) or ERV leakage is not considered either identified or unidentified leakage by Technical Specification and, therefore, is not applicable to this EAL. There is no Potential Loss threshold associated with Primary Containment Pressure.
- B~sis Referen~~(s)_:___ ___ __ _ ______ _
- 1. N 1-EOP-2 RPV RPV Control
- 2. N1-EOP-4 Primary Containment Control
- 3. NER-1 M-095, NMP1 Emergency Operating Procedures (EOP) Basis Document
- 4. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-54 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC4 IQiti~ting__ G~nditiqn_: _ RCS Leak Rate
- ape_rati_ng__Mo~e Appli_c~bility: : _
1, 2 Fi_s~ion Produc.t ~arri~rJFP~) Thr_es_l:toid: __ _ LOSS
- 1. UNISOLABLE Main Steam line, EC steam line, Feedwater, or RWCU line break.
OR
- 2. RPV Slowdown is required.
POTENTIAL LOSS
- 3. UNISOLABLE primary system leakage that results in EITHER of the following:
- a. ANY area temperature> N1-EOP-5 Detail T alarm setpoint.
OR
- b. ANY area radiation level > N1-EOP-5 Detail R alarm setpoint.
- Basis:
UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally. Failure to isolate the leak, within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification. Classification of a system break over system leakage is based on information available to the Control Room from the event. Indications that should be considered are:
- Reports describing magnitude of steam or water release.
- Use of system high flow alarms I indications, if available,
- Significant changes in makeup requirements,
- Abnormal reactor water level changes in response to the event.
The *use of the above indications provides the Control Room the bases to determine that the ongoing event is more significant than the indications that would be expected from system leakage and therefore should be considered a system break. Loss Threshold #1 Basis Large high-energy lines that rupture outside primary containment can discharge significant amounts of inventory and jeopardize the pressure-retaining capability of the RCS until they are isolated. If it is determined that the ruptured line cannot be promptly isolated, the RCS barrier Loss threshold is met. December 2018 NMP 2-55 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION
- 1;1asi~_ (con~):
Even though RWCU and Feedwater systems do not contain steam, they are included in the list because an UNISOLABLE break could result in the high-pressure discharge of fluid that is flashed to steam from relatively large volume systems directly connected to the RCS. Loss Threshold #2 Basis RPV Slowdown (Emergency RPV Depressurization) in accordance with the EOPs is indicative of a loss of the RCS barrier. If RPV Slowdown is performed, the plant operators are directed to open Electromatic relief valves (ERVs) and keep them open. Even though the RCS is being vented into the torus, a Loss of the RCS barrier exists due to the diminished effectiveness of the RCS to retain fission products within its boundary. Potential Loss Threshold #3 Basis Potential loss of RCS based on primary system leakage outside the primary containment is determined from EOP temperature or radiation Max Normal Operating values in areas such as main steam line tunnel, Emergency Condenser, RWCU etc., which indicate a direct path from the RCS to areas outside primary containment. A Max Normal Operating value is the highest value of the identified parameter expected to occur during normal plant operating conditions with all directly associated support and control systems functioning properly. The indicators reaching the threshold barriers and confirmed to be caused by RCS leakage from a primary system warrant an Alert classification. A primary system is defined to be the pipes, valves, and other equipment which connect directly to the RPV such that a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system. In general, multiple indications should be used to determine if a primary system is discharging outside Primary Containment. For example, a high area radiation condition does not necessarily indicate that a primary system is discharging into the Reactor Building since this may be caused by radiation shine from nearby steam lines or the movement of radioactive materials. Conversely, a high area radiation condition in conjunction with other indications (e.g. room flooding, high area temperatures, reports of steam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into the Reactor Building. An UNISOLABLE leak which is indicated by Max Normal Operating values escalates to a Site Area Emergency when combined with Containment Barrier CT6 Loss Threshold
#1 (following automatic or manual isolation) and a General Emergency when the Fuel Clad Barrier criteria is also exceeded.
December 2018 NMP 2-56 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC4 (cont)
- ~~s)i-ReJ~renc~(sj: _:_~_- :*-- -~- - _- ----~- - -- -- -
- 1. UFSAR Section VIII.A Protective Systems
- 2. UFSAR Section V.E Emergency Cooling System
- 3. UFSAR Section X.B Reactor Cleanup System
- 4. N1-EOP-5, Secondary Containment Control
- 5. N1-EOP-2 RPV Control
- 6. N1-EOP-3 Failure to Scram
- 7. N1-EOP-4 Primary Containment Control
- 8. N1-EOP-4.1 Primary Containment Venting
- 9. N1-EOP-5 Secondary Containment Control
- 10. N1-EOP-6 Radioactivity Release Control
- 11. N1-EOP-7 RPV Flooding
- 12. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-57 EP-AA-1.013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RCS }JJ!ti~~!l1_g_9_Q_11~ili_Q11; __ -- ---- __ ---------- ---- __ '.___ -- --- ___ ------- ----- --- ---- - ------ ------ Primary Containment Radiation
- Operating Mode Applicability~______ _____________________________ ----=--
- :=-~~::~:--=:_ ~-:~ _ : ~:_ _ :-~~--:___
1, 2
- Fission_Product_Barrier (FPB) Threshold: ______ ________________________________________ - _____ _
LOSS Drywell radiation reading > 100 R/hr.
- ~a~i~=--- ____________________________________________ _
The radiation monitor reading corresponds to an in$tantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier FC5 Loss Threshold since it indicates a loss of the RCS Barrier only. There is no RCS Potential Loss threshold associated with Primary Containment Radiation. '.~~~_i~ B~f~r~n9-~(s);_ ____ ___ ____ ____ ____ ___ ___________________________ _
- 1. EP-EAL-0513, Criteria for Choosing Drywell Radiation Monitor Reading Indicative of Loss of the RCS Barrier for NMP U1
- 2. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-58 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear-RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC7 Emergency Director Judgment.
¢~~r~tin_g_ M~ij~ Ai:ii>Jr<:iljfiify: -- -
1, 2 1 Fis~,9~ Prc;,d~<:t_~_a_rri_er_(F~~) T~-r~~tJol~:_ LOSS
- 1. ANY condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.
POTENTIAL LOSS
- 2. ANY condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.
.Basis: Loss Threshold #1 Basis This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the RCS Barrier is lost. Potential Loss Threshold #2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored. B;i~is Refer~-"-~~{s): _ __ _ _ __ __
- 1. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-59 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT2
;l_njticlltir.ig_g_~-~~j!i9rr; . ________ . . __ ____ ___ ___ ___ __ _ __ ___ ___
RPV Water Level
,Operating_Mode_Applicability: _______ _______________________ _
- 1, 2 J=Js~io~ PrQ_~uct Ba!r.i~! .ffe~til:i!es!'!old; _____ ________ ....
POTENTIAL LOSS SAP entry required. iBasis:
- The Potential Loss threshold is identical to the Fuel Clad Barrier FC2 Loss threshold RPV water level. The Potential Loss requirement for entry into the Severe Accident Plan (SAP) indicates adequate core cooling cannot be assured and that core damage is possible. BWR EOPs/SAP's specify the conditions when the EOPs are exited and SAPs are entered. Entry into SAPs is in response to the inability to restore and maintain adequate core cooling.
PRA studies indicate that the condition of this Potential Loss threshold could be a core melt sequence which, if not corrected, could lead to RPV failure and increased potential for primary containment failure. In conjunction with the RPV water level Loss thresholds in the Fuel Clad and RCS Barrier columns, this threshold results in the declaration of a General Emergency.
- Basis_Reference(s): _____________
- ______________________ ---*------------------------------------- _______ .
- 1. NER-1 M-095, NMP1 Emergency Operating Procedures (EOP) Basis Document
- 2. N1-EOP-2 RPV Control
- 3. N1-EOP-3 Failure to Scram
- 4. N1-EOP-7 RPV Flooding
- 5. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-60 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 Jnitiating qo_raqitiqra~. _ Primary Containment Conditions bper:~ting "ivfqcie App_lica~1li~: ____ : __ 1, 2 i=is~~on_ P_roc:luct Barrie_r (F~Bj Jhr~shQ!~;__ _ LOSS
- 1. UNPLANNED rapid drop in Primary Containment pressure following Primary Containment pressure rise.
OR
- 2. Primary Containment pressure response not consistent with LOCA conditions.
POTENTIAL LOSS
- 3. Torus pressure > 35 psig.
OR
- 4. a. Primary Containment Hydrogen concentration ~ 6%.
AND
- b. Primary Containment Oxygen concentration~ 5%.
OR
- 5. Heat Capacity Temperature Limit (N1-EOP-4 Figure M) exceeded.
Basis: UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. Loss Threshold #1 and #2 Basis Rapid UNPLANNED loss of Primary Containment pressure (i.e., not attributable to drywell spray or condensation effects) following an initial pressure rise indicates a loss of Primary Containment integrity. Primary Containment pressure should rise as a result of mass and energy release into the Primary Containment from a LOCA. Thus, Primary Containment pressure not increasing under these conditions indicates a loss of Primary Containment integrity. These thresholds rely on operator recognition of an unexpected response for the condition and therefore a specific value is not assigned. The unexpected (UNPLANNED) response is important because it is the indicator for a Primary Containment bypass condition. December 2018 NMP 2-61 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 _(cont)_ Potential Loss Threshold #3 Basis The threshold pressure is the Torus internal design pressure. Structural acceptance testing demonstrates the capability of the Torus to resist pressures greater than the internal design pressure. A pressure of this magnitude is greater than those expected to result from any design basis accident and represents a potential loss of the Containment Barrier. Potential Loss Threshold #4 Basis If hydrogen concentration reaches or exceeds the lower flammability limit, as defined in plant EOPs, in an oxygen rich environment, a potentially explosive mixture exists. If the combustible mixture ignites inside the Primary Containment, loss of the Containment Barrier could occur. Potential Loss Threshold #5 Basis The Heat Capacity Temperature Limit (HCTL} is a function of RPV pressure, torus temperature and torus water level. It is utilized to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant and therefore, the inability to maintain plant parameters below the limit constitutes a potential loss of Containment Barrier. ,ija~ls_Re[~r~-~ce_(~):_:-:_--~~-- _-_- -:-------~~----~-:_--:_---- - - --- ____ *:_-:-*-- --
- 1. UFSAR Section VI.B.1.2 Design Basis Accident (DBA)
- 2. NER-1 M-095, NMP1 Emergency Operating Procedures (EOP) Basis Document
- 3. N1-EOP-4.1 Primary Containment Venting
- 4. N1-EOP-4 Primary Containment Control
- 5. UFSAR Section VI.A.2.2 Loss-of-Coolant-Accident
- 6. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-62 EP-M-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT5
- !ni!i~~jng 9or-d_itL~l'.l_: __
Primary Containment Radiation 9P-~r~~-*iJg Moii~:_A~p1ic:c1bliity; ~ __ _ 1, 2 Fi~siQll prc:>e:~u~! ~-~rrier_ (FP~)__T~r~shold: __ _ POTENTIAL LOSS Drywell radiation reading > 1.1 E+04 R/hr (11,000 R/hr).
- Basis:
There is no Loss threshold associated with Primary Containment Radiation. The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that 20% of the fuel cladding has failed. This level of fuel clad failure is well above that used to determine the analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds. NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately 20% in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the emergency classification level to a General Emergency.
- ~a~Is}~et~rence(~f - -- ------- -- ---- _-_ -: -~-~-~ -_--~-: ---~~:-~- ~-~- -:_- -_- --:--~ _- -~~-- __
- 1. EP-EAL-0713, Criteria for Choosing Containment Radiation Values Indicating a Loss of Fuel Clad and a Potential Loss of Containment for Nine Mile Point Station Unit 1
- 2. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-63 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT6 '.l~itic1ti_ng CQn~_i~!~11.: __ _ _________ _ Primary Containment Isolation Failure '.9P~rc1ting N!o-~e-Appi(~ci~liity;-_ - ___ : :_~ ___ __ _____ :_ 1, 2 '.fi~s}ori ~r~~uc(~~rr~rJi=e_ijf ftir~_sfjQJd_:_~ _-~- --:~ -:: _~ ----:~-:-_:_ ----_ ---~---~-- -~ -_-_- -~- *: _-_:-:_- -- LOSS
- 1. UNISOLABLE direct downstream pathway to the environment exists following automatic or manual isolation signal.
OR
- 2. Intentional Primary Containment venting/purging per EOPs or SAPs due to accident conditions.
OR
- 3. UNISOLABLE primary system leakage that results in EITHER of the following:
- a. Maximum safe general area temperature> 135°F.
OR
- b. Maximum safe area radiation level > 8 R/hr.
- BSSiS:----------* --------**---- ---------~- *-- - *- ---
UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally. Failure to isolate the leak, within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification. These thresholds address incomplete containment isolation that allows an UNISOLABLE direct release to the environment. Loss Threshold #1 Basis The use of the modifier "direct" in defining the release path discriminates against release paths through interfacing liquid systems or minor release pathways, such as instrument lines. Leakage into a closed system is to be considered only if the closed system is breached and thereby creates a significant pathway to the environment. Examples include unisolable Main Steam line, Emergency Condenser line breaks, unisolable RWCU system breaks, and unisolable containment atmosphere vent paths. Examples of "downstream pathway to the environment" could be through the Turbine/Condenser, or direct release to the Turbine or Reactor Building. The existence of a filter is not considered in the threshold assessment. Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream. December 2018 NMP 2-64 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION
~-T~ (coa:,~)_
Basis (cont): Following the leakage of RCS into primary containment and a rise in primary containment pressure, there may be minor radiological releases associated with allowable primary containment leakage through various penetrations or system components. Minor releases may also occur if a primary containment isolation valve(s) fails to close but the primary containment atmosphere escapes to an enclosed system. These releases do not constitute a loss or potential loss of primary containment but should be evaluated using the Recognition Category R ICs. Loss Threshold #2 Basis EOPs may direct primary containment isolation valve logic(s) to be intentionally bypassed, even if offsite radioactivity release rate limits will be exceeded. Under these conditions with a valid primary containment isolation signal, the containment should also be considered lost if primary containment venting is actually performed. Intentional venting of primary containment for primary containment pressure or combustible gas control to the secondary containment and/or the environment is a Loss of the Containment Barrier. Venting for primary containment pressure control when not in an accident situation (e.g., to control pressure below the Drywell high pressure scram setpoint) does not meet the threshold condition. Loss Threshold #3 Basis The Max Safe Operating Temperature and the Max Safe Operating Radiation Level are each the highest value of these parameters at which neither: (1) equipment necessary for the safe shutdown of the plant will fail, nor (2) personnel access necessary for the safe shutdown of the plant will be precluded. EOPs utilize these temperatures and radiation levels to establish conditions under which RPV depressurization is required. The temperatures and radiation levels should be confirmed to be caused by RCS leakage from a primary system. A primary system is defined to be the pipes, valves, and other equipment which connect directly to the RPV such that a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system. In general, multiple indications should be used to determine if a primary system is discharging outside Primary Containment. For example, a high area radiation condition does not necessarily indicate that a primary system is discharging into the Reactor Building since this may be caused by radiation shine from nearby steam lines or the movement of radioactive materials. Conversely, a high area radiation condition in conjunction with other indications (e.g. room flooding, high area temperatures, reports of steam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into the Reactor Building. In combination with RCS Barrier RC4 Potential Loss Threshold #3 this threshold would result in a Site Area Emergency. December 2018 NMP 2-65 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT6 (cont) ,Ba~_i_s (~c:>_n!): There is no Potential Loss threshold associated with Primary Containment Isolation Failure.
- _~a~is_ flef~re11ce(~): _ _ __ _ __
- 1. N1-EOP-4 Primary Containment Control
- 2. N1-EOP-4.1 Primary Containment Venting
- 3. N1-EOP-5 Secondary Containment Control
- 4. NER-1 M-095, NMP1 Emergency Operating Procedures (EOP) Basis Document
- 5. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-66 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT7 Jr,i_tic1ting Condi_tiot:1_: _ Emergency Director Judgment. 9~~r!lti_!19 _M9_d_e_ Applicabi_lity_: 1, 2
- Fi~~fc~m Product :13_arr~er (F-~Bf °thr~s_h_old: _ ___ _
LOSS
- 1. ANY condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.
POTENTIAL LOSS
- 2. ANY condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.
'Basis: Loss Threshold #1 Basis This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Containment Barrier is lost. Potential Loss Threshold #2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.
- ~a~_i!)i_Ref~ren~e_(~)::___ -____ - ------~~ _ -_-
- 1. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-67 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG1 1_~_it!~tlrig__ g_cm~iti9_!1_:_ ____ _ Prolonged loss of all offsite and all onsite AC power to emergency buses. ,O_per~tll'.19 *ooo_g~- )~ppii~ibility:_~ __ - _ -~:.: -~: ___-_ ~ ~-~- _- --__ _ ___-_ -- :. ~-~- *:* -_- ___ ___ ___ 1, 2 J;~_~rg~Qgy .A~ti_QJJ _L~~e~ (~Ab):__ __ ___ _ _ __ ____ _ ____ _ Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
1 Loss of ALL offsite and onsite AC power to 4.16 kV Emergency Buses. AND
- 2. EITHER of the following:
- a. Restoration of at least one 4.16 kV Emergency Bus in < 4 hours is not likely.
OR
- b. RPV water level cannot be restored and maintained> -109 inches.
- easis:
SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses a prolonged loss of all power sources to AC emergency buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A prolonged loss of these buses will lead to a loss of any fission product barrier. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. The EAL should require declaration of a General Emergency prior to meeting the thresholds for IC FG1. This will allow additional time for implementation of offsite protective actions. December 2018 NMP 2-68 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS
- ~a_s!!;_(c:c;mt): _ _____ _ ___ ____ _ ___ _
Escalation of the emergency classification from Site Area *Emergency will occur if it is projected that power cannot be restored to at least one AC emergency bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and event trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers. The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation. Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public. The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.
- ~~sis ~efer~!!-~j(s};_ . ----- -- -- - - ----------- - ---- ----
- 1. N1-0P-30 4.16 KV, 600V, and 480V House Service
- 2. NER-1 M-025 SBO Evaluation
- 3. NER-1 M-095 NMP1 EOP and SAP Basis Document
- 4. NEI 99-01 Rev 6, SG1 December 2018 NMP 2-69 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1 Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer. Qp~i~_tir,g_ lY!~~-~-~ppfi~~~ll_ify~:_ . . ::- .---~:-- -- - . - -- ------- -.--* . . -- 1, 2 '~rr!~-rg~n-iiActkiri Ley~I(~,\[f~-- ---~~- ______ _ Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. Loss of ALL offsite and onsite AC power to 4.16 kV Emergency Buses.
AND
- 2. Failure to restore power to at least one 4.16 kV Emergency Bus from the time of loss of both offsite and onsite AC power in < 15 minutes.
- eas-is:___ --* ----- ------- ----- .. ----
SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. This IC represents a condition that *involves actual or likely major failures of plant functions needed for the protection of the public. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Escalation of the emergency classification level would be via ICs RG1, FG1, MG1, or MG2.
/
December 2018 NMP 2-70 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS
~-~1_ (~o~!)
~l;lasi~ ~efer~nce]sj:_ -- .-- :_- -----~ - ---- - --: **: -- ---
- 1. N1-0P-30 4.16 kV, 600V, and 480V House Service
- 2. UFSAR section IX Electrical Systems
- 3. NEI 99-01 Rev 6, SS1 December 2018 NMP 2-71 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA1 l_niti~~i11g ~~n_di~io~;_ _ _ __ Loss of all but one AC power source to emergency buses for 15 minutes or longer. QR~_ri!tirig)Vfgi{~_Pt-pp(icatiiJlty";:. ~-:__ -____ - --- -- . -- --- -- .. -- . - ... __ - --- --- .. -- --- .... 1, 2 E_merge11cy A_c_ti911 l:,..ev~I (!;AL): __ Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. AC power capability to 4.16 kV Emergency Buses reduced to only one of the following power sources for~ 15 minutes:
- T-101 N
- T-101 S
- DG-102 Emergency Diesel Generator
- DG-103 Emergency Diesel Generator AND
- 2. ANY additional single power source failure will result in a loss of all AC power to SAFETY SYSTEMS.
- Basis:
SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment. This IC provides an escalation path from IC MU1. An "AC power source" is a source recognized in SOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.
- A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).
December 2018 NMP 2-72 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA1 (cont)
- A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from the unit main generator.
- A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an offsite power source.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power. Escalation of the emergency classification level would be via IC MS1. 'Ba~i_!;_ R~feren~~{~t __ ______ _ ____ _ __ ___ _ ________ _
- 1. N1-0P-30 4.16 kV, 600V, and 480V House Service
- 2. UFSAR section IX Electrical Systems
- 3. NEI 99-01 Rev 6, SA1 December 2018 NMP 2-73 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU1 Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.
- 9p~rc1-ti~gJ11J~d'.e_ ,(ppl(~~},Ufty{-:_-_
1, 2
- !;_mE!rQ~l'.l~YACt!c;m_ ~-fi!~E!l (E;A!-): _
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
Loss of ALL offsite AC power capability to 4.16 kV Emergency Buses for~ 15 minutes:
- T-101 N
- T-101 S This IC addresses a prolonged loss of offsite power. The loss of offsite power sources renders the plant more vulnerable to a complete loss of power to AC emergency buses.
This condition represents a potential reduction in the level of safety of the plant. For emergency classification purposes, "capability" means that an offsite AC power source(s) is available to the emergency buses, whether or not the buses are powered from it.
- Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power.
Escalation of the emergency classification level would be via IC MA 1.
- J:3~si~_ R.efE!!enc~(s l: __ _ ______ _ ________ _
- 1. N1-0P-30 4.16 kV, 600V, and 480V House Service
- 2. UFSAR section IX Electrical Systems
- 3. NEI 99-01 Rev 6, SU1 December 2018 NMP 2-74 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG2 Jniti~!i_l)_g_Gonc;litio~: ___ ___ __ __ _ ___ Los~ of all AC and Vital DC power sources for 15 minutes or longer.
- oi>~r~ffng: M_o~e_:APPl!c~~11ity;:_ -~ - ____________ _
1, 2
- l;_m_~_i:gen~Y A~t]~r:! ~~~~I {l;~b)_: _
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. Loss of ALL offsite and onsite AC power to 4.16 kV Emergency Buses.
AND
- 2. Voltage is< 106 VDC on 125 VDC Battery Boards 11 and 12.
AND
- 3. ALL AC and Vital DC power sources have been lost for~ 15 minutes.
188,~i~_:__ - - - SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A loss of Vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both AC and DC power will lead to multiple challenges to fission product barriers. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. The 15-minute emergency declaration clock begins at the point when all EAL conditions are met. December 2018 NMP 2-75 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG2 (cont) Basis _Reference(s)~--- __ ________ ________ ____ ___ _____ ___ ___ ___ __ __ ____ __ __ __________ ----~--- ---~-~~-~-~ ~~---
- 1. N1-0P-30 4.16 KV, 600V, and 480V House Service
- 2. NER-1 M-025 SBO Evaluation
- 3. NER-1 M-095 NMP1 EOP and SAP Basis Document
- 4. N1-0P-47A 125 voe Power System
- 5. UFSAR section IX Electrical Systems
- 6. NMP1 Technical Specification 3.6.3
- 7. NEI 99-01 Rev 6, SGB December 2018 NMP 2-76 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS2 Loss of all vital DC power for 15 minutes or longer. -oi>erat,~g_ N(~c1_~ ~pp~i-~~b-~nti:______ -___-__ - - ______ _ 1, 2 1~1T1~rge"!~Y._ AcJi_c>_!! _L_~y~I_ (~A~)_~-- Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
Voltage is< 106 VDC on 125 VDC Battery Boards 11 and 12 for~ 15 minutes.
- Basis:
SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses a loss of Vital DC power which compromises the ability to monitor and control SAFETY SYSTEMS. In modes above Cold Shutdown, this condition involves a major failure of plc;mt functions needed for the protection of the public. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Escalation of the emergency classification level would be via ICs RG1, FG1 or MG2.
- -ea~1~-R~f~~eric:e(~f=:-___ --- ---- --
- 1. N1-0 P-4 7A 125 VDC Power System
- 2. UFSAR section IX Electrical Systems
- 3. NMP1 Technical Specification 3.6.3
- 4. NER-1 M-025 SBO Evaluation
- 5. NEI 99-01 Rev 6, SS8 December 2018 NMP 2-77 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3 Initiating C:onditi_c>n: Inability to shutdown the reactor causing a challenge to RPV Water Level or RCS heat removal. Op~rating Mode ~pplic;ab_il!ty: _ 1 ~merge~_cy Actie>Q_ Le"el (!;AL):
- 1. Automatic scram did not shutdown the reactor as indicated by Reactor Power> 6%.
AND
- 2. ALL manual/ ARI actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power> 6%.
AND
- 3. EITHER of the following conditions exist:
- RPV water level cannot be restored and maintained > -109 inches.
OR
- Heat Capacity Temperature Limit (N1-EOP-4 Figure M) exceeded.
Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, all subsequent operator manual actions, both inside and outside the Control Room including driving in control rods and boron injection, are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency. In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs. This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor. EAL #3 is considered to be exceeded when, as specified in the site-specific EOPs, RPV water level cannot be restored and maintained above the specified level. RPV values are actual levels, not indicated levels. Therefore, they may need level compensation depending on conditions. Escalation of the emergency classification level would be via IC RG1 or FG1. December 2018 NMP 2-78 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS ~as_ls_ ~~fer~nce(s)_:__ _ __ _
- 1. N1-EOP-3 Failure to Scram
- 2. NER-1 M-095 NMP1 EOP/SAP Basis Document
- 3. N1-EOP-7 RPV Flooding
- 4. N1-EOP-4 Primary Containment Control
- 5. N1-EOP-3.1 Alternate Rod Insertion
- 6. NEI 99-01 Rev 6, SS5 December 2018 NMP 2-79 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 Automatic or manual scram fails to shutdown the reactor, and subsequent manual actions taken at the Reactor Control Console are not successful in shutting down the reactor. ,O~e_ra_ti~g _IY!gfi~~pplj~~~i_l_i_ty_:_ __ _ ____ ___ __ _ __ _ _ 1
- l;m~!'9e.!l~Y Acti_o11 __L~~~! (l;~_b):
Note:
- A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.
- 1. Automatic or manual scram did not shutdown the reactor as indicated by Reactor Power> 6%. '
AND
- 2. Manual / ARI actions taken at the Reactor Control Console are not successful in shutting down the reactor as indicated by Reactor Power> 6%.
- Basis:
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, and subsequent operator manual actions taken at the Reactor Control Console to shutdown the reactor are also unsuccessful. This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the Reactor Control Console since this event entails a significant failure of the RPS. A manual action at the Reactor Control Console is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor scram. This action does not include manually driving in control rods or implementation of boron injection strategies. If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the Reactor Control Console (e.g., locally opening breakers). Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the Reactor Control Console". Taking the Reactor Mode Switch to Shutdown is considered to be a manual scram action. December 2018 NMP 2-80 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS __ _IVlf\3_ (c~r:-J)_
- ~a~Js~(~qritf :---~--~-- -~------~-:-:-_- - _-- __- :_-_- _-
The plant response to the failure of an automatic or manual reactor scram will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged enough to cause a challenge to the RPV water level or RCS heat removal safety functions, the emergency classification level will escalate to a Site Area Emergency via IC MS3. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC MS3 or FS1, an Alert declaration is appropriate for this event. It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL are included to ensure a timely emergency declaration.
- ~~sls~R~t~re~c~(~):~- _ -:_- ___ -: -_: _ --__ -----~=-:-~-~--~: - --------- ~--:~---:-:_
- 1. Technjcal Specifications Table 3.6.2.a
- 2. N1-EOP-2 RPV Control
- 3. N1-EOP-3 Failure to Scram
- 4. N1-EOP-3.1 Alternate Rod Insertion
- 5. NEI 99-01 Rev 6, SAS December 2018 NMP 2-81 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3
- Initiating Condition: ______ _ - --- - - ---- ------
Automatic or manual scram fails to shutdown the reactor.
- qp_tlr~_ttl}g_MQd~_Applic;_~Qi!j~: __ __________________________________________________________ _
1
- Emergency Action Level (EAL): ______________________________________ _________ - ________
Note:
- A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies. *
- 1. a. Automatic scram did not shutdown the reactor as indicated by Reactor Power> 6%.
AND
- b. Subsequent manual/ ARI action taken at the Reactor Control Console is successful in shutting down the reactor as indicated by Reactor Power~ 6%.
OR
- 2. a. Manual scram did not shutdown the reactor as indicated by Reactor Power> 6%.
AND
- b. EITHER of the following:
- 1. Subsequent manual / ARI action taken at the Reactor Control Console is
-successful in shutting down the reactor as indicated by Reactor Power~ 6%.
OR
- 2. Subsequent automatic scram / ARI is successful in shutting down. the reactor as indicated by Reactor Power~ 6%.
- Basis
- ___ ____ ____ ___ __ _ _ _________________ ___ _ _______ ____ _________ __ ____ __ __ ____________________________ --.. ---
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, and either a subsequent operator manual action taken at the Reactor Control Console or an automatic scram is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant. EAL #1 Basis Following the failure on an automatic* reactor scram, operators will promptly initiate manual actions at the Reactor Control Console to shutdown the reactor (e.g., initiate a manual reactor scram). If these manual actions are successful in shutting down the
- reactor, December 2018 I
NMP 2-82 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS
~U3- (cont)
Basjs_ (cont): core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems. EAL#2 Basis If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the Reactor Control Console to shutdown the reactor (e.g., initiate a manual reactor scram / ARI using a different switch). Depending upon several factors, the initial or subsequent effort to manually scram the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor scram signal. If a subsequent manual or automatic scram / ARI is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems. A manual action at the Reactor Control Console is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor scram). This action does not include manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the Reactor Control Console". Taking the Reactor Mode Switch to Shutdown is considered to be a manual scram action. The plant response to the failure of an automatic or manual reactor scram will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the Reactor Control Console are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC MA3. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC MA3 or FA1, an Unusual Event declaration is appropriate for this event. Should a reactor scram signal be generated as a result of plant work (e.g., RPS setpoint testing), the following classification guidance should be applied.
- If the signal generated as a result of plant work causes a plant transient that creates a real condition that should have included an automatic reactor scram and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.
- If the signal generated as a result of plant work does not cause a plant transient but should have generated an RPS scram signal and the scram failure is determined through other means (e.g., assessment of test results), then this IC and the EALs are not applicable and no classification is warranted.
December 2018 NMP 2-83 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont) ~B~sj~ Refere_~c~(~)~_ _ _ ___ _ __
- 1. Technical Specifications Table 3.6.2.a
- 2. N1-EOP-2 RPV Control
- 3. N1-EOP-3 Failure to Scram
- 4. N1-EOP-3.1 Alternate Rod Insertion
- 5. NEI 99-01 Rev 6, SU5 December 2018 NMP 2-84 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA4 UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.
- ai:,jfr~})n_g--Ni-o<!~~i>i>ii_c~~i1)1y_:: -_- -_:*_: -~
- 1, 2
_Eniergen_~y A_cJi9_1} L~y_~I (E_A~)_; _ __ __ Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. UNPLANNED event results in the inability to monitor ANY Table M1 parameter from within the Control Room for~ 15 minutes.
Table M1 Control Room Parameters
- Reactor Power
- RPV Water Level
- RPV Pressure
- Primary Containment Pressure
- Torus Water Level
- Torus Water Temperature AND
- 2. ANY Table M2 transient in progress.
Table M2 Significant Transients
- Turbine runback > 25% thermal reactor power
- Electrical Load Rejection >35% full electrical load
- Reactor scram
- ADS or Core Spray actuation
- Thermal power oscillations > 10%
December 2018 NMP 2-85 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA4 (cont)
- ~-~j!~::~-~--- - ~- ---~- - ---~-*:::~:~ ----~- *_:*:***** :*~--~-:*.~- .. :**-~---* ::-~- **-*** *--~----*--*~ _-*--** -***.
UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fission product barrier challenge is reduced. It thus represents a potential substantial degradation in the level of safety of the plant. As used in this EAL, an "inability to monitor means that values for any of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, computer point, digital and recorder source within the Control Room. An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making. This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, RPV water level and RCS heat removal. The loss of the ability to determine any of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for any of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for RPV water level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication. Escalation of the emergency classification level would be via ICs FS1 or IC RS1. Basis Refer~nce(si: _ --- -- - --- - *-
- 1. NEI 99-01 Rev 6, SA2 December 2018 NMP 2-86 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4 l!liti~tlrig _qqnditi_on: UNPLANNED loss of Control Room indications for 15 minutes or longer. Op~r~_ting nllode_A~plic_ability: __ 1, 2 .Emerg_en~y Actio11 Level (EA~): Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
UNPLANNED event results in the inability to monitor ANY Table M1 parameter from within the Control Room for~ 15 minutes. Table M1 Control Room Parameters
- Reactor Power
- RPV Water Level
- RPV Pressure
- Drywell Pressure
- Torus Water Level
- Torus Water Temperature
.Basis: UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. This condition is a precursor to a more significant event and represents a potential degradation in the level of safety of the plant. As used in this EAL, an "inability to monitor means that values for any of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room. December 2018 NMP 2-87 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4 (cont) An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making. This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine any of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for any of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication. Escalation of the emergency classification level would be via IC MA4. ~~~ij1~:~itei~-"~-~i~I=-~-----------~----~~-: -~-~---_:_~--:_ ---~- ~-:-- -------------------~ --~~----__ -*_:---__
- 1. NEI 99-01 Rev 6, SU2 December 2018 NMP 2-88 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MAS Hazardous event affecting a SAFETY SYSTEM required for the current operating mode. LOR~ra~J~g_nil_q~e-App]i~a~ll!w; ______ ~-=:*_ ---- -____________ --~- -- -~ -- --~ --=------- ---= :___ : 1, 2 J~me~g~ij~y Ac:ti9r:a Lev_~f(~A_b):=_--: _:__ ~-: -~-- ~- - ~ _- ~- --- ---- Note:
- This EAL is only applicable to SAFETY SYSTEMs having two (2) or more trains.
- If the affected SAFETY SYSTEM train was already inoperable before the hazardous event occurred, then this emergency classification is not warranted.
- If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.
- If a hazardous event occurs and it is determined that the conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.
- 1. a. The occurrence of ANY of the following hazardous events:
- Seismic event (earthquake)
- Internal or external flooding event
- High winds or tornado strike
- FIRE
- EXPLOSION
- Other events with similar hazard characteristics as determined by the Shift Manager AND
- b. Event damage has caused indications of degraded performance to one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.
AND
- c. EITHER of the following:
- Event damage has caused indications of degraded performance to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.
OR
- Event damage has resulted in VISIBLE DAMAGE to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.
December 2018 NMP 2-89 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MAS (cont) .Basis: . _ _ ____ ____ -*--- _ __ _ _____ _ 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. EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events may require a post-event inspection to determine if the attributes of an explosion are present. SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. VISIBLE DAMAGE: Damage to a SAFETY SYSTEM train that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected SAFETY SYSTEM train. This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. In order to provide the appropriate context for consideration of an Alert classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues. Note that this second SAFETY SYSTEM train is from the same SAFETY SYSTEM that has degraded performance for criteria 1.b of this EAL; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events. Indications of degraded performance address damage to a SAFETY SYSTEM train that is in operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train. Operators will make a determination of VISIBLE DAMAGE based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage. This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train. December 2018 NMP 2-90 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MAS (cont) .Basi~ (co11t)~ __ . Escalation of the emergency classification level would be via IC FS1 or RS1. If a hazardous event occurs and the EAL conditions of MAS are not met then assess the event via HU3, HU4, or HU6. ._~asi~ ~efer~ri~e(~); __
- 1. NEI 99-01, Rev 6 SA9 December 2018 NMP 2-91 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MUS RCS leakage for 15 minutes or longer.
- ciperating Nle>cJ~-Applfcabi-lity:_- _
1, 2 l:me_rge11~~ -~-~tj91J_ LC!J~! (EA_b):_ . Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. RCS unidentified or pressure boundary leakage in the Drywell > 10 gpm for
~ 15 minutes.
OR
- 2. RCS identified leakage in the Drywell > 25 gpm for~ 15 minutes.
OR
- 3. Leakage from the RCS to a location outside the Primary Containment > 25 gpm for
> 15 minutes.
Basis: UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally. This IC addresses RCS leakage which may be a precursor to a more significant event. In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant. EAL #1 and EAL #2 Basis These EALs are focused on a loss of mass from the RCS due to "unidentified leakage",
"pressure boundary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications).
EAL #3 Basis This EAL addresses a RCS mass loss caused by an UNISOLABLE leak through an interfacing system. These EALs thus apply to leakage into the containment, a secondary-side system or a location outside of containment. The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications. Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation). EAL #1 uses a lower value that reflects the* greater significance of unidentified or pressure boundary leakage. December 2018 NMP 2-92 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS
-------- --- - ---- -- - ---- - ------ -- ----- ---- ------ -- -M!J_& (~~~~}
~~s_ls (co_nt)_: ________ _ The release of mass from the RCS due to the as-designed/expected operation of any relief valve does not warrant an emergency classification. A stuck-open Electromatic Relief Valve (ERV) or ERV leakage is not considered either identified or unidentified leakage by Technical Specification and, therefore, is not applicable to this EAL. The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible. Escalation of the emergency classification level would be via ICs of Recognition Category R or F.
- easis_Reference(s); _ __ __ ____ __ __ ______ _____ __ _ ___________ ____________________ _
- 1. N1-ARP-H2 Annunciator H2-1-1 DRYWELL FLOOR DRAIN LEVEL-HIGH
- 2. N1-ARP-H2 Annunciator H2-4-7 DRYWELL WATER LEAK DETECTION SYS
- 3. ER-AB-331-1006, BWR Reactor Coolant System Leakage Monitoring and Action Plan 4 N1-0P-8, Primary Containment Area Cooling System
- 5. NEI 99-01 Rev 6, SU4 December 2018 NMP 2-93 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU7 Jnjti~!iJ1g Gond_itj_Qn; ______ _ Loss of all onsite or offsite communication capabilities . .QJ:i~-rat1i,g nnc;iij_~ AP_P_lic~~iity:*_- __ ~ - _-- - ___ - :_~:-_ -:_-_: 1, 2 ,E;l!l~rn~ncy _~_~tj_cmJ~_e~~l_(l;AI:-.): ________ _
- Loss of all Table M3 onsite communication capabilities affecting the ability to perform routine operations.
OR
- Loss of all Table M3 offsite communication capabilities affecting the ability to perform offsite notifications.
OR
- Loss of all Table M3 NRC communication capabilities affecting the ability to perform NRC notifications.
Table M3 Communication Capabilities System Onsite Offsite NRC Gaitronics X Hand Held Portable Radio (Station Radio) X PBX (Conventional Telephone lines) X X X I . Control Room installed satellite phone (non portable) X X ENS X X RECS X This IC addresses a significant loss of onsite, offsite, or NRC communication capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC. This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of onsite information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.). December 2018 NMP 2-94 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS _______ J_Vll)_! _(~o~!_)
- Basjs (c~
- m~):_
EAL #1 Basis Addresses a total loss of the communication methods used in support of routine plant operations. EAL #2 Basis Addresses a total loss of the communications methods used to notify all Offsite Response Organizations (OROs) of an emergency declaration. The Offsite Response Organizations (OROs) referred to here are listed in procedure EP-CE-114-100-F-05, Part 1 Notification Fact Sheet. EAL #3 Basis Addresses a total loss of the communication methods used to notify the NRG of an emergency declaration. B~S!S R~fei~f.lC_e(s): - - -- - --- ----~ - -_. ---
- 1. UFSAR Section 1OA, 2.4.5 Lighting and Communication
- 2. EP-CE-114-100-F-05, Part 1 Notification Fact Sheet
- 3. NEI 99-01 Rev 6, SU6 December 2018 NMP 2-95 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA1 l!l~ti!!ti.!19 Gontjitiq_r:a: ___ _ _ __ ___ _ Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.
- Qi>Eir~ttng__Nf~d~Ai>Pl_i~a~nity:_ -~:-~-------~ _: ___- _______ -:--~-- -- __ -:__ -- ___ ---~-- _: ~ _- _
3, 4, D
-- ------ -- --- -----*--~------- --- ------.- -
- l;m~rg_~n_c:;y A~ti~!'.I ~E!'(,1 (E~~)_:_ ______ _
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. Loss of all offsite and onsite AC power to 4.16 kV Emergency Buses.
AND
- 2. Failure to restore power to at least one 4.16 kV Emergency Bus from the time of loss of both offsite and onsite AC power in < 15 minutes.
- easis:
SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore an emergency bus to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Escalation of the emergency classification level would be via IC CS6 or RS1. December 2018 NMP 2-96 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear .Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA1 (cont} -~~~ls ~e_f~r~l}c;:e(~}:__ ___ ___ _ ___ __ _ _____________ _
- 1. N1-0P-30 4.16 kV, 600V, and 480V House Service
- 2. UFSAR section IX Electrical Systems
- 3. NEI 99-01 Rev 6, CA2 December 2018 NMP 2-97 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU1 _1_n,ti~!irt_g__Go11~!li.~n_; . __ . __ ..... __ Loss of all but one AC power source to emergency buses for 15 minutes or longer. Qp~c1t.i_ng _MQ~e_ APPH~a~_ility_: _ 3, 4, D l;~ergency Actie>n ke~el (l;Akl; Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. AC power capability to 4.16 kV Emergency Buses reduced to only one of the following power sources for~ 15 minutes:
- T-101 N
- T-101 S
- DG-102 Emergency Diesel Generator
- DG-103 Emergency Diesel Generator AND
- 2. ANY additional single power source failure will result in a loss of all AC power to SAFETY SYSTEMS.
Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment. When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the increased time available to restore another power source to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant. December 2018 NMP 2-98 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN/ REFUELING SYSTEM MALFUNCTIONS
----- - - ----- -------- -- ------- -- -- - --- ------- --- --- - --- --- - ------------ _q_~_1 {~~~~)_
- 1niti_a~il}_g C_Qt1dith;,r,;_ _ _ __ _____ _ __ __ __ __ ___ ____ _ __ ____ ___________ _
An "AC power source" is a source recognized in SOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.
- A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).
- A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from the unit main generator.
- A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an offsite power source.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power. The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA 1.
- 1]3a~js _~~f~r~n<;!!(~); _ ___ __ _ __ ______ ___ ____ _ _ __ ____ _ _ ____ _
- 1. N1-0P-30 4.16 kV, 600V, and 480V House Service
- 2. UFSAR section IX Electrical Systems
- 3. NEI 99-01 Rev 6 CU2 December 2018 NMP 2-99 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 Hazardous event affecting SAFETY SYSTEM required for the current operating mode.
- Qp~rat,
- ng_M~~~}(~p_n~~-~Hity: --_ -- -- - - -- _~-- ____ ~--- __---~--~--- --~- -~ -- -- -- - -- - ---- - -
3,4 J;_m~rg~nc;y__A<;tiQn_ ~~ve_l (~A~): __ Note:
- This EAL is only applicable to SAFETY SYSTEMs having two (2) or more trains.
- If the affected SAFETY SYSTEM train was already inoperable before the hazardous event occurred, then this emergency classification is not warranted.
- If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.
- If a hazardous event occurs and it is determined that the conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.
- 1. a. The occurrence of ANY of the following hazardous events:
- Seismic event (earthquake)
- Internal or external flooding event
- High winds or tornado strike
- FIRE
- EXPLOSION
- Other events with similar hazard characteristics as determined by the Shift Manager AND
- b. Event.damage has caused indications of degraded performance to one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.
AND
- c. EITHER of the following:
- Event damage has caused indications of degraded performance to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.
OR
- Event damage has resulted in VISIBLE DAMAGE to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.
December 2018 NMP 2-100 EP-AA-1013 Addendum 3 (Rev 4)
- Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 (cont}
*Basis: ...... __ _. ______ .. __ __ ... ___ .. _ ____ __ ___ ......
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. EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered a.n explosion. Such events may require a post-event inspection to determine if the attributes of an explosion are present. SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. VISIBLE DAMAGE: Damage to a SAFETY SYSTEM train that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected SAFETY SYSTEM train. This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. In order to provide the appropriate context for consideration of an Alert classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues. Note that this second SAFETY SYSTEM train is from the same SAFETY SYSTEM that has degraded performance for criteria 1.b of this EAL; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events. Indications of degraded performance address damage to a SAFETY SYSTEM train that is in operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train. Operators will make a determination of VISIBLE DAMAGE based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage. This December 2018 NMP 2-101 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 (cont) Bc!_S!S_ (c;cmt); - - VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train. Escalation of the emergency classification level would be via IC CS6 or RS1. If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6. -~c1s_is_Ref~r~n~e(s):__ ___________
- 1. NEI 99-01 Rev 6, CA6 December 2018 NMP 2-102 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS I --*- ----*- * - -** - - - - - *--* --* ** *. - - * ----- CU3 .l~iti~Jjng_g()n~JJ~gn:__ Loss of Vital DC power for 15 minutes or longer. ,Qp~~~tf~g_Mog~-~pp_lJc~bJl_ity::___:
- __ __ _ ___ _
3,4 'Eirierge*ri-cy A~{iq~-~~yeJ(E~~}:- - Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
Voltage is < 106 VDC on required 125 VDC Battery Boards 11 and 12 for
~ 15 minutes.
,Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses a loss of Vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions increase the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant. As used in this EAL, "required" means the Vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment. For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train Bis in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Depending upon the event, escalation of the emergency classification level would be via IC CA6 or GAS, or an IC in Recognition Category R. iB~sis ~~fer~nc~(s)_:_
- 1. N1-0P-47A 125 voe Power System
- 2. UFSAR section IX Electrical Systems
- 3. NMP1 Technical Specification 3.6.3
- 4. NEI 99-01 Rev 6, CU4 December 2018 NMP 2-103 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4
*1niJi~ff~gC°qnd_ifi9~:::~------ ---~:~--:-: ___ : -_- ---------- - - - - -------- ---- --- --__:-__:_ --:-:--_-:~
Loss of all onsite or offsite communication capabilities. /
- t~p~ratf~g_ivlq~e:A~~ti~ap}1(ti~:_-_-_ -_- - -- ___ -::_::-___:_
3, 4, D
!=IJl_ergency Act_io11 ~eyel(I;~_~)_: _ _ __ ___ __ ___ __ __ __ _ ____ _ _ _ ________ _
- 1. Loss of all Table C1 onsite communication capabilities affecting the ability to perform routine operations.
OR
- 2. Loss of all Table C1 offsite communication capabilities affecting the ability to perform offsite notifications.
OR
- 3. Loss of all Table C1 NRC communication capabilities affecting the ability to perform NRC notifications.
Table C1 Communication Capabilities System Onsite Offsite NRC Gaitronics X Hand Held Portable Radio (Station Radio) X PBX (Conventional Telephone lines) X X X Control Room installed satellite phone (non portable) X X ENS X X RECS X Basis: This IC addresses a significant loss of onsite, offsite, or NRC communication capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC. This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of onsite information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.). EAL#1 Basis Addresses a total loss of th_e communication methods used in support of routine plant operations. December 2018 NMP 2-104 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4 (cont)
~!l~!S (~qn_t):_ _ __
EAL#2 Basis Addresses a total loss of the communication methods used to notify all Offsite Response Organizations (OROs) of an emergency declaration. The Offsite Response Organizations (OROs) referred to here are listed in procedure EP-CE-114-100-F-05, Part 1 Notification Fact Sheet. EAL #3 Basis Addresses a total loss of the communication methods used to notify the NRC of an emergency declaration.
- 13asis R~t~r~_nc~(sj:~--
- 1. UFSAR Section 1OA, 2.4.5 Lighting and Communication
- 2. EP-CE-114-100-F-05, Part 1 Notification Fact Sheet
- 3. NEI 99-01 Rev 6, CU5 December 2018 NMP 2-105 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CAS 'l~J!i~ti_l}g C_onditjQn: _ ___ Inability to maintain the plant in cold shutdown.
- op_~r~tl-~g_ ~-o~e_APRil~~-~-ilify_:* - _-- -- - -- . --- -. -- - -
3,4 ~l;_mern~11cy A_ct_i.9n l:,.e'(~_I (!;A~)_: __ Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification.
- 1. UNPLANNED rise in RCS temperature to> 212°F for> Table C2 duration.
Table C2 RCS Heat-up Duration Thresholds RCS Containment Closure Heat-up Status Status Duration Intact Not Applicable 60 minutes* Established 20 minutes* Not Intact Not Established 0 minutes
- If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not applicable.
OR
- 2. UNPLANNED RPV pressure rise> 10 psig as a result of temperature rise.
UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs, etc.). December 2018 NMP 2-106 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 {cont) _Ba~i!:5_ (~0!"!t).: ____ _ This IC addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant. A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification. , The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact. The 20-minute criterion was included to allow time for operator action to address the temperature rise. The RCS Heat-up Duration Thresholds table also addresses a- rise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature rise without a substantial degradation in plant safety. Finally, in the case where there is a rise in RCS temperature, the RCS is not intact, and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) the evaporated reactor coolant may be released directly into the Containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel. EAL #2 provides a pressure-based indication of RCS heat-up. Escalation of the emergency classification level would be via IC CS6 or RS1. Basi~ __R~fer~!"IC~(!lt): ___ _
- 1. NMP1 Technical Specifications Definitions 1.1
- 2. N1-0P-43C Plant Shutdown
- 3. N1-0P-4 Shutdown Cooling System
- 4. OU-NM-103-101 Shutdown Safety Management Program
- 5. NMP1 Technical Specifications Definitions 1.11 and 1.12
- 6. NEI 99-01 Rev 6, CA3 December 2018 NMP 2-107 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS cus Tnlti_ating--co~di~iori: -_ -_ _ UNPLANNED rise in RCS temperature '.Qpe_rati_r1g_M~~e ~pplicabiHty: . __ _ 3,.4 l;me_rgen_cy Action _Level_ (EAL)_: _ Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification.
- 1. UNPLANNED rise in RCS temperature to> 212°F.
OR
- 2. Loss of the following for~ 15 minutes:
- ALL RCS temperature indications AND
- ALL RPV water level indications Basis:
UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. This IC addresses an UNPLANNED rise in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level, represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to IC CAS. RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs, etc.). A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification. December 2018 NMP 2-108 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU5 (cont) ,~a~j~ (c;:Qnt): _. EAL #1 Basis This involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications. During this condition, there is no immediate threat <;>f fuel damage because the core decay heat load has been reduced since the cessation of power operation. During an outage, the level in the reactor vessel will normally be maintained above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at reduced inventory may result in a rapid rise in reactor coolant temperature depending on the time after shutdown. EAL#2 Basis This reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication. Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA5 based on exceeding plant configuration-specific time criteria. '-~~~rs-~ef~re~ci(~):_. _:~_: ---~--~-_::_--:~--:_--- - --.-
- 1. NMP1 Technical Specifications Definitions 1.1
- 2. N1-0P-43C Plant Shutdown
- 3. N1-0P-4 Shutdown Cooling System
- 4. NEI 99-01 Rev 6, CU3 December 2018 NMP 2-109 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 )rii#~tfog-q9~int1_i>-n=- _:
- _-_-:- ~--- __ ::-:____ ----~-~: ~- :-~~~ - -_ -_: ~--*-_: -- -~- -~-: _-_ ~- -~---:- *-
Loss of RPV inventory affecting fuel clad integrity with containment challenged. 91?~-r~ti~g_M_o<<:I~ APP_lic_c1~iHty: _ __ _ 3,4
- 1fm~rg~-~-~YA~ttori_ ~iveJ(!;ALf --
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. a. RPV water level < - 84 inches for::. 30 minutes.
AND
- b. ANY Table C4 Containment Challenge Indication.
OR
- 2. a. RPV water level cannot be monitored for::. 30 minutes.
AND
- b. Core uncovery is indicated by ANY of the following:
- Table C3 indication of a sufficient magnitude to indicate core uncovery.
OR
- Refuel Bridge High Range Radiation Monitor reading ::. 3 R/hr.
AND
- c. ANY Table C4 Containment Challenge Indication.
Table C3 Indications of RCS Leakage
- UNPLANNED Drywell equipment drain tank level rise*
- UNPLANNED Drywell floor drain tank level rise*
- UNPLANNED Reactor Building equipment sump level rise*
- UNPLANNED Reactor Building floor drain sump level rise*
- UNPLANNED Torus water level rise*
- UNPLANNED RPV make up rate rise*
- Observation of leakage or inventory loss
*Rise in level is attributed to a loss of RPV inventory.
December 2018 NMP 2-110 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont) Emerg~n~y Acticm Level (E:A~) (cc;mt): Table C4 Containment Challenge Indications
- Primary Containment Hydrogen Concentration ~ 6% and Oxygen Concentration ~ 5%
- UNPLANNED rise in containment pressure
- CONTAINMENT CLOSURE not established*
- Reactor Building area radiation > 8 R/hr .
- If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.
Basis: UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions. CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary for BWR) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA Protective Action Guidelines (PAG) exposure levels offsite for more than the immediate site area. Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable. With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required. December 2018 NMP2-111 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS
---- ---- ----- -------- - ---- --- ---- --- ----- --- --- ---- ---- ------ ---- - - - - g9~J~~-n~)
- ~~~is_ (~qnt)_:_ __ ___ _ _______ _
UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity. In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged. EAL #1 Basis The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring. EAL#2 Basis The inability to monitor RPV water level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or Torus levels. Sump and/or Torus level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV. These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management. December 2018 NMP 2-112 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex
- Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS
. *****-** __ --- .. _____ -- --- -- -*-- ......... --*--*****--- .. __ . . _ ~-<;;~ (~01)~)_
~~~-i~.R~f~ren_~~(s):__ . ____________ . _ ___
- 1. N1-EOP-2 RPV Control
- 2. NER-1 M-095, NMP1 Emergency Operating Procedures (EOP) Basis Document
- 3. OU-NM-103-101 Shutdown Safety Management Program
- 4. NMP1 Technical Specifications Definitions 1.11 and 1.12
- 5. N1-EOP-5 Secondary Containment Control
- 6. UFSAR 1.4 Primary Coolant Leakage
- 7. Annunciator H2-1-1 DRYWELL FLOOR DRAIN LEVEL-HIGH
- 8. Annunciator H2-4-7 DRYWELL WATER LEAK DETECTION SYS
- 9. Annunciator H2-2-1 R BLDG FL DR SUMPS 11-16 AREA WTR LVL LEVEL HIGH
- 10. Annunciator H2-2-2 R BUILDING EQUIP DRAIN LEVEL-HIGH
- 11. N1-0P-38A Source Range Monitor
- 12. N1-0P-50A ARM System
- 13. NEI 99-01 Rev 6, CG1 December 2018 NMP2-113 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 lr:!id~tiri_g_ G_o_n_dj~iort: __ _ Loss of RPV inventory affecting core decay heat removal capability. Op~rati11g IVl~c:le Applic;:_~bility: 3,4 E~ergency A~tion ~ev~I {E.A.q:* _ Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. With CONTAINMENT CLOSURE not established, RPV water level< -10 inches.
OR
- 2. With CONTAINMENT CLOSURE established, RPV water level< -84 inches.
OR
- 3. a. RPV water level cannot be monitored for~ 30 minutes AND
- b. Core uncovery is indicated by ANY of the following:
- Table C3 indication of a sufficient magnitude to indicate core uncovery.
OR
- Refuel Bridge High Range Radiation Monitor reading ~ 3 R/hr.
Table C3 Indications of RCS Leakage
- UNPLANNED Drywell equipment drain tank level rise*
- UNPLANNED Drywell floor drain tank level rise*
- UNPLANNED Reactor Building equipment sump level rise*
- UNPLANNED Reactor Building floor drain sump level rise*
- UNPLANNED Torus water level rise*
I
- UNPLANNED RPV make up rate rise*
- Observation of leakage or inventory loss
*Rise in level is attributed to a loss of RPV inventory.
December 2018 NMP 2-114 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 (cont) Basis: UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary for BWR) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of
- plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.
Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable. Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions. The difference in the specified RCS/reactor vessel levels of EALs #1 and #2 reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment. EAL #3 Basis the 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring. The inability to monitor RPV water level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or Torus levels. Sump and/or Torus level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV. These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management. Escalation of the emergency classification level would be via IC CG6 or RG1. December 2018 NMP 2-115 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 (cont)
- ~a~ii RetEfr~_nce(~);: ---~ _- --
- 1. N1-EOP-2 RPV Control
- 2. NER-1 M-095, NMP1 Emergency Operating Procedures (EOP) Basis Document
- 3. OU-NM-103-101 Shutdown Safety Management Program
- 4. NMP1 Technical Specifications Definitions 1.11 and 1.12
- 5. UFSAR 1.4 Primary Coolant Leakage
- 6. Annunciator H2-1-1 DRYWELL FLOOR DRAIN LEVEL-HIGH
- 7. Annunciator H2-4-7 DRYWELL WATER LEAK DETECTION SYS
- 8. Annunciator H2-2-1 R BLDG FL DR SUMPS 11-16 AREA WTR LVL LEVEL HIGH
- 9. Annunciator H2-2-2 R BUILDING EQUIP DRAIN LEVEL-HIGH
- 10. N1-0P-38A Source Range Monitor
- 11. NEI 99-01 Rev 6, CS1 December 2018 NMP 2-116 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA6 J_~i~ia~i-~g <;on_c!iijcm_;___ __ _ Loss of RPV inventory . .Q~e~~tjng_ lYl9_<!e ~pp!ic~~jljty_: ___ _ 3,4
- Esri~~g~11cy Actiqn ~eye] _(EAb):___ __ _
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. Loss of RPV inventory as indicated by level < + 5 inches.
OR
- 2. a. RPV water level cannot be monitored for~ 15 minutes.
AND
- b. Loss of RPV inventory per Table C3 indication.
Table C3 Indications of RCS Leakage
- UNPLANNED Drywell equipment drain tank level rise*
- UNPLANNED Drywell floor drain tank level rise*
- UNPLANNED Reactor Building equipment sump level rise*
- UNPLANNED Reactor Building floor drain sump level rise*
- UNPLANNED Torus water level rise*
- UNPLANNED RPV make up rate rise*
- Observation of leakage or inventory loss
*Rise in level is attributed to a loss of RPV inventory.
- Basis:
UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety. December 2018 NMP 2-117 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA6 (cont)
~~si~J<;Qntj:_ -
EAL#1 Basis A lowering of water level below +5 inches indicates that operator actions have not been successful in restoring and maintaining RPV water level. The heat-up rate of the coolant will rise as the available water inventory is reduced. A continuing drop in water level will lead to core uncovery. Although related, EAL #1 is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). A rise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA5. EAL#2 Basis The inability to monitor RPV water level may be caused by instrumentation and/or power failures, or water level dropping below- the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or Torus levels. Sump and/or Torus level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV. The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS6 If the RPV water level continues to lower, then escalation to Site Area Emergency would be via IC CS6.
- Bc!~!s_ ~~feren_c;e(~)_:_ __ __ _ _ ________ _
- 1. N1-EOP-2 RPV Control
- 2. NER-1 M-095, NMP1 Emergency Operating Procedures (EOP) Basis Document
- 3. OU-NM-103-101 Shutdown Safety Management Program
- 4. NMP1 Technical Specifications Definitions 1.11 and 1.12
- 5. UFSAR 1.4 Primary Coolant Leakage
- 6. Annunciator H2-1-1 DRYWELL FLOOR DRAIN LEVEL-HIGH
- 7. Annunciator H2-4-7 DRYWELL WATER LEAK DETECTION SYS
- 8. Annunciator H2-2-1 R BLDG FL DR SUMPS 11-16 AREA WTR LVL LEVEL HIGH
- 9. Annunciator H2-2-2 R BUILDING EQUIP DRAIN LE;VEL-HIGH
- 10. N1-0P-38A Source Range Monitor
- 11. NEI 99-01 Rev 6, CA1 December 2018 NMP 2-118 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6
- i1J-iti~tl~g:G:ciridi_ti9ra{-_ --:*:_::- _-_ : ~--~-- --- ~ -~:-_-- ___- ~ --- : _ -~-- _---~ :-~- -
UNPLANNED loss of RPV inventory for 15 minutes or longer. 9p~r~~jng_Mo~e_Applica~il_ity_:_ ___ _ 3,4 _Ernerg~11~y _ActioQ L~v_el__ (E;~~);__ _ ___ _ _ __ Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. UNPLANNED loss of reactor coolant results in the inability to restore and maintain RPV water level to above the procedurally established lower limit for~ 15 minutes.
OR
- 2. a. RPV water level cannot be monitored AND *
- b. Loss of RPV inventory per Table C3 indication.
Table C3 Indications of RCS Leakage
- UNPLANNED Drywell equipment drain tank level rise*
- UNPLANNED Drywell floor drain tank level rise*
- UNPLANNED Reactor Building equipment sump level rise*
- UNPLANNED Reactor Building floor drain sump level rise*
- UNPLANNED Torus water level rise*
- UNPLANNED RPV make up rate rise*
- Observation of leakage or inventory loss
*Rise in level is attributed to a loss of RPV inventory .
.Basis: UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RPV water level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant. December 2018 NMP 2-119 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 (cont) .~at!i~__ (C9'1t)_:_ _ _ __ The procedurally established lower limit is not an operational band established above the procedural limit to allow for operator action prior to exceeding the procedural limit, but it is the procedurally established lower limit. Refueling evolutions that lower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level decreasing below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered. EAL #1 Basis Recognizes that the minimum required RPV water level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document. The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level. EAL#2 Basis Addresses a condition where all means to determine RPV water level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or Torus levels. Sump and/or Torus level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV. Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA6 or CA5. J~i:1~1iJ{efef~n-~~(~j: -: __: _-__ - --- -- _ -- -- -- --- - ___ _-__:: ~- ---
- 1. NMP1 Technical Specification 3.6.2 Table 3.6.2.d
- 2. P&ID C-18015-C, Reactor Vessel Instrumentation
- 3. UFSAR 1.4 Primary Coolant Leakage
- 4. Annunciator H2-1-1 DRYWELL FLOOR DRAIN LEVEL-HIGH
- 5. Annunciator H2-4-7 DRYWELL WATER LEAK DETECTION SYS
- 6. Annunciator H2-2-1 R BLDG FL DR SUMPS 11-16 AREA WTR LVL LEVEL HIGH
- 7. Annunciator H2-2-2 R BUILDING EQUIP DRAIN LEVEL-HIGH
- 8. NEI 99-01, Rev. 6 CU1 December 2018 NMP 2-120 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 Jnid~ting Condlti_<>n: - - HOSTILE ACTION within the PROTECTED AREA.
- c;,perating_ Mode Applicabinty:
1,2,3,4, D Eme_rgency Action Lev~I (EAi:,.): __ _ A notification from the Security Supervisor that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA. Basis: HOSTILE ACTION: An act toward a Nuclear Power Plant (NPP) 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 Nuclear Power Plant (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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROJECTILE: An object directed toward a Nuclear Power Plant (NPP) that could cause concern for its continued operability, reliability, or personnel safety. PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence. HOSTILE FORCE: Any 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. 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. This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment. Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program]. December 2018 NMP 2-121 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY
------- ---- - -- - - -- --- --- --- -- - ----- ------ ------ --- ----- -- ----- --~~~ _{_CC?_rlJ}
):3~~J~_ (~~nj): - - - --- --- - - --- - --- ------ - As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Site Area Emergency declaration will mobilize Offsite Response Organization (ORO) resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.
- This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA; such an attack should be assessed using IC HA1. It also does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73. 71 or 10 CFR
§ 50.72.
Escalation of the emergency classification level would be via IC RG1, RG2 and HG?.
- ea~i-~_ ~e_fe_r~ri-~~(~)_;_ __ _ _ ___
- 1. NMP Site Security Plan
- 2. NEI 99-01 Rev 6, HS1 December 2018 NMP 2-122 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 .lni#~t~rig bon~Hion_:: . . . .. - . HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes. Op~rat.ing .M.ode ~pplicability:_ 1, 2, 3, 4, D l;m~rgency Acti~n L~_vel (EALJ:
- 1. A validated notification from NRC of an aircraft attack threat < 30 minutes from the site.
OR
- 2. Notification by the Security Supervisor that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA.
. Basis: HOSTILE ACTION: An act toward a Nuclear Power Plant (NPP) 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 Nuclear Power Plant (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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROJECTILE: An object directed toward a Nuclear Power Plant (NPP) that could cause concern for its continued operability, reliability, or personnel safety. OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons entering for official business. PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.
- HOSTILE FORCE: Any 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.
This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact. December 2018 NMP 2-123 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND _OTHER CONDITIONS AFFECTING PLANT SAFETY
. - - **- ti~~- .<~~~_t)_
Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program]. As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions. This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are . not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73. 71 or 10 CFR § 50. 72. EAL#1 Basis Addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and Offsite Response Organizations (OROs) are in a heightened state of readiness. This EAL is met when* the threat-related information has been validated in accordance with OP-NM-106-104, , Security Contingency Event. EAL#2 Basis Applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRC. In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency. Escalation of the emergency classification level would be v~a IC HS1. December 2018 NMP 2-124 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY
-- _J-1_~1 {~Q~~}
.Ba~is_ ~eference_(~}:_ _ ___________
- 1. NMP Site Security Plan
- 2. NEI 99-01 Rev 6, HA1 December 2018 NMP 2-125 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU1 Jni~!~t~~g__g~ncliti~;m:_ . __ .. .. . _ _.. ___ _ . .. .. . . ____ _ Confirmed SECURITY CONDITION or threat.
- op~r~ti_ng_ M_e:>_de APPJic~bility:
1, 2, 3, 4, D
- !=rn_~rg_en_c~ Actl~n-~ev~L(l;A~):__ . -*-** _ . _ ___ ____ _ __ .. -*-** ..... _.. . . _
- 1. Notification of a credible security threat directed at the site as determined per SY-AA-101-132, Security Assessment and Response to Unusual Activities.
OR
- 2. A validated notification from the NRC providing information of an aircraft threat.
OR
- 3. Notification by the Security Supervisor of a SECURITY CONDITION that does not involve a HOSTILE ACTION.
- Bas_i~; ... _.
SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threaUcompromise to site security, threaUrisk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. HOSTILE ACTION: An act toward a Nuclear Power Plant (NPP) 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 Nuclear Power Plant (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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROJECTILE: An object directed toward a Nuclear Power Plant (NPP) that could cause concern for its continued operability, reliability, or personnel safety. This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1. December 2018 NMP 2-126 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY __ ____ ___ ___ ____ ___ _ ______ _ _ _ _______ ~~1_J_c~~!)
- ~~si~(cqnff ---~----- ---- ________ -- ----*
Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and Offsite Response Organizations (OROs). Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program]. EAL#1 Basis Addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with SY-AA-101-132. EAL #2 Basis Addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with OP-NM-106-104, Security Contingency Event. EAL#3 Basis References Security Supervisor because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR
§ 2.39 information.
Escalation of the emergency classification level would be via IC HA 1.
- _Be!~(~ _Refer~~~~-(~f _--_:---:_ :---~ _ __ __ _ -- - - - -- -~:~----- -_- _
- 1. NMP Site Security Plan
- 2. NEI 99-01 Rev 6, HU1 December 2018 NMP 2-127 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 Jniti~ti_ng_Condj_t_i<m:_ _ Inability to control a key safety function from outside the Control Room.
,Op_er_a~ing M~~~__Applicapilit~=-
1, 2, 3, 4, D E_rrierg~ncy Acticm Leve_l (EA~)~_ ___ Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per N1-S0P-21.2, Control Room Evacuation.
AND
- 2. Control of ANY Table H1 safety function is nm reestablished in< 15 minutes.
Table H1 Safety Functions
- Reactivity Control (ability to shut down the reactor and keep it shutdown)
- RPV Water Level (ability to cool the core)
- RCS Heat Removal (ability to maintain heat sink)
- Basis:
The time period to establish control of the plant starts when either: _a. Control of needed safety functions is no longer maintained in the Main Control Room OR
- b. The last Operator has left the Main Control Room.
This IC addresses an evacuation* of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plan control to alternate locations is a precursor to a challenge to any fission product barrier within a relatively short period of time. The determination of whether or not "control" is established at the remote safe shutdown location(s) is based on Emergency Director judgment. The Emergency Director is expected to make a reasonable, informed judgment within 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s). Escalation of the emergency classification level would be via IC FG1 or CG6. December 2018 NMP 2-128 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 (cont)
- ~a~_i~ -~~f~ren~~(~): __ _ ______ _
- 1. NEI 99-01, Rev 6 HS6
- 2. N1-S0P-21.2, Control Room Evacuation December 2018 NMP 2-129 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA2 ln_i~jc1~i_11g__ <;Qr;1_gitJQ_n_:_____ *- _ __ _ __ _ Control Room evacuation resulting in transfer of plant control to alternate locations. _9Q~r~t(rig_]ng~e)~ppifc~*bility\__ :-. -- - - --*- - 1, 2, 3, 4, D 1~-m~rg~nc;y_A~ti~n, l.-eye_l _(l;A~)_: ____ _ A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per N1-SOP-21.2, Control Room Evacuation. Basis: This IC _addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety. Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations. The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel. Activation of the ERO and emergency response facilities will assist in responding to these challenges. Escalation of the emergency classification level would be via IC HS2. ~c1~i-~-R.~ference(s);
- 1. NEI 99-01, Rev 6 HA6
- 2. N1-S0P-21.2, Control Room Evacuation December 2018 NMP 2-130 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 'Jni!iafi11g *¢.:9n~ttioJ1: -__ :_~ - -*_: -~-:*: ---- -- - ------- *-- * - -_~-~ :- _ -: _ --_ -~-- _:-_: ~- _: _-~ :*_-~- :_* ---- - FIRE potentially degrading the level of safety of the plant.
- oper~t,ng -~c;,_d~ Appli~a~i_lity:~- --- --- -
1, 2, 3, 4, D
- _~m~1i;i~~~iAcf~~~j" ~~~~U~A~):_
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- Escalation of the emergency classification level would be via IC CA2 or MAS.
- 1. A FIRE in ANY Table H2 area is not extinguished in< 15 minutes of ANY of the following FIRE detection indications:
- Report from the field (i.e., visual observation)
- Receipt of multiple (more than 1) fire alarms or indications
- Field verification of a single fire alarm Table H2 Areas
- Reactor Building (when inerted the Drywell is exempt)
- Control Room
- Screenhouse
- Turbine Building
- 11 and 12 Battery Rooms
- 11 and 12 Battery Board Rooms
- Cable Spreading Room
- 291' North
- Diesel Generator Engine and Board Rooms OR
- 2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of a FIRE).
AND
- b. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.
OR
- 3. A FIRE within the plant PROTECTED AREA not extinguished in< 60 minutes of the initial report, alarm or indication.
OR December 2018 NMP 2-131 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont) J;:1J1.E!_rg~11cy ~ction L.~yel (~A_L.)(~cmt): _ _________ _ 4 A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish. tBaS-1s*:-- -- ------ ----*- *-- -- ----- ---- -- - 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; PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence. 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. This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant. EAL#1 Basis The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc. Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration* clock also starts at the time of receipt of the initial alarms, indication or report. EAL #2 Basis This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed. A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress . December 2018 NMP 2-132 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont) ~Basis (cont):__ _ __ ___ _______ __ If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted. EAL #3 Basis In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety EAL #4 Basis If a FIRE within the plant PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish. Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions. ISFSI is not specifically addressed in EAL #3 and #4 since it is within the plant PROTECTED AREA and is therefore covered under EALs #3 and #4. Basis-Related Requirements from NFPA 805 NFPA 805 is a risk-informed performance-based standard for implementing fire protection at nuclear power plants. In accordance with the requirements and guidance in NFPA 805 Section 2.7.1 and NEI 04-02, NMPNS has documented analyses to support compliance with 10 CFR 50.48(c). 10 CFR 50.48(c) incorporates by reference, with exceptions, the National Fire Protection Association's NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants - 2001 Edition, as a voluntary alternative to 10 CFR 50.48 Section (b), Appendix R, and Section (f), Decommissioning. Criterion 3 of Appendix A to 10CFR50 specifies that "Structures, systems, and components important to safety shall be designed and located t.o minimize, consistent with other safety requirements, the probability and effect of fires and explosions." When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off. December 2018 NMP 2-133 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont) Ba!SJ!? _(co_n_t)_: Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MAS. 13a!5i~ R_efer~_nce(~):
- 1. UFSAR Section X
- 2. NEI 99-01, Rev 6 HU4 December 2018 NMP 2-134 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex
- Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4
- 1nitia~ing Con~iti_Qn: _
Seismic event greater than OBE levels. Op_e_r_ating l'Jlod_e APPl!~~bility: - 1, 2, 3, 4, D
- 1;111-ergency Acti~n Leyel (EAL):
Note:
- For emergency classification if EAL #2 is not able to be confirmed, then the occurrence of a seismic event is confirmed in a manner deemed appropriate by the Shift Manager or Emergency Director in~ 15 minutes of the event.
- Escalation of the emergency classification level would be via IC CA2 or MA5 Seismic event as indicated by:
- 1. Control Room personnel feel an actual or potential seismic event.
AND
- 2. ANY one of the following confirmed in ~ 15 minutes of the event:
- The earthquake resulted in Modified Mercalli Intensity (MMI) :=. VI and occurred
~ 3.5 miles of the plant.
- The earthquake was magnitude:=. 6.0
- The earthquake was magnitude:=. 5.0 and occurred ~ 125 miles from the plant.
- NMP-2 seismic instrumentation indicates > 0.075g
- If the above bullets are not able to be confirmed, then the occurrence of a seismic event is confirmed in a manner deemed appropriate by the Shift Manager or Emergency Director.
'Basis: This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (QBE) 1 . An earthquake greater than an QBE but less than a Safe Shutdown Earthquake (SSE) 2 should . have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event 1 An QBE is vibratory ground motion for which those features of a nuclear power plant necessary for continued operation without undue risk to the health and safety of the rublic will remain functional. An SSE is vibratory ground motion for which certain (generally, safety-related) structures, systems, and components must be designed to remain functional. December 2018 NMP 2-135 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 {cont) Ba~_i~ (c:q_nt):_____ _ condition of the plant (e.g., performs walk-downs and post-event inspections). Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety of the plant. Event verification with external sources should not be necessary during or following an QBE. Earthquakes of this magnitude should be readily felt by onsite personnel and recognized as a seismic event. The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration. EAL #2 Basis This is included to ensure that a declaration does not result from felt vibrations caused by a non-seismic source (e.g., a dropped load). The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., call to USGS, check internet source, etc.) however, the verification action must not preclude a timely emergency declaration. This guidance recognizes that it may cause the site to declare an Unusual Event while another site, similarly affected but with readily available QBE indications in the Control Room, may not. Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MAS. ~~~]!lS_~efer:e11c_~(!ii): ~ _
- 1. NMP2 UFSAR Section 3. 7A.1.1
- 2. N2-SOP-90 Natural Events
- 3. N1-SOP-28 Seismic Event
- 4. UFSAR Section 1.8.13 Characteristics - Structural Design
- 5. US NRC Reg. Guide 1.166. Pre-Earthquake Planning and Immediate Nuclear Power Plant Operator Earthquake Actions.
- 6. NEI 99-01, Rev 6 HU2 December 2018 NMP 2-136 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HAS 'lni_tia!i!lgJ~or:u;li1i~n:__ _ ___ _ _____ _ Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown . .9p~r~-t(rig Mci.c{e)~pp_1Ic~-~ffity: -~- --- -- -- _--~_-__-: ---~---:- ----- 2, 3, 4 J=~'!~9~r:ic~ ~_c;Ji~r:i__b~'l'!l _(E:~b): Note:
- If the equipment in the listed room or area was already inoperable, or not available, before the event occurred, then no emergency classification is warranted.
- 1. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area.
Table H3 Areas with Entry Related Mode Applicability Entry Related Mode Area Applicability Reactor Building 198' Northeast corner 261' North and Shutdown Cooling Room Modes 2, 3, and 4 281' North Turbine Building 291' North AND
- 2. Entry into the room or area is prohibited or impeded
- Basis:
This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedures. This condition represents an actual or potential substantial degradation of the level of safety of the plant. Assuming all plant equipment is operating as designed, normal operation is capable from the Main Control Room (MGR). The plant is also able to transition into a hot shutdown condition from the MGR, therefore Table H3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a 1 manual/local action necessary to transition the plant from normal plant operation to December 2018* NMP 2-137 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HAS (cont)
- -a~~*j}cont): _- -- -- -- -- -- - --- -- -- -
cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown. This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections). This Table does not include the Control Room since adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas. An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the gaseous release precludes the ability to place shutdown cooling in service. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release. Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed). An emergency declaration is not warranted if any of the following conditions apply.
- The plant is in an operating mode different than the mode specified for the affected room/area* (i.e., entry is not required during the operating mode in effect at the time of the gaseous release). For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.
- The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).
- The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
- The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.
An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by 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. December 2018 NMP 2-138 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HAS {cont) 1 B_c1si_~ (cont): This EAL does not apply to firefighting activities that generate smoke, that automatically or manually activate a fire suppression system in an area, or to intentional inerting of containment. Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.
- i;i~~!-5. Re_fer~11_c_~(~)~ ____ _
- 1. UFSAR Section X
- 2. NFPA 12 A Halon 1301 Fire Extinguishing Systems
- 3. NEI 99-01, R~v 6 HA5 December 2018 NMP 2-139 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 l_r"!~tj~ti[lg_go_'1_f:t_itJ~I'.!_;_ ______________________________________________________________ _ Hazardous Event
- operating_Mode AppJicability_;_ __ _ _ __ _______ __ ____________ __ ______ ___ _______ ___________________ _
1, 2, 3, 4, D i~_m~_r9~!1~~-A~ti_ol'.l_~~~~(~Ab);____________________: _________________________________ : Note:
- EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.
- Escalation of the emergency classification level would be via IC CA2 or MAS.
- 1. Tornado strike within the PROTECTED AREA.
OR
- 2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating mode.
OR
- 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).
OR
- 4. A hazardous event that results in onsite conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.
OR
- 5. Intake water level < 238.8 feet.
!Basis: *
- PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.
SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. December 2018 NMP 2-140 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HUS (cont) This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant. EAL #1 Basis Addresses a tornado striking (touching down) within the Protected Area. EAL #2 Basis Addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns. Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode. EAL#3 Basis Addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA. EAL#4 Basis Addresses a hazardous event that causes an onsite impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of such an event include site flooding caused by a hurricane, heavy rains, or high winds. This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011. EAL #5 Basis: The low intake level is based on intake forebay level and corresponds to the minimum intake water level for operability of Emergency Service Water, Emergency Diesel Generator cooling water, Containment Spray Raw Water and Diesel and Electric FIRE Pump. Escalation of the emergency classification level would be based on ICs in Recognition Categories R, F, M, Hor C. December 2018 NMP 2-141 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HUS (cont)
- ~-~its_*_~ef~i-~11-~e-(~)= --- -- _:_: *: -_-~:-: -~:-__ -~
- __
- _-*-*-
- 1. N1-0P-64 Meteorological Monitoring
- 2. Calculation SO-FLOOD-F001 Internal Flooding Hazard Analysis
- 3. UFSAR Section X Reactor Auxiliary and Emergency Systems
- 4. UFSAR Section 111-F Screenhouse, Intake and Discharge Tunnels
- 5. UFSAR Section X-F Service Water System
- 6. N1-ARP-H2 Annunciator H2-1-3
- 7. N1-SOP-18.1 Service Water Failure/Low Intake Level
- 8. S13.1-100F003
- 9. S14-93F003
- 10. S16.9NPSHAM002
- 11. Cale No. S14-93-F007
- 12. NEI 99-01, Rev 6 HU3 -
December 2018 NMP 2-142 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY.
- Op~rating _!\ll_e:>_d_~-~PPli~ct_~ili~; __ . _____ _
1, 2, 3, 4, D
- _E_r
- ne_rg_~nc;y A_c!i~~ J,..eye_l__(E_A_~): _ _ __________ . _
Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area. Basis: IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions. HOSTILE ACTION: An act toward a Nuclear Power Plant (NPP) 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 Nuclear Power Plant (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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a Nuclear Power Plant (NPP) that could cause concern for its continued operability, reliability, or personnel safety. This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a General Emergency . .Bas,~-Rete:r~nc-e(~):: ~ . *- - -- -- --*** . - . - --- -----
- 1. NEI 99-01, Rev 6 HG7 December 2018 NMP 2-143 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY. Op_~rati_ng M_q_g_e A~pl_ic~bility; __ 1, 2, 3, 4, D E_l"!_l~rg_~~c::y Ac;tion L~v~_l _(~A_~): Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equiprnent 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. '.i3asis: HOSTILE ACTION: An act toward a Nuclear Power Plant (NPP) 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 Nuclear Power Plant (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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a Nuclear Power Plant (NPP) that could cause concern for its continued operability, reliability, or personnel safety. This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a Site Area Emergency.
--- - - -- --- --~ --
Bas_is Re_ference(s): _
- 1. NEI 99-01, Rev 6 HS?
December 2018 NMP 2-144 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA7
- f~-itj_iij,-ng_¢_c;,ncfit_ior:-:*_~-~-=- -___ :~-~- _--_ : _-_-: ~-- -- --- -- - -_- :*- -~~-----~: -.-:_-__:~--- :~- __-_-~--~----_- *: _____ _
Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT. t<'-_P_~ranrig N1"<<;><!~:~~-pftcitifiJfyi-.-:* :** _- _________ _ 1, 2, 3, 4, D
- ~IT!~ig~i:J~y-A~tfo*~-}:;ey~.U'=A~l= ~ ~- ~ :*_*: *-_:: - -- ----_- -~~-=---~---:*_- ~~--::~_-:--~-~-.--~- __
Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels. HOSTILE ACTION: An act toward a Nuclear Power Plant (NPP) 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 Nuclear Power Plant (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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a Nuclear Power Plant (NPP) that could cause concern for its continued operability, reliability, or personnel safety. This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.
- ~~~!~ _R~fE!~nc;~(s)
- ____ _____ _
- 1. NEI 99-01, Rev 6 HA?
December 2018 NMP 2-145 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTl~G PLANT SAFETY HU7 1 lnjtiating Co11di_t!9!1_;___ ___ __ ____ __ __ _ _ __ ____ _ _ _ ___ __ _ _ ___________ _ Other conditions exist which in the judgment of the Emergency Director warrant declaration of an UNUSUAL EVENT. .
- 9pe_r~l1ng _Nfoj;fQ-Appti~~-~fli_fY.:_-~---_
1, 2, 3, 4, D
- 1:_JTJ_~rg_~_n~y ~c:t~~~-_h~yel_ (l;~_q_: __ ___ ________ _
Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs. Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an UNUSUAL EVENT. E3asi~_~efer~r:ace(~); ________________ _
- 1. NEI 99-01, Rev 6 HU7 December 2018 NMP 2-146 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ISFSI MALFUNCTIONS E-HU1 lnit_i_ating Ccmditio!'l _ Damage to a loaded cask CONFINEMENT BOUNDARY. 6perating-1Viog:e Applic~bility:: _-~ 1, 2, 3, 4, D
- Em_~rgel)~Y Action_Level (~A~);
Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading: For 61 BT DSC:
* > 800 mrem/hr 3 feet from the HSM surface OR
* > 200 mrem/hr outside the HSM door on centerline of DSC OR
* > 40 mrem/hr end of shield wall exterior For 61 BTH DSC:
* > 1400 mrem/hr on the HSM or HSM-H front surface OR
* > 200 mrem/hr on the HSM or HSM-H door centerline OR
* > 40 mrem/hr on the end shield wall exterior
.Basis:
CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment. 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. This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The word cask, as used in this EAL, refers to the storage container in use at the site for dry storage of irradiated fuel. The issues of concern are the creation of a potential or actual release path to the environment, degradation of any fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage. December 2018 NMP 2-147 EP-AA-1013 Addendum 3 (Rev 4)
Nine Mile Point Nuclear Station Unit 1 Annex Exelon Nuclear RECOGNITION CATEGORY ISFSI MALFUNCTIONS E-HU1 (cont) ,r The existence of "damage" is determined by radiological survey. The technical specification multiple of "2 times", which is also used in Recognition Category R IC RU1, is used here to distinguish between non-emergency and emergency conditions. The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the "on-contact" dose rate limit is exceeded may be determined based *on measurement of a dose rate at some distance from the cask. Security-related events for ISFSls are covered under ICs HU1 and HA1.
- ~~~t~--~_ejeren_c_~(~)~ ___ __ ___ __ . _ _____ _ ___ _____ __ _______ _ ____ ____ __ _ ___ ___ __ __ ___ ______ _
- 1. NEI 99-01, Rev 6 E-HU1.
- 2. ATTACHMENT A, TECHNICAL SPECIFICATIONS, TRANSNUCLEAR, INC.
STANDARDIZED NUHOMS HORIZONTAL MODULAR STORAGE SYSTEM, CERTIFICATE OF COMPLIANCE NO. 1004, AMENDMENT NO. 10, DOCKET 72-1004 December 2018 NMP 2-148 EP-AA-1013 Addendum 3 (Rev 4)
ATTACHMENT 3 Radiological Emergency Addendum Revision EP-AA-1013, Addendum 4, Revision 3, "Nine Mile Point Nuclear Station Unit 2 Emergency Classification Technical Bases"
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EP-AA-1013 Addendum 4 =?Exelon Generation Revision 3 Nine Mile Point Nuclear Station Unit 2 Emergency Classification Technical Bases
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear REVISION HISTORY Rev. 0 February 2015 Rev. 1 May 2017 Rev.2 July 2017 Rev. 3 December 2018 December 2018 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear Section 1: Classification of Emergencies 1.1 General Section D of the Exelon Nuclear Standardized Emergency Plan divides the types of emergencies into four EMERGENCY CLASSIFICATION LEVELS (ECLs). The first four are the UNUSUAL EVENT (UE), ALERT, SITE AREA EMERGENCY (SAE), and GENERAL EMERGENCY (GE). These ECLs are entered by satisfying the Initiating Condition (IC) through meeting an Emergency Action Level (EAL) of the IC provided in this section of the Annex. The ECLs are escalated from least severe to most severe according to relative threat to the health and safety of the public and emergency workers. Depending on the severity of an event, prior to returning to a standard daY:,-to-day organization, a state or phase called Recovery may be entered to provide dedicated resources and organization in support of restoration and communication activities following the termination of the emergency. Unusual Event (UE): 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. 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 exposure levels. Site Area Emergency (SAE): Events are in progress or have occurred which involve an 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. 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 Protective Action Guideline exposure levels offsite for more than the immediate site area. Recovery: Recovery can be considered as a phase of the emergency and is entered by meeting emergency termination criteria provided in EP-CE-111 Emergency Classification and Protective Action Recommendations. December 2018 NMP 1-1 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear Emergency Classification Level (ECL}: One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The Emergency Classification Levels, in ascending order of severity, are:
- UNUSUAL EVENT (UE)
- ALERT
- SITE AREA EMERGENCY (SAE)
- GENERAL EMERGENCY (GE)
Initiating Condition (IC): An event or condition that aligns with the definition of one of the four Emergency Classification Levels by virtue of the potential or actual effects or consequences. Emergency Action Level (EAL): A pre-determined, site-specific, observable threshold for an Initiating Condition that, when met or exceeded, places the plant in a given Emergency Classification Level. December 2018 NMP 1-2 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear An emergency is classified by assessing plant conditions and comparing abnormal conditions to ICs and EALs, based on the designated Operational Condition (MODE). Modes 1 through 5 are based on Reactor Mode Switch Position and average reactor coolant temperature. "Defueled" Mode was established for classification purposes under NEI 99-01 to reflect conditions where all fuel has been removed from the Reactor Pressure Vessel. OPERATING MODES REACTOR MODE SWITCH POSITION TEMP (1) Power Operation: Run N/A (2) Startup: Refuel (a) or Startup/Hot Standby N/A (3) Hot Shutdown (al: Shutdown > 200° F (4) Cold Shutdown (al: Shutdown s 200° F (5) Refueling (bl: Shutdown or Refuel N/A (D) Defueled: All reactor fuel removed from reactor pressure vessel (full core off load during refueling or extended outage). (a) All reactor vessel head closure bolts fully tensioned. (bl One or more reactor vessel head closure bolts less than fully tensioned. Hot Matrix - applies in modes (1 ), (2), and (3) Cold Matrix - applies in modes (4), (5), and (D) Individuals responsible for the classification of events will refer to the Initiating Condition and EALs on the matrix of the appropriate station Standardized Emergency Plan Annex (this document). This matrix will contain ICs, EALs, Mode Applicability Designators, appropriate EAL numbering system, and additional guidance necessary to classify events. It may be provided as a user aid. The matrix is set up in six Recognition Categories. The first is designated as "R" and relates to Abnormal Radiological Conditions/ Abnormal Radiological Effluent Releases. The second is designated as "F" and relates to Fission Product Barrier Degradation. The third is designated as "M" and relates to hot condition System Malfunctions. The fourth is designated as "C" and relates to Cold Shutdown / Refueling System Malfunctions. The fifth is designated as "H" and relates to Hazards and Other Conditions Affecting Plant Safety. The sixth is designated "E-H" and relates to ISFSI Malfunctions. The matrix is designed to provide an evaluation of the Initiating Conditions from the worst conditions (General Emergencies) on the left to the relatively less severe conditions on the right (Unusual Events). Evaluating conditions from left to right will reduce the possibility that an event will be under classified. All Recognition Categories should be reviewed for applicability prior to classification. December 2018 NMP 1-3 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear The Initiating Conditions are coded with a two letter and one number code. The first letter is the Recognition Category designator, the second letter is the classification Level, "U" for (NOTIFICATION OF) UNUSUAL EVENT, "A" for ALERT, "S" for SITE AREA EMERGENCY and "G" for GENERAL EMERGENCY. The EAL number is a sequential number for that Recognition Category series. All ICs that are describing the severity of a common condition (series) will have the same number. The EAL number may then be used to reference a corresponding page(s), which provides the basis information pertaining to the IC:
- EAL
- Mode Applicability
- Basis Classification is not to be made without referencing, comparing and satisfying the specified Emergency Action Levels.
A list of definitions is provided as part of this document (Section 1. 7) for terms having specific meaning to the EALs. Site specific definitions are provided for terms with the intent to be used for a particular IC/EAL and may not be applicable to other uses of that term at other sites, the Emergency Plan or procedures. References are also included to documents that were used to develop the EALs. References to the Emergency Director means the person in Command and Control as defined in the Emergency Plan. Classification of emergencies is a non-delegable responsibility of Command and Control for the onsite facilities with responsibility assigned to the Shift Emergency Director (Control Room Shift Manager) or the Corp,erate Emergency Director (Emergency Operations Facility). Classification of emergencies remains the responsibility of the Shift Emergency Director until Command and Control is transferred to the Corporate Emergency Director (Emergency Operations Facility). 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 EAL has been exceeded. While this is particularly prudent at the higher EGL (as the early classification may provide for more effective implementation of protective measures), it is nonetheless applicable to all .EC Ls. December 2018 NMP 1-4 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear 1.2 Classification, Instrumentation and Transient Events 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 indication's operability, the condition's existence, or the report's accuracy is removed. Implicit in this is the need for timely assessment. Indications used for monitoring and evaluation of plant conditions include the normally used instrumentation, backup or redundant instrumentation, and the use of other parameters that provide information that supports determination if an EAL has been reached. When an EAL refers to a specific instrument or indication
. that is determined to be inaccurate or unavailable, then alternate indications shall be used to monitor the specified condition.
During an event that results in changing parameters trending towards an EAL classification, and instrumentation that was available to monitor this parameter becomes unavailable or the parameter goes off scale, the parameter should be assumed to have been exceeded consistent with the trend and the classification made if there are no other direct or indirect means available to determine if the EAL has not been exceeded. The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL has been exceeded (e.g., dose assessments, chemistry sampling, RCS leak rate calculation, etc.); the EAL, and/or the associated basis discussion will identify the necessary analysis. In these cases, the 15-minute declaration period starts with the availability of the analysis results that show the EAL to be exceeded (i.e., this is the time that the EAL information is first available). 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 site's Technical Specifications. Activities which cause the site to operate beyond that allowed by the site's Technical Specifications, planned or unplanned, may result in an EAL being met or exceeded. Planned evolutions to test, manipulate, repair, perform rnaintenance or modifications to systems and equipment that result in an EAL 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 specific operating license. However, these conditions may be subject to the reporting requirements of 10 CFR 50.72. December 2018 NMP 1-5 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear When two or more EALs are determined, declaration will be made on the highest classification level for the unit. When both units are affected, the highest classification for the Station will be used for notification purposes and both units' ECLs will be noted. Concerning ECL Downgrading, Exelon Nuclear policy is that ECLs shall not be downgraded to a lower classification. Once declared, the event shall remain in effect until no classification is warranted or until such time as conditions warrant classification to Recovery. 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, the guidance of NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73 and the Reportability Reference Manual, should be applied. 1.3 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 can be made, the declaration shall be based on the mode that existed at the time the event occurred. 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 Matrix EALs are applicable only to events that initiate in Hot Shutdown or higher.
- If there is a change in Mode following an event declaration, any subsequent events involving EALs outside of the current declaration escalation path will be evaluated on the Mode of the plant at the time the subsequent events occur.
1.4 Emergency Director Judgment Emergency Director (ED) Judgment EALs are provided in the Hazards and Other Condition Affecting Plant Safety section and on the Fission Product Barrier (FPB) Matrix. Both of the ED Judgment EALs have specific criteria for when they should be applied. The Hazards Section ED Judgment EALs are intended to address unanticipated conditions which are not addressed explicitly by other EALs but warrant declaration of an emergency because conditions exist which are believed by the ED to fall under specific emergency classifications (UE, Alert, SAE or GE). December 2018 NMP 1-6 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear The FPB Matrix ED Judgment EALs are intended to include unanticipated conditions, which are not addressed explicitly by any of the other FPB threshold values, but warrant determination because conditions exist that fall under the broader definition for a significant Loss or Potential Loss of the fission product barrier (equal to or greater than the defined FPB threshold values). 1.5 Fission Product Barrier (FPB) Threshold A fission product barrier threshold is a pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier. FPB thresholds represent threats to the defense in depth design concept that precludes the release of radioactive fission products to the environment. This concept relies on multiple physical barriers, any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment. The primary FPBs are: Fuel Clad (FC) Reactor Coolant System (RCS) Containment (CT) Upon determination that one or more FPB thresholds have been exceeded, the combination of barrier loss and/or potential loss thresholds is compared to the FPB IC/EAL criteria to determine the appropriate EGL. In some accident sequences, the ICs and EALs presented in the Abnormal Radiation Levels/ Radiological Effluent (R) Recognition Category will be exceeded at the same time, or shortly after, the loss of one or more fission product barriers. This redundancy is intentional as the former ICs address radioactivity releases that result in certain offsite doses from whatever cause, including events that might not be fully encompassed by fission product barriers (e.g., spent fuel pool accidents, design containment leakage following a LOCA, etc.). 1.6 Fission Product Barrier Restoration Fission Product Barriers are not treated the same as EAL threshold values. Conditions warranting declaration of the loss or potential loss of a FPB may occur resulting in a specific classification. The condition that caused the loss or potential loss declaration could be rectified as the result of Operator action, automatic actions, or designed plant response. Barriers will be considered re-established when there are direct verifiable indications (containment penetration or open valve has been isolated, coolant sample results, etc) that the barrier has been restored and is capable of mitigating future events. December 2018 NMP 1-7 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear The reestablishment of a FPB does not alter or lower the existing classification. Termination and entry into Recovery phase is still required for exiting the present classification. However the reestablishment of the barrier should be considered in determining future classifications should plant conditions or events change. 1.7 Definitions CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment. CONTAINMENT CLOSURE: The procedurally defined actions taken to secure containment -(primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events may require a post-event inspection to determine if the attributes of an explosion are present. FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fire. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed. FISSION PRODUCT BARRIER (FPB) THRESHOLD: A pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. HOSTILE ACTION: An act toward a Nuclear Power Plant (NPP) 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). December 2018 NMP 1-8 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction. IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions. 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. NORMAL LEVELS: As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value. OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons entering for official business. PROJECTILE: An object directed toward a Nuclear Power Plant (NPP) that could cause concern for its continued operability, reliability, or personnel safety. PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence. REFUELING PATHWAY: All the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel* below the flange. SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems*classified as safety-related. 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. UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally. UNPLANNl::.D: A parameter change or an event that is not 1) the result of a.n intended evolution or 2) an expected plant response to a transient. The cause of tbe parameter change or event may be known or unknown. VISIBLE DAMAGE: Damage to a SAFETY SYSTEM train that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected SAFETY SYSTEM train. December 2018 NMP 1-9 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear EMERGENCY ACTION LEVEL TECHNICAL BASIS PAGE INDEX General Site Area Alert Unusual Event EAL Pg. EAL Pg. EAL Pg. EAL Pg. RG1 2-26 RS1 2-28 RA1 2-30 RU1 2-33 RG2 2-36 RS2 2-37 RA2 2-38 RU2 2-41 RA3 2-43 RU3 2-46 FG1 2-47 FS1 2-48 FA1 2-49 . Fuel Clad RCS Containment FC1 2-50 FC2 2-51 RC2 2-55 CT2 2-63 RC3 2-57 CT3 2-64 RC4 2-58 FC5 2-53 RC5 2-61 CT5 2-66
- CT6 2-67 FC7 2-54 RC7 2-62 CT7 2-70 MG1 2-71 MS1 2-73 MA1 2-75 MU1 2-77 MG2 2-78 MS2 2-80 MS3 2-81 MA3 2-83 MU3 2-85 MA4 2-88 MU4 2-90 MA5 2-92 MU6 2-95 MU7 2-97 CA1 2-99 CU1 2-101 CA2 2-103 CU3 2-106 CU4 2-108 CA5 2-110 CU5 2-112
*CG6 2-114 CS6 2-118 CA6 2-122 CU6 2-124 HS1 2-127 HA1 2-129 HU1 2-132 HS2 2-134 HA2 2-136 HU3 2-137 HU4 2-141 HA5 2-144 HU6 2-147 HG7 2-150 HS7 2-151 HA7 2-152 HU7 2-153 E-HU1 2-154 December 2018 NMP 1-10 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Abnormal Rad Levels / Radiological Effluents RG1 RS1 RA1 RU1 Release of gaseous radioactivity resulting in offsite dose greater Release of gaseous radioactivity resulting in offsite dose greater Release of gaseous or liquid radioactivity resulting in offsite Release of gaseous or liquid radioactivity greater than 2 times than 1,000 mRem TEDE or 5,000 mRem CDE thyroid. than 100 mRem TEDE or500 mRem CDE thyroid. dose greater than 10 mrem TEDE or SO mrem CDE thyroid. the ODCM limits for 60 minutes or longer. Emergency Action Level (EAL): Emergency Action Level (EAL): Emergency Action Level (EAL): Emergency Action Level (EAL): Notes: Notes: Notes: Notes:
- The Emergency Director should declare the event promptly
- The Emergency Director should declare the event promptly
- The Emergency Director should declare the event
- The Emergency Director should declare the event upon determining that the applicable time has been upon determining that the applicable time has been promptly upon determining that the applicable lime has promptly upon determining that the applicable time has exceeded, or will likely be exceeded. exceeded, or will likely be exceeded. been exceeded, or will likely be exceeded. been exceeded, or will likely be exceeded.
- If an ongoing release is detected and the release start time
- If an ongoing release is detected and the release start time
- If an ongoing release is detected and'the release start
- If an ongoing release is detected and the release start is unknown, assume that the release duration has is unknown, assume that the release,duration has time is unknown, assume that the release duration has time is unknown, assume that the release duration has exceeded 15 minutes. exceeded 15 minutes. exceeded 15 minutes. exceeded 60 minutes.
- Classification based on effluent monitor readings assumes
- Classification based on effluent monitor readings assumes
- Classification based on effluent monitor readings assumes
- Classification based on effluent monitor readings assumes that a release path to the environment is established. If the that a release path to the environment is established. If the that a release path to the environment is established. If that a release path to the environment is established. If effluent flow past an effluent monitor is known to have effluent flow past an effluent monitor is known to have the effluent flow.past an effluent monitor is known to have the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the stopped due to actions to isolate the release path, then the stopped due to. actions to isolate the release path, then stopped due to actions to isolate the release path, then effluent monitor reading is no longer valid for classification effluent monitor reading is no longer valid for classification the effluent monitor reading is no longer valid for the effluent monitor reading is no longer valid for J!l purposes. purposes. classification*purposes. classification purposes.
C
- The pre-calculated effluent monitor values presented in
- The pre-calculated effluent monitor values presented in
- The pre-calculated effluent monitor values presented in Cl)
- I EAL #1(Table R1) should be used for emergency EAL #1 (Table R1) should be used for emergency EAL #1 (Table R1) should be used for emergency classfficafion assessments until the results from a dose classification assessments until the results from a dose
- 1. Reading on the Liquid Radwaste Effluent Monitor (LWS-ii: - classification assessments until the results from a dose RE206) > 2 llmes ORMS High (red) established by a w assessment using actual meteorology are available. assessment using actual meteorology are available. assessment using actual meteorology are available.
current radioactive release discharge permit iii 1. Readings on ANY Table R1 EffluentMonitor>TableR1 value for~ 60 minutes. u 1. Readings on ANY Table R1 Effluent Monitor> Table R1 value 1. Readings on ANY Table R1 Effluent Monitor> Table R1 value for.?, 15 minutes. "a, for?. 15 minutes. tor?, 15 minutes. OR 0 OR OR 2. Readings on ANY Table R1 Effluent Monitor> Table R1 value 0 OR 2. Dose assessment using actual meteorology indicates doses at =scu 2. Dose assessment Using actual meteorology'indicates doses at or beyond the site boundary of EITHER: 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: for?. 60 minutes.
- a. > 10 mRem TEDE OR a: a. > 1000 mRem TEDE or beyond the site boundary of EITHER:
OR
- a. > 100 mRem TEDE 3. Confirmed sample analyses for gaseous or liquid releases OR b. > 50 mRem CDE Thyroid indicate concentrations or release rates
- b. > 5000 mRem COE Thyroid OR OR > 2 times ODCM Limit with a release duration OR b. > 500 mRem CDE Thyroid 3. Analysis of a liquid effluent sample indicates a concentration of?. 60 minutes.
- 3. Field survey results at or beyond the site boundary indicate or release rate that would result in doses greater than OR EITHER of the following at or beyond the site boundary:
EITHER:
- a. Gamma (closed window) dose rates 3. Field survey results at or beyond the site boundary indicate a. 10 mRem TEDE for 60 minutes of exposure, EITHER: OR
> 1000 mR/hr are expected to continue for?. 60 minutes. b. 50 mRem CDE Thyroid for 60 minutes
- a. Gamma (closed window) dose rates of exposure.
OR > 100 mR/hr are expected to continue for?. 60 minutes. OR
- b. Analyses offield survey samples indicate 4. Field survey results at or beyond the site boundary indicate
> 5000 mRem CDE Thyroid for 60 minutes OR EITHER:
of inhalation. b. Analyses of field survey samples indicate a. Gamma (closed window) dose rates
> 500 mRem CDE Thyroid for 60 minutes > 10 mR/hr are expected to continue of inhalation. for a:, 60 minutes.
OR
- b. Analyses of field survey samples indicate
> 50 mRem CDE Thyroid for 60 minutes of inhalation.
Modes: 1 - Power Operation 2-Startup ~-=3_-_,H..:;o::.:t.,S"'h"'u,,td::o.::w.c:n_ _ _...,4_-...,C"'o"ld=S.c:hu,,,t::d=.ow"-n"---"'5_-_,R_,,e,,fu,,,e"'li"'n"-A_ _=D_-...,D=.e::.:f.:ue"'l"ed=-----------------------------------, Table R1 Effluent Monitor Thresholds Effluent Monitor General Emergencv Site Area Emeraencv Alert Unusual Event Radwaste/RB Vent Effluent (2RMS-PNL 1 BOC) 4.80 E+07 µCi/sec 4.80 E+OS µCi/sec 4.80 E+05 µCi/sec 1.69 E+05 µCi/sec Main Stack Effluent (2RMS-PNL 170C) 1.02 E+11 µCi/sec 1.02 E+1 O µCi/sec 1.02 E+09 µCi/sec 7 .12 E+05 µCi/sec December 2018 HOT MATRIX NMP2-1 HOT MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Abnormal Rad Levels / Radiological Effluents RG2 RS2 RA2 RU2 Spent fuel pool level cannot be restored to at least 330 feet Spent fuel pool level at 330 feet. Significant lowering of water level above, or damage to, UNPLANNED loss of water level above irradiated fuel. for 60 minutes or longer. irradiated fuel. Emergency Action Level (EAL): Emergency Action Level !EAL): Emergency Action Levels (EAL): Emergency Action Level !EAL): Lowering of spent fuel pool level to 330 feet as indicated Note: The Emergency Director should declare the event 1. a. UNPLANNED water level drop in the REFUELING on 2SFC-Ll413A or B. promptly upon determining that the applicable time PATHWAY as indicated by ANY of the following:
- 1. Uncovery of irradiated fuel in the REFUELING has been exceeded, or will likely be exceeded. PATHWAY.
- Inability to restore and maintain Spent Fuel Pool water level > low water level alarm.
Spent fuel pool level cannot be restored to at least OR 330 feet as indicated on 2SFC-Ll413A or B OR
- 2. Damage to irradiated fuel resulting in a release of for::: 60 minutes. Table R2 Refuel Floor radioactivity from the fuel as indicated by ANY
- Indication or report of a drop in water level Radiation Monitors Table R2 Radiation Monitor Alarm. in the REFUELING PATHWAY.
OR AND
- 2RMS-RE111
- 3. Lowering of spent fuel pool level to 340 feet as b. UNPLANNED Area Radiation Monitor reading rise
- 2RMS-RE112 indicated on 2SFC-Ll413A orB. on ANY Table R2 radiation monitor.
- 2RMS-RE113
.l!l C
- 2RMS-RE114 Cl)
- J
- 2HVR*RE14A ffi
- 2HVR*RE14B RA3 RU3 iii u Radiation levels that impede access to equipment necessary Reactor coolant activity greater than Technical
- s, for normal plant operations, cooldown or shutdown. Specification allowable limits.
0 Table R4 0 Table R3 Areas with Entry Related Mode Applicability Emergency Action Level !EAL): Emergency Action Level !EAL):
- a Areas Requiring Continuous Occupancy Note: If the equipment in the room or area listed in Table
~ Entry Related R4 was already inoperable, or out of service, before 1 Offgas radiation ORMS high (red) alarm Area the event occurred, then no emergency classification for::: 15 minutes.
- Main Control Room Mode Applicability is warranted.
OR
- Central Alarm Station - (by survey) Reactor Building 1. Dose rate> 15 mR/hr in ANY of the areas in Table R3.
- 2. Specific coolant activity > 4.0 µCi/gm Dose Equivalent 175' RHS A Pump Room (RHR AJ OR 1-131.
196' Az 56 Deg (RHR AJ 2. UNPLANNED event results in radiation levels that Mode 3, 4, prohibit or significantly impede access to ANY of the 175' RHS B Pump Room (RHR A & B) and 5 areas in Table R4. Control Building 261' Div 1 Switchgear Room (RHR A & BJ 261' Div 2 Switchgear Room (RHR A & BJ Modes. 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5 - Refueling D- Defueled December 2018 HOT MATRIX NMP2-2 HOT MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex HOT MATRIX HOT MATRIX Exelon Nuclear FC - Fuel Clad RC - Reactor Coolant System CT - Containment Sub.Category Loss Potential Loss Loss Potential Loss Loss Potential Loss Coolant activity> 300 uCi/gm Dose Equivalent 1-131.
- 1. RCS Activity None None None None None
- 1. SAP entry required 2. RPV water level £i!!!.D.2! be restored and 1. RPV water level .£!!Il.!!g! be restored and SAP entry requlr~d maintained> -14 inches (TAF). maintained> -14 inches (TAF).
- 2. RPV Water Level None None OR OR
- 3. RPV water level~ be determined. 2. RPV water level~ be determined.
- 1. a. Primary Containment pressure 1. UNPLANNED rapid drop in Primary 3. Primary Containment pressure> 45 psig.
> 1.68 psig. Containment pressure following Primary OR AND Containment pressure rise.
- 4. a. Primary Containment hydrogen
- b. Primary Containment pressure rise is OR concentration~ 6%.
- 3. Primary Containment due to RCS leakage. 2. Primary Containment pressure response n!!! AND None None None consistent with LOCA conditions.
Pressure/ b. Primary Containment oxygen concentration Conditions _::5%. OR
- 5. Heat Capacity Temperature Limit (HCTL)
(N2-EOP-PC Figure M) exceeded.
- 1. UNISOLABLE Main Steam Line (MSL), 3. UNISOLABLE primary system leakage that RCIC, Feedwater, orWCS line break. results in EITiiER of the following:
OR a. RB area temperature above an
- 4. RCS Leak Rate None None 2. RPV Slowdown Is required. isolation setpo!nt. None None OR
- b. RB area radiation above an alarm setpoint.
Drywall radiation monitor reading Drywall radiation monitor reading Drywall radiation monitor reading
- 5. Primary
> 1.4 E+D3 Rlhr (1.4 E+06 mR/hr). > 100 Rlhr (1.0 E+OS mR/hr). > 1.4 E+04 Rlhr (1.4 E+07 mRlhr).
Containment None None None Radiation
- 1. UNISOLABLE direct downstream pathway to the environment exists after Primary Containment Isolation signal.
OR
- 2. Intentional Primary Containment venting/purging per EOPs or SAPs due to accident conditions.
a.Primary OR Containment None None None None None Isolation Failure 3. UNISOLABLE primary system leakage that results in EITHER of the following:
- a. Exceeding RB area temperature Maximum Safe Value (N2-EOP-SC Detail S).
OR
- b. RB area radiation> 8.00 E+03 mR/hr.
- 1. ANY Condition in the opinion of the 2. ANY Condition in the opinion of the 1. ANY Condition In the opinion of the 2.ANY Condition In the opinion of the 1.ANY Condition in the opinion of the 2. ANY Condition in the opinion of the
- 7. Emergency Emergency Director that indicates Loss Emergency Director that indicates Emergency Director that indicates Loss of Emergency Diredor that indicates Potential Emergency Director that indicates Loss of the Emergency Director that indicates Potential Diredor of the Fuel Clad Barrier. Potential Loss of the Fuel Clad Barrier.
- the RCS Barrier. Loss oflhe RCS Barrier. Containment Barrier. Loss of the Containment Barrier.
Judgment Modes: 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5 - Refueling D- Defueled December 201 B HOT MATRIX NMP2-3 HOT MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex HOT MATRIX HOT MATRIX Exelon Nuclear I GENERAL EMERGENCY SITE AREA EMERGENCY ALERT System Malfunction MG1 MS1 JTI[fil[] MA1 MU1 Prolonged loss of all offsite and all onsite AC power to Loss of all offsite and onsite AC power to emergency Loss of all but one AC power source to emergency buses for Loss of all offsite AC power capability to emergency buses emergency buses. buses for 15 minutes or longer. 15 minutes or longer. for 15 minutes or longer. Emergency Action Level (EAL): Emergency Action Level (EAL): Emergency Action Level (EAL): Emergency Action Level (EAL): Note: The Emergency Director should declare the event Note: The Emergency Director should declare the event Note: The Emergency Director should declare the event Note: The Emergency Director should declare the event promptly upon determining that the applicable time has promptly upon determining that the applicable time promptly upon determining that the applicable time promptly upon determining that the applicable time I II.. 1. been exceeded, or will likely be exceeded. Loss of ALL offsite and onsite AC power to 4.16 kV emergency buses 2ENS*SWG101 and 2ENS*SWG103. 1. has been exceeded, or will likely be exceeded. Loss of ALL offsite and onsite AC power to 4.16 kV has been exceeded, or will likely be exceeded.
- 1. AC power capability to 4.16 kV emergency buses has been exceeded, or will likely be exceeded.
Loss of ALL offsite AC power capability to 4.16 kV
~ AND emergency buses 2ENS*SWG101 and 2ENS*SWG103.
2ENS*SWG101 and 2ENS*SWG103 reduced to only one of the following power sources for~ 15 minutes: emergency buses 2ENS*SWG101 and 2ENS*SWG103 for~ 15 minutes: 0 2. EITHER of the following: AND Reserve Transformer A en a. Restoration of at least one 4.16 kV emergency bus Reserve Transformer A en 2ENS*SWG101 or 2ENS*SWG103 in< 4 hours is 2. Failure to restore power to at least one 4.16 kV Reserve Transformer B 0
..J .!!f!!likely. emergency bus 2ENS*SWG101 or 2ENS*SWG103 in Aux Boiler Transformer Reserve Transformer B OR < 15 minutes from the time of loss of both offsite and 2EGS*EG1 Aux Boiler Transformer onsite AC power.
- b. RPV water level Efil!..!!.!!! be restored and maintained 2EGS*EG3
> -39 inches. 2EGS*EG2 AND
- 2. ANY additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.
MG2 MS2 Loss of all AC and Vital DC power sources for 15 minutes or Loss of all Vital DC power for 15 minutes or longer. longer. Emergency Action Level (EAL): Emergency Action Level (EAL): Note: The Emergency Director s,hould declare the event Note: The Emergency Director should declare the event promptly upon determining that the applicable time I II.. 0 1. promptly upon determining that the applicable time has been exceeded, or will likely be exceeded. Loss of ALL offsite and onsite AC power to 4.16 kV has been exceeded, or will likely be exceeded. Voltage is< 105 voe on 2BYS*SWG002A and 2BYS*SWG002B for~ 15 minutes. C 0 emergency buses 2ENS*SWG101 and 2ENS*SWG103. AND en 2. Voltage is < 105 VDC on Vital DC buses 2BYS*SWG002A en and 2BYS*SWG002B. 0
..J AND
- 3. ALL AC and Vital DC power sources in EALs #1 and #2 (excluding Division 3) have been lost for~ 15 minutes.
Modes: 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5-Refueling D-Defueled December 201 B HOT MATRIX NMP2-4 HOT MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT System Malfunction MS3 MA3 rrmi MU3 Inability to shutdown the reactor causing a challenge to RPV Automatic or manual scram fails to shutdown the Automatic or manual scram fails to shutdown the reactor. water level or RCS heat removal. reactor, and subsequent manual actions taken at the Emergency Action Level (EAU: Reactor Control Console are not successful in shutting Emergency Action Level (EAU: down the reactor. Note: A manual action is any operator action, or set of
- 1. Automatic scram did not shutdown the reactor as actions, which causes the control rods to be rapidly Emergency Action Level (EAL):
indicated by Reactor Power> 4%. inserted into the core. This action does not include Note: A manual action is any operator action, or set of manually driving in control rods or implementation of AND actions, which causes the control rods to be rapidly boron injection strategies.
- 2. ALL manual / ARI actions to shutdown the reactor have inserted into the core. This action does not include 1 a. Automatic scram did not shutdown the reactor as been unsuccessful as indicated by Reactor Power> 4%. manually driving in control rods or implementation of
- indicated by Reactor Power> 4%.
boron injection strategies. I!! AND AND
.2 1. Automatic or manual scram did not shutdown the 'iii 3. EITHER of the following conditions exist: b. Subsequent manual / ARI action taken at the IL reactor as indicated by Reactor Power> 4%.
Reactor Control Console is successful in shutting U)
- RPV water level cannot be restored and maintained AND down the reactor as indicated by II.. > -39 inches. Reactor Power:; 4%.
a:: 2. Manual / ARI actions taken at the Reactor Control OR Console are.!!!!! successful in shutting down the reactor OR
- Heat Capacity Temperature Limit (HCTL) as indicated by Reactor Power> 4%. 2. a. Manual scram did not shutdown the reactor as (N2-EOP-PC Figure M) exceeded. indicated by Reactor Power> 4%.
AND
- b. EITHER of the following:
- 1. Subsequent manual / ARI action taken at the Reactor Control Console is successful in shutting down the reactor as indicated by Reactor Power:; 4%.
OR
- 2. Subsequent automatic scram / ARI is successful in shutting down the reactor as indicated by Reactor Power :; 4 % .
MA4 MU4 Ill UNPLANNED loss of Control Room indications for 15 UNPLANNED loss of Control Room indications for 15 C 0 minutes or longer with a significant transient in progress. minutes or longer.
- .:=
I'll Table M1 Control Room Parameters Table M2 Significant Transients Emergency Action Level (EAL): Emergency Action Level (EAL): u i:i
.E . Reactor Power
- Turbine runback > 25% thermal reactor Note: The Emergency Director should declare the event Note: The Emergency Director should declare the event E . power promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
promptly upon determining that the applicable time has been exceeded, or will likely be exceeded. 0 0 a:: . RPV Water Level
- Electric load rejection > 25% full electric e..
C
.. RPV Pressure Primary Containment Pressure
- load Reactor Scram
- 1. UNPLANNED event results in the inability to monitor ANY Table M1 parameter from within the Control Room for::. 15 minutes .
UNPLANNED event results in the inability to monitor ANY Table M1 parameter from within the Control Room for::. 15 minutes. Suppression Pool Level 0 0
. Suppression Pool Temperature ECCS Activation Thermal Power oscillations > 10%
AND
- 2. ANY Table M2'transient in progress .
Modes: 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5 - Refueling D-Defueled December 2018 HOT MATRIX NMP2-5 HOT MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex HOT MATRIX HOT MATRIX Exelon Nuclear ALERT UNUSUAL EVENT System Malfunction MAS ITI~~ Hazardous event affecting a SAFETY SYSTEM required for the current operating mode. Emergencl,! Action Level (EAL!: Note:
. This EAL is only applicable to SAFETY SYSTEMs
. having two (2) or more trains.
If the affected SAFETY SYSTEM train was already inoperable before the hazardous event occurred,
. then this emergency classification is not warranted.
If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded perfonnance to at least one train of a SAFETY SYSTEM, then this emergency classification is not E
/JI
. warranted .
If a hazardous event occurs and it is detennined that the conditions of MA5 are not met then assess en the event via HU3, HU4, or HUB. ~ ,! 1. a. The occurrence of ANY of the following hazardous Ill events: en Cl Seismic event (earthquake)
- Su
. Internal or external flooding event High winds or tornado strike c( FIRE /JI EXPLOSION
'O Ill Other events with similar hazard N characteristics as determined by the Shift Ill
- c Manager AND
- b. Event damage has caused indications of degraded performance to one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.
AND C. EITHER cif the following: Event damage has caused indications of degraded performance to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode. OR Event damage has resulted in VISIBLE DAMAGE to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode. Modes.. 1 - Power Operation 2 - Startup 3 - Hot Shutdown 4 - Cold Shutdown 5-Refueling D-Defueled December 201 B HOT MATRIX NMP2-6 HOT MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT System Malfunction MUS ITilfil~ RCS leakage for 15 minutes or longer. Emergencit: Action Level (EAL}: Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded . ..IO: ftl Cl) 1. RCS unidentified or pressure boundary leakage ...I in the Drywell > 10 gpm for~ 15 minutes. en 0 OR a:: 2. RCS identified leakage in the Drywell > 25 gpm for~ 15 minutes. OR
- 3. Leakage from the RCS to a location outside the Drywell > 25 gpm for~ 15 minutes.
, MU7 [][fil~
Table M3 Communication Capabilities Loss of all onsite or offsite communication capabilities. System Onsite Offsite NRC Emergencit: Action Level (EAL}: Gaitronics X 1. Loss of ALL Table M3 onsite communication UI capabilities affecting the ability to perform routine C operations. 0 Hand Held Portable X
~ Radio (Station Radio) OR ftl u 2. Loss of ALL Table M3 offsite communication
- c:I PBX (Conventional X X X capabilities affecting the ability to perform offsite E Telephone lines) notifications.
E OR 0 Control Room installed X X 0 3. Loss of ALL Table M3 NRG communication satellite phone (non capabilities affecting the ability to perform NRG portable) notifications. ENS X X RECS X Modes. 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5 - Refueling D- Defueled December 2018 HOT MATRIX NMP2-7 HOT MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Plant Safety HS1 II]~~@l@J[g HA1 II]~~@l@J[g HU1 II]~~@l@J[g HOSTILE ACTION within the PROTECTED AREA. HOSTILE ACTION within the OWNER CONTROLLED Confirmed SECURITY CONDITION or threat. AREA or airbome attack threat within 30 minutes. Emergencll: Action Level (EAL}: Emergencll: Action Level (EAL}: Emergencll: Action Level (EAL): A notification from the Security Supervisor that a HOSTILE 1. Notification of a credible security threat directed at the C 0 ACTION is occurring or has occurred within the 1. A validated notification from NRG of an aircraft site as determined per SY-AA-101-132, Security
- PROTECTED AREA. attack threat< 30 minutes Irom the site. Assessment and Response to Unusual Activities.
u < OR OR ~ 2. A validated notification from the NRC providing
- 2. Notification by the Security Supervisor that a information of an aircraft threat.
UI 0 HOSTILE ACTION is occurring or has occurred
- c OR within the OWNER CONTROLLED AREA.
- 3. Notification by the Security Supervisor of a SECURITY CONDITION that does not involve a HOSTILE ACTION.
HS2 II]~~@l@J[g HA2 II]~~@l@J[g Inability to control a key safety function from outside the Control Room evacuation resulting in transfer of plant Table H1 Safety Functions Control Room. control to alternate locations.
. Reactivity Control (ability to shutdown the reactor and keep ii shutdown)
Emergencll: Action Level (EAL): Emergencll: Action Level (EAL): -. .. Note: The Emergency Director should declare the event A Control Room evacuation has resulted in plant control ci RPV Water Level (ability to cool the core) promptly upon determining that the applicable time has being transferred from the Control Room to alternate C locations per N2-SOP-78, Control Room Evacuation. 0 been exceeded, or will likely be exceeded. 0 C ca ii: RCS Heat Removal (ability to maintain a heat sink)
- 1. A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate 0
locations per N2-SOP-78, Control Room Evacuation. AND UI C 2. Control .of ANY Table H1 key safety function is not ca reestablished in < 15 minutes . Modes. 1 - Power Operalion 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5- Refueling D-Defueled December 2018 HOT MATRIX NMP2-8 HOT MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Plant Safety HU3 FIRE potentially degrading the level of safety of the plant. Emergency Action Level (EAL): Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- Escalation of the emergency classification level would be via IC CAZ or MA5.
Table H2 Areas 1. A FIRE in ANY Table H2 area is not extinguished in< 15 minutes of ANY of the following FIRE detection
. Reactor Building (when inerted the Drywell is exempt) indicafions:
- Report from the field (i.e., visual observation)
. Control Room
- Receipt of mulfiple (more than 1) fire alarms or
. Relay Room
- indications Field verification of a single fire alarm I!!
. Diesel Generator Engine and Board Rooms OR ii:
. Standby Switchgear and Battery Rooms
- 2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of a FIRE).
. HPCS Switchgear and Battery Roonis AND
- b. The existence of a FIRE is not verified
. Remote Shutdown Rooms in< 30 minutes of alarm receipt.
I OR Control Building HVAC Rooms 3. A FIRE within the plant PROTECTED AREA not extinguished in< 60 minutes of the initial report, alarm or Electrical Protection Assembly Room indication. Service Water Pump Rooms OR
- 4. A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.
Modes. 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5- Refueling D- Defueled December 2018 HOT MATRIX NMP2-9 HOT MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex HOT MATRIX HOT*MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Plant Safety HU4 ITI~@l@l@l[g Seismic event greater than QBE levels. Emewencl£ Action Level (EAL): Note:
. For emergency classification if EAL# 2.b is not able to be confirmed, then the occurrence of a seismic event is confirmed in a manner deemed appropriate by the Shift manager or Emergency Director in!£ 15 minutes of the event.
. Escalation of the emergency classification level would be via IC CA2 or MA5.
- 1. Seismic event> Operating Basis Earthquake (OBE) as indicated by:
. Computer Point ERSNC02, QBE Detected OR GI
. ANY amber LED light lit at the Seismic Monitor Panel, Response Spectrum Annunciator.
l'G
- s OR er
..c 2. When Seismic Monitoring Equipment is !!!!! available: t:: l'G a. Control Room personnel feel an actual or potential w seismic event. AND
- b. ANY one of the following confirmed in !£ 15 minutes of the event:
The earthquake resulted in Modified Mercalli Intensity (MMI) ~ VI and occurred!£ 3.5 miles of
. the plant.
The earthquake was magnitude ~ 6.0
- The earthquake was magnitude~ 5.0 and
. occurred!£ 125 miles from the plant.
If the above bullets are not able to be confirmed, then the occurrence of a seismic event is confirmed in a manner deemed appropriate by the Shift Manager or Emergency Director. Modes: 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5-Refueling D-Defueled December 201 B HOT MATRIX NMP2-10 HOT MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Plant Safety Table H3 HAS @!@][§ Areas with Entry Related Mode Applicability Gaseous release impeding access to equipment Entry Related necessary for normal plant operations, cooldown or Area Mode shutdown. UI Aoolicabilitv Emergency Action Level (EAL): ta Reactor Building Cl Note: If the equipment in the listed room or area was CJ 175' RHS A Pump Room (RHR A) already inoperable, or out of service, before the
- c event occurred, then no emergency classification 0 196' Az. 56 Deg (RHR A)
I- is warranted. 175' RHS B Pump Room (RHR A & B) Mode 3, 4, and 5 1. Release of a toxic, corrosive, asphyxiant or Control Building flammable gas in ANY Table H3 area. 261' Div 1 Switchgear Room (RHR A & B) AND
- 2. Entry into the room or area is prohibited or 261' Div 2 Switchgear Room (RHR A & B) impeded.
HUS II]~@l@l@llg Hazardous Event Emergency Action Level (EAL): Note:
. EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.
-C Cl)
. Escalation of the emergency classification level would be via IC CA2 or MA5.
w UI 1. Tornado strike within the PROTECTED AREA.
=
0 "C ta OR 2 . Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a Iii SAFETY SYSTEM component required by Technical J: Specifications for the current operating mode. OR
- 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).
OR
- 4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.
OR
- 5. Intake Water Level< 237 feet.
Modes. 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5 - Refueling D-Defueled December 2018 HOT MATRIX NMP 2-11 HOT MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Plant Safety HG7 HS7 HU7 Other conditions exist which in the judgment of the Other conditions exist which in the judgment of the Other conditions exist which in the judgment of the Other conditions exist which in the judgment of the Emergency Director warrant declaration of a GENERAL Emergency Director warrant declaration of a SITE AREA Emergency Director warrant declaration of an ALERT. Emergency Director warrant declaration of an UNUSUAL EMERGENCY. EMERGENCY. EVENT. Emergency Action Level (EAL): Emergency Action Level (EAU: Emergency Action Level (EAL): Emergency Action Level (EAL): Other conditions exist which, in the judgment of the Other conditions exist which in the judgment of the Other conditions exist which in the judgment of the Emergency Director, indicate that events are in progress or Other conditions exist which in the judgment of the Emergency Emergency Director indicate that events are in progress or Emergency Director indicate that events are in progress or have occurred which involve an actual or potential Director indicate that events are in progress or have occurred have occurred which involve actual or IMMINENT substantial have occurred which involve actual or likely major failures of substantial degradation of the level of safety of the plant or a which indicate a potential degradation of the level of safety of core degradation or melting with potential for loss of plant functions needed for protection of the public or HOSTILE security event that involves probable life threatening risk to the plant or indicate a security threat to facility protection has containment integrity or HOSTILE ACTION that results in an ACTION that results in intentional damage or malicious acts, site personnel or damage to site equipment because of been initiated. No releases of radioactive material requiring actual loss of physical control of the facility. Releases can be (1) toward site personnel or equipment that could lead to the HOSTILE ACTION. Any releases are expected to be limited offsite response or monitoring are expected unless further reasonably expected to exceed EPA Protective Action likely failure of or, (2) that prevent effective access to to small fractions of the EPA Protective Action Guideline degradation of safety systems occurs. Guideline exposure levels offsite for more than the immediate equipment needed for the protection of the public. Any exposure levels. -C G) E Cl site area. releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.
/
'C ~ I!! Q
~
C G) e> G) E w Modes: 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5-Refuelmg D- Defueled December 201 B HOT MATRIX NMP2-12 HOT MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex HOT MATRIX HOT MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT ISFSI Malfunction E-HU1 ITI~@l~@Jlll Damage to a loaded cask CONFINEMENT BOUNDARY. EmergencJl Action Level (EALl: Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading: For 61 BT DSC:
. > 800 mrem/hr 3 feet from the HSM surface
. OR
> 200 mrem/hr outside the HSM door on centerline of DSC
. OR
> 40 mrem/hr end of shield wall exterior For 61 BTH DSC:
. > 1400 mrem/hr on the HSM or HSM-H front surface rn...
!!?
. OR
> 200 mrem/hr on the HSM or HSM-H door centerline
. OR
> 40 mrem/hr on the end shield wall exterior Modes. 1 - Power Operafion 2-Starlup 3 - Hot Shutdown 4 - Cold Shutdown 5-Refuehng D- Defueled December 201 B HOT MATRIX NMP2-13 HOT MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Abnormal Rad Levels / Radiological Effluents RG1 RS1 RA1 RU1 Release of gaseous radioactivity resulting in offsite dose greater Release of gaseous radioactivity resulting in offsite dose greater Release of gaseous or liquid radioactivity resulting in offsite dose Release of gaseous or liquid radioactivity greater than 2 than 1,000 mRem TEDE or 5,000 mRem CDE thyroid. than 100 mRem TEDE orSOO mRem COE thyroid. greater than 10 mrem TEDE or 50 mrem CDE thyroid. times the ODCM limits for 60 minutes or longer. Emergency Action Level (EALI: Emergency Action Level (EAL): Emergency Action Level (EAU: Emergency Action Level (EAL): Notes: Notes: Notes: Notes:
- The Emergency Director should declare the event promptly
- The Emergency Director should declare the event promptly
- The Emergency Director should declare the event promptly
- The Emergency Director should declare the event upon determining that the applicable time has been upon determining that the applicable time has been upon determining that the applicable time has been exceeded, promptly upon determining that the applicable time has exceeded, or will likely be exceeded. exceeded, or will likely be exceeded. or will likely be exceeded. been exceeded, or will likely be exceeded.
- If an ongoing release is detected and the release start time
- If an ongoing release is detected and the release start time
- If an ongoing release is detected and the release start time is
- If an ongoing release is detected and the release start is unknown, assume that the release duration has is unknown, assume that the release duration has unknown, assume that the release duration has exceeded 15 time is unknown, assume that the release duration has exceeded 15 minutes. exceeded 15 minutes. minutes. exceeded 60 minutes.
- Classification based on effluent monitor readings assumes
- Classification based on effluent monitor readings assumes
- Classification based on effluent monitor readings assumes that
- Classification based on effluent monitor readings that a release path to the environment is established. If the that a release path to the environment is established. If the a release path to the environment is established. If the effluent assumes that a release path to the environment is effluent flow past an effluent monitor is known to have effluent flow past an effluent monitor is known to have flow past an effluent monitor is known to have stopped due to established. If the effluent flow past an effluent monitor stopped due to actions to isolate the release path, then the stopped due to actions to isolate the release path, then the actions to isolate the release path, then the effluent monitor is known to have stopped due to actions to isolate the effluent monitor reading is no longer valid for classification effluent monitor reading is no longer valid for classification reading is no longer valid for classification purposes. release path, then the effluent monitor reading is no J!l C
purposes. purposes.
- The pre-calculated effluent monitor values presented in EAL longer valid for classification purposes.
Cl)
- The pre-calculated effluent monitor values presented in
- The pre-calculated effluent monitor values presented in #1 (Table R1) should be used for emergency classification
=
iE EAL #1(Table R1) should be used for emergency classification assessments until the results from a dose EAL #1(Table R1) should be used for emergency classification assessments until the results from a dose assessments until the results from a dose assessment using actual meteorology are available.
- 1. Reading on the Liquid Radwaste Effluent Monitor w (LWS-RE206) > 2 times DRMS High (redl established assessment using actual meteorology are available. assessment using actual meteorology are available.
by a current radioactive release discharge permit for iii u
- 1. Readings on ANY Table R1 Effluent Monitor> Table R1 value for 2: 60 minutes.
- 1. Readings on ANY Table R1 Effluent Monitor> Table R1 value 1. Readings on ANY Table R1 Effluent Monitor> Table R1 value ? 15 minutes.
"c, for~ 15 minutes. for~ 15 minutes. OR OR C c OR OR 2. Dose assessment using actual meteorology indicates doses at or 2. Readings on ANY Table R1 Effluent Monitor> Table R1 =a 2. Dose assessment Using actual meteorology indicates doses at
- 2. Dose assessment using actual meteorology indicates doses at beyond the site boundary of EITHER:
- a. > 10 mRem TEDE value for~ 60 minutes.
&! or beyond the site boundary of EITHER:
- a. > 1000 mRem TEOE or beyond the site boundary of EITHER: OR OR
- a. > 100 mRem TEOE b. > 50 mRem COE Thyroid 3. Confirmed sample analyses for gaseous or liquid releases OR indicate concentrations or release rates OR OR
- b. > 5000 mRem COE Thyroid > 2 times ODCM Limit with a release duration
- 3. Analysis of a liquid effluent sample indicates a concentration or OR b. > 500 mRem COE Thyroid release rate that would result in doses greater than EITHER of of~ 60 minutes.
- 3. Field survey results at or beyond the site boundary indicate the following at or beyond the site boundary:
OR EITHER: a. 10 mRem TEOE for 60 minutes of exposure
- a. Gamma (closed window) dose rates 3. Field survey results at or beyond the site boundary indicate OR EITHER:
> 1000 mR/hr are expected to continue b. 50 mRem COE Thyroid for 60 minutes for~ 60 minutes. a. Gamma (closed window) dose rates of exposure OR > 100 mR/hr ar11. expected to continue OR
- b. Analyses of field survey samples indicate for~ 60 minutes. 4. Field survey results at or beyond the site boundary indicate
> 5000 mRem COE Thyroid for 60 minutes OR EITHER:
of inhalation. a. Gamma (closed window) dose rates
- b. Analyses offield survey samples indicate
> 500 mRem COE Thyroid for 60 minutes > 10 mR/hr are expected to continue for~ 60 minutes.
of inhalation. OR
- b. Analyses of field survey samples indicate
> 50 mRem COE Thyroid for 60 minutes of inhalation.
Modes: 1 - Power Operation 2 Startun 3 Hot Shutdown 4 - Cold Shutdown 5 Refuelina D Defueled Table R1 Effluent Monitor Thresholds Effluent Monitor General Emeraencv Site Area Emergencv Alert Unusual Event Radwaste/RB Vent Effluent (2RMS-PNL 1 BOC) 4.80 E+07 µCi/sec 4.80 E+06 µCi/sec 4.80 E+05 µCi/sec 1.69 E+05 µCi/sec Main Stack Effuent (2RMS-PNL 170C) 1.02 E+11 µCi/sec 1.02 E+1 O µCi/sec 1.02 E+09 µCi/sec 7.12 E+05 µCi/sec December 2018 COLD SHUTDOWN/REFUELING MATRIX NMP2-14 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Abnormal Rad Levels/ Radiological Effluents RG2 RS2 RA2 RU2 Spent fuel pool level cannot be restored to at least 330 Jee! Spent fuel pool level at 330 feet. Significant lowering of water level above, or damage to, UNPLANNED loss of water level above irradiated fuel. for 60 minutes or longer. irradiated fuel. Emergency Action Level (EAL): Emergency Action Level (EAL): Emergency Action Levels (EAL): Emergency Action Level (EAL): Lowering of spent fuel pool level to 330 feet as indicated 1. a. UNPLANNED water level drop in the REFUELING Note: The Emergency Director should declare the event on 2SFC-Ll413A or B. PATHWAY as indicated by ANY of the following: promptly upon determining that the applicable time 1. Uncovery of irradiated fuel in the REFUELING has been exceeded, or will likely be,exceeded. PATHWAY.
- Inability to restore and maintain Spent Fuel Pool water level> low water level alarm.
Spent fuel pool .level cannot be restored to at least OR OR 330 feet as indicated on 2SFC-Ll413A or B 2. Damage to irradiated fuel resulting in a release of for::_ 60 minutes. radioactivity from the fuel as indicated by ANY
- Indication or report of a drop in water level in Table R2 Refuel Floor Table R2 Radiation Monitor Alarm. the REFUELING PATHWAY.
Radiation, Monitors OR AND
- 2RMS-RE111
- 3. Lowering of spent fuel pool level to 340 feet b. UNPLANNED Area Radiation Monitor reading rise
- 2RMS-RE112 on ANY Table R2 radiation monitor.
as indicated on 2SFC-Ll413A or B.
- 2RMS-RE113 J!l C
- 2RMS-RE114 GI
- I
- 2HVR*RE14A 5:
w
- 2HVR*RE14B RA3 iii u Radiation levels that impede access to equipment necessary
*s, for normal plant operations, cooldown or shutdown.
0 Table R4 0 Areas with Entry Related Mode Applicability Emergency Action Level (EAL):
'6 I}_ Table R3 Entry Note: If the equipment in the room or area listed in Table Areas Requiring Continuous Occupancy Related Area R4 was already inoperable, or out of service, before Mode Aoolicabilitv the event occurred, then no emergency classification
- Main Control Room is warranted.
Reactor Building
- Central Alarm Station - (by survey) 175' RHS A Pump Room (RHR A)
- 1. Dose rate > 15 mR/hr in ANY of the areas 196' Az 56 Deg (RHR A) in Table R3.
175' RHS B Pump Room (RHR A & B) Mode 3, 4, OR and 5
- 2. UNPLANNED event results in radiation levels that Control Building prohibit or significantly impede access to ANY 261' Div 1 Switchgear Room (RHR A & B) of the areas in Table R4*.
261' Div 2 Switchgear Room (RHR A & B) Modes: 1 - Power Operation 2*-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5 - Refueling D-Defueled December 2018 COLD SHUTDOWN/REFUELING MATRIX NMP2-15 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Cold Shutdown / Refueling System Malfunctions CA1 fil!Il[g CU1 fil!Il[g Loss of all offsite and onsite AC power to emergency buses Loss of all but one AC power source to emergency buses for 15 for 15 minutes or longer. minutes or longer. Emergencl£ Action Level (EALl: EmergenCJl Action Level (EALl: Note: The Emergency Director should declare the event Note: The Emergency Director should declare the event promptly upon determining that the applicable time promptly upon determining that the applicable time has has been exceeded, or will likely be exceeded. been exceeded, or will likely be exceeded.
- 1. Loss of ALL offsite and onsite AC power to 4.16 kV 1. AC power capability to 4.16 kV emergency buses emergency buses 2ENS*SWG101 and 2ENS*SWG103. 2ENS*SWG101 and 2ENS*SWG103 reduced to only one of the following power sources for:! 15 minutes:
AND Reserve Transformer A
- 2. Failure to restore power to at least one 4.16 kV Reserve Transformer B emergency bus 2ENS*SWG101 or 2ENS*SWG103 in< 15 minutes from the time of loss of both offsite and Aux Boiler Transformer a,
onsite AC power. 2EGS*EG1 2EGS*EG3 2EGS*EG2 0 II. AND 0 2. ANY additional single power source failure will result in a loss 0 UI UI 0 of ALL AC power to SAFETY SYSTEMS. ..J Modes: 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5-Refuehng D-Defueled December 2018 COLD SHUTDOWN/REFUELING MATRIX NMP 2-16 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Cold Shutdown / Refueling System Malfunctions CA2 illm Hazardous event affecting SAFETY SYSTEM required for the
' current operating mode.
Emergencll: Action Level (EALJ: Note:
. This EAL is only applicable to SAFETY SYSTEMs
. having two (2) or more trains.
If the affected SAFETY SYSTEM train was already inoperable before the hazardous event occurred, then
. this emergency classification is not warranted.
If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not E .21 en U)
. warranted .
If a hazardous event occurs and it is determined that the conditions of CA2 are not met then assess the event via HU3, HU4, or HU6 . .?;- ,S! 1. a. The occurrence of ANY of the following hazardous I'll U) events: CD . Seismic event (earthquake) C u
- i. .. Internal or external flooding event High winds or tornado strike
'Cl I'll N
.. FIRE EXPLOSION I'll Other events with similar hazard characteristics J: as determined by the Shift Manager AND
- b. Event damage has caused indications of degraded performance to one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.
AND C. EITHER of the following: Event damage has caused indications of degraded performance to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.
. OR Event damage has resulted in VISIBLE DAMAGE to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.
Modes: 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5- Refueling D-Defueled December 201 B COLD SHUTDOWN/REFUELING MATRIX NMP2-17 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Cold Shutdown / Refueling System Malfunctions CII CU3 Loss of Vital DC power for 15 minutes or longer. ffi[§
~
CL Emergency Action Level (EAL): 0 Note: The Emergency Director should declare the event C promptly upon determining that the applicable time has been exceeded, or will likely be exceeded. Voltage is < 105 VDC on required Vital DC buses 2BYS*SWG002A and 2BYS*SWG002B for 2!. 15 minutes. CU4 ffi[fil!g Table C1 Communication Capabilities Loss of all onsite or offsite communication capabilities. Svstem Onsite Offsite NRC Emergency Action Level (EAL): (I) Gaitronics X C 0 Hand Held 1. Loss of ALL Table C1 onsite communication Ill Portable Radio X capabilities affecting the abilityto perform routine u (Station Radio) operations. "i:
- I PBX OR E (Conventional X X X E Teleohone lines) 2. Loss of ALL Table C1 offsite communication 0 capabilities affecting the ability to perform offsite 0 Control Room notifications.
installed satellite X X OR phone (non portable) 3. Loss of ALL Table C1 NRG communication ENS X X capabilities affecting the ability to perform NRG RECS X notifications. CA5 ffi[§ CU5 ffi[§ Table C2 RCS Heat-up Duration Thresholds Inability to maintain plant in cold shutdown. UNPLANNED rise in RCS temperature. RCS Containment Heat-up Status Closure Status Duration Emergency Action Levels (EAL): Emergency Action Levels (EAL): Intact Not Apolicable 60 minutes* Note: .lie Established 20 minutes* . Note: The Emergency Director should declare the event promptly upon determining that the applicable time
. The Emergency Director should declare the event promptly upon determining that the applicable time C Not Intact has been exceeded, or will likely be exceeded.
has been exceeded, or will likely be exceeded. iii Ill CII
- c Not Established 0 minutes
. A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification. not warrant classification.
- If an RCS heat removal system is in operation within this time frame and RCS temperature is being 1. UNPLANNED rise in RCS temperature to > 200 °F 1. UNPLANNED rise in RCS temperature to > 200 °F.
reduced, then EAL #1 is not applicable. for> Table C2 duration. OR OR 2. Loss of the following for:!. 15 minutes.
- 2. UNPLANNED RCS pressure rise > 1 O psig as a result of temperature rise
. ALL RCS temperature indications AND Modes. 1 - Power Operation 2 - Startup 3 - Hot Shutdown 4 - Cold Shutdown 5 - Refueling D - Defueled
. ALL RPV water level indications December 2018 COLD SHUTDOWN/REFUELING MATRIX NMP 2-18 ' COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex COLD SHUTDOWN/REFUELING MATRIX COLDSHUTDDWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Cold Shutdown / Refueling System Malfunctions CG6 CS6 CA6 CU& Loss of RPV inventory affecting fuel clad integrity with Loss of RPV inventory affecting core decay heat removal Loss of RPV inventory. UNPLANNED loss of RPV inventory for 15 minutes containment challenged. capabilities. or longer. Emergency Action Level (EAL): Emergency Action Level (EAL): Emergency Action Level (EAL}: Emergency Action Level (EAL): Note: The Emergency Director should declare the event Note: The Emergency Director should declare the event Note: The Emergency Director should declare the event promptly upon determining that the applicable time Note: The Emergency Director should declare the event promptly upon determining that the applicable time promptly upon determining that the applicable time has been exceeded, or will likely be exceeded. promptly upon determining that the applicable time has been exceeded, or will likely be exceeded. has,been exceeded, or will likely be exceeded. has been exceeded, or will likely be exceeded.
- 1. Loss of RPV inventory as indicated by 1 a. RPV water level < -14 inches for :c:_ 30 minutes. 1. With CONTAINMENT CLOSURE!!!!! established, level < 108.8 inches. 1. UNPLANNED loss of reactor coolant results in the AND RPV water level < 17 .8 inches. inability to restore and maintain RPV level to above the OR OR procedurally established lower limit
- b. ANY Table C5 Containment Challenge Indication.
- 2. With CONTAINMENT CLOSURE established, RPV 2. a. RPV water level cannot be monitored for :c:_ 15 minutes.
OR water level < - 14 inches. for :c:_ 15 minutes. OR
- 2. a. RPV water level cannot be monitored OR AND for :c:. 30 minutes. 3. a. RPV water level cannot be monitored for 2. a. RPV water level cannot be monitored.
- b. Loss of RPV inventory per Table C4 indications.
AND :c:_ 30 minutes. AND
~ b. Core uncovery is indicated by ANY of the following: AND
.s C
- Table C4 indication of a sufficient magnitude
- b. Core uncovery is indicated by ANY of the
- b. Loss of RPV inventory per Table C4 indications .
following:
~ to indicate core uncovery.
a, en ca OR ANY Table C3 Refuel Floor Rad monitor
- c:_ 3 R/hr.
Table C4 indication of a sufficient magnitude to indicate core uncovery. OR ANY Table C3 Refuel Floor Rad monitor ca AND :c:_3 R/hr. GI ...I c. ANY Table C5 Containment Challenge Indication. ~ Table CJ Refuel Floor ARMs Table C4 Indications of RCS Leakage Table CS Containment Challenge Indications
- UNPLANNED Drywell equipment drain sump level
- 2RMS-RE111 rise*
- Primary Containment Hydrogen Concentration
- 2RMS-RE112
- UNPLANNED Drywell floor drain* sump level rise*
- c:_ 6% and Oxygen :c:. 5%
- 2RMS-RE113
- UNPLANNED Reactor Building equipment sump level
- UNPLANNED rise in containment pressure rise*
- 2RMS-RE114
- CONTAINMENT CLOSURE not established*
- UNPLANNED Reactor Building floor drain sump level rise*
- RB area radiation > 8.00 E+03 mR/hr
- UNPLANNED Suppression Pool level rise*
- If CONTAINMENT CLOSURE is re.-established prior
- UNPLANNED vessel make up rate rise* to exceeding the 30-minute core uncovery time limit,
- Observation of leakage or inventory loss then escalation to a General Emergency is not required.
*Rise in level is attributed to a loss of RPV inventory Modes: 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5- Refueling 0-Defueled December 2018 COLD SHUTDOWN/REFUELING MATRIX NMP2-19 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Plant Safety HS1 []~[fil@J[fil[g HA1 []~[fil@J[fil[g HU1 []~[fil@J[fil[g HOSTILE ACTION within the PROTECTED AREA. HOSTILE ACTION within the OWNER CONTROLLED Confirmed SECURITY CONDITION or threat. AREA or airborne attack threat within 30 minutes. EmergenCJl Action Level (EAL): EmergencJl Action Level (EAL): EmergencJl Action Level (EAL): A notification from the Security Supervisor that a HOSTILE 1. Notification of a credible security threat directed at C 0 ACTION is occurring or has occurred within the 1. A validated notification from NRC of an aircraft the site as determined per SY-AA-101-132, Security
- PROTECTED AREA. attack _threat < 30 minutes from the site. Assessment and Response to Unusual Activities.
u c( OR OR
~ 2. A validated notification from the NRC providing
- 2. Notification by the Security Supervisor that a information of an aircraft threat.
,n 0 HOSTILE ACTION is occurring or has occurred J: OR within the OWNER CONTROLLED AREA.
- 3. No_tification by the Security Supervisor of a SECURITY CONDITION that does not involve a HOSTILE ACTION.
HS2 []~[fil@J[fil[g HA2 II]~ [fil@J [fil [g Inability to control a key safety function from outside the Control Room evacuation resulting in transfer of plant Table H1 Safety Functions Control Room. control to alternate locations.
. Reactivity Control (ability to shutdown the reactor and keep it shutdown)
EmergencJl Action Level (EAL): EmergencJl Action Level (EAL): ec . RPV Water Level (ability to cool the core) Note: The Emergency Director should declare the event promptly upon determining that the applicable time has A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate 0
. been exceeded, or will likely be exceeded. locations per N2-SOP-78, Control Room Evacuation.
0 C ca RCS Heat Removal (ability to maintain a heat sink)
- 1. A Control Room evacuation has resulted in plant control
...a: being transferred from the Control Room to alternate 0
,n locations per N2-SOP-78, Control Room Evacuation .
AND C 2. Control of ANY Table H1 key safety function is not I! reestablished in< 15 minutes. I-Modes. 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5 - Refueling D-Defueled December 2018 COLD SHUTDOWN/REFUELING MATRIX NMP 2-20 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Plant Safety HU3 FIRE potentially degrading the level of safety of the plant. Emergency Action Level (EAL): Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- Escalation of the emergency classification level would be via IC CA2 or MAS
- 1. A FIRE in ANY Table H2 area is not extinguished in Table H2 Areas < 15 minutes of ANY of the following FIRE detection
. Reactor Building (when inerted the Drywell is exempt) indications:
- Report from the field (i.e., visual observation)
. Control Room
- Receipt of multiple (more than 1) fire alarms or
. Relay Room
- indications Field verification of a single fire alarm
. Diesel Generator Engine and Board Rooms OR I!!
ii: . Standby Switchgear and Battery Rooms
- 2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of a FIRE).
AND
. HPCS Switchgear and Battery Rooms
- b. The existence of a FIRE is not verified in
< 30 minutes of alarm receipt
. Remote Shutdown Rooms OR
. Control Building HVAC Rooms 3. A FIRE within the plant PROTECTED AREA not
. Electrical Protection Assembly Room extinguished in < 60 minutes of the initial report, alarm or indication.
. Service Water Pump Rooms 4.
OR A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish. Modes: 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5- Refueling D-Defueled December 2018 COLD SHUTDOWN/REFUELING MATRIX NMP2-21 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Plant Safety HU4 IIJ0@l@l@I[§ Seismic event greater than QBE levels. Emernency: Action Level (EAL): Note:
. For emergency classification if EAL # 2.b is not able to be confirmed, then the occurrence of a seismic event is confirmed in a manner deemed appropriate by the Shift Manager or Emergency Director in :, 15 minutes of
. the event Escalation of the emergency classification level would be via IC CA2 or MA5.
- 1. Seismic event > Operating Basis Earthquake (QBE) as indicated by:
. Computer Point ERSNC02, QBE Detected OR
~ GI
. ANY amber LED light lit at the Seismic Monitor Panel, Response Spectrum Annunciator.
ca
- s OR er
.c 2. When Seismic Monitoring Equipment is .!ll!! available: t:: ca a. Control Room personnel feel an actual or potential w seismic event. AND
- b. ANY one of the following confirmed in:, 15 minutes of the event:
. The earthquake resulted in Modified Mercalli Intensity (MMI)::. VI and occurred:, 3.5 miles of
.. the plant.
The earthquake was magnitude::. 6.0 The earthquake was magnitude::. 5.0 and occurred
- , 125 miles from the plant.
. If the above bullets are not able to be confirmed, then the occurrence of a seismic event is confirmed in a manner deemed appropriate by the Shift Manager or Emergency Director.
Modes: 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5- Refueling D- Defueled December 2018 COLD SHUTDOWN/REFUELING MATRIX NMP 2-22 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Plant Safety HAS ~n~rn Table H3 Gaseous release impeding access to equipment Areas with Entry Related Mode Applicability necessary for nonmal plant operations, cooldown or shutdown. Entry rn Emergencl£ Action Level (EAL}: ra Area Related C) Mode u Note: If the equipment in the listed room or area was Applicability 'i( already inoperable, or out of service, before the 0 Reactor Building event occurred, then no emergency classification I-175' RHS A Pump Room (RHR A) is warranted. 196' Az 56 Deg (RHR A) 1. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area. 175' RHS B Pump Room (RHR A & B) Mode 3, 4, and 5 AND Control Building 2. Entry into the room or area is prohibited or impeded 261' Div 1 Switchgear Room (RHR A & B) 261' Div 2 Switchgear Room (RHR A & B) HUS II]~@l@l@llg Hazardous Event Emergencl£ Action Level (EAL}: Note:
. EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.
.. . Escalation of the emergency classification level would be via IC CA2 or MA5 C GI w> 1. Tornado strike within the PROTECTED AREA. rn OR
- I 0 2. Internal room or area flooding of a magnitude sufficient to
...ra
'Cl require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical N ra Specifications for the current operating mode.
- c OR
- 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).
OR
- 4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles. -
OR
- 5. Intake Water Level < 237 feet.
Modes. 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5-Refuehng D-Defueled December 201 B COLD SHUTDOWN/REFUELING MATRIX NMP 2-23 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Plant Safety HG7 HS7 HA7 Other conditions exist which in the judgment of the Other conditions exist which in the judgment of the Other conditions exist which in the judgment of the Other conditions exist which in the judgment of the Emergency Director warrant declaration of a GENERAL Emergency Director warrant declaration of a SITE AREA Emergency Director warrant declaration of an ALERT. Emergency Director warrant declaration of an UNUSUAL EMERGENCY. EMERGENCY. EVENT. Emergency Action Level !EAL): Emergency Action Level (EAL): Emergency Action Level !EAL): Emergency Action Level !EAL): other conditions exist which, in the judgment of the Other conditions exist which in the judgment of.the Other conditions exist which in the judgment of the Emergency Director, indicate that events are in progress or other conditions exist which in the judgment of the Emergency Emergency Director indicate that events are in progress or Emergency Director indicate that events are in progress or have occurred which involve an actual or potential Director indicate that events are in progress or have occurred have occurred which involve actual or IMMINENT substantial have occurred which involve actual or likely major failures of substantial degradation of the level of safety of the plant or a which indicate a potential degradation of the level of safety of core degradation or melting with potential for loss of plant functions needed for protection of the public or HOSTILE security event that involves probable life threatening risk to the plant or indicate a security threat to facility protection has containment integrity or HOSTILE ACTION that results in an ACTION that results in intentional damage or malicious acts, site personnel or damage to site equipment because of been initiated. No releases of radioactive material requiring actual loss of physical control of the facility. Releases can be (1) toward site personnel or equipment that could lead to the HOSTILE ACTION. Any releases are expected to be limited offsite response or monitoring are expected unless further reasonably expected to exceed EPA Protective Action likely failure of or, (2) that prevent effective access to to small fractions of the EPA Protective Action Guideline degradation of safety systems occurs. Guideline exposure levels offsite for more than the immediate equipment needed for the protection of the public. Any exposure levels. site area. releases are not expected to result in exposure levels which 1: exceed EPA Protective Action Guideline exposure levels a, beyond the site boundary. E en ,:i ~ I!! c
~
C a, ei a, E w
/
Modes. 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5- Refueling D-Defueled December 2018 COLD SHUTDOWN/REFUELING MATRIX NMP 2-24 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Exelon Nuclear GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT ISFSI Malfunction E-HU1 [I]~@l@l[fil(g Damage to a loaded cask CONFINEMENT BOUNDARY. Emergency Action Level (EAL): Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading: For 61 BT DSC:
. > 800 mrem/hr 3 feet from the HSM surface
. OR
> 200 mrem/hr outside the HSM door on centerline of DSC
. OR
> 40 mrem/hr end of shield wall exterior For 61 BTH DSC:
. > 1400 mrem/hr on the HSM or HSM-H front surface cij . OR
> 200 mrem/hr on the HSM or HSM-H door centerline LL
~ . OR
> 40 mrem/hr on the end shield wall exterior Modes: 1 - Power Operation 2-Startup 3 - Hot Shutdown 4 - Cold Shutdown 5 - Refueling D-Defueled December 2018 COLD SHUTDOWN/REFUELING MATRIX NMP2-25 COLD SHUTDOWN/REFUELING MATRIX EP-AA-1013 Addendum 4 (Rev.3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RG1
- 1ijJtJ~!*it,d~Q!1_~]~9ri: :_ -___-_-_:_ :_* _*:*--~----::.~:.* :*: -_ --- :*~--- *:_
Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRem TEDE or 5000 mRem COE thyroid.
- cfp_~r~Hi,g_NfoijiAPPiJci-bill"tY~~-- -_- ~:*:*_ ~--~~-~-:-_:_ ~-~ _: -~--- ~--~- *:* __
1,2,3,4,5, D
- _~iTie.rgtin-~ii--A~tJ~~I~ey~} (~~tf ~- *_:*---~---~~-::*:-~ *:_-_-___ :___-- _---~:- _--_ -:*
Notes:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
- Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
- The pre-calculated effluent monitor values presented in EAL #1 (Table R1) should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1. Readings on ANY Table R1 Effluent Monitor> Table R1 value for~ 15 minutes.
OR
- 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- a. > 1000 mRem TEDE OR
- b. > 5000 mRem CDE Thyroid OR
- 3. Field survey results at or beyond the site boundary indicate EITHER:
- a. Gamma (closed window) dose rates> 1000 mR/hr are expected to continue for~ 60 minutes.
OR
- b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.
December 2018 NMP 2-26 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS/ RADIOLOGICAL EFFLUENT RG1 (cont)
- Emergency Action_LeveL(EAL)_(cont): ___________ __________________________________________ ,
Table R1 Effluent Monitor Thresholds Effluent Monitor General Emergency Radwaste/RB Vent Effluent (2RMS-PNL 180C) 4.80 E+07 µCi/sec Main Stack Effuent (2RMS-PNL 170C) 1.02 E+11 µCi/sec LBa_sis: ________ ------- -------------- ------------------ ------ -----------. --- ----------------- __ :_________ -------- This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public. Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at the EPA PAG of 1000 mRem while the 5000 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE. IBasfs_Reference(s): __ ____________________________________________ ~--------- ________ -_____ _
- 1. EP-EAL-0634, Calculation of Nine Mile Point Unit 2 Table R-1 EAL Threshold Values
- 2. CY-NM-170-301 Figure D.1.0-1
- 3. EP-AA-112-500-F-55, NMP Offsite Monitoring Team Guidance
- 4. EP-AA-110-200, Dose Assessment
- 5. EP-AA-110-201, On-Shift Dose Assessment
- 6. NEI 99-01 Rev 6, AG1 December 2018 NMP 2-27 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS/ RADIOLOGICAL EFFLUENT RS1 Release of gaseous radioactivity resulting in offsite'dose greater than 100 mRem TEDE or 500 mRem COE thyroid. l9.P~r~tiJ!9 nfl_o_d_e_AP~J!~~~ll!ty~--- _________________________________ .. ______ _ . _ ____ ____ __ _ __ ! 1,2,3,4,5, D ~Emergency Action_Level (EAL): ________________________________________________ . _________ _ Notes:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
- Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
- The pre-calculated effluent monitor values presented in EAL #1 (Table R1) should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1. Readings on ANY Table R1 Effluent Monitor> Table R1 value for~ 15 minutes.
OR
- 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- a. > 100 mRem TEDE OR
- b. > 500 mRem CDE Thyroid OR
- 3. Field survey results at or beyond the site boundary indicate EITHER:
a .. Gamma (closed window) dose rates> 100 mR/hr are expected to continue for~ 60 minutes. OR
- b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.
December 2018 NMP 2-28 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RS1 (cont)
- Emergency Action_Level (EAL)(cont):____ ____ __________________________________________________ _
Table R1 Effluent Monitor Thresholds Effluent Monitor Site Area Emergency Radwaste/RB Vent Effluent (2RMS-PNL 180C) 4.80 E+06 µCi/sec Main Stack Effuent (2RMS-PNL 170C) 1.02 E+10 µCi/sec
- Basis:
L: ____ --- -- **-- -- ---
---- ----*~----- * * - - - - -- - - - - -----*- ----- *---- -* .. ------ - - - - - -- - - - - - - - - - -- - - ---------- - - - - - - - - - -- - -
This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at 10% of the EPA PAG of 1000 mRem while the 500 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE. Escalation of the emergency classification level would be via IC RG1. ~Basis Reference(s): _________ ____
- ______________________________________________________ -____ :
- 1. EP-EAL-0634, Calculation of Nine Mile Point Unit 2 Table R-1 EAL Threshold Values
- 2. CY-NM-170-301 Figure D.1.0-1
- 3. EP-AA-112-500-F-55, NMP Offsite Monitoring Team Guidance
- 4. EP-AA-110-200, Dose Assessment
- 5. EP-AA-110-201, On-Shift Dose Assessment
- 6. NEI 99-01 Rev 6, AS1 December 2018 NMP 2-29 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS/ RADIOLOGICAL EFFLUENT RA1 Tnffiatfng-ccind-itk,-n: _-----_- __ --- -_--_ -- _---- _- - _--- -___ ------- -_-_-_---_ -___---- -_. -----__ --- - -- --------1 Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRem TEDE or 50 mRem COE thyroid.
- operating Mode Applicability~--_________ ___ _ _________________________________________ -
1, 2, 3, 4, 5, D
- Emergency Action Level (EAL)
- __ _________________________________
Notes:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
- Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
- The pre-calculated effluent monitor values presented in EAL #1 (Table R1) should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1. Readings on ANY Table R1 Effluent Monitor> Table R1 value for~ 15 minutes.
OR
- 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- a. > 10 mRem TEDE OR
- b. > 50 mRem CDE Thyroid OR
- 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary:
- a. 10 mRem TEDE for 60 minutes of exposure OR
- b. 50 mRem CDE Thyroid for 60 minutes of exposure OR December 2018 NMP 2-30 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS/ RADIOLOGICAL EFFLUENT RA1 (cont)
- Emergency Action Level(EAL)(cont}: ___________________ --------------------------*- ________ ,
- 4. Field survey results at or beyond the site boundary indicate EITHER:
- a. Gamma (closed window) dose rates > 10 mR/hr are expected to continue for~ 60 minutes.
OR
- b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.
Table R1 Effluent Monitor Thresholds Effluent Monitor Alert Radwaste/RB Vent Effluent (2RMS-PNL1SOC) 4.80 E+05 µCi/sec Main Stack Effuent (2RMS-PNL 170C) 1.02 E+09 µCi/sec ~!l~i~;--==-=:-~:~:-~~:~=---~~~=~---==-~-=-~~=----=~~:==-~ =:-==-=- ---==~~_-__ :_:.~=~-- - -~==-~-~ This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release). Radiological effluent EALs are also included to provide a basis* for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at 1% of the EPA PAG of 1000 mRem while the 50 mRem thyroid COE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid COE. Escalation of the emergency classification level would be via IC RS1. December 2018 NMP 2-31 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RA1 (cont) '~~~J~--~~f-~r~!l-~~-(~);__ _ __ _ ___ _ _ __ ___ _ ___ __ _____________________________ _
- 1. EP-EAL-0634, Calculation of Nine Mile Point Unit 2 Table R-1 EAL Threshold Values
- 2. CY-NM-170-301 Figure D.1.0-1
- 3. EP-AA-112-500-F-55, NMP Offsite Monitoring Team Guidance
- 4. EP-AA-110-200, Dose Assessment
- 5. EP-AA-110-201, On-Shift Dose Assessment
- 6. NEI 99-01 Rev 6, AA 1 December 2018 NMP 2-32 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RU1 )ri1tiating--conii1iion:-- - - --- -__ ---- -- - -_----- ---____-_--~~-:: _-: ~--~ ~=~-- --:--~- -~- ==-~-~-:~-~ ~:_::-_:_--_---=~- , Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.
- operating _Mode Applicability:_ ___ ____ _ _ ____ ___ ___________ ____ __ ___ __ _____ __ _____ __ _ ___
1,2,3,4,5, D
- Emergency Action Level_(EAL); ___ _______________________________________________________________
Notes:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.
- Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
- 1. Reading on the Liquid Radwaste Effluent Monitor (LWS-RE206) > 2 times ORMS High (red) established by a current radioactive release discharge permit for~ 60 minutes.
OR
- 2. Readings on ANY Table R1 Effluent Monitor> Table R1 value for~ 60 minutes:
Table R1 Effluent Monitor Thresholds Effluent Monitor Unusual Event Radwaste/RB Vent Effluent (2RMS-PNL 1BOC) 1.69 E+05 µCi/sec Main Stack Effuent (2RMS-PNL 170C) 7.12 E+05 µCi/sec OR
- 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of~ 60 minutes.
December 2018 NMP 2-33 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS/ RADIOLOGICAL EFFLUENT RU1 (cont) ,Basis: This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared. Nuclear power plants incorporate design features intended to control the release of radioa.ctive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive- release to the environment is indicative of degradation in these features and/or controls. Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL. EAL#1 Basis This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas). The effluent monitor listed is normally used for planned discharges.
\
EAL#2 Basis This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous effluent pathways. EAL#3 Basis This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.). Escalation of the emergency classification level would be via IC RA 1. December 2018 NMP 2-34 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT RU1 (cont)
- eas1s-Reference(s): -- ---_------- --- -___ ---_--- ------ _- __ --------------~---_-------- ------ ___ --------- --_-*;
- 1. EP-EAL-0634, Calculation of Nine Mile Point Unit 2 Table R-1 EAL Threshold Values
- 2. CY-NM-170-301 Figure D.1.0-1
- 3. N2-0P-79, Radiation Monitoring System
- 4. NEI 99-01 Rev 6, AU1 December 2018 NMP 2-35 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT
- 1n1tfaiing-Conditio"r1: _~- -~~~~=:~~ =---~~:-~. __ - ~~ -= _- --~-~--~:--~--~-:-~------- -_-* - *-- -_*--___ ----- _-- RG2 Spent fuel pool level cannot be restored to at least 330 feet for 60 minutes or longer.
(Operating_Mode Applicability: _________ .__________________________________________ *___ __ 1, 2, 3, 4, 5, D
- Emergency Action Level (EAL): ________ ___________________________________________________________________ _
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
Spent fuel pool level cannot be restored to at least 330 feet as indicated on 2SFC-Ll413A or B for?_ 60 minutes. Basis: This IC addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment. Level indicators 2SFC-Ll413A and Bare located in Control Building 306 elevation West and East Cable Chases. It is recognized that this IC would likely not be met until well after another General Emergency IC was met; however, it is included to provide classification diversity . .~a~i_s_l~ef~~~I}<:~(~)_:_ __ ______ ___ _____ ____ ....... ___ . _____________ _
- 1. NER-2M-039, NMP2 Emergency Operating Procedures and Severe Accident Procedures (EOP/SAP) Basis Document
- 2. NEI 99-01 Rev 6, AG2 December 2018 NMP 2-36 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS/ RADIOLOGICAL EFFLUENT RS2
~Ql!i~ii~_g_ 9<>ndiJlc;>_n_: ----- --- _.. _ ___ __
Spent fuel pool level at 330 feet !Operating_ModeAppJicability~ ________________________________ _ 1, 2, 3, 4, 5, D 1 Emergency Action LeveL(EAL): ___________
- _____________________________________________ _
Lowering of spent fuel pool level to 330 feet as indicated on 2SFC-Ll413A or B. !Basis: This IC addresses a significant loss of spent fuel pool inventory control and makeup capability leading to IMMINENT fuel damage. This condition entails major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration. Level indicators 2SFC-Ll413A and B are located in Control Building 306 elevation West and East Cable Chases. It is recognized that this IC would likely not be met until well after another Site Area Emergency IC was met; however, it is included to provide classification diversity. Escalation of the emergency classification level would be via IC RG1 or RG2. ,E3~~i~R~f~r~mc~.(~)__: __________ . __ . _ __________ _____ __ __ . ___ .. __ _
- 1. NER-2M-039, NMP2 Emergency Operating Procedures and Severe Accident Procedures (EOP/SAP) Basis Document
- 2. NEI 99-01 Rev 6, AS2 December 2018 NMP 2-37 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS/ RADIOLOGICAL EFFLUENT RA2 Jnitiating Condition: ________________________________________________________________________________________ ; Significant lowering of water level above, or damage to, irradiated fuel.
- Operating Mode AppHcability: ____________________________________________ *____________________________*
1,2,3,4,5, D lEmergencyAction Level(EAL): _ ----------- __________________________________________________ *
- 1. Uncovery of irradiated fuel in the REFUELING PATHWAY.
OR
- 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R2 Radiation Monitor Alarm.
OR
- 3. Lowering of spent fuel pool level to 340 feet as indicated on 2SFC-Ll413A or B.
Table R2 Refuel Flo9r Radiation Monitors
- 2RMS--RE111
- 2RMS-RE112
- 2RMS-RE113
- 2RMS-RE114
- 2HVR*RE14A
- 2HVR*RE14B
~asis: ________________________________________________________________________________________________________ _ REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.
- IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.
CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment. This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly or a significant lowering of water level within the spent fuel pool. December 2018 NMP 2-38 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT
- Basis _(cont): ___ ____________________ . ___ __ ____ __ _______ _____ _____ _ ____________________ . .. ______ _
These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant. This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1. EAL #1 Basis This EAL escalates from RU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations. While an area radiation monitor could detect a rise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss. A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes. EAL#2 Basis This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction With in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident). EAL #3 Basis: Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool. Level indicators 2SFC-Ll413A and B are located in Control Building 306 elevation West and East Cable Chases. Escalation of the emergency would be based on either Recognition Category R or C ICs. December 2018 NMP 2-39 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS/ RADIOLOGICAL EFFLUENT RA2 (cont)
- Basis Reference(s): __________ _________________________________________________________________________*
- 1. NER-2M-039, NMP2 Emergency Operating Procedures and Severe Accident Procedures (EOP/SAP) Basis Document
- 2. N2-SOP-39 Refuel Floor Events
- 3. N2-ARP-01 Annunciator Response Procedures for annunciator 851254
- 4. USAR Section 9.1.2
- 5. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.7.6
- 6. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.9.6
- 7. NEI 99-01 Rev 6, AA2 December 2018 NMP 2-40 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS/ RADIOLOGICAL EFFLUENT RU2 T~)i~ti~g~g<?~-~*!ii~J:_ -_:----~-~::: ~- - ~ -_-: _:--:--~-~- ~~~ ~~~-~ --~- ~~-~~~~ ~~- ~~ _ -:_: _-~_ -_ --~---- ~ ~=-~~~-- - - 1 UNPLANNED loss of water level above irradiated fuel. . !Op~rating Mode Applicability:_ _ ___ _ _ __________________________ -- _ __________ -=--- ~ ~--~~ 1, 2, 3, 4, 5, D
!Emergency Action Level (EAL):_______ ____ _____ ____ _ ____ _______________ ______ ___ _____ ______ i
- 1. - a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following:
- Inability to restore and maintain Spent Fuel Pool water level
> low water level alarm.
OR
- Indication or report of a drop in water level in the REFUELING PATHWAY.
AND
- b. UNPLANNED Area Radiation Monitor reading rise on ANY Table R2 radiation monitor.
Table R2 Refuel Floor Radiation Monitors
- 2RMS-RE111
- 2RMS-RE112
- 2RMS-RE113
- 2RMS-RE114
- 2HVR*RE14A
- 2HVR*RE14B
- easis_:_ - ----_ ---
UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange. This IC addresses a loss in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also December 2018 NMP 2-41 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS/ RADIOLOGICAL EFFLUENT RU2 (cont)
- sasis~(con-t)
- ___ ------ ------~--~~~~~~~ __ -----_ --- ---_-_ ----- __ -------- ----__ -- --_-- --- -__ ----- _-- --- --------:_ -,
indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant. A water level loss will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available) or from any other temporarily installed monitoring instrumentation. A significant drop in the water level may also cause a rise in the radiation levels of adjacent areas that can be detected by monitors in those locations. The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may rise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level. A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes. Escalation of the emergency classification level would be via IC RA2.
- easfsReterence(s):________ -____ ----------- ---- _______ --_-----~-~::- ___________ ~-::~-~-~~- ___
- 1. USAR Section 9.1.2
- 2. N2-ARP-01 Annunciator Response Procedures for annunciator 873317
- 3. N2-ARP-01 Annunciator Response Procedures for annunciator 875117
- 4. N2-0P-38 Spent Fuel Pool Cooling and Cleanup System
- 5. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.7.6 6 Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.9.6
- 7. N2-SOP-39 Refuel Floor Events
- 8. N2-ARP-851100, 2CEC*PNL851 Series 100 Alarm Response Procedures
- 9. NEI 99-01 Rev 6, AU2 December 2018 NMP 2-42 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS/ RADIOLOGICAL EFFLUENT RA3 1
- initiating ConditiQI!: ___________________________________________________
- ________ -----------*----------*
Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.
- operating MQde _Applicability
- ____ . ______________________ -*-------------------*-*------------- ________ _
1,2,3,4,5, D 1EmergencyAction_Level(EAL):____________ **---*--*------ __________________________
- ___ ;
Note:
- If the equipmenfin (he room or area listed in Table R4 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.
- 1. Dose rate > 15 mR/hr in ANY of the areas in Table R3.
Table R3
- Main Control Room
- Central Alarm Station - (by survey)
OR
- 2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the areas in Table R4.
Table R4 Areas with Entry Related Mode Applicability Entry Related Mode Area Applicability Reactor Building 175' RHS A Pump Room (RHR A) 196' Az 56 Deg (RHR A) 175' RHS B Pump Room (RHR A & B) Mode 3, 4, and 5 Control Building 261' Div 1 Switchgear Room (RHR A & B) 261' Div 2 Switchgear Room (RHR A & B) December 2018 NMP 2-43 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS/ RADIOLOGICAL EFFLUENT RA3 (cont) .Basis: UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedures. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the increased radiation levels and determine if another IC may be applicable. Table R4 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown. This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections). Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including the Control Room. For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the elevated radiation levels preclude the ability to place shutdown cooling in service. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding beyond that required by procedures, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits). An emergency declaration is not warranted if any of the following conditions apply.
- The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation rise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.
- The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.).
December 2018 NMP 2-44 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS/ RADIOLOGICAL EFFLUENT RA3 (cont) [Basis_(cont): . _________________________ ~-=-~~-~-~~=-~~~--~-==~~~~=~-~-~-=-==~::-~-=~=~-~-~==-=~:==~~
- The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
- The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.
- Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.
- easis_ Referenca(s): _______________________________________________ *---- _____
- 1. N2-ARP-01 Annunciator Response Procedures for annunciator 851246
- 2. NEI 99-01 Rev 6, AA3 December 2018 NMP 2-45 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS/ RADIOLOGICAL EFFLUENT RU3 J~iti_~tJr:-g _c;:o~gJtior1: _____________________________ _ Reactor coolant activity greater than Technical Specification allowable limits. '_9~r~fiijg ~MO::~e Ap-pti_~aijf!Jty~-:_-::: = - : __ -_____ :- -_ -: : _::~~~- :-=~::_ :=---~ -:-___--::-:-: _- __-_: ~--: :-:--~:~:, 1,2,3 /Emergency Action Level (EAL): _ _______________________________________________________________ :
- 1. Offgas radiation ORMS high (red) alarm for:: 15 minutes.
OR
- 2. Specific coolant activity> 4.0 µCi/gm Dose Equivalent 1-131.
- Basis:
. --------- -* --- - - --- -* - --- -------- ---- - - *- -- .. ---- - -- - - -~ ---- - --- - ---- --------- ---- -----------* This IC addresses a reactor coolant activity value _that exceeds an allowable limit specified in Technical Specifications. This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant. This EAL addresses site-specific radiation monitor readings that provide indication of a degradation of fuel clad integrity. Escalation of the emergency classification level would be via ICs FA 1 or the Recognition Category R ICs.
- ~i~f~~-~efijrenc_e(s): - -:-_ -=-~-::--=_:-::--:-_:-_-_ -: --~--- =----=:=-~- _:--:_-~----_:--: ::_:----~::-_: _-:_~-=-~
- 1. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.4.8
- 2. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.4.8.A.1
- 3. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No.2, 3.7.4
- 4. N2-ARP-01 Annunciator Response Procedures for annunciator 851253
- 5. N2-ARP-01 Annunciator Response Procedures for annunciator 851326
- 6. N2-SOP-17 Fuel Failure or High Activity in Rx Coolant or Offgas
- 7. CY-NM-170-301 Section 3.3.2
- 8. NEI 99-01 Rev 6, SU3 December 2018 NMP 2-46 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FG1 f1Dit1ati~g_¢_Qi!-~it!C?-r:i;_--- _:- ~--- -~:- -~ ---~-~- _:_~ --___ - --~~ :--=- ~--:_- _-::: ~- -~- ___ :-___-_--____ _ Loss of ANY two barriers AND Loss or Potential Loss of the third barrier. ,pp~rat_ing M_ode AppJicability: ___________________________________________________ _ 1,2,3 ,~m~rgencyAction_ Level _(EAL): __ ______ - ___________________ -___ - ____ -______ -_--~~ ~-~---_-_-_-_-:-::__~_ -_ Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.
- Basis: ____________________________________________________________________ ______________________ _
Fuel Cladding, RCS and Containment comprise the fission product barriers. At the General Emergency classification level each barrier is weighted equally.
- easis Reference(s): _- -- ~---:::~~-- -~-:-- --_-_- _- -~- ----__---_---: --_-_-_-_ -_-___-_ --_ __ ___
- 1. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-47 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FS1 llrJi1la_!!ng_9p~~iJ:~QI}_: __ ___ __ __ ____ __ __ ____ _________ _ Loss or Potential Loss of ANY two barriers.
- c;>pe~~,i_ng_~Qd~ ~ppl!c~_~il_iW; __
1, 2, 3 ~Emergency ActionJ..ev~I (EALt_ __ _ ___ ___ ____ _ ____ __ ____ _ ____________________________ _ Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status. 'Basis: Fuel Cladding, RCS and Containment comprise the fission product barriers. At the Site Area Emergency classification level, each barrier is weighted equally.
- sasfs_Reterence(s>=*---- ----- --_-- --- _- --- _ -------- --_ -----_-_- ---- ---------- -------_--_-----____-- -_-,
- 1. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-48 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FA1 rl_n_jt_l~li~g--~~!l~_i!ip_a:,~_ -----~- _____ _ _ __ ____ __ ____ ____ ___ __ _ ______ ____ __ ___ ___ _______ ___ ___ __: ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.
- operating Mode_Applicabilify: ____ _ ____________________________________________ -----*
1, 2, 3
- Emergency Action Level(EAL); _______________________________________________________ - ___ ---~
Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.
- Basis: -
Fuel Cladding, RCS and Containment comprise the fission product barriers. At the Alert classification level,. Fuel Cladding and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability. Note that the loss or potential loss of Containment barrier in combination with loss or potential loss of either Fuel Cladding or RCS barrier results in declaration of a Site Area Emergency under EAL FS1. !Basis Reference(s): ___ ___________ ------*
- 1. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-49 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex . Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC1 ilnitiating_ Condition: __________________________________________________________________________________ RCS Activity 1 0perating_Mode Applicability: ___________ _______ _ 1, 2, 3 !Fission Product Barrier_(FPB) Threshold: ________________ ______
- _________________________
- _'
LOSS Coolant activity> 300 uCi/gm Dose Equivalent 1-131.
- Basis:
This threshold indicates that RCS radioactivity concentration is greater than 300 µCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier. It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications. There is no Potential Loss threshold associated with RCS Activity. [~aj~~ 1\~fEifr~n-~i(~}:: :_:*-:* _ :~-~-~ ~~ -~ =~-~- =--~~:___ ~~-~: ____-. _-_ _:--~~--~- - -~- -.~ - - * :_:* :*_- :*:-* -~------ -----
- 1. General Electric NED0-22215, Procedures for the Determination of the Extent of Core Damage Under Accident Conditions
- 2. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-50 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station .Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 !Initiating Condition: RPV Water Level J;fP~fitfr*g_M-o!!~~P~fic_~_~JffW::_:-_:=-~-- -_: *--~ :::*__*----~ ~~-=- ~~==--:= -=:-=*~:_:_ -~=- ~--~~--__---: ___--_~*.:=-=--~- 1, 2, 3 Fission Product Barrier(FPB) Threshold: ___ _________________________ - -~=-~=:~=--~~=--~-~~ LOSS
- 1. SAP entry required.
POTENTIAL LOSS
- 2. RPV water level cannot be restored and maintained> -14 inches (TAF).
OR
- 3. RPV water level cannot be determined.
iBasis: ___ _ RPV values are actual levels, not indicated levels. Therefore, they may need level compensation depending on conditions. Compensated values may be used in accordance with the EOP/SAP program. Loss Threshold #1 Basis The Loss threshold represents the EOP requirement for SAP entry. This is identified in the BWROG EPGs/SAGs when the phrase, "Enter SAPs," appears. Since a site-specific RPV water level is not specified here, the Loss threshold phrase, "SAP entry required," also accommodates the EOP need to enter SAPs when RPV water level cannot be determined and core damage, due to inadequate core cooling is believed to be occurring. Potential Loss Threshold #2 and #3 Basis This water level corresponds to the top of the active fuel and is used in the EOPs to indicate a challenge to core cooling. The RPV water level threshold is the same as RCS Barrier RC2 Loss threshold. Thus, this threshold indicates a Potential Loss of the Fuel Clad barrier and a Loss of the RCS barrier that appropriately escalates the emergency classification level to a Site Area Emergency. This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV water level cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization. EOPs allow the operator a wide December 2018 NMP 2-51 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION
***-**-***--*------*** _FC2Jcont)
]!~_~Js* l~ci11t~- :~: :~ ~ -~ -_: ~- :.~ *~--::*~ -~-~-.~ ~-:-~ ~ *__ =-* **: _-~ *____ _ __________._ ____ ___ __.... _ __ _ ___ __ choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this Fuel Clad barrier Potential Loss is met only after either: 1) the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory. The term "cannot be restored and maintained above" means the value of RPV water level is not able to be brought above the specified limit (top of active fuel). The determination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation below the limit; the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained. Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to "restore and maintain" level above TAF resulting in this threshold being met. In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level in order to reduce reactor power. Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority. For such events, ICs MA3 or MS3 will dictate the need for emergency classification. Since the loss of ability to determine if adequate core cooling is being provided presents a significant challenge to the fuel clad barrier, a potential loss of the fuel clad barrier is specified.
- ~asl~ R~!~r~n_ce{!
- 5):___ __ *- _____ . ___ ___ _____ _ . ---*-*--* ..... ____ -**. _______ __ _ _______ ..
- 1. NER-2M-039, NMP2 Emergency Operating Procedures (EOP) Basis Document
- 2. N2-EOP-C4 RPV Flooding
- 3. N2-EOP-C5 Failure to Scram
- 4. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-52 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC5 )riitTuting_ concfition:-- _-- --_-_- __ -_---- *__ --
- __ -_-- --- ---_--- _----_- ----- -__ -- ------ * -- ------ --_ === -~:=-~--:--~:~-~-,
Primary Containment Radiation ,Qp_~r~tin_g__~e>g~ -~p_pli~~Pi_l_lty_;____ ______ ______ _ ______________________________________________ ) 1, 2, 3 tFiss_icm_Product Barrier (FPB) Threshold: _______________ ________________________________________ *, LOSS Drywell area radiation monitor reading > 1.4 E+03 R/hr (1.4 E+06 mR/hr).
- Basis:
The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals 300 µCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier. The radiation monitor reading in this threshold is higher than that specified for RCS Barrier RCS Loss Threshold since it indicates a loss of both the Fuel Clad Barrier and the RCS Barrier. Note that a combination of the two thresholds appropriately escalates the emergency classification level to a Site Area Emergency. There is no Fuel Clad Barrier Potential Loss threshold associated with Primary Containment Radiation.
- 1. EP-EAL-0716, Criteria for Choosing Containment Radiation Values Indicating a Loss of Fuel Clad and a Potential Loss of Containment for Nine Mile Point Station Unit 2
- 2. NEI 99-01 Rev 6; Table 9-F-2 December 2018 NMP 2-53 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC7 Emergency Director Judgment.
- .9~eJ~~i~9-~9-c!~-~~p!i_~c!_~!_li_ty~_ ________________________ : ~~~---:-~:-~::~-
1, 2, 3 .Fission Product Barri~r (FPB) Threshold: _ ___ _____ ____ _ ___ ___ ___ _ _ ______ __ __ ___ _ LOSS
- 1. ANY condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.
POTENTIAL LOSS
- 2. ANY condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.
- ~i~~ij=-=~:~.:=*-* :~.:~~---=----=--=~-~---~:_-_-_---~:-~ _:*:_ *:=:-~ -_---_- -~-~---- ~----~--~ ~-__ -:_ -: : . - _ - .
Loss Threshold #1 Basis This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad Barrier is lost. Potential Loss Threshold #2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored. E!~st!; ~eJ~r:_e~~_e(~): ______________ _
- 1. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-54 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION r*---------- -- --- ------~--------- -- ---------- - ---------- -----------------------------------. RC2 ' 1lnitiating_Condition: _________ ________________________________________________ ._________________________ , RPV Water Level ,Operating Mode_Applicability: ___________________________________________________________ _ 1,2,3 !Fission Product_Barrier (FPB)Threshold:_____ ____ ________ ___ _ _________________________ _ LOSS
- 1. RPV water level cannot be restored and maintained> -14 inches (TAF)
OR
- 2. RPV water level cannot be determined.
- ~~Si~: ____ __________________________________________________________________________________________ _
RPV values are actual levels, not indicated levels. Therefore, they may need level compensation depending on conditions. Compensated values may be used in accordance with the EOP/SAP program. This water level corresponds to the Top of Active Fuel (TAF) and is used in the EOPs to indicate challenge to core cooling. The RPV water level threshold is the same as Fuel Clad Barrier FC2 Potential Loss threshold. Thus, this threshold indicates a Loss of the RCS barrier and Potential Loss of the Fuel Clad barrier and that appropriately escalates the emergency classification level to a Site Area Emergency. This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV water level cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this RCS barrier Loss is met only after either: 1) the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory. December 2018 NMP 2-55 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION
- ~~~Ij]~Qijff:=--- _ -~ -~ _- __--_- _-__ -__ -~ ---__ ~---- - :~-----=- - _-_-:-~ -_:_ ----~- _-_ -= ~:-
RC2 (cont)
~::-__ :_ :__ -=~---~- _ :=:-~ _ :_-_ :~= _ -_:-_.
The term, "cannot be restored and maintained above," means the value of RPV water level is not able to be brought above the specified limit (top of active fuel). The determination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active . fuel, but does not permit extended operation beyond the limit; the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained. Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to "restore and maintain" level above TAF resulting in this threshold being met. In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level in order to reduce reactor power. Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority. For such events, ICs MA3 or MS3 will dictate the need for emergency classification. There .is no RCS Potential Loss threshold associated with RPV Water Level.
'Basis Reference(s); _________________________________________________________
- ____________________
- 1. NER-2M-039, NMP2 Emergency Operating Procedures (EOP) Basis Document
- 2. N2-EOP-C4 RPV Flooding
- 3. N2-EOP-C5 Failure to Scram
- 4. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-56 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC3 Primary Containment Pressure I Conditions
- OperatingModeApplicability; *-*-- ___ ___ ____ _ ______________________________
1, 2, 3
- i=issfori Product Barrier_(FPB)Threshold: __ . _____ . _-_ ~~=:*:_ _~~--=-*:*---~ :-~- ----- - . ~- ~*=-=~~ ~.
LOSS 1 . a. Primary Containment pressure > 1.68 psig. AND
- b. Primary Containment pressure rise is due to RCS leakage The > 1.68 psig primary containment pressure is the Drywell high pressure setpoint which indicates a LOCA by automatically initiating ECCS.
The second threshold condition focuses the fission product barrier loss threshold on a failure of the RCS instead of the non-LOCA malfunctions that may adversely affect primary containment pressure. Pressures of this magnitude can be caused by non-LOCA events such as a loss of Drywell cooling or inability to control primary containment vent/purge. The release of mass from the RCS due to the as-designed/expected operation of any relief valve does not warrant an emergency classification. A stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is not applicable to this EAL. There is no Potential Loss threshold associated with Primary Containment Pressure. !~~~~=R~t~~ficj(~>; ~:-_:* :~~~--_-::-:::-_~:_:__--_:*- _~:
- ___ :- _-*- -_ -__ *:**- --_---~.~ _*:*_ -:__
- 1. N2-EOP RPV RPV Control
- 2. N2-EOP-PC Primary Containment Control
- 3. NER-2M-039, NMP2 Emergency Operating Procedures (EOP) Basis Document
- 4. USAR Section 6.2
- 5. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-57 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC4 [foitiaiin~i condition:-_------- _- ---- _---- -- -__ ---- -- __ --- __ ---_---- __--- ----- ------- ----- --_-_ --- _-__ ---- --- --: RCS Leak Rate [9p~rc1ti~g_M~g-~APP]~~biJ!!Y~-- _________________________________________________________ _ 1,2,3 Fission Product Barrier (FPB)_Threshold: ____________________________________________________________ r LOSS
- 1. UNISOLABLE Main Steam Line (MSL), RCIC, Feedwater, or WCS line break.
OR
- 2. RPV Slowdown is required.
POTENTIAL LOSS
- 3. UNISOLABLE primary system leakage that results in EITHER of the following:
- a. RB area temperature above an isolation setpoint.
OR
- b. RB area radiation above an alarm setpoint.
iBasis: ___ ______________________________ -___________________- ____ --__ -___________________________________ UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally. Failure to isolate the leak, within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification. Classification of a system break over system leakage is based on information available to the Control Room from the event. Indications that should be considered are:
- Reports describing magnitude of steam or water release.
- Use of system high flow alarms I indications, if available,
- Significant changes in makeup requirements,
- Abnormal reactor water level changes in response to the event.
The use of the above indications provides the Control Room the bases to determine that the on going event is more significant than the indications that would be expected from system leakage and therefore should be considered a system break. December 2018 NMP 2-58 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION ___ RC4 (cont}
- easis ~(cont);"~----~~-~~ -~~-=~~~ -~-=-~~--:----~~~-~~----~:_*_ _-~- : *_ ~--~:*:~----~---- ~-:-~~- - ------ -- -------- ---- _,
Loss Threshold #1 Basis Large high-energy lines that rupture outside primary containment can discharge significant amounts of inventory and jeopardize the pressure-retaining capability of the RCS until they are isolated. If it is determined that the ruptured line cannot be promptly isolated, the RCS barrier Loss threshold is met. Even though WCS and Feedwater systems do not contain steam, they are included in the list because an UNISOLABLE break could result in the high-pressure discharge of fluid that is flashed to steam from relatively large volume systems directly connected to the RCS. Loss Threshold #2 Basis RPV Slowdown (Emergency RPV Depressurization) in accordance with the EOPs is indicative of a loss of the RCS barrier. If Emergency RPV Depressurization is performed, the plant operators are directed to open safety relief valves (SRVs) and keep them open. Even though the RCS is being vented into the suppression pool, a Loss of the RCS barrier exists due to the diminished effectiveness of the RCS to retain fission products within its boundary. Potential Loss Threshold #3 Basis Potential loss of RCS based on primary system leakage outside the primary containment is determined from RB temperature isolation setpoint or radiation alarm setpoint values such as in areas that contain piping associated with main steam line, RCIC, Feedwater, WCS, etc., which indicate a direct path from the RCS to areas outside primary containment. A RB temperature isolation setpoint or radiation alarm setpoint value is the highest value of the identified parameter expected to occur during normal plant operating conditions with all directly associated support -, and control systems functioning properly. The indicators reaching the threshold barriers and confirmed to be caused by RCS leakage from a primary system warrant an Alert classification. A primary system is considered to be the pipes, valves, and other equipment which connect directly to the RPV such that a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system. In general, multiple indications should be used to determine if a primary system is discharging outside Primary Containment. For example, a high area radiation condition does not necessarily indicate that a primary system is discharging into the Reactor Building since this may be caused by radiation shine from nearby steam lines or the movement of radioactive materials. Conversely, a high area radiation condition in conjunction with other indications (e.g. room flooding, high area temperatures, reports of steam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpected December 2018 NMP 2-59 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Main Turbine Control Valve closure) may indicate that a primary system is discharging into the Reactor Building. An UNISOLABLE leak which is indicated by temperature isolation setpoint or radiation alarm setpoint values escalates to a Site Area Emergency when combined with Containment Barrier CT6 Loss Threshold #1 (after a containment isolation) and a General Emergency when the Fuel Clad Barrier criteria is also exceeded.
- Basis_Reference(s)
- _ _
- _'. __ *_*_-_-__: ______ -_-_:-~ -~ - --_-_-: _:~--~:: _---__-_ ~-: __ _
- 1. USAR Section 5.4.5
- 2. USAR Section 5.4.6
- 3. USAR Section 5.4.8
- 4. USAR Section 5.4.9
- 5. N2-EOP-RPV RPV Control
- 6. N2-EOP-PC primary Containment Control
- 7. N2-EOP-SC Secondary Containment Control
- 8. N2-EOP-RR Radioactivity Release Control
- 9. N2-EOP-PCH Hydrogen Control
- 10. N2-EOP-C3 Steam Cooling
- 11. N2-EOP-C5 Failure to Scram
- 12. N2-EOP-C4 RPV Flooding
- 13. NER-2M-039, NMP2 Emergency Operating Procedures (EOP) Basis Document
- 14. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-60 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RCS Primary Containment Radiation (Qp~ratingJ~1~~Je-~~~pffc~6fiify~ --~-- - - ~- ~:-----~----~:-~ --__ ---~-~: -=-:~ - ~-~ -~~--: ~--: ~ ~-- _-_: __:=*-------~ 1,2,3
- ffss_1_~*ri_P~<?~~~t~ifrr1~f ti:~~t-:fhr~sJipJcf ~-~----~--:~~~--~--: *_:: :-~-~~-~~:: _~_-_- ~ ~ ~~-----~-~:-~~~=- - -~
LOSS Drywell radiation monitor reading> 100 R/hr (1.0 E+05 mR/hr).
- ~c!~_is
- ______ ________________ *-----**---- ________________________________________________________________ J The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier FC5 Loss Threshold since it indicates a loss of the RCS Barrier only.
There is no RCS Potential Loss threshold associated with Primary Containment Radiation. [Basis_Reference(s); __ _________ - _________________________________________ ------*--**----*-- ________ _
- 1. EP-EAL-0514, Criteria for Choosing Drywell Radiation Monitor Reading Indicative of Loss of the RCS Barrier for NMP U2
- 2. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-61 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear - RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC7 [Initiating Condition:_ _________ __ ___ ____ ___ _ _____________ ________ ____________ -___ - _______ - ____ - ... *: Emergency Director Judgment. '.O~erating Mode Applicability;__ _______ _ ___________________________________________________ - - ----~ : 1, 2, 3 ifission Product BarrieL(FPB) Threshold: . _____________________________ -______ - i LOSS
- 1. ANY condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.
POTENTIAL LOSS
- 2. ANY condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.
lBasis:_ _______ -----------*---------*---- _________________________ ,. _______________ ----*--*-----*--------~- Loss Threshold #1 Basis This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the RCS Barrier is lost. Potential Loss Threshold #2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored. ~Basis _Reference(s): ____________ _ ________ ______ ________________________________ -_____ ---____ -_-_______ :_- -,
- 1. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-62 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION
- -- **- ----- - **- -- ----~ - - *- *----- - --- -- - ------ - --- --- - -* - - - - - *------ - --. ---*-
CT2
- Initiating Condition:________________ _______ _ ________ **-- __ . -----------------*------ _________ .
RPV Water Level igp_(!r~tj__l}g_NJ~~~-~~~l!c;:~~m~~--------*--- --------*- --- ----*- ----- ------------ *-------*-- _____ : 1, 2, 3 [F_i_ssion Product Barrier(FPB) Threshold:________________ _______________________________ .~ POTENTIAL LOSS SAP entry required. iBasis: __ __ ____ _ ____ ____ ___ __ _ _ __: __-~- ~~-- ~--_-_ ~ ~~--~ =-~---- _:- -~~~~--~~=:~=-~~-- ~:-~- =- -~-: : ~- -~:_-_ :_=--__: The Potential Loss threshold is identical to the Fuel Clad Barrier FC2 Loss threshold RPV Water Level. The Potential Loss requirement for entry into the Severe Accident Procedures (SAPs) indicates adequate core cooling cannot be restored and maintained and that core damage is possible. Entry into SAPs is in response to the inability to restore and maintain adequate core cooling. PRA studies indicate that the condition of this Potential Loss threshold could be a core melt sequence which, if not corrected, could lead to RPV failure and increased potential for primary containment failure. In conjunction with the RPV water level Loss thresholds in the Fuel Clad and RCS barrier columns, this threshold results in the declaration of a General Emergency. i~-~~-*~-R~fir~ijc~t~)~:_ ::_-- :~- ~-~:-:-~:-_-_:--_ -_ ::._~ ~ ___:_: :~- _:-:_~_ ~-:- :~_--:-_--=-- ~-::=--~ -:: -~~-_-:.
- 1. NER-2M-039, NMP2 Emergency Operating Procedures (EOP) Basis Document
- 2. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-63 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 ,Initiating_ Cond_ition: _ _ ___ _ _ ___ _ _ __ ___ ____ ___ __________________________________________ , Primary Containment Pressure/ Conditions _Operating_ Mode Applicability; ____ ________________ _ 1, 2, 3 lFission Product Barrier (FPB) Threshold: ___ ________ ---------*------- ______ ___ _______________ : LOSS
- 1. UNPLANNED rapid drop in Primary Containment pressure following Primary Containment pressure rise.
OR
- 2. Primary Containment pressure response not consistent with LOCA conditions.
POTENTIAL LOSS
- 3. Primary Containment pressure > 45 psig.
OR
- 4. a. Primary Containment hydrogen concentration ~ 6%.
AND
- b. Primary Containment oxygen concentration ~ 5%.
OR
- 5. Heat Capacity Temperature Limit (HCTL) (N2-EOP-PC Figure M) exceeded.
J:lc!~1~; ____________________ -----------------***----------------- - ------------- - --- ----------------- - ------- ----* UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.
- Loss Threshold #1 and #2 Basis Rapid UNPLANNED loss of primary GOntainment pressure (i.e., not attributable to Drywell spray or condensation effects) following an initial pressure rise indicates a loss of primary containment integrity. Primary containment pressure should rise as a result of mass and energy release into the primary containment from a LOCA. Thus, primary containment pressure not increasing under these conditions indicates a loss of primary containment integrity.
These thresholds rely on operator recognition of an unexpected response for the condition and therefore a specific value is not assigned. The unexpected (UNPLANNED) response is important because it is the indicator for a containment bypass condition. A pressure suppression bypass path would not be an indication of a containment breach. December 2018 NMP 2-64 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION _CT3 _ (cont}_ fBasis_(cont): _________________________________________________________________________________ _ Potential Loss Threshold #3 Basis The threshold pressure is the primary containment internal design pressure. Structural acceptance testing demonstrates the capability of the primary containment to resist pressures greater than the internal design pressure. A pressure of this magnitude is greater than those expected to result from any design basis accident and, thus, represent a Potential Loss of the Containment barrier. Potential Loss Threshold #4 Basis If hydrogen concentration reaches or exceeds the lower flammability limit, as defined in plant EOPs, in an oxygen rich environment, a potentially explosive mixture exists. If the combustible mixture ignites inside the primary containment, loss of the Containment barrier could occur. Potential Loss Threshold #5 Basis The HCTL is a function of RPV pressure, suppression pool temperature and suppression pool water level. It is utilized to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant and therefore, the inability to maintain plant parameters below* the limit constitutes a potential loss of containment. Basis Referenc~(s):______ ___ __ ___ ____________ ___________________________________________ _
- 1. USAR Section 6.2.1.1.2
- 2. - N2-EOP-PCH Hydrogen Control
- 3. N2-EOP-PC Primary Containment Control
- 4. NER-M2-039, NMP2 Emergency Operating Procedures (EOP) Basis Document
- 5. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-65 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION 11nftiaHn9--co-ncnHon:-- ____ ___ __----- -------- ---_---- -------_--~- ~~~~ :~:- -~ -~:-: _ =--~~~ _-~- -:_ CTS
~::-_ ~::
Primary Containment Radiation
- c;>p_~r~t
- !!19 IVl_<!_d_~_App_li~a_bjJity~_ _ _______________ _
1, 2, 3 !Fission Product Barrier_(FPB) Threshold: __________ ______________________________ -________________ _ POTENTIAL LOSS Drywell radiation monitor reading > 1.4 E+04 R/hr (1.4 E+07 mR/hr).
- Basis
- __ ___________________________________________________________________________________________________________ _
There is no Loss threshold associated with Primary Containment Radiation. The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that 20% of the fuel cladding has failed. This level of fuel clad failure is well above that used.to determine the analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds. NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately 20% in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the emergency classification level to a General Emergency. lBasis_Reference(s): ___________________________________________ _
- 1. EP-EAL-0716, Criteria for Choosing Containment Radiation Values Indicating Loss of Fuel Clad and a Potential Loss of Containment for Nine Mile Point Station Unit 2
- 2. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-66 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT6
- lnitlc1ti!)g C~!'ldi_tio_l'!: _
Primary Containment Isolation Failure
- _Q13-Eir~ti~g-M_~de-}\pp-lJ_c_a~ffi!i;:-_- :.-.. ~ ~--________ ~-:~~ ::**-~:-:_-
1, 2, 3 fi_~sJ<>_I'! ~r.Qc:J_~.u;t J~~rr.l~r (Ff>BLThres_!t_ol_ct _________ _ LOSS
- 1. UNISOLABLE direct downstream pathway to the environment exists after Primary Containment isolation signal.
OR
- 2. Intentional Primary Containment venting/purging per EOPs or SAPs due to accident conditions.
OR
- 3. UNISOLABLE primary system leakage that results in EITHER of the following:
- a. Exceeding RB area temperature Maximum Safe Value (N2-EOP-SC Detail S).
OR
- b. RB area radiation > 8.00 E+03 mR/hr.
UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally. Failure to isolate the leak, within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification. These thresholds address incomplete containment isolation that allows an UNISOLABLE direct release to the environment. Loss Threshold #1 Basis The use of the modifier "direct" in defining the release path discriminates against release paths through interfacing liquid systems or minor release pathways, such as instrument lines, not protected by the Primary Containment Isolation System (PCIS). Leakage into a closed system is to be considered only if the closed system is breached and thereby creates a significant pathway to the environment. Examples include UNISOLABLE Main Steam Line, or RCIC steam line breaks, UNISOLABLE WCS system breaks, and UNISOLABLE containment atmosphere vent paths. Examples of "downstream pathway to the environment" could be through the Turbine/Condenser, or direct release to the Turbine or Reactor Building. December 2018 NMP 2-67 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT6 {cont)
- Ba~is_(co!Jt): ___ _______________________________________________________________________________ _
The existence of a filter is not considered in the threshold assessment. Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream. Following the leakage of RCS mass into primary containment and a rise in primary containment pressure, there may be minor radiological releases associated With allowable primary containment leakage through various penetrations or system components. Minor releases may also occur if a primary containment isolation valve(s) fails to close but the primary containment atmosphere escapes to an enclosed system. These releases do not constitute a loss or potential loss of primary containment but should be evaluated using the Recognition Category R ICs. Loss Threshold #2 Basis EOPs may direct primary containment isolation valve logic(s) to be intentionally bypassed, even if offsite radioactivity release rate limits will be exceeded. Under these conditions with a valid primary containment isolation signal, the containment should also be considered lost if primary containment venting is actually performed. Intentional venting of primary containment for primary containment pressure or combustible gas control to the secondary containment and/or the environment is a Loss of the Containment. Venting for primary containment pressure control when not in an accident situation (e.g., to control pressure below the Drywell high pressure scram setpoint) does not meet the threshold condition. Loss Threshold #3 Basis The Max Safe Operating. Temperature and the Max Safe Operating Radiation Level are each the highest value of these parameters at which neither: (1) equipment necessary for the safe shutdown of the plant will fail, nor (2) personnel access necessary for the safe shutdown of the plant will be precluded. EOPs utilize these temperatures and radiation levels to establish conditions under which RPV depressurization is required. The temperatures and radiation levels should be confirmed to be caused by RCS leakage from a primary system. A primary system is considered to be the pipes, valves, and other equipment which connect directly to the RPV such that a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system. In general, multiple indications should be used to determine if a primary system is discharging outside Primary Containment. For example, a high area radiation condition does not necessarily indicate that a primary system is discharging into the Reactor Building since this may be caused by radiation shine from nearby steam lines or the movement of radioactive materials. Conversely, a high area radiation condition in conjunction with other indications (e.g. room flooding, high area temperatures, reports of December 2018 NMP 2-68 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT6 (cont) !Basis _(cont): ______________________________________________________________________________________________: steam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into the Reactor Building. In combination with RCS Barrier RC4 Potential Loss Threshold #3 this threshold would result in a Site Area Emergency. There is no Potential Loss threshold associated with Primary Containment Isolation Failure. ~Basis Referenc~(s); _____________ _________________________
- _______________________________ _
- 1. NER-M2-039, NMP2 Emergency Operating Procedures (EOP) Basis Document
- 2. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, Table 3.6.1.3-1
- 3. N2-EOP-PC Primary Containment Control
- 4. . N2-EOP-PCH Hydrogen Control
- 5. EOP-6 NMP2 EOP Support Procedure
- 6. N2-EOP-SC Secondary Containment Control
- 7. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-69 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT7 foitlat_in_g:_¢_e>n_d!ii.o~-=- __ :_:-.-~---~--: :_-::_ -=-:~~------- -__---~-- :~--~-: ~:-- -:_*_:~ --~---- : ____ -~- :-=--=-* Emergency Director Judgment.
- Qperc1!i_~gJVl9~~ APP!i~t!~mty_~_ ___ ___ ___ _ _ _ __ __ _ __ _ __________ _
1, 2, 3 r**---------- --- -- - -- -- -- --- --- - -- ---- -- ----- ------ --- -- -- ----- --* - - ------ ---- -- ---- --- -------- . -- --- - ---- -- - --- - f!~~i<?I}_ i:>rQ~~~tJ~t!rri~r__(EP~) .Tll!~~l:lc;,t<.:1: _ __ ___________________________________________ ~ LOSS
- 1. ANY condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.
POTENTIAL LOSS
- 2. ANY condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.
- Basis: __ ___________
- __________________________ _
Loss Threshold #1 Basis: . This threshold addresses any other* factors that are to be used by the Emergency Director in determining whether the Containment Barrier is lost. Potential Loss Threshold #2 Basis: This threshold. addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.
- ~~~J~_ t{~t~r~~c~l~>-=--
- : _-_:: ~--*_: _:- ~ ~ -- :_*----__-___ -- - --:---: -~ - _____ _
- 1. NEI 99-01 Rev 6, Table 9-F-2 December 2018 NMP 2-70 EP-AA-1013Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG1 ilnitiating__ Condition:_ __ ___ __ __ ___ ____________ _ __ _______ ___ __________ ___ _ __ -----~-~- -~~~ - =~:~ -~- =~--~-~~~- Prolonged loss of all offsite and all onsite AC power to emergency buses.
- operating_Mode AppJicability: ________
- ____ ---_-:-=---~-~~--~--~:-: _- ___________ _
1,2,3
- Emergen~yAction Level(EAL):
- ___ *
- ___________ *_ __ _______________ _
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. Loss of ALL offsite and onsite AC power to 4.16 kV emergency buses 2ENS*SWG101 and 2ENS*SWG103.
AND
- 2. EITHER of the following:
- a. Restoration of at least one 4.16 kV emergency bus 2ENS*SWG101 or 2ENS*SWG103 in < 4 hours is not likely.
OR
- b. RPV water level cannot be restored and maintained > -39 inches
,_Ba~i_s: __ ___ _ ___ _____ _ __ ______ __ __ ____ _ __ _ _____ _ SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses a prolonged loss of all power sources to AC emergency buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A prolonged loss of these buses will lead to a loss of any fission product barrier. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. RPV values are actual levels, not indicated levels. Therefore, they may need level compensation depending on conditions. December 2018 NMP 2-71 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG1 (cont) J;1!1~i~ (c~_nt}; ____ ____ ___ _ ___ __ __ ___ ________ _ _ _______ ______ ____ __ _ _ __ ___ ____ _ _________ ~-- _ _______ :: The EAL should require declaration of a General Emergency prior to meeting the thresholds for IC FG1. This will allow additional time for implementation of offsite protective actions. Escalation of the emergency classification from Site Area Emergency will occur if it is projected that power cannot be restored to at least one AC emergency bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and event trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers. The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation. Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public. The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.
- Basis Reference(s): __ _ __ ________ __ ________ ______________________________________________________ _
- 1. USAR Section 8.2
- 2. USAR Section 8.3
- 3. N2-SOP-03 Loss of AC Power
- 4. N2-SOP-01 Station Blackout
- 5. USAR Section 8.3.1.5.2
- 6. NER-2M-039, NMP2 Emergency Operating Procedures (EOP) Basis Document
- 7. N2-EOP-C4 RPV Flooding
- 8. N2-EOP-C5 Failure to Scram
- 9. NEI 99-01 Rev 6, SG1 December 2018 NMP 2-72 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1
- Initiating Condition: ____________________________________________________ ______ _
Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.
- 01ieraHng)io-cieAppJfo-aliliity; ___ --- --.-_---*- --------_-----_-- - ----- --_ ----_-_-- ------_- _ ----_- -:---- _.
1, 2, 3 LEl!)e_rgency Action Le'{el(EAL):_____ ________ ___ _ ____ _ ____ _____ ___ ___ ____ _____ _______ __ ___ _______ ________
- Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. Loss of ALL offsite and onsite AC power to 4.16 kV emergency buses 2ENS*SWG101 and 2ENS*SWG103.
AND
- 2. Failure to restore power to at least one 4.16 kV emergency bus 2ENS*SWG101 or 2ENS*SWG103 in < 15 minutes from the time of loss of both offsite and onsite AC power.
/~-~~js;_ __ ----- --- - ---- --- -- ----- --- ----- - -- SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Escalation of the emergency classification level would be via ICs RG1, FG1, MG1, or MG2. December 2018 NMP 2-73 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS
- BasisReference(s):__________ _________________________________________________________ _
- 1. USAR Section 8.2
- 2. USAR Section 8.3
- 3. N2-SOP-03 Loss of AC Power
- 4. N2-SOP-01 Station Blackout
- 5. . NEI 99-01 Rev 6, SS1 December 2018 NMP 2-74 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA1 Loss of all but one AC power source to emergency buses for 15 minutes or longer.
- 9p~ri!*_n1iMQd~~Ai>li.fi~~ii~1f1fy;
- :- --_ _ __: _- ~ -_-_ - --_ ~~ ~ ----~- _:__ ~-:-:_ -~ _--
1, 2, 3
- Emergency Action_Level_(EAL): _____ __________________________________ _
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. AC power capability to 4.16 kV emergency buses 2ENS*SWG101 and 2ENS*SWG103 reduced to only one of the following power sources for
~ 15 minutes:
- Reserve Transformer A
- Reserve Transformer B
- Aux Boiler Transformer
- 2EGS*EG1
- 2EGS*EG3
- 2EGS*EG2 AND
- 2. ANY additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.
Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
- This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment. This IC provides an escalation path from IC MU1.
An "AC power source" is a source recognized in SOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below. December 2018 NMP 2-75 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS ,------- ----**--- ---- ------ ------ --------- ---- -- ------------*- -*-- --**-------------~----.---*~-----*---------- MA1 (cont)
- Basis
, ______ ____(cont): _. ---- ---* *--*------- --- - *- - - - - - ---* *- - --** ----~---- - -------- --- -- ---* ----*- - -*---* --- **------ -----**- --- - --**---* - --- ---:
- A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).
- Loss of offsite power and 2EGS*EG2 is aligned and providing power to 2ENS*SWG101 or 2ENS*SWG103,. or 2EGS*EG2 is able to provide power to 2ENS*SWG101 or 2ENS*SWG103 within 15 minutes.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power. Escalation of the emergency classification level would be via IC MS1.
- easis_ Reference(s): ___ _______ ---*- ________ _____ ______ _______ ____ ____________ ___ ____ *
- 1. USAR Section 8.2
- 2. USAR Section 8.3
- 3. N2-SOP-03 Loss of AC Power
- 4. N2-SOP-01 Station Blackout
- 5. NEI 99-01 Rev 6, SA 1 December 2018 NMP 2-76 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU1 Initiating Condition: -----*---- ____ .. ____ __ __ -** _ . ___ *-*- __________________________________________ i Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.
- operating Mode Applicability: ______ ____ --***--*-*- _______________ *--------*------------- _.
1, 2, 3
- Emergency_Action_Level (EAL):_______ _____________________ _____ r__ ___ _____ ________ ____ _
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
Loss of ALL offsite AC power capability to 4.16 kV emergency buses 2ENS*SWG101 and 2ENS*SWG103 for~ 15 minutes:
- Reserve Transformer A
- Reserve Transformer B
- Aux Boiler Transformer
- Basis:
-----* ---- ----- ------------- --------*----* ----- - ---- --------- --~------- ------- ------* ----- ___ .. __ -- - - - ----------*--
This IC addresses a prolonged loss of offsite power. The loss of offsite power sources renders the plant more vulnerable to a complete loss of power to AC emergency buses. This condition represents a potential reduction in the level of safety of the plant. For emergency classification purposes, "capability" means that an offsite AC power source(s) is available to the emergency buses, whether or not the buses are powered from it. (e.g. unit cross-tie breakers) Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power. Escalation of the emergency classification level would be via IC MA1.
- ~;;t~_i_s R._eJer~!)~~(s): ___ . ___________________________ _
- 1. USAR Section 8.2
- 2. USAR Section 8.3
- 3. N2-SOP-03 Loss of AC Power
- 4. N2-SOP-01 Station Blackout
- 5. NEI 99-01 Rev 6, SU1 December 2018 NMP 2-77 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG2 lrijtic!tjng _~~m_d_iti_on; ____ _ __ ___ _ _ __ ___ _ _ ______ _ Loss of all AC and Vital DC power sources for 15 minutes or longer.
~qp-~iaJingJV10~~-Ai>i>J*~e:1~1Jify~---_-_-_ -__ ------~-------~~--- -__ -:- _- _-_-_ ~~:~ _- _:_ -______________ _-- ______ ',
1,2,3
- E_m~rgijrrciY Ac_Hon)~~y~i]EA_L}:- - ~-
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. Loss of ALL offsite and onsite AC power to 4.16 kV emergency buses 2ENS*SWG101 and 2ENS*SWG103.
AND
- 2. Voltage is < 105 VDC on Vital DC buses 2BYS*SWG002A and 2BYS*SWG002B.
AND
- 3. ALL AC and Vital DC power sources in EALs #1 and #2 (excluding Division 3) have been lost for?_ 15 minutes.
*Basis:
SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it i'n the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. , This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A loss of Vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both AC and DC power will lead to multiple challenges to fission product barriers. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. The 15-minute emergency declaration clock begins at the point when all EAL conditions are met. December 2018 NMP 2-78 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG2 (cont) lBasis Reference(s): __ __ ____________ ___ ___ _ ____ -
- 1. USAR Section 8.2
- 2. USAR Section 8.3
- 3. N2-SOP-03 Loss of AC Power
- 4. N2-SOP-01 Station Blackout
- 5. USAR Section 8.3.2.1.2
- 6. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.8.4
- 7. N2-SOP-04 Loss of DC Power
- 8. EC-203 Battery 2BYS*BAT2A and 2BYS*BAT2B Shed Coping Time for ELAP Event
- 9. NEI 99-01 Rev 6, SG8 December 2018 NMP 2-79 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS2
- 1r1iti~Jing C_or1gi_tiQr1:_ _ _ _ _ _____________________________ _
Loss of all vital DC power for 15 minutes or longer.
- Qt:ier~tin 9 _~Mqd~~~ppJ.i~~-~i1_ify: ~~:_-- ~:::**:_~- __ --_:-~ _-*:=---- -~--: *:- --~ _--~---_--- :*_
1, 2, 3 'E'l'.l~rn~~~~ A~t~9n_k~"_el (~A~)~-- __ _ Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
Voltage is < 105 VDC on 2BYS*SWG002A and 2BYS*SWG0028 for~ 15 minutes. 'Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses a loss of Vital DC power which compromises the ability to monitor and control SAFETY SYSTEMS. In modes above Cold Shutdown, this condition involves a major failure of plant functions needed for the protection of the public. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Escalation of the emergency classification level would be via ICs RG1, FG1 or MG2.
- B~sj~_~eferer1ce_(~):_ ___ _____ ___ _ _ _________ _ _ _ __ _ ___ ___ _ _ _ __________ _ __________
- 1. USAR Section 8.3.2.1 .2
- 2. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.8.4
- 3. N2-SOP-04 Loss of DC Power
- 4. EC-203 Battery 2BYS*BAT2A and 2BYS*BAT28 Shed Coping Time for ELAP Event
- 5. NEI 99-01 Rev 6, SS8 December 2018 NMP 2-80 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3
- Initiating Condition: ___ ______________________________________________ ~---- ________________
- Inability to shutdown the reactor causing a challenge to RPV water level or RCS heat removal.
- o~erating_Mode Applicability:____ ______ ____ __ _ ______ ___ ____ _ __________ _________ :
1, 2
- Emergency_Action_Level (EAL): ______________________ _____________________________________________ :
- 1. Automatic scram did not shutdown the reactor as indicated by Reactor Power> 4%.
AND
- 2. ALL manual / ARI actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power> 4%.
AND
- 3. EITHER of the following conditions exist:
- RPV water level cannot be restored and maintained > -39 inches.
OR
- Heat Capacity Temperature Limit (HCTL) (N2-EOP-PC Figure M) exceeded.
- Basis: _________________________________________________________________________________________________ _
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, all subsequent operator manual actions, both inside and outside the Control Room including driving in control rods and boron injection, are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency. In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs. This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusiqn of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor. RPV values are actual levels, not indicated levels. Therefore, they may need level compensation depending on conditions. Escalation of the emergency classification level would be via IC RG1 or FG1. December 2018 NMP 2-81 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3 (cont)
- eas-is Reference(s): _______ __ _____ ___________ __ _____-___________ -________________________________________ *
- 1. N2-EOP-C5 Failure to Scram
- 2. NER-2M-039, NMP2 Emergency Operating Procedures (EOP) Basis Document
- 3. N2-EOP-C4 RPV Flooding
- 4. N2-EOP-PC Primary Containment Control
- 5. NEI 99-01 Rev 6, SS5 December 2018 NMP 2-82 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 [lnitTating_Condition: ____ ______ -___ ____ ___ ______ ___ ______ ________ __ _______ ___________ __________ _ Automatic or manual scram fails to shutdown the reactor, and subsequent manual actions taken at the Reactor Control Console are not successful in shutting down the reactor. iOperating_Mode Applicability:_____ __________ __ ____ _ ________ __ _______________________ _ 1, 2
- Emergency_Action_Level (EAL)~---------- _________________________ ---~----------------- ______
Note:
- A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core. This action does not include manually driving in control rods or implementation of boron injection strategies.
- 1. Automatic or manual scram did not shutdown the reactor as indicated by Reactor Power> 4%.
AND
- 2. Manual / ARI actions taken at the Reactor Control Console are not successful in shutting down the reactor as indicated by Reactor Power> 4%.
- Basis:____ ___ _______ ___ _ __ ________ ______ ___ __ __ _____________________________________ . ___________________ _
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, and subsequent operator manual actions taken at the Reactor Control Console to rapidly shutdown the reactor are also unsuccessful. This condition represents an actual or potential' substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the reactor control console since this event entails a significant failure of the RPS. A manual action at the Reactor Control Console is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor scram, ARI). This action does not include manually driving in control rods or implementation of boron injection strategies. If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the Reactor Control Console (e.g., locally opening breakers). Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the Reactor Control Console". Taking the Reactor Mode Switch to Shutdown is considered to be a manual scram action. December 2018 NMP 2-83 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 {cont) iBasis(cont):__ ___ _ ________ __ __ __ _ ______________________________________________________ : The plant response to the failure of an automatic or manual reactor scram will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged enough to cause a challenge to the RPV water level or RCS heat removal safety functions, the emergency classification level will escalate to a Site Area Emergency via IC MS3. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC MS3 or FS1, an Alert declaration is appropriate for this event. It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL are included to ensure a timely emergency declaration. LBasis Reference(s ): _ _ __ _ __ __ _____ __ __ __ _ ____ _____ ____ ___ _____ _ __ ____ ____ _____ ____ _______ *______ *
- 1. N2-EOP-C5 Failure to Scram
- 2. NER-2M-039, NMP2 Emergency Operating Procedures (EOP) Basis Document
- 3. NEI 99-01 Rev 6, SAS December 2018 NMP 2-84 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 .Initiating_ Condition: __ _ Automatic or manual scram fails to shutdown the reactor.
- operating_Mode Applicabmty
- ---*-- _______________ .. _____________________ . _____________ :
1, 2 ,E111ergency_Action_ Level (EAL): _ ___ .... _____________________________________________________ _ Note:
- A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core. This action does not include manually driving in control rods or implementation of boron injection strategies.
- 1. a. Automatic scram did not shutdown the reactor as indicated by Reactor Power> 4%.
AND
- b. Subsequent manual / ARI action taken at the Reactor Control Console is successful in shutting down the reactor as indicated by Reactor Power~ 4%.
OR
- 2. a. Manual scram did not shutdown the reactor as indicated by Reactor Power> 4%.
AND
- b. EITHER of the following:
- 1. Subsequent manual / ARI action taken at the Reactor Control Console is successful in shutting down the reactor as indicated by Reactor Power~ 4%.
OR
- 2. Subsequent automatic scram / ARI is successful in shutting down the reactor as indicated by Reactor Power~ 4%.
r - -- - *-- -------------- - - - -----*---- - - - - - -*-- *---*-* * - - - -- -
- ~~!;i~:. ***-*-* . -..... -**** --* -..... - .. - .. --- ...... - -***- . -- ---* -- --- .......... - .......... *- *****-*---* ..... .. ' --- .. - -*
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, and either a subsequent operator manual action taken at the Reactor Control Console or an automatic scram is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant. December 2018 NMP 2-85 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS .J3~sis (corit):_ _ EAL#1 Basis Following the failure on an automatic reactor scram, operators will promptly initiate manual actions at the Reactor Control Console to shutdown the reactor (e.g., initiate a manual reactor scram/ARI). If these manual actions are successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems. EAL#2 Basis If an initial manual reactor trip is unsuccessful, operators will promptly take other manual actions on the Reactor Control Console to shutdown the reactor (e.g., initiate a manual reactor scram / or initiating ARI using a different switch). Depending upon several factors, the initial or subsequent effort to manually scram the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor scram signal. If a subsequent manual or automatic scram, including ARI, is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems. A manual action at the Reactor Control Console is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor scram). This action does not include manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the Reactor Control Console". Taking the Reactor Mode Switch to Shutdown is considered to be a manual scram action. The *plant response to the failure of an automatic or manual reactor scram will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the Reactor Control Console are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC MA3. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC MA3 or FA1, an Unusual Event declaration is appropri'ate for this event. Should a reactor scram signal be generated as a result of plant work (e.g., RPS setpoint testing), the followi~g classification guidance should be applied.
- If the signal generated as a result of plant work causes a plant transient that creates a real condition that should have included an automatic reactor scram and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.
December 2018 NMP 2-86 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont) ~ij-~~ji(~g~~fff _-~---=-----= ~~----:-----=~--~~- _- -~- _:~ ~: _ -: _::_ ~~--:- --- =- =-~ _- ~-- ~: _ _ - -_-_- _- _ - ~~ -~-- -~-_ :
~-~
- If the signal generated as a result of plant work does not cause a plant transient but should have generated an RPS scram signal and the scram failure is determined through other means (e.g., assessment of test results), then this IC and the EALs are not applicable and no classification is warranted.
~-- ----** - ---- -- .L------ - -------------------- ------- -- --- - - -- ------- - --- ------------
- ~~~~~-~~f~r~_r:i_c;~(~): _ _________________________________________________________________ _
- 1. N2-EOP-C5 Failure to Scram
- 2. NER-2M-039, NMP2 Emergency Operating Procedures (EOP) Basis Document
- 3. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, Table 3.3.1.1-1
- 4. NEI 99-01 Rev 6, SUS December 2018 NMP 2-87 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA4 ifnitla!!_ng_ <<;:on.~Iti!>_li: ____ ________________ ___ __ _____ ______ _____________________________________ ' UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.
- operating_ Mode AppJicability
- __ ________________ ___ _______ ____ ___________ ___________________
- ____ :
1, 2, 3 1EmergencyAction_Level (EAL): __________ _ -*----~- - - - - ~ ---- 1, Note:
- The Emergency Director should declare the event promptly upon determining that the *applicable time has been exceeded, or will likely be exceeded.
- 1. UNPLANNED event results in the inability to monitor ANY Table M1 parameter from within the Control Roomfor ~ 15 minutes.
Table M1 Control Room Parameters
- Reactor Power
- RPV Water Level
- RPV Pressure
- Primary Containment Pressure
- Suppression Pool Level
- Suppression Pool Temperature AND
- 2. ANY Table M2 transient in progress.
Table M2 Significant Transients
- Turbine runback > 25% thermal reactor power
- Electric load rejection > 25% full electric load
- Reactor Scram
- ECCS Activation
- Thermal Power oscillations > 10%
December 2018 NMP 2-88 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA4 (cont) = -*- \ -------- **------* ----------** .-, lBasis: _______________________________ ------*-----*------- ____________________________ **-***---** UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fission product barrier challenge is reduced. It thus represents a potential substantial degradation in the level of safety of the plant. As used in this EAL, an "inability to monitor means that values for any of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, computer point, digital and recorder source within the Control Room. An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making. This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, RPV water level and RCS heat removal. The loss of the ability to determine any of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for any of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for RPV water level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication. Escalation of the emergency classification level would be via ICs FS1 or IC RS1.
- ~~s[s-R~f~.r~~~~(~)
- ; _---------_-~: __ - ~ -~~ _::-~:_-_:~--~- -__: -- - - ~-- -_- . . _-:-* -- --- - ~~- _ -~---_-_-- --~- -_ *_ -_-:_- **-- -
- 1. NEI 99-01 Rev 6, SA2 December 2018 NMP 2-89 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4
- Initiating_ Condition: _____________________________________________________ - - -~~~=-=~~-~-~ ---==:--~-~-~-~
UNPLANNED loss of Control Room indications for 15 minutes or longer.
- operating_ModeAppJicability; _______________ ____________________________________________ --:
1, 2, 3.
- t;rru~_rg~11cyA~~!QI1_~~¥~t(!;A~>~-- ___________________________________________________________
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
UNPLANNED event results in the inability to monitor ANY Table M1 parameter from within the Control Room for~ 15 minutes. Table M1 Control Room Parameters
- Reactor Power
- RPV Water Level
- RPV Pressure
- Primary Containment Pressure
- Suppression Pool Level
- Suppression Pool Temperature
- B_a~is: ______________________ ..... ___________________ --------*-*-***-------------- _______________ _
UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. This condition is a precursor to a more significant event and represents a potential degradation in the level of safety of the plant. As used in this EAL, an "inability to monitor means that values for any of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room. December 2018 NMP 2-90 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4 (cont) ,Basis (cont): ___ ___________________________________________________________________________ : An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making. This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine any of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for any of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication. Escalation of the emergency classification level would be via IC MA4. '.13-~si~-~~f~r~!!~e(s)_:___ ___ __ ____ _
- 1. NEI 99-01 Rev 6, SU2 December 2018 NMP 2-91 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MAS !Initiating Condition: _ _____________ - ________ ______ _____ _ _____________________________________________ ~ Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.
- operating_Mode Applicability
- _ ____________________________________________________________ :
1, 2, 3 iEmergency Action_ Level(EAL): _ Note:
- This EAL is a,nly applicable to SAFETY SYSTEMs having two (2) or more trains.
- If the affected SAFETY SYSTEM train was already inoperable before the hazardous event occurred, then this emergency classification is notwarranted.
- If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.
- If a hazardous event occurs and it is determined that the conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.
- 1. a. The occurrence of ANY of the following hazardous events:
- Seismic event (earthquake)
- Internal or external flooding event
- High winds or tornado strike
- FIRE
- EXPLOSION
- Other events with similar hazard characteristics as determined by the Shift Manager AND
- b. Event damage has caused indications of degraded performance to one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.
AND
- c. EITHER of the following:
- Event damage has caused indications of degraded performance to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.
OR
- Event damage has resulted in VISIBLE DAMAGE to a second tr;:iin of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.
December 2018 NMP 2-92 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MAS {cont) Basis: _______________________________________________ ______________________________________________ _ 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. EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion.
- Such events may require a post-event inspection to determine if the attributes of an explosion are present.
SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant-and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. VISIBLE DAMAGE: Damage to a SAFETY SYSTEM train that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected SAFETY SYSTEM train. This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. In order to provide the appropriate context for consideration of an Alert classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the* second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues. Note that this second SAFETY SYSTEM train is from the same SAFETY SYSTEM that has degraded performance for criteria 1.b of this EAL; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events. Indications of degraded performance address damage to a SAFETY SYSTEM train that is in operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train. Operators_ will make a determination of VISIBLE DAMAGE based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage. This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train. December 2018 NMP 2-93 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MAS (cont) 1~~~!!5 (C~!]!)_~ __ _ ___ __ ___ ___ _____ _ __ __ _______ _ ____ ___ _ ____ _ ______ ..... ____ .... _ __ . __ _ ______ _ Escalation of the emergency classification level would be via IC FS1 or RS1. If a hazardous event occurs and the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6. J~a~i~_R~fE!!.r~nc;;e_(s): ______________________________ _
- 1. NEI 99-01, Rev 6 SA9 December 2018 NMP 2-94 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU6 [Initiating Condition:__ --------------------------------___________________________ ______ RCS leakage for 15 minutes or longer. iOperating Mode AppJicabilLty:__ __ _ _______ _ _ _ ____ ______________ ___ ___ _______ _____ _______________ : 1, 2, 3
- Emergency Action Level (EAL)~----- _______________________________ ___________________________ ;
Note:
- The EmergencY. Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. RCS unidentified or pressure boundary leakage in the Drywell > 10 gpm for~ 15 minutes.
OR
- 2. RCS identified leakage in the Drywell > 25 gpm for~ 15 minutes.
OR
- 3. Leakage from the RCS to a location outside the Drywell > 25 gpm for~ 15 minutes.
iBasis: __ _____________________ ------------------------------ __________________________________________________________ UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally. This IC addresses RCS leakage which may be a precursor to a more significant event. In this case, RCS leakage has *been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant. EAL #1 and EAL #2 Basis These EALs are focused on a loss of mass from the RCS due to "unidentified leakage",
"pressure bou_ndary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications).
EAL #3 Basis This EAL addresses a RCS mass loss caused by an UNISOLABLE leak through an interfacing system. The assessment of this EAL may be based on the results of RCS leak rate calculation that may be necessary to ascertain whether the EAL has been exceeded. In this case, the 15-minute declaration period starts with the availability of the RCS leak rate calculation results that show the EAL to be exceeded (i.e., this is the time that the EAL information is first available). These three EALs thus apply to leakage into the containment, a secondary-side system or a location outside of containment. December 2018 NMP 2-95 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS ______ MU6 (cont) !i;l~!?l~.(~QI!!);_ - -- ------ The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications. EAL #1 uses a lower value that reflects the greater significance of unidentified or pressure boundary leakage. The release of mass from the RCS due to the as-designed/expected operation of any relief valve does not warrant an emergency classification. A stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is not applicable to this EAL. The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible. Escalation of the emergency classification level would be via ICs of Recognition Category R or F.
- 1;1ast~-R~t~r~-~~~(~j/__ -_--~-
- ~ ---~-~~::*--- -:-_-*: _ : --=- -__ - _-: __-~: ~~ ::*--:~--~ __________ _
- 1. N2-ARP-01 Annunciator Response Procedures for annunciator 873115
- 2. N2-ARP-01 Annunciator Response Procedures for annunciator 873111
- 3. N2-ARP-01 Annunciator Response Procedures for annunciator 873105
- 4. N2-ARP-01 Annunciator Response Procedures for annunciator 873110
- 5. N2-0SP-LOG-S001 Shift Checks - Mode 1
- 6. N2-0P-67 Drywell Equipment and Floor Drains System
- 7. NEI 99-01 Rev 6, SU4 December 2018 NMP 2-96 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU7 Loss of all onsite or offsite communication capabilities. 'Qpef~_tfog Nio_cte_AiiPiica~ifiti;_-: -- ____ -*:_:--~ :- -- 1, 2, 3 Em_~!9~1"!<?Y A_ctio_r,_ -~~vel (EA!-:-):_ _ __ __ __ _ __ _ __ ___ _ ___ _ ___ _
- 1. Loss of ALL Tab.le M3 onsite communication capabilities affecting the ability to perform routine operations.
OR
- 2. Loss of ALL Table M3 offsite communication capabilities affecting the ability to perform offsite notifications.
OR
- 3. Loss of ALL Table M3 NRC communication capabilities affecting the ability to perform NRC notifications.
Table M3 Communication Capabilities System Onsite Offsite NRC Gaitronics X Hand Held Portable Radio (Station Radio) X PBX (Conventional Telephone lines) X X X Control Room installed satellite phone (non portable) X X ENS X X RECS X Basis: This IC addresses a significant loss of onsite, offsite, or NRC communication capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC. This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.). EAL#1 Basis Addresses a total loss of the communication methods used in support of routine plant operations. December 2018 NMP 2-97 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS __MU7 (cont)
- -~~.§l!5_(C~f'!t);_ _ __ _
EAL #2 Basis Addresses a total loss of the communication methods used to - notify all Offsite Response Organizations (OROs) of an emergency declaration. The Offsite Response Organizations (OROs) referred to here are listed in procedure EP-CE-114-100-F-05, Part1 Notification Fact Sheet. EAL#3 Basis Addresses a total loss of the communication methods used to notify the NRC of an emergency declaration.
- s~~_lj}{efe:a,jrj_~~(s.)_:_ ---- : -- -~~ -_ -~-:.- -*: ---~~-~-- ~-~--- - - .- - - --- __:___ -: _--- - -_:-_-- _-- _ :~--- _ -__ --- -
- 1. EP-CE-114-1 OO-F-05, Part 1 Notification Fact Sheet
- 2. USAR Section 9.5.2
- 3. Nine Mile Point Nuclear Station Site Emergency Plan, Section 7.2
- 4. N2-0P-76 Plant Communications
- 5. NEI 99-01 Rev 6, SU6 December 2018 NMP 2-98 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN/ REFUELING SYSTEM MALFUNCTIONS CA1 !fiijt_l~tfrig-go~ri_~:Htfoo_:__- ~---_-*::: *:=:~-- :* _ ----~=--- ~~---=:-__ =- __-:-*_*-=- :__ - -~~ :--~--:--:=-= -_:---~--- :----~---: Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer. [Qperclltl11_g_N19~~A~~IJ-~~~m~:_ ____ ___ ____ __ ______ ------ ::-: :***:._*_-~:**=*: *_:--: -~ --=:~-------_ -- - 4,5, D _l;_rn~rg~~-~y-~ctic;,n__!._~v~_l_(~!J;________ --- ------------------ ----------- --------- - ------ -- Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. Loss of ALL offsite and onsite AC power to 4.16 kV emergency buses 2ENS*SWG101 and 2ENS*SWG103.
AND
- 2. Failure to restore power to at least one 4.16 kV emergency bus 2ENS*SWG101 or 2ENS*SWG103 in< 15 minutes from the time of loss of both offsite and onsite AC power.
- easis:______ --- -- ---- ---- *-. --- ----------------- ------------------- ---- ---------- --------- --- ----- ---------- --------
SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore an emergency bus to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant. December 2018 NMP 2-99 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA1 (cont) ,easisJcont): ____ _ Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Escalation of the emergency classification level would be via IC CS6 or RS1. J3~jJs: t{~f~i~ij~~Iif;~ ___ :_-~:-~ _ -:*_*::-~.:-.:~_-:-_: -__: -- -~*:_ -~: -----~-:=--- *:-: --=~--: ~-~-: *: : _ -:~--~--:-~=-----_- --*
- 1. USAR Section 8.2
- 2. USAR Section 8.3
- 3. N2-SOP-03 Loss of AC Power
- 4. N2-SOP-01 Station Blackout
- 5. NEI 99-01 Rev 6, CA2 December 2018 NMP 2-100 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU1 .lnitl_at_i~g--~~n~i!i_9_n;__ __ __ ____ _ __ ___ _____________________ -~ ___ _ _ __ __ __ _________ _ Loss of all but one AC power source to emergency buses for 15 minutes or longer.
- 9P_~ratj_rJ_gJ\ll~g~_A~~li~~bll!ty__; ___ ______
4,5,D
- !;_'!l!!rQ~!'ICY_Act!~fl __ley~l_(§_Ab)
- __ ____________ _
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. AC power capability to 4.16 kV emergency buses 2ENS*SWG101 and 2ENS*SWG103 reduced to only one of the following power sources for
~ 15 minutes: *
- Reserve Transformer A
- Reserve Transformer B
- Aux Boiler Transformer
- 2EGS*EG1
- 2EGS*EG3
- 2EGS*EG2 AND
- 2. ANY additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.
Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment. When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the increased time available to restore another power source to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant. December 2018 NMP 2-101 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS
.. ------- --- --- -- ------ ... -------- ---------- -----. -- ------~~~ J~~!_l~)
~e~~Js__(c:9_11t)~ _ _ _ _ __ _ __ ___ __ _ ___ __ __ __ __ _ _ ____ _ An "AC power source" is a source recognized in SOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.
- A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).
- Loss of offsite power and 2EGS*EG2 is aligned and providing power to 2ENS*SWG101 or 2ENS*SWG103, or 2EGS*EG2 is able to provide power to 2ENS*SWG101 or 2ENS*SWG103 within 15 minutes.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power. The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA 1.
- ~i~is~_~jf~rciric:i(aj=--- _*
- 1. USAR Section 8.2
- 2. USAR Section 8.3
- 3. N2-SOP-03 Loss of AC Power
- 4. N2-SOP-01 Station Blackout
- 5. NEI 99-01 Rev 6 CU2 December 2018 NMP 2-102 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 1 1.i:ii~iatjr.ig_G<>ndjti_ol]_;__ _ _ _ __ ____ ___ ___ __ _ _ __ __ _______ __ _________ __ ________ _ Hazardous event affecting SAFETY SYSTEM required for the current operating mode. rqpjf!ij1~g-M_od~-~,i~_11c_~~HJti=~ -*-** -* ~ -~~==-~-:--_- :-_- :_*--=~-~-~-~--*- -_ * : ___~-~::_* _-:~-~--~---~-~-~: 4,5
- ~~~-rn~~~y-~~t~c:l!l.J-:~.'(~L(~Ak): __ _________ . _ __ __ _ _
Note:
- This EAL is only applicable to SAFETY SYSTEMs havin*g two (2) or more trains.
- If the affected SAFETY SYSTEM train was already inoperable before the hazardous event occurred, then this emergency classification is not warranted.
- If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.
- If a hazardous event occurs and it is determined that the conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.
- 1. a. The occurrence of ANY of the following hazardous events:
- Seismic event (earthquake)
- Internal or external flooding event
- High winds or tornado strike
- FIRE
- EXPLOSION
- Other events with similar hazard characteristics as determined by the Shift Manager AND
- b. Event damage has caused indications of degraded performance to one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.
AND
- c. EITHER of the following:
- Event damage has caused indications of degraded performance to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.
OR
- Event damage has resulted in VISIBLE DAMAGE to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.
December 2018 NMP 2-103 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 (cont)
- aasiS£_______ -------- *--- --- * --- * -- - -* ------------* --- ------*- -- ---- --- ---
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. EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events may require a post-event inspection to determine if the attributes of an explosion are present. SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. VISIBLE DAMAGE: Damage to a SAFETY SYSTEM train that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected SAFETY SYSTEM train. This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. In order to provide the appropriate context for consideration of an Alert classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues. Note that this second SAFETY SYSTEM train is from the same SAFETY SYSTEM that has degraded performance for criteria 1.b of this EAL; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events. Indications of degraded performance address damage to a SAFETY SYSTEM train that is in operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cau,se concern regarding the operability or reliability of the SAFETY SYSTEM train. Operators will make a determination of VISIBLE DAMAGE based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage. This December 2018 NMP 2-104 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 (cont) VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train. Escalation of the emergency classification level would be via IC CS6 or RS1. If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6. !Basis _Reference(s); __ ... _ _ ________ *--* ~ __________-_________ ~ _____ -~- ___ ~-- ___ ____ _ _ __________________ _
- 1. NEI 99-01 Rev 6, CA6 December 2018 NMP 2-105 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU3 'I_Qi_t_ic!t_i~g_ C~m_d_it~~IJ: ______ __ __ __ _ _ ___ ___ ___ _ ____ _ Loss of Vital DC power for 15 minutes or longer.
- 9p~~~Jlng_-lYl<i_~_e~AriPff~~JJinti~ __---~
- --~-::_ ~~~~ -~-~~- -~~ ::~-:- _:---~ -~~ ___-_:_____:~- ~~- _-~~-- _-:--
4, 5
- !=!l)~rgE!~_cy_A~tfc;,_r:,_~~y_eJ (E;AI-): ____ _________________________ _
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
Voltage is < 105 VDC on required Vital DC buses 2BYS*SWG002A and 2BYS*SWG0028 for~ 15 minutes.
--- - -- . - - . ____ _, --- *------ --- --------. ---- ------ - . - ---*. --- --- - - ------- ---- ~ --- - --- - -- --- ---
- Basis:
SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses a loss of Vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions increase the time available to restore a vital DC bus to ~ervice. Thus, this condition is considered to be a potential degradation of the level of safety of the plant. As used in this EAL, "required" means the Vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment. For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Depending upon the event, escalation of the emergency classification level would be via IC CA6 or CA5, or an IC in Recognition Category R. December 2018 NMP 2-106 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN/ REFUELING SYSTEM MALFUNCTIONS ,B~sJs ~e_ferc:mce_(!;); _ ___ _ ____ _
--- ~-u~ (c;~~Jl
- 1. USAR Section 8.3.2.1 .2
- 2. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.8.5
- 3. N2-SOP-04 Loss of DC Power
- 4. NEI 99-01 Rev 6, CU4 December 2018 NMP 2-107 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4
- ~ni_tia!lr-g_ ~9n_ditJ~.IJ~ _________ ... _____ - -_ * .. --_ ~- -___ -________________ _
Loss of all onsite or offsite communication capabilities. r.- - -- --- --- *- - --- - .. ----. --------- -- . ------------- -- - --- -- -- -- -- *------ - -----* ---------** -- ,Op~~a_!i~g IVl9~e ~~pli~~l?iljty: _____ ___ ___ _______ __ _ _ __ _ __ ______________ _ 4,5,D
- t:;ijl~_rgen_~y}~~t_i~~~J:;~"~r (~AW~~~- _~--_- *_*:*~----~-~ ---~-- :* _:-_ -~:-*:_-~ __ ~::= *~:-. ~-- -: *:_:_ *: _-_-: --~=-:.
- 1. Loss of ALL Table C1 onsite communication capabilities affecting the ability to perform routine operations.
OR
- 2. Loss of ALL Table C1 offsite communication capabilities affecting the ability to perform offsite notifications.
OR
- 3. Loss of ALL Table C1 NRG communication capabilities affecting the ability to perform NRG notifications.
Table C1 Communication Capabilities System Onsite Offsite NRC Gaitronics X Hand Held Portable Radio (Station Radio) X PBX (Conventional Telephone lines) X X X Control Room installed satellite phone (non portable) X X ENS X X RECS X !Basis: This IC addresses a significant loss of onsite, offsite, or NRG communication capabilities. While not a. direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRG. This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.). EAL#1 Basis Addresses a total loss of the communication methods used in support of routine plant operations. December 2018 NMP 2-108 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS
- -------- --- --------- ---*-- - - ---- - ------ -------- - ----- ---- _ __ _____ _ _ ---~_U4_ (c:_~11-~}
- B~~i~_(COl)t):___ ____ ________________________ _
EAL#2 Basis Addresses a total loss of the communication methods used to notify all Offsite Response Organizations (OROs) of an emergency declaration. The Offsite Response Organizations (OROs) referred to here are listed in procedure EP-CE-114-100-F-05, Part 1 Notification Fact Sheet. EAL#3 Basis Addresses a total loss of the communication methods used to notify the NRC of an emergency declaration.
- e-as1s-Rete-rence(sj:**---__ -- ---_--__ - ----- __ -_- _-_-_ ------ --~-~----=--~:_* -~-----~-~----:* -- -____ _
- 1. USAR Section 9.5.2
- 2. Nine Mile Point Nuclear Station Site Emergency Plan, Section 7.2
- 3. N2-0P-76 Plant Communications
- 4. EP-CE-114-1 OO-F-05, Part 1 Notification Fact Sheet
- 5. NEI 99-01 Rev 6, CU5 December 2018 NMP 2-109 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 l_r1Jt!i:lt~ng -~9!1~ltJQ11_~_ __ __ _ ____ _ Inability to maintain the plant in cold shutdown. Qp_~t~_t_i11g_MQ_g_~_~p~l_i_~a~mJy; ___ __ _ ________________ _ 4,5 'Emerge-nc}'Action Ievei(EAL)*:- ___ Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification.
- 1. UNPLANNED rise in RCS temperature to> 200 °F for> Table C2 duration.
Table C2 RCS Heat-up Duration Thresholds RCS Containment Closure Heat-up Status Status Duration Intact Not Applicable 60 minutes* Established 20 minutes* Not Intact Not Established 0 minutes
- If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not applicable.
OR
- 2. UNPLANNED RPV pressure rise> 10 psig as a result of temperature rise.
Basis: UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary) arid its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. December 2018 NMP 2-110 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS
. - - -- .. ~A~ <~<>!1~>
B~~i!; (cont): _ __ ___ __ __ _ RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs, etc.). This IC addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant. A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification. The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact. The 20-minute criterion was included to allow time for operator action to address the temperature rise. The RCS Heat-up Duration Thresholds table also addresses a rise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature rise without a substantial degradation in plant safety. Finally, in the case where there is a rise in RCS temperature, the RCS is not intact, and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) the evaporated reactor coolant may be released directly into the Containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel. EAL #2 provides a pressure-based indication of RCS heat-up. Escalation of the emergency classification level would be via IC CS6 or RS1.
- B_~~,i~~f~ren~~(~)_:-: - - -__--: ~ _-:_:_ _____ -~- -~---- ----~ _-:- -__ ~-- - -_ _ __ ________ _
- 1. Technical Specifications Table 1.1-1
- 2. N2-0SP-RCS-@001 RCS Pressure/Temperature 'verification
- 3. NIP-OUT-01 Shutdown Safety
- 4. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.6.1.1
- 5. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.6.4.1
- 6. N2-0P-34 Nuclear Boiler, Automatic Depressurization and Safety Relief Valves, Attachment 1
- 7. NEI 99-01 Rev 6, CA3 December 2018 NMP 2-111 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU5
- !niti_~~tQ_g_go!l~J!~Q!l= ____________ .. ___ ___ ______ ____ __ __ ___ ___ __ _
UNPLANNED rise in RCS temperature
- _QP~J_ati_'!9 M9~-~ AP~i_c~~i_licy;__ __ __ ____ ___ ___ __ _ _________ ----- - --- ~---~:-*~:---~ _- ~~-~~*
4,5
- E_~~rg~l}cy A~_tjc;,11_ ~~v~I J~~-b)~ __ __ ____ _ ____ __ ____ _____ _______________ _
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification.
- 1. UNPLANNED rise in RCS temperature to> 200 °F.
OR
- 2. Loss of the following for~ 15 minutes.
- ALL RCS temperature indications AND
- ALL RPV water level indications
- easis
- -** .... -- --- . --- -- - ------ *- - --*---- - -- __ ...,
I UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. This IC addresses an UNPLANNED rise in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level, represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to IC CAS. RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs, etc.). December 2018 NMP 2-112 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU5 (cont) ~~~~i~_{~Qr,t): ___ ------ ------------ ------ ------ - --- ---------------- --- - ----- ---- ---- . A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification. EAL#1 Basis This involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation. During an outage, the level in the reactor vessel will normally be maintained above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at reduced inventory may result.in a rapid rise in reactor coolant temperature depending on the time after shutdown. EAL #2 Basis This reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication. Escalation to Alert would be via IC CA6 based on an inventory loss or IC CAS based on exceeding plant configuration-specific time criteria . !Basis_Reference(s): _______________________________________________________________________
- 1. Technical Specifications Table 1.1-1
- 2. N2-0SP-RCS-@001 RCS Pressure/Temperature Verification
- 3. NEI 99-01 Rev 6, CU3 December 2018 NMP 2-113 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6
-* - - - - . l Loss of RPV inventory affecting fuel clad integrity with containment challenged.
~q~~_r~JJ11g __M_Qd~~~PH~ctl?i!!fy; __ __________________________________________ _ 4,5
- t;rii~~e~iici~~-~ti~"- -~~~~C<~A~ff~ --~ -*_-_ ---~ :_-_: ~~-~- - ~ *=~---*:~---- *:=*~
- _ *_-_: -~ ~-- _ *~-:- ---~ - ~ ~-- * *
- Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. a. RPV water level < -14 inches for~ 30 minutes.
AND
- b. ANY Table C5 Containment Challenge Indication.
OR
- 2. a. RPV water level cannot be monitored for~ 30 minutes.
AND
- b. Core uncovery is indicated by ANY of the following:
- Table C4 indication of a sufficient magnitude to indicate core uncovery.
OR
- ANY Table C3 Refuel Floor Rad monitor~ 3 R/hr.
AND
- c. ANY Table C5 Containment Challenge Indication.
Table C3 Refuel Floor ARMs
- 2RMS-RE111
- 2RMS-RE112
- 2RMS-RE113
- 2RMS-RE114 December 2018 NMP 2-114 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex . Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont)
- Emergency Action Level_(EAL)Jcont)
- __________ _
Table C4 Indications of RCS Leakage
- UNPLANNED Prywell equipment drain sump level rise*
- UNPLANNED Drywell floor drain sump level rise*
- UNPLANNED Reactor Building equipment sump level rise*
- UNPLANNED Reactor Building floor drain sump level rise*
- UNPLANNED Suppression Pool level rise*
- UNPLANNED vessel make up rate rise*
- Observation of leakage or inventory loss
*Rise in level is attributed to a loss of RPV inventory.
Table CS Containment Challenge Indications
- Primary Containment Hydrogen Concentration ~ 6% and Oxygen ~ 5%
- UNPLANNED rise in containment pressure
- CONTAINMENT CLOSURE not established*
- RB area radiation > 8.00 E+03 mR/hr
- If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.
,Basis: - ---- --*-- ---- -- - ---*-- ---- -- -.. -* ----- - -- - - *- - ------- - ---------- -- - --- --- - --- ----- - - -- - - - -~.. -- - --*- ------ ----- ~ -- ' UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions. CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. December 2018 NMP2-115 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS c~-~ J~<?-~~l This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA Protective Action Guidelines (PAG) exposure levels offsite for more than the immediate site area. Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable. With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required. The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity. In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will pr:eclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged. EAL#2 Basis The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred -(i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring. The inability to monitor RPV water level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV. December 2018 NMP 2-116 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS
- ~~sls__(~q_!Jt); _ ___ _
- '--,- ----- --- -- -- --- -- ---- _q_~~-(~~!'l~l These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
- B.i!__s~ ~~ff3_r~ncf3{~)~--- ____ - _______________
- 1. USAR Section 5.2.5
- 2. USAR Section 7.6.1.3
- 3. N2-EOP-PC Primary Containment Control
- 4. N2-0P-92 Neutron Monitoring
- 5. N2-EOP-RPV RPV Control
- 6. NER-2M-039, NMP2 Emergency Operating Procedures (EOP) Basis Document
- 7. NIP-OUT-01 Shutdown Safety
- 8. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.6.1.1
- 9. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.6.4.1
- 10. N2-EOP-PCH Hydrogen Control
- 11. N2-EOP-SC Secondary Containment Control
- 12. Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States
- 13. NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management
- 14. NEI 99-01 Rev 6, CG1 December 2018 NMP2-117 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6
- ll"!it~~!in_g C_o._ng_iti_Q_I"!: _____ __ ____ __ ___________
Loss of RPV inventory affecting core decay heat removal capability.
- 9pe.rc!'t!.ng_ lV!9c_l_~_Appl!caJ>Jl~ty; ______________________________________ _
4,5 ~Ern_e_~9~!1_cy .Ac;tl<<?!l__~e'(~I (l;Abl;__ ______ ____ _______ _ __ ____ ______ ____ ___ ____ ___ __ _ ______________________ _ Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. With CONTAINMENT CLOSURE not established, RPV water level
< 17.8 inches.
OR
- 2. With CONTAINMENT CLOSURE established, RPV water level< -14 inches.
OR
- 3. a. RPV water level cannot be monitored for~ 30 minutes AND
- b. Core uncovery is indicated by ANY of the following:
- Table C4 indication of a sufficient magnitude to indicate core uncovery.
OR
- ANY Table C3 Refuel Floor Rad monitor~ 3 R/hr.
Table C3 Refuel Floor ARMs
- 2RMS-RE111
- 2RMS-RE112
- 2RMS-RE113
- 2RMS-RE114 December 2018 NMP2-118 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 (cont) '.~11_1e_rg_~_l!~y_-~J;t!_~r1-~_~y~I (!;A~) (~C>l'.l_t)~ _ ___ __ _ ____ _ ____ ___ ___ _ _ __ _ ___ _ _______________ _ Table C4 Indications of RCS Leakage
- UNPLANNED Drywell equipment drain sump level rise*
- UNPLANNED Drywell floor drain sump level rise*
- UNPLANNED Reactor Building equipment sump level rise*
- UNPLANNED Reactor Building floor drain sump level rise*
- UNPLANNED Suppression Pool level rise*
- UNPLANNED vessel make up rate rise*
- Observation of leakage or inventory loss
*Rise in level is attributed to a loss of RPV inventory.
UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration. Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable. Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions. The difference in the specified RCS/reactor vessel levels of EALs #1 and #2 reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment. December 2018 NMP 2-119 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 (cont)
- Basis (cont):___ ___ __ ___________ __ __ __ _____ _ __ ______________ _______________________________ :
EAL #3 Basis The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring. The inability to monitor RPV water level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV. These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management. Escalation of the emergency classification level would be via IC CG6 or RG1. December 2018 NMP2-120 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 (cont)
- Basis Reference(s): _ _____ __ __ ____ __ ____ __ _____ ____ __
- 1. USAR Section 5.2.5
- 2. USAR Section 7.6.1.3
- 3. N2-EOP-PC Primary Containment Control
- 4. N2-0P-92 Neutron Monitoring
- 5. N2-EOP-RPV RPV Control
- 6. NER-2M-039, NMP2 Emergency Operating Procedures (EOP) Basis Document
- 7. NIP-OUT-01 Shutdown Safety
- 8. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.6.1.1
- 9. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.6.4.1
- 10. N2-EOP-PCH Hydrogen Control
- 11. N2-EOP-SC Secondary Containment Control
- 12. Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States
- 13. NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management
- 14. NEI 99-01 Rev 6, CS1 December 2018 NMP 2-121 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS I --- - --- - *** .-- - -, - --- **-- * -------- * - *- - -- - - - - - * . - - *--* -~-- - --*-** CA6 Jr:!i_ti_a_t~11g__Qo_n_dj~i_c;>r1:___ __ ____ ____ __ ________________ _ Loss of RPV inventory.
- o~~-r-~tirig-_M-oJ!~-A~JiiJc3-~i)_ifi~ -___-_-:-- ~~:~ -_ - :--~ _~ - _::- __::__--- ----
4, 5 'i:;_l'l'.le_rg~_S:-~YA_~~i~a:i-~~-vel (~!d~): __ ____ _____ __ ____ ______ _ _ ___ __ __ _ _ _____ ____ _ _________
- Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. Loss of RPV inventory as indicated by level < 108.8 inches.
OR
- 2. a. RPV water level cannot be monitored for~ 15 minutes.
AND
- b. Loss of RPV inventory per Table C4 indications.
*Table C4 Indications of RCS Leakage
- UNPLANNED Drywell equipment drain sump level rise*
- UNPLANNED Drywell floor drain sump level rise*
- UNPLANNED Reactor Building equipment sump level rise*
- UNPLANNED Reactor Building floor drain sump level rise*
- UNPLANNED Suppression Pool level rise*
- UNPLANNED vessel make up rate rise*
- Observation of leakage or inventory loss
*Rise in level is attributed to a loss of RPV inventory . .Basis:
UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety. December 2018 NMP 2-122 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS
---- - - -- - _________________ ~~6_ (c~-~-~l B~si~J~o_nt):__ _
EAL#1 Basis A lowering of water level below 108.8 inches indicates that operator actions have not been successful in restoring and maintaining RPV water level. The heat-up rate of the coolant will rise as the available water inventory is reduced. A continuing drop in water level will lead to core uncovery. Although related, EAL #1 is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). A rise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA5. EAL#2 Basis The inability to monitor RPV water level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV. The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS6 If the RPV water level continues to lower, then escalation to Site Area Emergency would be via IC CS6. '~asj~_ R__efe~~nc~(~)_: _ __
- 1. USAR Section 5.2.5
- 2. USAR Section 7.6.1.3
- 3. N2-EOP-PC Primary Containment Control
- 4. N2-0P-33 High Pressure Core Spray
- 5. N2-EOP-RPV RPV Control
- 6. N2-0P-34 Nuclear Boiler, Automatic Depressurization, and Safety Relief Valves
- 7. NEI 99-01 Rev 6, CA1 December 2018 NMP 2-123 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 )_riit(citfr~g :Poniji!*~ri: *_ ~-:*.~. . -** .- - -. - UNPLANNED loss of RPV inventory for 15 minutes or longer. i.PP~i~f*riiJ iVfo~iArii>JJc;:j~ffi_ty~--- ------~ .... 4,5 ~E.i:!l_~_rg~ri~YA~~Ie>~--~ei~UEA~): __ -__*_: * - Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. UNPLANNED loss of reactor coolant results in the inability to restore and maintain RPV water level above the procedurally established lower limit for~ 15 minutes.
OR
- 2. a. RPV water level cannot be monitored.
AND
- b. Loss of RPV inventory per Table C4 indications.
Table C4 Indications of RCS Leakage
- UNPLANNED Drywell equipment drain sump level rise*
- UNPLANNED Drywell floor drain sump level rise*
- UNPLANNED Reactor Building equipment sump level rise*
- UNPLANNED Reactor Building floor drain sump level rise*
- UNPLANNED Suppression Pool level rise*
- UNPLANNED vessel make up rate rise*
- Observation of leakage or inventory loss
*Rise in level is attributed to a loss of RPV inventory.
December 2018 NMP 2-124 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 (cont) !Basis: ___ _______________________________________________________________________________ _ UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown. This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RPV water level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant. The procedurally established lower limit is not an operational band established above the procedural limit to allow for operator action prior to exceeding the procedural limit, but it is the procedurally established lower limit. Refueling evolutions that lower RCS water inventory are carefully planned and controlled. An UNPLANNED* event that results in water level lowering below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered. _ EAL #1 Basis This recognizes that the minimum required RPV water level can change several times during the course of a refueling outage as different plant configurc::1tions and system lineups are_implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document. The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the . expected water level. This criterion excludes transient conditions causing a brief lowering of water level. EAL #2 Basis This addresses a condition where all means to determine RPV water level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV. Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA6 or GAS. December 2018 NMP 2-125 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN/ REFUELING SYSTEM MALFUNCTIONS CU6 (cont)
- ~a,s_is_Re_f_~re11~~(s): . .. _ ___ __ _____ _ __________
- 1. N2-EOP-RPV ~PV Control
- 2. N2-0P-34 Nuclear Boiler, Automatic Depressurization, and Safety Relief Valves
- 3. NIP-OUT-01 Shutdown Safety
- 4. N2-SOP-31 R Refueling Operations Alternate Shutdown Cooling
- 5. Improved Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, 3.4.7
- 6. USAR Section 5.2.5
- 7. USAR Section 7 .6.1.3
- 8. N2-EOP-PC Primary Containment Control
- 9. NEI 99-01, Rev. 6 CU1 December 2018 NMP 2-126 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 ,l_~itiating C~nd_ition: HOSTILE ACTION within the PROTECTED AREA.
- Qp_era~ing l'.lllc;>~e APP.li~alJi_ltty: __ _
1, 2, 3, 4, 5, D 'gm_ergency_Action_- ~evef (EAL): - -- A notification from the Security Supervisor that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.
- Basis:
HOSTILE ACTION: An act toward a NPP 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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety. PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence. HOSTILE FORCE: Any 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. 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. This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment. Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program]. December 2018 NMP 2-127 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY _______________ __ __ _____ _____ ____ __ _____ ___ H_~1__ (~~n!) ~-c!~is_ (c~m_t):_ ___ __ __ As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Site Area Emergency declaration will mobilize Offsite Response Organization (ORO) resources and have them available to develop and irnplement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions. This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA; such an attack should be assessed using IC HA 1. It also does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR.
§ 50.72.
Escalation of the emergency classification level would be via IC RG1, RG2 and HG7. j_~~~i~:R~f~r~-rj~e(~f:_ ----_ -_ - ~-- - ---- --~- __ :: ~ ~ :_ ~:~ ~~--~-- -:_-:: _:_--~- ~--:-_ .- -_-:_ :_~ -~_::-~ -
- 1. NMP Site Security Plan
- 2. NEI 99-01 Rev 6, HS1 December 2018 NMP 2-128 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY
- - - -- ~ ... - -
HA1 'lni_tja!l_ng_Gc:>ndi~ior_'!:__ _ __ HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes. ,gp~r_~~j!Jg l\ll_qd_~ ApplJc~llmfy: ____ _ 1,2,3,4,5, D E_ITl8.!9~-n~i _A~_tlc:>!1 _be."aj___(~Al.)_~_ _ _____ . __ _
- 1. A validated notification from NRC of an aircraft attack threat< 30 minutes from the site.
OR
- 2. Notification by the Security Supervisor that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA.
Basis: HOSTILE ACTION: An act toward a NPP 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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety. OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons entering for official business. PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence. HOSTILE FORCE: Any 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. This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the December 2018 NMP 2-129 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 (cont) _Basis (cont)_: PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact. Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program]. As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions. This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, _etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. EAL#1 Basis Addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with OP-NM-106-104, Security Contingency Event. EAL #2 Basis Applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA. The NRG Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRG. In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRG. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency. Escalation of the emergency classification level would be via IC HS1. December 2018 NMP 2-130 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 (cont) ~-~~-i~_~ef~r~n_c~(s)_: _____ _
- 1. NMP Site Security Plan
- 2. OP-NM-106-104, Security Contingency Event
- 3. NEI 99-01 Rev 6, HA1 December 2018 NMP 2-131 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU1 tn!~i-~tlng G9_nditiori_:_ _____ __ __ __ __ _ ____ _ _ _ _______ _ Confirmed SECURITY CONDITION or threat. '(5p-~r~I*n_g-Mgg_e App1_1~ij~fi.ty_:_ _ -_ --_-_:-_:-----~---: :~-~--~:_-. 1,2,3,4,5, D J~jnjfrgii~~Y },~f1~iiJ~~f~C<~A~l;~--- :~~:-~-- ~~-=-- - -: :-_ -_ -_-_: :_- - _- - -_ - :- - - ~- - ___ -_-_- _-_-:- -~- -*:_*
- 1. Notification of a credible security threat directed at the site as determined per SY-AA-101-132, Security Assessment and Response to Unusual Activities.
OR
- 2. A validated notification from the NRC providing information of an aircraft threat.
OR
- 3. Notification by the Security Supervisor of a SECURITY CONDITION that does not involve a HOSTILE ACTION.
Basis: 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 SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. HOSTILE ACTION: An act toward a NPP 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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety. This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the December 2018 NMP 2-132 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY _1-1y1_ (con~)
- Ba~i~ (cor:it)_:
requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1. Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and Offsite Response Organizations (OROs). Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program]. EAL #1 Basis Addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with SY-AA-101-132. EAL#2 Basis Addresses the threat from the impact of an aircraft on the plant. The NRG Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRG. Validation of the threat is performed in accordance with OP-NM-106-104, Security Contingency Event. EAL #3 Basis References Security Supervisor because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR
§ 2.39 information.
Escalation of the emergency classification level would be via IC HA1. 'Bails ~ef~_ren~e(~): *_ ____ _ _ __ __ ~ --_ :- ___ ~:- __
- 1. NMP Site Security Plan
- 2. OP-NM-106-104, Security Contingency Event
- 3. SY-AA-101-132, Security Assessment and Response to Unusual Activities
- 4. NEI 99-01 Rev 6, HU1 December 2018 NMP 2-133 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 J'1i~(af(~gj~~~-diji9._~~- _--~-:--~-~ _- --=----__:_- -_ -_::~ _-- ~-::--- _ --_::-_ -_ -~~~_-_::~:-~-~~:-_-_-~ - -~ --:~--~-~ Inability to control a key safety function from outside the Control Room. iQi:!ir~!i!lg]\ij~~~)~ppii~~!)_llify:-:_~ _-__________:--~~ -_:- __ :--:: ~- :- : ~-- _-_- 1, 2, 3, 4, 5, D
- e_n1irg-iriciA~t1~~-ley~IftA~l-:__-
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per N2-S0P-78, Control Room Evacuation.
AND
- 2. Control of ANY Table H1 key safety function is not reestablished in< 15 minutes.
Table H1 Safety Functions
- Reactivity Control (ability to shut down the reactor and keep it shutdown)
- RPV Water Level (ability to cool the core)
- RCS Heat Removal (ability to maintain heat sink)
'Basis: The time period to establish control of the plant starts when either:
- a. Control of needed safety functions is no longer maintained in the Main Control Room OR
- b. The last Operator has left the Main Control Room.
This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plant control to alternate locations is a precursor to a challenge to any fission product barrier within a relatively short period of time. December 2018 NMP 2-134 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 (cont) 1 ~~~!~ _(COrJt)~_ _ _ ____ _ The determination of whether or not "control" is established at the remote safe shutdown location(s) is based on Emergency Director judgment. The Emergency Director is expected to make a reasonable, informed judgment within 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s). Escalation of the emergency classification level would be via IC FG1 or CG6.
]~~~1s*Re.f.ei~:Qc~(~i=:-~:-=*---- _-_*-:-:_--
- 1. USAR Section 9B.8.2.2
- 2. N2-S0P-78, Control Room Evacuation
- 3. NEI 99-01, Rev 6 HS6 December 2018 NMP 2-135 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA2 J~it1~fii1g- Go~dfti91i:::--_ -______ -_ -_- __ -:~_: _-: ~ ___ --,;_::-_ :---:~~- -~--:~:~--~--- _: :_ -~:---------~ -~---_: ::. :_-__ -~ -_:_ - Control Room evacuation resulting in transfer of plant control to alternate locations.
- qp~fij_nng)ij~~_App"fi_~a~-i)_ify-:_:_ -_ -_- __:: ~: ~:--*- - --- -- ----_- -: --~-- --~~--:---~- _____ _
1 , 2, 3, 4, 5, D A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per N2-S0P-78, Control Room Evacuation.
- ~~~i_!;_;_ . - -- ------ - . ---- ---- --- ------ ---- - ------- - ----------------- -- ----- ---------* ------
This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety. Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations. The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel. Activation of the ERO and emergency response facilities will assist in responding to these challenges. Escalation of the emergency classification level would be via IC HS2. '.i3asii_~~t~riri~i(~>=_---__ -: :--~--: -~-~-: :-*~~- - __ ----:-~_: __-- ~-- - _ -~ _--- __ :* -~- - -:~ : -_-_:_~-- -:-:_ :_ --~: --
- 1. USAR Section 98.8.2.2
- 2. N2-S0P-78, Control Room Evacuation
- 3. NEI 99-01, Rev 6 HA6 December 2018 NMP 2-136 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 .foii1_~f1~g _¢_c;,~~#19n::~ ~::~-: : __ -::-:--~----- . ________ _ FIRE potentially degrading the level of safety of the plant. ~Qp~rati_ng __M_9~-~ ~~pl_!~~~ll~ty~ __ _ _ ___ . _ . __ _ . __ 1,2,3,4,5, D
- i;riii~g~-"~iAit1Qn_-~~i~f(E~1;1:*_-__-_-- -:-- --~-- _____ .
Note:
- The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- Escalation of the emergency classification level would be via IC CA2 or MAS.
- 1. A FIRE in ANY Table H2 area is not extinguished in < 15 minutes of ANY of the following FIRE detection indications:
- Report from the field (i.e., visual observation)
- Receipt of multiple (more than 1) fire alarms or indications
- Field verification of a single fire alarm Table H2 Areas
- Reactor Building (when inerted the Drywell is exempt)
- Control Room
- Relay Room
- Diesel Generator Engine and Board Rooms
- Standby Switchgear and Battery Rooms
- HPCS Switchgear and Battery Rooms
- Remote Shutdown Rooms
- Control Building HVAC Rooms
- Electrical Protection Assembly Room
- Service Water Pump Rooms OR
- 2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of a FIRE).
AND
- b. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.
OR December 2018 NMP 2-137 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)
- Ef!le_rg~n~y _Ac_tio_!I_ ~~"-~I (E_A~)_ (~o_Q.t): _____ ___ _ ____ __ __ __ _ _____ ________ __ __ _ ________ _
- 3. A FIRE within the plant PROTECTED AREA not extinguished in< 60 minutes of the initial report, alarm or indication.
OR
- 4. A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.
- easis:_________ -- ----- ---------- ---- - - ----- ------------- - ------ ------- ------------------- -----------------*
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. PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence. 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. This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant. EAL #1 Basis The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc. Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, ahd not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarms, indication or report. EAL#2 Basis This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed. December 2018 NMP 2-138 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont) A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress. I If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted. EAL#3 Basis In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety. EAL#4 Basis If a FIRE within the plant PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency*to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade ~o extinguish. Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions. ISFSI is not specifically addressed in EAL #3 and #4 since it is within the plant PROTECTED AREA and is therefore covered under EALs #3 and #4. Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part: Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements,. the probability and effect of fires and explosions." When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off. Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire December 2018 NMP 2-139 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont) ,BasisJcont): __ damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents. In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period. Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MA5.
- Basis Reference(s)
- ______________________ _
- 1. USAR 98 and Figure 9B.6-1
- 2. NEI 99-01, Rev 6 HU4 December 2018 NMP 2-140 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 J~itl~ti_11g <;:o~~m_i~_r:1:____ _ Seismic event greater than OBE levels.
- 9p~rif~og-_Njc;,_<!~-_AppJicj-61Hfyi
- =~ ___--==-:-.~~~ ~-- -~~~-- -~--~- --
1,2,3,4,5,D '.~rr,~g~-n~iA~Hi,ri *i~~el]~Ai;)i- -~ :~--~-~~-- ---~- _--~ ----___-- -~: :_- ~~~- _--~ --- :--:-_*: Note:
- For emergency classification if EAL # 2.b is not able to be confirmed, then the occurrence of a seismic event is confirmed in a manner deemed appropriate by the Shift Manager or Emergency Director in~ 15 minutes of the event.
- Escalation of the emergency classification level would be via IC CA2 or MAS
- 1. Seismic event > Operating Basis Earthquake (QBE) as indicated by:
- Computer Point ERSNC02, QBE Detected OR
- ANY amber LED light lit at the Seismic Monitor Panel, Response Spectrum Annunciator.
OR
- 2. When Seismic Monitoring Equipment is not available:
- a. Control Room personnel feel an actual or potential seismic event.
AND
- b. ANY one of the following confirmed in ~ 15 minutes of the event:
- The earthquake resulted in Modified Mercalli Intensity (MMI) ~ VI and occurred
~ 3.5 miles of the plant.
- The earthquake was magnitude ~ 6.0
- The earthquake was magnitude~ 5.0 and occurred~ 125 miles from the plant.
- If the above bullets are not able to be confirmed, then the occurrence of a seismic event is confirmed in a manner deemed appropriate by the Shift Manager or Emergency Director.
December 2018 NMP 2-141 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 (cont)
- Basis:
.EAL #1 Basis This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (QBE) 1 . An earthquake greater than an QBE but less than a Safe Shutdown Earthquake (SSE)2 should have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections). Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety of the plant. Event verification with external sources should not be necessary during or following an OBE. Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event. The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration. EAL#2 Basis EAL #2 is included to ensure that a declaration does not result from felt vibrations caused by a non-seismic source (e.g., a dropped load). The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., call to USGS, check internet source, etc.) however, the verification action must not preclude a timely emergency declaration. This guidance recognizes that it may cause the site to declare an Unusual Event while another site, similarly affected but with readily available QBE indications in the Control Room, may not. Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MAS. 1 An QBE is vibratory ground motion for which those features of a nuclear power plant necessary for continued operation without undue risk to the health and safety of the rublic will remain functional. An SSE is vibratory ground motion for which certain (generally, safety-related) structures, systems, and components must be designed to remain functional. December 2018 NMP 2-142 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 (cont) J~_c1~!~ ~~f~r~~~e(s): __________ _
- 1. USAR Section 3.7
- 2. Technical Requirements Manual Section 3.3.7.2
- 3. N2-0P-90 Seismic Monitor
- 4. N2-SOP-90 Natural Events *
- 5. USAR Section 2.1.1.1
- 6. US NRC Reg. Guide 1.166, Pre-Earthquake Planning and Immediate Nuclear Power Plant Operator Earthquake Actions
- 7. NEI 99-01, Rev 6 HU2 December 2018 NMP 2-143 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HAS Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.
- _Qp~r~ti"!g_MC?_d~_AppJj_c;~b_l!Jty:_ _ _ __ __ _ _ _____ ______ ____ _______ _
3,4,5 ._E;_rn~rg~n~y A_~ti_<>.'!_ L~yel _(!;~J,.)_:_ __ _____ ___ ___ ___ _ _ _____ __ _____ _ ___ _____ ______ __ _ _ __ ___ Note:
- If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.
- 1. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area.
Table H3 Areas with Entry Related Mode Applicability Entry Related Area Mode Applicability Reactor Building 175' RHS A Pump Room (RHR A) 196' Az 56 Deg (RHR A) 175' RHS B Pump Room (RHR A & B) Mode 3, 4, and 5 Control Building 261' Div 1 Switchgear Room (RHR A & B) 261' Div 2 Switchgear Room (RHR A & B) AND
- 2. Entry into the room or area is prohibited or impeded 1
easis: -- ----- -------- - -- - - --- This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to transition the plant from normal . plant operation to cooldown and shutdown as specified in normal plant procedures. This condition represents an actual or potential substantial degradation of the level of safety of the plant. Assuming all plant equipment is operating as designed, normal operation is capable December 2018 NMP 2-144 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY
.-------- ----- ... -- -- --- - ---- - - -- -------- ~-A?__(~-°--"~l from the Main Control Room (MCR). The plant is also able to transition into a hot shutdown condition from the MCR, therefore Table H3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown.
This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections). This Table does not include the Control Room since adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas. An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the gaseous release preclude the ability to place shutdown cooling in service. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release. Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill .effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed). An emergency declaration is not warranted if any of the following conditions apply.
- The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release). For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.
- The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).
- The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
December 2018 NMP 2-145 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY __________ ~-A~ (~Q_n_!l
- The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.
An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by 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. This EAL does not apply to firefighting activities that generate smoke, that automatically or manually activate a fire suppression system in an area, or to intentional inerting of containment.
- Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.
-~~~~~~~fer~l"lce(~):___ _ __ ________ _
- 1. USAR 98 and Figure 9B.6-1 --.
- 2. NFPA 12 A Halon 1301 Fire Extinguishing Systems
- 3. N2-0P-31, Residual Heat Removal System Operation
- 4. NEI 99-01, Rev 6 HA5 December 2018 NMP 2-146 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 Joitic1~i_rig 9o_r1d_i!km;_ ___ __ _ ______ _ ________________ Hazardous Event
- Op~_r~tira_g t\ll_Q~~-~ppl_i_c_a~i!i_~;_ ____ _______________ _
1,2,3,4,5,D Ern~rg~r:,cr ~c_ti_c;,_r:,__~~y~I_ (~~~);___________________________________ _ Note:
- EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.
- Escalation of the emergency classification level would be via IC CA2 or MAS.
- 1. Tornado strike within the PROTECTED AREA.
OR
- 2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical specifications for the current operating mode.
OR
- 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).
OR
- 4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.
OR
- 5. Intake Water Level< 237 feet.
'Basis: PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence. SAFETY SYSTEM: A system required for safe plant operation, cooling down the _plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant. December 2018 NMP 2-147 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HUS (cont) J~_a~!~. (cqnt)_:______________ _ EAL#1 Basis Addresses a tornado striking (touching down) within the Protected Area. EAL#2 Basis Addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns. Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode. EAL#3 Basis Addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA. EAL#4 Basis Addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of such an event include site flooding caused by a hurricane, heavy rains, or high winds. This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011. EAL #5 Basis The low level is based on intake water level and corresponds to the design minimum lake level. The probable minimum low water level of Lake Ontario at the site has been determined to be 72.0 m (236.3 ft) resulting from a setdown caused by a Probable Maximum Wind Storm concurrent with the lowest probable lake level. Escalation of the emergency classification level would be based on ICs in Recognition Categories R, F, M, Hor C. December 2018 NMP 2-148 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 (cont)
- -- -- -----*~ - - - --*--
.B~~is_~e.t~r~~~e(~): __ _ _ _ ___ _
- 1. USAR Section 2.4.1 .2
- 2. USAR Section 2.4.11.2
- 3. N2-0SP-LOG-W001, Weekly Checks
- 4. USAR Section 9.2.5.3.1
- 5. USAR 98 and Figure 9B.6-1
- 6. USAR Section 3.3.1 .1
- 7. N2-0P-102 Meteorological Monitoring
- 8. N2-SOP-90 Natural Events
- 9. NEI 99-01, Rev 6 HU3 December 2018 NMP 2-149 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY. '.Qp~j-~t(ng]Vt~~t~:Ai>i>IJ~_alifUty:_ -_ -- ---~--- ~-. -- ~=-: : --:_:_: --- - _-_:_:-=~:: :-~--- _: _:_ ---:--- - _- _-_:--~ 1,2,3,4,5, D
- Emergency Action Level_ (EAL): ______ _
Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area. J3_aji~= : _ -~:: _:-~--- :-::~---_ :.::---- ~~ -__ :=_ :-=--:- _-_ -_: ---~: -___~:-_:----~ --:~:: * ==:~: :-=-: :**-=- -_:_ :: IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions. HOSTILE ACTION: An act toward a NPP 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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety. This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a General Emergency. ,-~~~i~__Re~er~iice(~f:-_. __
- 1. NEI 99-01, Rev 6 HG?
December 2018 NMP 2-150 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS7 [lniti_~tiJ1g C_Q!l~itio_n_: __ _____ _ Other conditions exist which in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY.
- ~}p~~~~!rig _M_9~~-APPff~i~J f(ty;=-=__:=~--_ ~---~ _-~:- --_: -
1,2,3,4,5, D
- ~i!iejg-e~f;il\~tlgfl).~~~f(f;AC):::_~- - =~=~ _: _--=- ~~----:: _-____ :~ -~- -_:-:- _- - ~~~= ~--: ~- -~~ --~-= ~--_-_- ---~-=:-_
Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.
- easis:
HOSTILE ACTION: An act toward a NPP 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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station - PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety. This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a Site Area Emergency.
- ~~~i_s__~e_f~~~nc~(s)~_________ _
- 1. NEI 99-01, Rev 6 HS7 December 2018 NMP 2-151 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT. '.9P~r~~(rig1~f9ciEi~~ppii~8-~1J_iti=~~~~: ~~- ------ ---~---~~- -:- -__--_ - 1,2,3,4,5, D
- i:-niejgenciAcficin-Levei]EALj:- --_----- __---- - _-- -__ -- __ -- ---__ ---- _-_ -___ -- ----_ -_--_---__ ----- --:
Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.
- Basis:
HOSTILE ACTION: An act toward a NPP 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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a NPP that could cause concern. for its continued operability, reliability, or personnel safety. This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert. '.~r:1s,~J~~t~r~n-~e(~ff:: -~---- _- _
- 1. NEI 99-01, Rev 6 HA?
December 2018 NMP 2-152 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU7 jrii_t]~}ln.gJ~i~_ndifi<>il~- -. *: *-_ .: ~-:- *_* ---~ : ~_-_--_ ---~:__ _---~ ~ :--____ .:~ *-_- _*_:_ --_ ~ _~ _:_ - ~- * ~- - --- other conditions exist which in the judgment of the Emergency Director warrant declaration of an UNUSUAL EVENT.
- R~~r-~t_ia:,g __M~geAPPll~-~bility_: _______ ______________________________ _
1, 2, 3, 4, 5, D
- iti1'.l~rein~i .A~t,~n. _b~~~-1 I~A[)i_: _--. _-_: :_---~~~---~ ~-.. ~:-~--** ~- -~~ ___ ~~ :_ : .~~--_~ ~:~~:-
other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs. Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an UNUSUAL EVENT. B~~i~Ji~f~r~a:,_CE;!(~)_: ____ . __
- 1. NEI 99-01, Rev 6 HU7 December 2018 NMP 2-153 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ISFSI MALFUNCTIONS E-HU1-
- _lniti_8-!i_i:1g C.Ql!c;!_i!iq_~_ ___ _ _ ___ _ ___ _ _ _______ _
Damage to a loaded cask CONFINEMENT BOUNDARY. ,9pe!~ti_ng_MQc;_l~_APPH~~billty~--- _____ ________ ____ _ ______________ _ 1,2,3,4,5, D J;~-~.!9~11~Y_Acth~nJ._ey~!J~A~): __________________________________ _ Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading: For 61 BT DSC:
* > 800 mrem/hr 3 feet from the HSM surface OR
* > 200 mrem/hr outside the HSM door on centerline of DSC OR
* > 40 mrem/hr end of shield wall exterior For 61 BTH DSC:
* > 1400 mrem/hr on the HSM or HSM-H front surface OR
* > 200 mrem/hr on the HSM or HSM-H door centerline OR
* > 40 mrem/hr on the end shield wall exterior 1
- Sa"sfs: ----------- -* ------ ------ - --- * ---- - - --------- ----------
CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment. 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. This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The word cask, as used in this EAL, refers to the storage container in use at the site for dry storage of irradiated fuel. The issues of concern are the creation of a potential or actual release path to the environment, degradation of any fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage. December 2018 NMP 2-154 EP-AA-1013 Addendum 4 (Rev 3)
Nine Mile Point Nuclear Station Unit 2 Annex Exelon Nuclear RECOGNITION CATEGORY ISFSI MALFUNCTIONS E-HU1 (cont)
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The existence of "damage" is determined by radiological survey. The technical specification multiple of "2 times", which is also used in Recognition Category RIC RU1, is used here to distinguish between non-emergency and emergency conditions. The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the "on-contact" dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask. Security-related events for ISFSls are covered under ICs HU1 and HA1. !eas-is-Reterence(s):_____ ------ -----_-_-- --__ ------ -_-_- --- -_--------- ----- --------_--------_ -----
- 1. NEI 99-01, Rev 6 E-HU1
- 2. ATTACHMENT A, TECHNICAL SPECIFICATIONS, TRANSNUCLEAR, INC.
STANDARDIZED NUHOMS HORIZONTAL MODULAR STORAGE SYSTEM, CERTIFICATE OF COMPLIANCE NO. 1004, AMENDMENT NO. 10, DOCKET 72-1004 December 2018 NMP 2-155 EP-AA-1013 Addendum 4 (Rev 3)
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