Text

Enclosures 1 to 3 - EAL Scheme Revisions Enclosure Summary, Discussion of Change and Mps EAL Scheme Revisions-Supporting Documents
	ML19011A171
Person / Time
Site:	Millstone, Surry, North Anna, 07200002, 07200055
Issue date:	01/04/2019
From:	; Dominion Energy Nuclear Connecticut, Virginia Electric & Power Co (VEPCO)
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML19011A237	List: ML19011A170; ML19011A171; ML19011A172; ML19011A173; ML19011A174; ML19011A175; ML19011A176; ML19011A177; ML19011A179; ML19011A180; ML19011A181; ML19011A182; ML19011A183;
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	Download: ML19011A171 (592)
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Serial No.18-364 Docket Nos.: 50-245/336/423/338/339/280/281 72-2/16/4 7/55/56 ENCLOSURE 1 EAL SCHEME REVISIONS ENCLOSURE

SUMMARY

Dominion Energy Nuclear Connecticut, Inc. (DENC)

Virginia Electric and Power Company (Dominion Energy Virginia)

Millstone Power Station Units 1, 2 and 3 and ISFSI North Anna Power Station Units 1 and 2 and ISFSI Surry Power Station Units 1 and 2 and ISFSI

Serial No.18-364 Docket Nos.: 50-245/336/423/338/339/260/281 72-2/16/47/55/56 Enclosure 1 Page 1 of 3 EAL SCHEME REVISIONS ENCLOSURE

SUMMARY

- EAL Scheme Revisions Enclosure Summary . - Discussion of Change - MPS EAL Scheme Revisions - Supporting Documents Attachment 1A MPS1 EAL Comparison Matrix Document Attachment 18 MPS2 EAL Comparison Matrix Document Attachment 1C MPS3 EAL Comparison Matrix Document Attachment 2A MPS1 EAL Technical Bases Document (Marked-up)

Attachment 28 MPS2 EAL Technical Bases Document (Marked-up)

Attachment 2C MPS3 EAL Technical Bases Document (Marked-up)

Attachment 3A MPS1 EAL Technical Bases Document (Final)

Attachment 38 MPS2 EAL Technical Bases Document (Final)

Attachment ~C MPS3 EAL Technical Bases Document (Final) - NAPS EAL Scheme Revisions - Supporting Documents Attachment 1 NAPS EAL Comparison Matrix Document Attachment 2 NAPS EAL Technical Bases Document (Marked-up)

Attachment 3 NAPS EAL Technical Bases Document (Final) - SPS EAL Scheme Revisions - Supporting Documents Attachment 1 SPS EAL Comparison Matrix Document Attachment 2 SPS EAL Technical Bases Document (Marked-up)

Attachment 3 SPS EAL Technical Bases Document (Final) - Emergency Action Level 'Matrices Attachment 1 MPS1 EAL Matrix Attachment 2 MPS2 EAL Matrices (Hot and Cold)

2A MPS2 EAL Matrix - Hot Conditions (RCS >200 °F) 28 MPS2 EAL Matrix - Cold Cpnditions (RCS ~200 °F)

Attac~ment 3 MPS3 EAL Matrices (Hot and Cold) 3A MPS3 EAL Matrix - Hot Conditions (RCS >200 °F) 38 MPS3 EAL Matrix- Cold Conditions (RCS ~200 °F)

Attachment 4 NAPS EAL Matrices (Hot and Cold) -

4A NAPS EAL Matrix - Hot Conditions (RCS >200 °F) 48 NAPS EAL Matrix - Cold Conditions (RCS ~200 °F)

Serial No.18-364 Docket Nos.: 50-245/336/423/338/339/280/281 72-2/16/4 7/55/56 Enclosure 1 Page 2 of 3 Attachment 5 SPS EAL Matrices (Hot and Cold)

SA SPS EAL Matrix - Hot Conditions (RCS >200 °F) 58 SPS EAL Matrix - Cold Conditions (RCS .:::_200 °F) - Summary of Calculations Attachment 1 Calculations for Gaseous Effluent Radiation Monitor Thresholds

Calculation RP-18-08, "MPS1 Abnormal

Rad

Release Gaseous EAL Thresholds Based on NEI 99-01, Revision 6"

Calculation RP-18-02, "MPS2 Abnormal Rad Release Gaseous EAL Thresholds Based on NEI 99-01, Revision 6"

Calculation RP-18-03, "MPS3 Abnormal Rad Release Gaseous EAL Thresholds Based on NEI 99-01, Revision 6"

Calculation RP-08-22, "North Anna Abnormal Rad Release Gaseous EAL Thresholds Based on NEI 99-01, Revision 6"

Calculation RP-18-01, "Surry Abnormal Rad Release Gaseous EAL Thresholds Based on NEI 99-01, Revision 6" Attachment 2 Calculations for Containment High* Range Radiation Monitor Responses to a LOCA

Surry Calculation RA-0063, "Expected Containment High Range Radiation Monitor Response to a LOCA Based on Fuel Rod Gap Fractions Defined in

. NUREG 1228"

North Anna Calculation RA-0064, "Expected

.Containment High Range Radiation Monitor Response to a LOCA Based on Fuel Rod Gap Fractions Defined in NUREG 1228"

. Calculation RA-0074, "Millstone Unit 2 Expected Containment High Range Radiation Monitor Response to a LOCA Based on Fuel Rod Gap Fractions Defined in NUREG 1228"

Calculation RA-0075, "Millstone Unit 3 Expected Containment High Range Radiation Monitor Response to a LOCA Based on Fuel Rod Gap Fractions Defined in NUREG 1228"

Serial No.18-364 Docket Nos.: 50-245/336/423/338/339/280/281 72-2/16/4 7/55/56 Enclosure 1 Page 3 of 3 Detector Response to an RCS Sample

Fleet Calculation RA-0059, "Detector Response to an RCS Sample for EAL Classification of Fuel Clad Degradation and Barrier Loss" Post-Accident Radiation Response for Primary Sample Line

Fleet Calculation RA-0079, "Post- Accident Radiation Response Curves for Primary Hot Leg Sample Lines" Post-Accident Radiation Monitor Response for Core Uncovery

Calculation RA-0078, "Verification of Rad Monitor Response to Core Uncovery"

Calculation M2EP-04164R2, "Rad Monitor Response to Core Uncovery" Post-Accident Letdown Radiation Monitor Response

North Anna Calculation PA-0234, Rev. 1, "Post-Accident Letdown Radiation Monitor Response"

Calculation PA-0236, Rev. 0., Add.* A, "Post-Accident Letdown Radiation Monitor Response for Surry"

Serial No.18-364 Docket Nos.: 50-245/336/423/338/339/280/281 72-2/16/4 7/55/56 ENCLOSURE 2 DISCUSSION OF CHANGE Dominion Energy Nuclear Connecticut, Inc. (DENC)

Virginia Electric and Power Company (Dominion Energy Virginia)

Millstone Power Station Units 1, 2 and 3 and ISFSI North Anna Power Station Units 1 and 2 and ISFSI Surry Power Station Units 1 and 2 and ISFSI

Serial No.: 18-364 Docket Nos.: 50-245/336/423/338/339/280/281 72-2/16/4 7 /55/56 Enclosure 2 Page 1 of 4 DISCUSSION OF CHANGE BACKGROUND North Anna Power Station (NAPS) and Surry Power Station (SPS)

By letter dated March 28, 2007, as supplemented by letters dated October 2, 2007 and January 18, 2008, Virginia Electric and Power Company (Dominion Energy Virginia) requested Nuclear Regulatory Commission (NRC) approval of changes to the emergency action levels (EALs) for NAPS Units 1 and 2 and SPS Units 1 and 2. The requested changes were to convert from an EAL scheme based on NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plan and Preparedness in Support of Nuclear Power Plants," to one based on NEI 99-01,

"Methodology for Development of Emergency Action Levels," Revision 4. The NRC completed a technical and regulatory review of the proposed EAL changes and supporting documentation. The NRC staff concluded that incorporation of the proposed EAL changes would not decrease the effectiveness of the applicable Emergency Plans and the revised Plans would continue to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50. The NRC Safety Evaluation Report (SER) dated February 4, 2008 documented the staff's basis for accepting the proposed EAL changes based on Nuclear Energy Institute (NEI) 99-01, Revision 4, for NAPS and SPS.

Since February 4, 2008, four EAL changes in accordance with NEI 99-01, Revision 4 have been submitted and approved by the NRC as documented in SERs dated April 8, 2009, January 26, 2011, September 25, 2011, and February 2, 2016.

Millstone Power Station (MPS)

By letter dated June 27, 1994, as supplemented by letter dated January 3, 1995, Northeast Nuclear Energy Company requested NRC approval of changes to the EALs for MPS Units 1, 2 and 3. The requested changes were to convert from an EAL scheme based on NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plan and Preparedness in Support of Nuclear Power Plants," to one based on NUMARC/NESP-007, Revision 2. The NRC completed a technical and regulatory review of the proposed EAL changes and supporting documentation. The NRC staff .concluded that incorporation of the proposed EAL changes would meet the

-requirements of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50. NRC SER dated February 27, 1995 documented the staff's basis for accepting the proposed EAL changes* in accordance with NUMARC/NESP-007, Revision 2, for MPS, and subsequently endorsed the EAL scheme in NRC SER dated June 4, 1998 as part of the review of the MPS Emergency Plan, Revision 24.

A revision to the EALs for MPS Unit 1 (MPS 1) was processed in 2000 to reflect the permanently defueled status of the unit. The revised EALs were developed using

Serial No.: 18-364 Docket Nos.: 50-245/336/423/338/339/280/281 72-2/16/4 7/55/56 Enclosure 2; Page 2 of 4 NEI 99-01, Draft Revision 4, since it was the industry guidance available at that time.

The EAL changes were implemented in Revision 26 of the MPS1 Emergency Plan and were reviewed by the NRC during subsequent on-site annual inspections of the MPS1 Emergency Plan.

Proposed Change The proposed EAL change will implement new EAL schemes based on NEI 99-01, Revision 6, "Methodology for Development of Emergency Action Levels for Non-Passive Reactors," for MPS1, 2 and 3, and NAPS and SPS Units 1 and 2. An EAL Comparison Matrix has been prepared for MPS1, MPS2, MPS3, NAPS and SPS [collectively referred to as site/unit] which provides a means for assessing site/unit differences and deviations from the NRC endorsed guidance provided in NEI 99-01, Rev. 6. The EAL Comparison Matrix documents are provided in Enclosures 3, 4 and 5 for MPS, NAPS and SPS, respectively.

The proposed EAL revisions constitute EAL scheme changes from the previously approved NRC EALs. 10 CFR 50, Appendix E, Section IV.B.2, stipulates that a licensee desiring to change its entire EAL scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change.

Therefore, DENG and Dominion. Energy Virginia are requesting NRG review and approval of the proposed EAL revisions for MPS, NAPS and SPS.

Justification The proposed changes affect the MPS, NAPS and SPS EALs, but do not alter the requirements of the Operating Licenses or the Technical Specifications.

The changes do not alter any of the assumptions used in the safety analyses, nor do they cause any safety system parameters to exceed their acceptance limit. Therefore, the proposed changes have no adverse effect on plant safety. Additionally, the changes can be made without adverse impact to plant operations or to the health and safety of the public. The proposed changes are also being requested, in part, to more accurately reflect expected site dose rates. A summary of the site-specific and EP-FAQ approved NEI 99-01, Rev. 6, deviations is included in Table 3 of Enclosures 3, 4 and 5 for MPS, NAPS and SPS, respectively. Based on the technical analysis performed by DENG and Dominion Energy Virginia, the proposed change is considered acceptable.

No Significant Hazards Consideration Dominion has evaluated whether or not a significant hazards consideration is warranted with the proposed change addressing the three criteria set forth in 10 CFR 50.92(c) as discussed below.

Serial No.: 18-364 Docket Nos.: 50-245/336/423/338/339/280/281 72-2/16/4 7 /55/56 Enclosure 2; Page 3 of 4 Criterion 1:

Do the proposed amendments involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes affect the MPS, NAPS and SPS EALs by incorporating new EAL schemes, as well as associated revised engineering analysis, but do not alter any of the requirements of the Operating Licenses or the Technical Specifications. The proposed changes do not modify any plant equipment and do not impact any failure modes that could lead to an accident. Additionally, the proposed changes have no effect on the consequences of any analyzed accident since the changes do not affect any equipment related to accident mitigation. Based on this discussion, the proposed changes do not increase the*probability or consequences of an accident previously evaluated.

Criterion 2:

Do the proposed amendments create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes affect the MPS, NAPS and SPS EALs by incorporating new EAL schemes, as well as associated revised engineering analysis, but do not alter any of the requirements of the Operating Licenses or the Technical Specifications. The changes do not modify any plant equipment'and there are no impacts on the capability of existing equipment to perform its intended design functions. No system setpoints are being modified and no new failure modes are introduced by the proposed changes. The proposed changes do not introduce any new accident initiators or malfunctions that would cause a new or different kind of accident. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Criterion 3:

Do the proposed amendments involve a significant reduction in a margin of safety?

Response: No.

The proposed changes affect the MPS, NAPS and SPS EALs by incorporating new EAL schemes, as well as a~sociated revised engineering analysis, but do not alter any of the requirements of the Operating Licenses or the Technical Specifications. The proposed changes do not affect any of the assumptions used in the accident analyses, nor do the proposed changes affect any operability requirements for equipment important to plant safety. Therefore, the proposed changes will not result in a significant reduction in the margin of safety.

In summary, DENC and Dominion Energy Virginia conclude that the proposed changes do not represent a significant hazards consideration under the standards set forth in 10 CFR 50.92(c).

Serial No.: 18-364 Docket Nos.: 50-245/336/423/338/339/280/281 72-2/16/4 7 /55/56 Enclosure 2; Page 4 of 4 Environmental Consideration DENG and Dominion Energy Virginia have determined that the proposed changes would not change requirements with respect to use of a facility component located within the restricted area, as defined by 1o CFR 20, nor would they change inspection or surveillance requirements. DENG and Dominion Energy Virginia have evaluated the proposed changes and have determined that the changes do not involve:

1. A Significant Hazards Consideration, -

2. A significant change in the types or significant increase in the amounts of an effluent that may be released offsite, or

3. A significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (1 O)(ii). Therefore, pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes.

References

1. NRC SER dated February 4, 2008 (reference Virginia Electric and Power Company letter Serial No.07-001 dated March 28, 2007, as supplemented by letters dated October 2, 2007, and January 18, 2008), including the associated EAL Matrices (Hot & Cold).

2. NRC SER dated February 27, 1995 (reference Northeast Nuclear Energy Company letter dated June 27, 1994, as supplemented by letter dated January 3, 1995); for using the guidance contained in NUMARC/NESP-007, Revision 2.

3. RIS 2003-18, Use of Nuclear Energy Institute (NEI) 99-01, "Methodology .for Development of Emergency Action Levels," Revision 4, dated January 2003, Supplement 1, dated July 13, 2004 and Supplement 2, dated December 21, 2005.

4. NEI 99-01, "Methodology for Development of Emergency Action Levels," Revision 4, dated January 2003.

5. NUMARC/NESP-007, "Methodology for Development of Emergency Action Levels,"

Revision 2, dated January 1992.

6. NUREG 1228, "Source Term Estimation during Incident Response to Severe Nuclear Power Plant Accidents," October 1988. *

7. NUREG 1465, "Accident Source Terms for Light-Water Nuclear Power Plants,"

dated February 1995.

8. Letter from Mark Thaggard, NRC Acting Director Division of Preparedness and Response to Susan Perkins-Grew, NEI Director Emergency Preparedness, dated March 28, 2013 [ADAMS Accession No. ML12346A463].

Serial No.: 18-364 Docket Nos.: 50-245/336/423/72-4 7 ENCLOSURE 3 MPS EAL SCHEME REVISIONS SUPPORTING DOCUMENTS Dominion Energy Nuclear Connecticut, Inc. (DENC)

Millstone Power Station Units 1, 2 and 3 and ISFSI

Serial No.: 18-364 Docket No.: 50-245 Enclosure 3 ATTACHMENT 1A MPS1 EAL COMPARISON MATRIX DOCUMENT Dominion Energy Nuclear Connecticut, Inc. (DENC)

Millstone Power Station Unit 1

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 1 of 25 Millstone Power Station Unit 1 NEI 99-01, Revision 6 EAL Comparison Matrix Document

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 2 of 25 Table of Contents Section ......................................................................................................................... Page Introduction .................................................................................................................................................... 1 Comparison Matrix Format ............................................................................................................................ 1 EAL Wording ............................................. :................................................................................................... 1 EAL Emphasis Techniques ........................................................................................................................... 1 Global Differences ......................................................................................................................................... 2 Differences and Deviations ..................................................................................... ;..................................... 5 Table 1 - NEI / MPS1 EAL Identification Cross-Reference .......................................................................... 7 Table 2 - Summary of Deviations ................................................................................................................. 8 Table 3 - MPS1 Comparison Matrix ........................................................................................................... 10

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 3 of 25 Introduction characteristics - locale, plant design, operating features, terminology, etc.

Meeting this goal will result in a shorter and less cumbersome NRG review A comparison of the Initiating Conditions {ICs), Emergency Action Levels and approval process, closer alignment with the schemes of other nuclear (EALs) and Notes in NEI 99-01, Rev. 6, "Final, Development of Emergency power plant sites and better positioning to adopt future industry-wide scheme Action Levels for Non-Passive Reactors," (ADAMS Accession No.

enhancements".

ML12326A805) and Millstone Power Station Unit 1 (MPS1) ICs, EALs and Notes are provided in this document. Specifically, Recognition Category PD To assist the Director of Station Emergency Operations (DSEO) / Assistant (Permanently Defueled) ICs, EALs and Notes in NEI 99-01, Rev. 6 are Director Technical Support (ADTS), the MPS1 EALs have been written in a compared to the ICs, EALs and Notes for MPS1, a permanently defueled clear and concise style (to the extent that the differences from the NEI EAL reactor. The results of the comparison are provided in Table 3, MPS1 wording could be reasonably documented and justified). This supports timely Comparison Matrix. and accurate classification in the tense atmosphere of an emergency event.

The EAL differences introduced to reduce reading burden comprise almost This document provides a means of assessing MPS1 differences and all of the differences justified in this document.

deviations from the NRG endorsed guidance given -in NEI 99-01, Rev. 6. The MPS1 EAL Technical Bases Document includes a discussion of the MPS1 EAL bases and source document references. It is, therefore, advisable to E:AL Emphasis Techniques refer to the MPS1 EAL, Technical Bases Document for background Due to the width of the table columns and table formatting constraints in this information while using this document.

document, line breaks and indentation may differ slightly from the appearance of comparable wording in the source documents. NEI 99-01, Comparison Matrix Format Rev. 6 is the source document for the NEI EALs; the MPS1 EAL Technical Bases Document is the source document for the MPS1 EALs.

The ICs and EALs discussed in the MPS1 Comparison Matrix are grouped by NEI 99-01 Recognition Category. Within each Recognition Category, the Development of the MPS1 IC/EAL wording has attempted to minimize ICs and EALs are listed in tabular format according to the order in which they inconsistencies and apply sound human factors principles. As a result, are given in NEI 99-01, Rev. 6. Generally, each row of the MPS1 differences occur between NEI and MPS1 ICs/EALs for these reasons alone.

Comparison Matrix provides the following information: When such difference may infer a technical difference in the associated NEI IC/EAL, the difference is identified a,nd a justification is provided.

NEI IC/Ex. EAL identifier The print and paragraph formatting conventions summarized below guide

NEI IC/Ex. EAL wording presentation of the MPS1 EALs in accordance with the EAL writing criteria.

MPS1 IC/EAL identifier Space restrictions in the EAL table of this document sometimes override this criteria in cases when following the ,criteria would introduce undesirable

MPS1 IC/EAL wording complications in the EAL layout.

Justification of any difference or deviation

Upper case-bold underline print is used for the logic terms AND, OR and EITHER.

EAL Wording

Bold print is also used for certain logic terms, negative terms (not, ,

NEI 99-01, Section 4.1, recommends"the following: "The guidance in NEI 99- cannot, etc.), any, all.

01 is not intended to be applied to plants "as-is"; however, developers should

Upper case print is reserved for defined terms, acronyms, system attempt to keep their site-specific schemes as close to the generic* guidance abbreviations, logic terms (and, or,. etc. when not used as a as possible. The goal is to meet the intent of the generic Initiating Conditions conjunction), a.nd annunciator window engravings.

{ICs) and Emergency Action Levels (EALs) within the context of site-specific

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 4 of 25

Three or more items in a list are normally introduced with "Any of the

NEI Recognition Category S, "System Malfunctions," has been following ... " or "All of the following ... " Items of the list begin with changed to Category M, "System Malfunctions," consistent with bullets when a priority or sequence is not inferred. the MPS2 and MPS3 EAL schemes.

The use of and/or logic within the same EAL has been avoided

NEI 99-01 defines the thresholds requiring emergency when possible. When such logic cannot be avoided, indentation and classification (example EALs) and assigns them to ICs which, in separation of subordinate contingent phrases is employed. turn, are grouped in "Recognition Categories." MPS1 endeavors to optimize the NEI EAL organization and identification scheme Global Differences to enhance usability of the plant-specific EAL set. To this end, the MPS1 IC/EAL scheme includes the following features:

The differences listed below generally apply throughout the set of EALs and are not repeated in the Justification sections of this document. The global a. Category and subcategory titles are selected to represent differences do not change the intent of NEI 99-01. conditions that are operationally significant to the EAL-user.

Subcategories are used as necessary to further divide the

1. Plant operating modes are not applicable to permanently defueled EALs of a category into logical sets of possible emergency ICs/EALs and therefore are not specified. classification thresholds. The MPS1 EAL

2. The NEI phrase "Notification of Unusual Event" has been changed to categories/subcategories and their relationship to NEI "Unusual Event" or abbreviated "UE" to reduce EAL-user reading Recognition Categories are listed in Table 1.

burden. b. Unique identification of each EAL - Four characters

3. The title "Emergency Director" is replaced with the MPS1-specific comprise the EAL identifier as illustrated in Figure 1.

title "Director of Station Emergency Operation (DSEO/ADTS)"

4. NEI 99-01 IC Example EALs are implemented in separate plant Figure 1 - EAL Identifier EALs to improve clarity and readability. For example, NEI lists all IC PD-AA1 Example EALs under one IC. The corresponding MPS1 EAL Identifier EALs appear as unique EALs (e.g., RA1.1 through RA1.4). xxx.x

5. NEI 99-01 uses the terms greater than, less than, greater than or Category (R, H, M) _J II L Sequential number within subcategory/classification equal to, etc. in the wording of some example EALs. For consistency Emergency classification (A, U) _J L Subcategory number (1 if no subcategory) and to reduce EAL-user reading burden, MPS1 has adopted use of The first character is a letter associated with the category in boolean symbols in place of the NEI 99-01 text modifiers within the which the EAL is located. The second character is a letter EAL wording. associated with the emergency Classification level (A for Alert, and U for Unusual Event). The third character is a

6. "min." is the standard abbreviation for "minutes" and is used to number associated with one or more subcategories within a reduce EAL user reading burden. given category. Subcategories are sequentially numbered

7. IC/EAL identification: beginning with the number "1". If a category does not have a subcategory, this character is assigned the number "1". The

NEI Category A, "Abnormal Radiation Levels/ Radiological fourth character is a number preceded by a period for each Effluents," has been changed to Category R, "Abnormal Rad EAL within a subcategory. EALs are sequentially numbered Levels / Rad Effluents." The designator "R" is more intuitively within the emergency classification level of a subcategory associated with radiation (rad) or radiological events. NEI IC beginning with the number "1".

designators beginning with "A" have likewise been changed to "R.,,

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 5 of 25 The EAL identifier is designed to fulfill the following The following are examples of differences:

objectives:

Choosing the applicable EAL based upon plant type (i.e., BWR vs.

o Uniqueness - The EAL identifier ensures that there PWR).

can be no confusion over which EAL is driving the

Using a numbering scheme other than that provided in NEI 99-01 need for emergency classification.

that does not change the intent of the overall scheme.

o Speed in locating the EAL of concern - When the

Where the NEI 99-01 guidance specifically provides an option to not EALs are displayed in a matrix format, knowledge of include an EAL, if equipment for the EAL does not exist at MPS1 the EAL identifier alone can lead the EAL-user to the (e.g., automatic real-time dose assessment capability).

location of the EAL within the classification matrix. The identifier conveys the category, .subcategory and

Pulling information from the bases section up to the actual EAL that classification level. This assists ERO responders (who does not change the intent of the EAL.

may not be in the same facility as the DSEO/ADTS) to

Using synonymous wording (e.g., greater than or equal to vs. at or find the EAL of concern in a timely manner without the above, less than or equal vs. at or below, greater than or less than need for a word description of the classification vs. above or below, etc.)

threshold.

Adding MPS1 equipment/instrument identification and/or noun o Possible classification upgrade The names to EALs.

category/subcategory/identifier scheme helps the EAL-user find higher emergency classification EALs that

Combining like ICs that are exactly the same but have different may become active if plant conditions worsen. operating modes as long as the intent of each IC is maintained and the overall progression of the EAL scheme is not affected.

Table 1 lists the MPS1 Category, Subcategory and EAL that correspond to the NEI IC/Example EAL when the above

Any change to the IC and/or EAL, and/or basis wording, as stated in EAUIC organization and identification scheme is NEI 99-01, that does not alter the intent of the IC and/or EAL, i.e.,

implemented. the IC and/or EAL continues to:

o Classify at the correct classification level.

Differences and Deviations o Logically integrate with other EALs in the EAL scheme.

In accordance NRC Regulatory Issue Summary (RIS) 2003-18, "Use of o Ensure that the resulting EAL scheme is complete (i.e.,

Nuclear Energy Institute (NEI) 99-01, Methodology for Development of classifies all potential emergency conditions).

Emergency Action Levels," Supplements 1 and 2, a "difference" is an EAL The following are examples of deviations:

change in which the basis scheme guidance differs in wording but agrees in meaning and intent, such that classification of an event would be the same,

Use of altered mode applicability.

whether using the basis scheme guidance or the MPS1 EAL. A "deviation" is

Altering key words or time limits.

an EAL change in which the basis scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be

Changing words of physical reference (protected area, safety-related different between the basis scheme guidance and the MPS1 proposed EAL. equipment, etc.).

Administrative changes that do not actually change the textual content are

Eliminating an IC.

neither differences nor deviations. Likewise, any format change that does not

Not using NEI 99-01 definitions. The intent is for all NEI 99-01 users alter the wording of the IC or EAL is not considered a difference or a to have a standard set of defined terms as delineated in NEI 99-01.

deviation.

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A

Page 6 of 25 Differences due to plant types are permissible (BWR or PWR).

Verbatim compliance to the wording in NEI 99-01 is not necessary as long as the intent of the defined word is maintained. Use of the wording provided in NEI 99-01 is encouraged since the intent is for all users to have a standard set of delineated terms as defined in NEI 99-01.

Any change to the IC and/or EAL, and/or basis wording as stated in NEI 99-01 ,that does alter the intent of the IC and/or EAL (For example, the IC and/or EAL):

o Does not classify at the classification level consistent with NEI 99-01.

o Is not logically integrated with other EALs in the EAL scheme.

o Results in an incomplete EAL scheme (i.e., does not classify all potential emergency conditions).

The "Difference/Deviation Justification" column identifies each difference between the NEI 99-01, Rev. 6 IC/EAL wording and the MPS1 IC/EAL wording. Justification for each difference is then provided. If the difference is determined to be a deviation, a statement is made to that affect and an explanation is provided as to why classification may be different from the NEI 99-01, Rev. 6 IC/EAL and the reason it is acceptable. In all cases, the differences and deviations do not change the intent of NEI 99-01. A summary list of MPS1 EAL deviations from NEI 99-01, Rev. 6 is provided in Table 2.

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 7 of 25 Table 1 - NEI / MPS1 EAL Identification Cross-Reference NEI MPS1 Example EAL IC Category and Subcategory EAL PD-AU1 1 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RU1.1 RU1.2 PD-AU1 2 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RU1.3 PD-AU2 1 A - Abnormal Rad Levels / Rad Effluent, 2 - Area Radiation Levels RU2.1 PD-AU2 2 A - Abnormal Rad Levels / Rad Effluent, 2 - Area Radiation Levels RU2.2 PD-AA1 1 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.1 PD-AA1 2 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.2 PD-AA1 3 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.3 PD-AA1 4 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.4 PD-AA2 1 N/A N/A PD-AA2 2 A - Abnormal Rad Levels / Rad Effluent, 2 - Area Radiation Levels RA2.1 PD-HU1 1, 2, 3 N/A N/A PD-HU2 1 H - Hazards, 1 - Hazardous Events Affecting Safety Systems HU1.1 PD-HU3 1 H - Hazards, 2 - DSEO/ADTS Judgment HU2.1 PD-HA1 1, 2 N/A N/A PD-HA3 1 H - Hazards, 2- DSEO/ADTS Judgment HA2.1 PD-SU1 1 M - System Malfunction, 1 - Loss of SFP Cooling MU1.1

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 8 of 25 Table 2 - Summary of Deviations NEI MPS1 (

Description EAL IC Example EAL PD-HU2 1 HU1.1 The proposed MPS1 HU1 .1 wording is intended to ensure that an Unusual Event should be declared only when actual or potential performance issues with SAFETY SYSTEMS (SFP Cooling or Decay Heat Removal Systems) have occurred as a result of a hazardous event. In order to warrant declaration, the hazardous event should cause indications of degraded performance to either

. SAFETY SYSTEM (SFP Cooling or Decay Heat Removal).

The EAL and the Basis section have been revised to ensure potential classification of an Unusual Event, due to a hazardous event, is appropriate as the concern associated with this EAL is: (1) a hazardous event has occurred, and (2) either SAFETY SYSTEM (SFP Cooling or Decay Heat Removal) is having performance issues as a result of the hazardous event.

A loss of offsite AC power is excluded as the loss of power does not result in actual damage to the specified SAFETY SYSTEMS.

The definition for VISIBLE DAMAGE has been deleted to reflect the fact (SFP Cooling or Decay Heat Removal) that the EAL is based upon degraded performance of either SAFETY SYSTEM rather than just damage to individual components or structures that do not result in degraded safety system performance.

The proposed HU1 .1 is derived from NRG FAQ 2016-002 requiring degraded performance or visible damage to more than one safety system train caused by the specified events. However, for MPS1, the only Safety Systems are SFP Cooling and Decay Heat Removal. Neither of these systems have multiple trains.

That is, they are each single train safety systems. Therefore this threshold has been limited to degraded performance of either safety system.

While FAQ 2016-02 is applicable to NEI 99-01, Rev. 6 ICs CA6 and SA9 for operating reactors, IC/EAL PD-HU2 is the permanently defueled reactor equivalent of those thresholds.

This revised wording is a deviation from the NEI 99-01 Rev. 6 PD-HU2 generic wording and bases. This deviation is deemed acceptable consistent

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 9 of 25 NEI MPS1 Description EAL IC Example EAL with the intent of the endorsed NRC EP FAQ 2016-002 as applied to a Permanently Defueled reactor that does not have multiple safety system

- trains.

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 10 of 25 Table 3 - MPS1 Comparison Matrix MPS1 Difference/Deviation Justification NEI IC# NEI IC Wording MPS1 IC Wording IC#(s)

PD-AU1 Release of gaseous or liquid RU1 Release of gaseous or liquid The MPS1 REMODCM is the site-specific effluent release radioactivity greater than 2 times radioactivity greater than 2 times the controlling document.

the (site-specific effluent release allocated REMODCM limits for 60 controlling document) limits for minutes or longer 60 minutes or longer.

NEI Ex. MPS1 Difference/Deviation Justification NEI Example EAL Wording MPS1 EAL Wording EAL# EAL#

1 Reading on ANY effluent RU1.1 Reading on RM-SFPl-02 Unit 1 Spent PD-AU1, Example EAL #1 has been split into two EALs to radiation monitor greater than 2 Fuel Pool Island Monitor > 1.1 E-2 address gaseous (continuous) and liquid (batch) releases times the alarm setpoint µCi/cc for ~ 60 min. (Notes 1, 2, 3) separately.

established by a current The NEI phrase " ... effluent radiation monitor greater than 2 radioactivity discharge permit for times the (site-specific effluent release controlling document)"

60 minutes or longer has been replaced with " ... Reading on RM-SFPl-02 Unit 1 Spent Fuel Pool Island Monitor > 1.1 E-2 µCi/cc."

The basis for the Millstone Unit 1 UE value corresponds to the unplanned release of gaseous radioactivity greater than two times the site specific effluent release limit. This NOUE gaseous release criterion is consistent with NEI 99-01, Rev.

6 guidance but different from the alternative criterion

. proposed for Dominion Energy's operating nuclear facilities.

The operating facilities use a dose-based criterion based on exceeding 1 mrem TEDE for 60 minutes or longer. For a shutdown nuclear facility like Millstone 1 that has essentially only Kr-85 as a source term, dose-based criteria would be inappropriate. This is due to fact that the damage to fuel to produce sufficient source to create 1 mrem TEDE would be inconsistent with the Unusual Event definition and basis (represents a loss of plant control and deqradation in the

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 11 of 25 Table 3 - MPS1 Comparison Matrix level of safety). To create a release that would result in 1 mrem TEDE, nearly 600 irradiated fuel assemblies decayed for over 22 years would need to fail. Setting the NOUE threshold based on a release greater' than two times the site-specific release limit would correlate to the failure of approximately1 .5 irradiated fuel assemblies. This number of .

fuel assembly failures would appropriately represent the Unusual Event definition and basis.

RU1.2 Reading on RE-M6-11 O Liquid Waste PD-AU1, Example EAL #1 has been split into two EALs to Effluent Discharge Monitor > 2 x the address gaseous (continuous) and liquid (batch) releases "alarm" setpoint established by a separately.

current radioactivity discharge permit The NEI phrase" ... effluent radiation monitor greater than 2 for .:: 60 min. (Notes 1, 2, 3) times the (site-specific effluent release controlling document)"

has been replaced with " ... Reading on RE-M6-110 Liquid Waste Effluent Discharge Monitor."

The specified value, consistent with the NEI bases, represents two times the REMODCM release limits for liquid releases.

2 Sample analysis for a gaseous RU1.3 Sample analysis for a gaseous or The REMODCM is the site-specific effluent release or liquid release indicates a liquid release indicates a controlling document.

concentration or release rate concentration or release rate greater than 2 times the (site- > 2 x the allocated REMODCM limits specific effluent release for .:: 60 min. (Notes 1, 2) controlling document) limits for 60 minutes or longer.

Notes

The Emergency Director should declare the Unusual N/A Note 1: The DSEO/ADTS should declare the event promptly The classification timeliness note has been standardized across the MPS1 EAL scheme by referencing the "time limit" Event promptly upon upon determining that the specified within the EAL wording.

determining that 60 minutes time limit has been has been exceeded, or will exceeded, or will likely be likely be exceeded. exceeded.

The classification timeliness note has been standardized

If an onqoinq release is Note 2: If an ongoing release is

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 12 of 25 Table 3 - MPS1 Comparison Matrix detected and the release detected and the release across the MPS1 EAL scheme by referencing the "time limit" start time is unknown, start time is unknown, specified within the EAL wording.

assume that the release assume that the release duration has exceeded 60 duration has exceeded the minutes. specified time limit.

If the effluent flow past an effluent monitor is known to Note 3: If the effluent flow past an effluent monitor is known to None have stopped due to actions have stopped due to actions to isolate the release path, to isolate the release path, then the effluent monitor then the effluent monitor reading is no longer valid for reading is no longer VALID classification purposes. for classification purposes.

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 13 of 25 Table 3 - MPS1 Comparison Matrix MPS1 NEI IC# NEI IC Wording MPS1 IC Wording Difference/Deviation Justification IC#{s)

PD-AU2 UNPLANNED rise in plant RU2 UNPLANNED rise in plant radiation None radiation levels levels NEI Ex. MPS1 NEI Example EAL Wording MPS1 EAL Wording Difference/Deviation Justification EAL# EAL#

1 a. UNPLANNED water level RU2.1 UNPLANNED water level drop in the Site-specific level indications incorporated.

drop in the spent fuel pool as SFP as indicated by any of the Site-specific area radiation monitors incorporated.

indicated by ANY of the following:

following:

(site-specific level indications).

SPENT FUEL POOL LEVEL LOW alarm PLC-AL 101 AND

SPENT FUEL POOL LEVEL LOW-LOW alarm PLC-AL 100

b. UNPLANNED rise in area radiation levels as indicated by ANY of the following

Report of dropping level in SFP radiation monitors.

Loss of SFP Cooling suction flow (site-specific list of area AND radiation monitors).

UNPLANNED rise in area radiation levels as indicated by any of the following radiation monitors:

RM-SFPl-01 Channel 1 Refuel Floor West (Low Range)

RM-SFPl-01 Channel 2 Refuel Floor East

RM-SFPl-01 Channel 3 Refuel Floor West (High Range)

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 14 of 25 Table 3 - MPS1 Comparison Matrix 2 Area radiation monitor reading or RU2.2 Area radiation monitor reading or None survey result indicates an survey result indicates an UNPLANNED rise of 25 mR/hr UNPLANNED rise of 25 mR/hr over over NORMAL LEVELS NORMAL LEVELS

'- Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 15 of 25 Table 3 - MPS1 Comparison Matrix MPS1 NEI IC# NEI IC Wording MPS1 IC Wording Difference/Deviation Justification IC#(s)

PD-AA1 Release of gaseous or liquid RA1 Release of gaseous or liquid The thyroid CDE dose component has been eliminated as radioactivity resulting in offsite radioactivity resulting in offsite dose allowed by the 2017 EPA-400, PAG Manual: Protective dose greater than 10 mrem greater than 1O mrem TEDE Action Guides and Planning Guidance for Radiological TEDE or 50 mrem thyroid CDE. Incidents. This is consistent with protective action decision-making criteria provided by the States of Connecticut and New York.

This revised threshold is considered a difference from the NEI 99-01, Revision 6 PD-AA1 .generic wording and bases and is deemed acceptable consistent with NRG endorsed EP-FAQ 2017-01.

NEI Ex. MPS1 Difference/Deviation Justification NEI Example EAL Wording MPS1 EAL Wording EAL# EAL#

1 Reading on ANY of the following RA1.1 Reading on RM- SFPl-02 Unit 1 Spent RM- SFPl-02 Unit 1 Spent Fuel Pool Island Monitor is the radiation monitors greater than Fuel Pool Island Monitor > 4.0E+ 1 gaseous effluent monitor for Unit 1. The value shown the reading shown for 15 µci/cc for ;;: 15 min. (Notes 1, 2, 3, 4) corresponds to the 10 mrem site boundary dose.per minutes or longer: calculation RP 18-08.

(site-specific monitor list and threshold values) -

2 Dose assessment using actual RA1.2 Dose assessment using actual The site boundary area is the site-specific receptor point.

meteorology indicates doses meteorology indicates doses > 10 The thyroid CDE dose component has been eliminated as greater than 1O mrem TED!= or mrem TEDE at or beyond the SITE allowed by EPA-400, PAG Manual: Pro.tective Action Guides 50 mrem thyroid CDE at or BOUNDARY (Note 4) and Planning Guidance for Radiological Incidents. See IC beyond (site-specific dose justification above.

receptor point).

3 Analysis of a liquid effluent RA1.3 Analysis of a liquid effluent sample The site boundary area is the site-specific receptor point.

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 16 of 25 Table 3 - MPS1 Comparison Matrix sample indicates a concentration indicates a concentration or release The thyroid CDE dose component has been eliminated as or release rate that would result rate that would result in doses > 10 allowed by EPA-400, PAG Manual: Protective Action Guides in doses greater than 10 mrem mrem TEDE at or beyond the SITE and Planning Guidance for Radiological Incidents. See IC TEDE or 50 mrem thyroid CDE BOUNDARY for 60 min. of exposure justification above.

at or beyond (site-specific dose (Notes 1, 2) receptor point) for one hour of exposure.

4 Field survey results indicate RA1.4 Field survey results indicate closed The site boundary is the site-specific field survey receptor EITHER of the following at or window dose rates > 10 mR/hr point.

beyond (site-specific dose expected to continue for c:: 60 min. at The thyroid CDE dose component has been eliminated as receptor point): or beyond the SITE BOUNDARY allowed by EPA-400, PAG Manual: Protective Action Guides (Notes 1, 2) and Planning Guidance for Radiological Incidents. See IC

Closed window dose rates greater than 1O mR/hr justification above.

expected to continue for 60 minutes or longer.

Analyses of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.

Notes

The Emergency Director should declare the Alert N/A Note 1: The DSEO/ADTS should declare the event promptly The classification timeliness note has been standardized across the MPS1 EAL scheme by referencing the "time limit" promptly upon determining upon determining that the specified within the EAL wording.

that the applicable time has time limit has been been exceeded, or will likely exceeded, or will likely be be exceeded. exceeded.

The classification timeliness note has been standardized

If an ongoing release is detected and the release Note 2: If an ongoing release is detected and the release across the MPS1 EAL scheme by referencing the "time limit" start time is unknown, specified within the EAL wording.

start time is unknown, assume that the release assume that the release duration has exceeded 15 duration has exceeded the minutes. specified time limit.

None

If the effluent flow past an effluent monitor is known to Note 3: If the effluent flow past an effluent monitor is known to

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 17 of 25 Table 3 - MPS1 Comparison Matrix have stopped due to actions have stopped due to actions to isolate the release path, to isolate the release path, then the effluent monitor then the effluent monitor reading is no longer valid for reading is no longer valid for classification purposes. classification purposes s.

The pre-calculated effluent monitor values presented in Note 4: The pre-calculated effluent monitor values presented in Incorporated site-specific EAL number associated with generic EAL#1 .

EAL #1 should be used for EAL RA 1.1 should be used emergency classification for emergency classification assessments until the results assessments until the from a dose assessment results from a dose using actual meteorology are assessment using actual available. meteorology are available.

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 18 of 25 Table 3 - MPS1 Comparison Matrix MPS1 NEI IC# NEI IC Wording MPS1 IC Wording Difference/Deviation Justification IC#(s)

PD-AA2 UNPLANNED rise in plant RA2 UNPLANNED rise in plant radiation None '

radiation levels that impedes levels that IMPEDES plant access plant access required to maintain required to maintain spent fuel spent fuel integrity. integrity NEI Ex. MPS1 '

NEI Example EAL Wording MPS1 EAL Wording Dif.ference/Deviation Justification EAL# EAL# .

1 UNPLANNED dose rate greater N/A N/A MPS1 does not have any area that requires continuous than 15 mR/hr in ANY of the occupancy. Therefore, this example EAL is not applicable to following areas requiring MPS1.

continuous occupancy to maintain control of radioactive '

material or operation of systems ..

needed to maintain spent fuel integrity:

(site-specific area list) 2 UNPLANNED Area Radiation RA2.1 UNPLANNED Area .Radiation Monitor The MPS1 Reactor Building is the only area where access Monitor readings or survey readings or survey results indicate a may be required to perform a manual action to maintain results indicate a rise by 100 rise by 100 mR/hr over NORMAL control of radioactive material or operation of systems mR/hr over NORMAL LEVELS LEVELS that IMPEDES access to needed to maintain spent fuel integrity.

that impedes access .to ANY of areas of the Reactor Building needed

the following areas needed to to maintain control of radioactive maintain control of radioactive material or operation of systems material or operation of systems needed to maintain spent fuel integrity needed to maintain spent fuel integrity:

(site-specific area list)

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 19 of 25 Table 3 - MPS1 Comparison Matrix MPS1 NEI IC# NEI IC Wording MPS1 IC Wording Difference/Deviation Justification IC#(s)

PD-HU1 Confirmed SECURITY N/A N/A MPS1 shares a common Protected Area and Owner CONDITION or threat Controlled Area with MPS2 and MPS3. Classifiable events, including security related events, affecting MPS1 are classified by the MPS3 Shift Manager. Therefore, security events are classified under the MPS3 security based EALs.

NEI Ex. MPS1 NEI Example EAL Wording MPS1 EAL Wording Difference/Deviation Justification EAL# EAL#

1 A SECURITY CONDITION that N/A N/A See IC above.

does not involve a HOSTILE ACTION as reported by the (site-specific security shift supervision).

2 Notification of a credible security threat directed at the site.

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

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 20 of 25 Table 3 - MPS1 Comparison Matrix MPS1 NEI IC# NEI IC Wording MPS1 IC Wording Difference/Deviation Justification IC#(s)

PD-HU2 Hazardous event affecting HU1 Hazardous event affecting SAFETY None SAFETY SYSTEM equipment SYSTEM equipment necessary for necessary for spent fuel cooling spent fuel cooling NEI Ex. MPS1 NEI Example EAL Wording MPS1 EAL Wording Difference/Deviation Justification EAL# EAL#

1 a. The occurrence of ANY of HU1.1 The occurrence of any Table The hazardous events have been tabularized in Table H-1.

the following hazardous H-1 hazardous event The proposed MPS1 HU1 .1 wording is intended to ensure events: AND that an Unusual Event should be declared only when actual

Seismic event (earthquake)

Event damage (excluding loss of offsite AC power) has caused or potential performance issues with SAFETY SYSTEMS (SFP Cooling or Decay Heat Removal Systems) have

Internal or external flooding event indications of degraded performance of EITHER:

occurred as a result of a hazardous event. In order to warrant declaration, the hazardous event must cause indications of

High winds or tornado strike

Spent Fuel Pool Cooling degraded performance to either SAFETY SYSTEM (SFP Cooling or Decay Heat Removal).

System

FIRE

Decay Heat Removal System The EAL and the Basis section have been revised to ensure

EXPLOSION potential classification of an Unusual Event, due to a

(site-specific hazards) hazardous event, is appropriate as the focus of this EAL is:

Other events with similar hazard characteristics (1) a hazardous event has occurred, (2) either SAFETY SYSTEM (SFP Cooling or Decay Heat Removal) is indicating as determined by the performance issues as a result of the hazardous event.

Shift Manager A loss of offsite AC power is excluded because a loss of AND power does not result in actual damage to the specified SAFETY SYSTEMS.

b. The event has damaged at least one train of a SAFETY The definition of VISIBLE DAMAGE has been deleted to SYSTEM needed for spent reflect the fact that the EAL is based upon degraded fuel cooling. performance of either SAFETY SYSTEM rather than just

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 21 of 25 Table 3 - MPS1 Comparison Matrix AND damage to individual components or structures that do not result in degraded safety system performance.

C. The damaged SAFETY SYSTEM train(s) cannot, or The proposed HU1 .1 is derived from NRC FAQ 2016-002 potentially cannot, perform requiring degraded performance or visible damage to more its design function based on than one safety system train caused by the specified events.

EITHER: ', However, for MPS1, the only Safety Systems are SFP Cooling and Decay Heat Removal. Neither of these systems

Indications of degraded have multiple trains. That is, they are each single train safety performance systems. Therefore, this threshold has been limited to

VISIBLE DAMAGE degraded performance of either safety system.

While the cited FAQ, as approved, is applicable to NEI 99-01, Revision 6 ICs CA6 and SA9 for operating reactors, IC/EAL PD-HU2 is the permanently shutdown reactor equivalent of those thresholds.

This revised wording is a deviation from the NEI 99-01, Revision 6 PD-HU2 generic wording and bases but is deemed acceptable consistent with the intent of the endorsed NRC EP FAQ 2016-002 as applied to a Permanently Defueled reactor that does n_ot have multiple safety system trains.

Added parenthetical note to Table H-1 FIRE event to provide guidance related to potential classification of a fire in the common MPS Protected Area per Unit 2/3 EALs.

Serial No.18-364

MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 22 of 25 Table H-1 Hazardous Events

Seismic event (earthquake)

Internal or external FLOODING event

High winds or tornado strike

FIRE (refer to Unit 2/3 EALs for a fire within the Protected Area)

EXPLOSION

Other events with similar hazard characteristics as determined by the Shift Manager

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 23 of 25 Table 3 - MPS1 Comparison Matrix MPS1 NEI IC# NEI IC Wording MPS1 IC Wording Difference/Deviation Justification IC#(s)

PD-HU3 Other conditions exist which in the HU2 Other conditions existing that in The DSEO is the site-specific term for Emergency Director.

judgment of the Emergency the judgment of the DSEO Director warrant declaration of a warrant declaration of a UE (NO)UE NEI Ex. MPS1 NEI Example EAL Wording MPS1 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Other conditions exist which in the HU2.1 Other conditions exist which in The DSEO is the site-specific term for Emergency Director.

judgment of the Emergency the judgment of the DSEO Director indicate that events are in indicate that events are in progress or have occurred which progress or have occurred which indicate a potential degradation of indicate a potential degradation the level of safety of the plant or of the level of sat ety of the plant indicate a security threat to facility or indicate a security threat to protection has been initiated. No facility protection has been releases of radioactive material initiated. No releases of requiring offsite response or radioactive material requiring monitoring are expected unless offsite response or monitoring further degradation of safety are expected unless further systems occurs. degradation of SAFETY SYSTEMS occurs.

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 24 of 25 Table 3 - MPS1 Comparison Matrix MPS1 NEI IC# NEI IC Wording MPS1 IC Wording Difference/Deviation Justification IC#(s)

PD-HA3 Other conditions exist which in the HA2 Other conditions exist that in the The DSEO/ADTS is the site-specific term for Emergency Director.

judgment of the Emergency judgment of the DSEO warrant Director warrant declaration of an declaration of an Alert Alert.

NEI Ex. MPS1 NEI Example EAL Wording MPS1 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Other conditions exist which, in HA2.1 Other conditions exist which, in The DSEO/ADTS is the site-specific.term for Emergency Director.

the judgment of the Emergency the judgment of the Director, indicate that events are DSEO/ADTS, indicate th.at in progress or have occurred events are in progress or have which involve an actual or occurred which involve an actual potential substantial degradation or potential substantial of the level of safety of the plant degradation of the level of safety or a security event that involves of the plant or a security event probable life threatening risk to that involves probable life site personnel or damage to site threatening risk to site personnel equipment because of HOSTILE or damage to site equipment ACTION. Any releases are because of HOSTILE ACTION.

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

Serial No.18-364 MPS1 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1A Page 25 of 25 Table 3- MPS1 Comparison Matrix MPS1 NEI IC# NEI IC Wording MPS1 IC Wording Difference/Deviation Justification IC#(s)

PD-$U1 UNPLANNED spent fuel pool MU1 UNPLANNED spent fuel pool None temperature rise. temperature rise NEI Ex. MPS1 NEI Example EAL Wording MPS1 EAL Wording Difference/Deviation Justification EAL# EAL#

1 UNPLANNED spent fuel pool MU1.1 UNPLANNED spent fuel pool The maximum allowed bulk SFP water temperature is 140°F. The temperature rise to greater than temperature rise to > 140 °F requirement to maintain the spent fuel pool bulk water temperature s (site-specific° F) 140°F ensures that high water temperature will not degrade the resin in the spent fuel pool demineralizer, the fuel pool structure, pool liner, fuel racks, or external cooling system. With a complete loss of external cooling and a closed airspace above the pool, it would take approximately 7.5 days for SFP water temperature to rise to 212°F if starting from the TRM upper temperature limit of 140°F.

Serial No.: 18-364 Docket Nos.: 50-336; 72-47 Enclosure 3 ATTACHMENT 18

/

MPS2 EAL COMPARISON MATRIX DOCUMENT Dominion Energy Nuclear Connecticut, Inc. (DENC)

Millstone Power Station Unit 2 and ISFSI

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1 B Page 1 of 126 Millstone Power Station Unit 2 NEI 99-01, Revision 6 EAL Comparison Matrix Document

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-245 Enclosure 3; Attachment 1B Page 2 of 126 Table of Contents Section Page Introduction .................................................................................................................................................. 3 Comparison Matrix Format ........................................................................................................................... 3 EAL Wording ............................................................................................................................................... 3 EAL Emphasis Techniques ........................................................................................................................... 3 Global Differences ....................................................................................................................................... 4 Differences and Deviations ......................................................................................................................... 5 Table 1 - MPS2 EAL Categories/Subcategories ........................................................................................ 7 Table 2 - NEI / MPS2 EAL Identification Cross-Reference ........................................................................ 8 Table 3 - Summary of Deviations ............................................................................................................. 13 Table 4 - MPS2 Comparison Matrix ......................................................................................................... 19 Category A - Abnormal Rad Levels / Rad Effluents ................................................................................. 19 Category C - Cold Shutdown/ Refueling System Malfunction~ ................................................................ 39 Category D - Permanently Defueled Station Malfunction ......................................................................... 64 Category E - Events Related to Independent Spent Fuel Storage Installations ...................................... 65 Category F - Fission Product Barrier Degradation ................................................................................... 66 Category H - Hazards and Other Conditions Affecting Plant Safety ........................................................ 77 Category S - System Malfunction ............................................................................................................. 98

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 3 of 126 Introduction Meeting this goal will result in a shorter and less cumbersome NRC review and approval process, closer alignment with the schemes of other nuclear A comparison of the Initiating Conditions (ICs), Mode Applicability and power plant sites and better positioning to adopt future industry-wide scheme Emergency Action Levels (EALs) in NEI 99-01, Rev. 6, "Final, Development enhancements" of Emergency Action Levels for Non-Passive Reactors," (ADAMS Accession No. ML12326A805) and Millstone Power Station Unit 2 (MPS2) ICs, MODE To assist the Director of Station Emergency Operations (DSEO) I Assistant Applicability and EALs are provided in this document. The results of the Director Technical Support (ADTS), the MPS2 EALs have been written in a comparison are provided in Table 4, MPS2 Comparison Matrix. This clear and concise style (to the extent that the differences from the NEI EAL document provides a means of assessing MPS2 differences and deviations wording could be reasonably documented and justified). This supports timely from the NRC endorsed guidance given in NEI 99-01. Discussion of MPS2 and accurate classification in the tense atmosphere of an emergency event.

EAL bases and lists of source document references are given in the EAL The EAL differences introduced to reduce reading burden comprise almost Technical Bases Document. It is, therefore, advisable to reference the EAL all of the differences justified in,this document.

Technical Bases Document for background information while using this document.

EAL Emphasis Techniques Due to the width of the table columns and table formatting constraints in this Comparison Matrix Format document, line breaks and indentation may differ slightly from the The ICs and EALs discussed in the MPS2 Comparison Matrix are grouped appearance of comparable wording in the source documents. NEI 99-01, by NEI 99-01 Recognition Category and presented alphabetically by group. Rev. 6 is the source document for the NEI EALs; the MPS2 EAL Technical Within each Recognition Category group, the ICs and EALs are listed in Bases Document is the source document for the MPS2 EALs.

tabular format according to the order in which they are given in NEI 99-01, Development of the MPS2 IC/EAL wording has attempted to minimize Rev. 6. Generally, each row of the comparison matrix provides the following inconsistencies and apply sound human factors principles. As a result, information: differences occur between NEI and MPS2 ICs/EALs for these reasons alone.

.* NEI IC/Ex. EAL identifier When such difference may infer a technical difference in the associated NEI IC/EAL, the difference is identified and a justification is provided.

NEI IC/Example EAL wording and mode applicability The print and paragraph formatting conventions summarized below guide

MPS2 IC/EAL identifier presentation of the MPS2 EALs in accordance with the EAL writing criteria.

MPS2 IC/EAL wording and mode applicability Space restrictions in the EAL table of this document sometimes override this criteria in cases when following the criteria would introduce undesirable

Justification of any difference or deviation complications in the EAL layout.

Upper case-bold underline print is used for the logic terms AND, OR EAL Wording and EITHER.

NEI 99-01, Section 4.1, recommends the following: "The guidance in NEI 99-

Bold print is also used for certain logic terms, negative terms (not, 01 is not intended to be applied to plants "as-is"; however, developers should cannot, etc.), any, all.

attempt to keep their site-specific schemes as close to the generic guidance as possible. The goal is to meet the intent of the generic Initiating Conditions

Upper case print is reserved for defined terms, acronyms, system (ICs) and Emergency Action Levels (EALs) within the context of site-specific abbreviations, logic terms (and, or, etc. when not used as a characteristics - locale, plant design, operating features, terminology, etc. conjunction), and annunciator window engravings.

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Three or more items in a list are normally introduced with "Any of the 7. IC/EAL identification:

following ... " or "All of the following ... " Items of the list begin with bullets when a priority or sequence is not inferred.

NEI Recognition Category A, "Abnormal Radiation Levels/

Radiological Effluents," has been changed to Category R,

The use of and/or logic within the same EAL has been avoided "Abnormal Rad Levels / Rad Effluents." The designator "R" is when possible. When such logic cannot be avoided, indentation and more intuitively associated with radiation (rad) or radiological separation of subordinate contingent phrases is employed. events. NEI IC designators beginning with "A" have likewise been changed *to "R."

Global Differences

NEI Recognition Category S, "System Malfunctions," has been The differences listed below generally apply throughout the set of EALs and changed to Category M, "System Malfunctions." The designator are not repeated in the Justification sections of this document. The global "M" precludes possible interpretation of "SA" as Site Area differences do not change the intent of NEI 99-01. Emergency.

1. The NEI phrase "Notification of Unusual Event" has been changed to

NEI 99-01 defines the thresholds requiring emergency "Unusual Event" or abbreviated "UE" to reduce EAL-user reading classification (example EALs) and assigns them to ICs which, in burden. turn, are grouped in "Recognition Categories." MPS2 endeavors to optimize the NEI EAL organization and identification scheme

2. The title "Emergency Director" is replaced with the MPS2-specific to enhance usability of the plant-specific EAL set. To this end, title "Director of Station Emergency Operation (DSEO)/ Assistant the MPS2 IC/EAL scheme includes the following features:

Director Technical Support (ADTS)"

a. Division of the NEI EAL set into three groups:

3. NEI 99-01 IC Example EALs are implemented in separate plant EALs to improve clarity and readability. For example, NEI lists all IC o EALs applicable under all plant operating conditions -

HU3 Example EALs under one IC. The corresponding MPS2 EALs This group would be reviewed by the EAL-user any appear as unique EALs (e.g., HU3.1 through HU3.4). time emergency classification is considered.

4. Operational Condition (MODE) applicability identifiers o EALs applicable only under hot operating conditions -

(numbers/letter) modify the NEI 99-01 mode applicability names as This group would only be reviewed by the EAL-user follows: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot when the plant is in Power Operation, Startup, Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling, DEF - Defueled. NEI Standby or Hot Shutdown mode.

99-01 defines Defueled as follows: "All reactor fuel removed from o EALs applicable only under cold operating conditions -

RPV. (Full core off load during refueling or extended outage)."

This group would only be reviewed by the EAL-user

5. NEI 99-01 uses the terms greater than, less than, greater than or when the plant is in Cold Shutdown, Refueling or equal to, etc. in the wording of some example EALs. For consistency Defueled mode.

and to reduce EAL-user reading burden, MPS2 has adopted use of The purpose of the groups is to avoid review of hot boolean symbols in place of the NEI 99-01 text modifiers within the condition EALs when the plant is in a cold condition and EAL wording.

avoid review of cold condition EALs when the plant is in a

6. "min." is the standard abbreviation for "minutes" and is used to hot condition. This approach significantly minimizes the reduce EAL user reading burden. total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user

Serial No. 1.8-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 5 .of 126 reading burden and, thereby, speeds identification of the o . Uniqueness - The EAL identifier ensures that there EAL that applies to the emergency. can be no confusion over which EAL is driving the

b. Within each -of the above three groups, assignment of need for emergency classification.

EALs to categories/subcategories - Category and o Speed in locating the EAL of concern - When the subcategory titles are selected to represent conditions EALs are displayed in a matrix format, knowledge that are operationally significant to the EAL-user. of the EAL identifier alone can lead the EAL-user to Subcategories are used as necessary to further divide the the location of the EAL within the classification EALs of a category into logical sets of possible matrix. The identifier conveys the category, emergency classification thresholds. The MPS2 EAL subcategory and classification level. This assists categories/subcategories and their relationship to NEI ERO responders (who may not be in the same Recognition Categories are listed in Table 1. facility as the DSEO/ADTS) to find the EAL of

c. Unique identification of each EAL - Four characters concern in a timely manner without the need for a comprise the EAL identifier as illustrated in Figure 1. word description of the classification threshold.

o Possible classification upgrade - The category /

subcategory I identifier scheme helps the EAL-user Figure 1 - EAL Identifier find higher emergency classification EALs that may .

EAL Identifier become active if plant conditions worsen.

xxx.x Table 2 lists the MPS2 Category, Subcategory and EAL

Category (R, H, E, M, F, C) _J II L Sequential number within subcategory/classification that correspond to the NEI IC/Example EAL when the Emergency classification (G, S, A, U) _J L Subcategory number (1 if no subcategory) above EAUIC organization and identification scheme is implemented.

The first character is a letter associated with the category Differences and Deviations in which the EAL is located. The second character is a letter associated with the emergency classification level In accordance NRC Regulatory Issue Summary (RIS) 2003-18, "Use of (G for General Emergency, S for Site Area Emergency, A Nuclear Energy Institute (NEI) 99-01, Methodology for Development of for Alert, and U for Unusual Event). The third character is Emergency Action Levels" Supplements 1 and 2, a "difference" is an EAL a number associated with one or more subcategories change in which the basis scheme guidance differs in wording but agrees in within a given category. Subcategories are sequentially meaning and intent, such that classification of an event would be the same, numbered beginning with the number "1". If a category whether using the basis scheme guidance or the MPS2 EAL. A "deviation" is does not have a subcategory, this character is assigned an EAL change in which the basis scheme guidance differs in wording and is the number "1". The fourth character is a number altered in meaning or intent, such that classification of the event could be preceded by a period for each EAL within a subcategory. different between the basis scheme guidance and the MPS2 proposed EAL.

EALs are sequentially numbered within the emergency Administrative changes that do not actually change the textual content are classification level of a subcategory beginning with the neither differences nor deviations. Likewise, any format change that does not number "1". alter the wording of the IC or EAL is not considered a difference or a The EAL identifier is designed to fulfill the following deviation.

objectives: The following are examples of differences:

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Choosing the applicable EAL based upon plant type (i.e., BWR vs.

Changing words of physical reference (protected area, safety-related PWR). equipment, etc.).

Using a numbering scheme other than that provided in NEI 99-01

Eliminating an IC. This includes the removal of an IC from the that does not change the intent of the overall scheme. Fission Product Barrier Degradation category as this impacts the

Where the NEI 99-01 guidance specifically provides an option to not logic of Fission Product Barrier ICs.

include an EAL, if equipment for the EAL does not exist at MPS2

Changing a Fission Product Barrier from a Loss to a Potential Loss (e.g., automatic real-time dose assessment capability). or vice-versa.

Pulling information from the bases section up to the actual EAL that

Not using NEI 99-01 definitions. The intent is for all NEI 99-01 users does not change the intent of the EAL. to have a standard set of defined terms as delineated in NEI 99-01.

Differences due to plant types are permissible (BWR or PWR).

Choosing to state ALL Operating Modes are applicable instead of stating N/A, or listing each mode individually under the Abnormal Verbatim compliance to the wording of defined terms in NEI 99-01 is not* necessary as long as the intent of the defined word is Rad Level/Radiological Effluent and Hazard and Other Conditions maintained. Use of the wording provided in NEI 99-01 is encouraged Affecting Plant Safety sections.

since the intent is for all users to have a standard set of *defined

Using synonymous wording (e.g., greater than or equal to vs. at or terms as delineated in NEI 99-01.

above, less than or equal vs. at or below, greater than or less than vs. above or below, etc.)

Any change to the IC and/or EAL, and/or basis wording as stated in NEI 99-01 that does alter the intent of the IC and/or EAL (For

Adding MPS2 equipment/instrument identification and/or noun example, the IC and/or EAL):

names to EALs.

o Does not classify at the classification level consistent with

Combining like ICs that are exactly the same but have different NEI 99-01.

operating modes as long as the intent of each IC is maintained and o Is not logically integrated with other EALs in the EAL the overall progression of the EAL scheme is not affected.

scheme.

Any change to the IC and/or EAL, and/or basis wording, as stated in o Results in an incomplete EAL scheme (i.e., does not classify NEI 99-01, that does not alter the intent of the IC and/or EAL, i.e., all potential emergency conditions).

the IC and/or EAL continues to:

The *"Difference/Deviation Justification" column identifies each difference o Classify at the correct classification level. between the NEI 99-01 IC/EAL wording anc;l the MPS2 IC/EAL wording.

o Logically integrate with other EALs in the EAL scheme. Justification for each difference is then provided. If the difference is determined to be a deviation, a statement is made to that affect and an o Ensure that the resulting EAL scheme is complete (i.e.,

explanation is provided as to why classification may be different from the NEI classifies all potential emergency conditions).

99-01, Rev. 6 IC/EAL and the reason it is acceptable. In all cases, however, The following are examples of deviations: the differences and deviations do not change the intent of NEI 99-01. A

Use of altered mode applicability. summary list of MPS2 EAL deviations from NEI 99-01, Rev. 6 is provided in Table 3.

Altering key words or time limits.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 7 of 126 Table 1 - MPS2 EAL Categories/Subcategories MPS2 EALs 1 - Radiological Effluent Abnormal Rad Levels/Radiological Effluent 2 - Irradiated Fuel Event R - Abnormal Rad Levels/Rad Effluent ICs/EALs 3 - Area Radiation Levels H - Hazards and Other Conditions Affecting 1 - Security Hazards and Other Conditions Affecting Plant Safety 2 - Seismic Event Plant Safety ICs/EALs 3 - Natural or Technological Hazard 4- Fire 5 - Hazardous Gas 6 - Control Room Evacuation 7 - DSEO/ADTS Judgment E- ISFSI 1 - Confinement Boundary ISFSI ICs/EALs 1 - Loss of Emergency AC Power System Malfunction ICs/EALs 2 - Loss of Vital DC Power 3 - Loss of Control Room Indications 4 - RCS Activity M - System Malfunction 5- RCS Leakage 6 - RPS Failure 7 - Loss of Communications 8 - Containment Failure 9 - Hazardous Event Affecting Safety Systems F - Fission Product Barrier None Fission Product Barrier ICs/EALs 1- RCS Level Cold Shutdown./ Refueling System 2- Loss of Emergency AC Power Malfunction ICs/EALs C - Cold Shutdown/Refueling System 3- RCS Temperature Malfunction 4- Loss of Vital DC Power 5- Loss of Communications 6- Hazardous Event Affecting Safety Systems

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 8 of 126 Table 2 - NEI / MPS2 EAL Identification Cross-Reference NEI MPS2 Example IC Category and Subcategory EAL EAL AU1 1 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiologic~! Effluent RU1.1 RU1.4 AU1 2 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RU1.2 AU1 3 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RU1.3 RU1.5 AU2 1 A - Abnormal Rad Levels / Rad Effluent, 2 - frradiated Fuel Event RU2.1 AA1 1 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.1 AA1 2 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.2 AA1 3 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.3 AA1 4 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.4 AA2 1 A - Abnormal Rad Levels/ Rad Effluent, 2 - Irradiated Fuel Event RA2.1 AA2 2 A - Abnormal Rad Levels/ Rad Effluent, 2 - Irradiated Fuel Event RA2.2 AA2 3 A - Abnormal Rad Levels/ Rad Effluent, 2 - Irradiated Fuel Event RA2.3 AA3 1 A - Abnormal Rad Levels / Rad Effluent, 3 - Area Radiation Levels RA3.1 AA3 2 A - Abnormal Rad Levels / Rad Effluent, Area Radiation Levels RA3.2 AS1 1 A - Abnormal Rad Levels / Rad Effluent; 1 - Radiological Effluent RS1.1 AS1 2 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RS1.2

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1 B Page 9 of 126 Table 2 - NEI / MPS2 EAL Identification Cross-Reference NEI MPS2 Example IC Category and Subcategory EAL EAL AS1 3 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RS1.3 AS2 1 A-Abnormal Rad Levels/ Rad Effluent, 2 - Irradiated Fuel Event RS2.1 AG1 1 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RG1.1 AG1 2 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RG1.2 AG1 3 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RG1.3 AG2 1 A - Abnormal Rad Levels/ Rad Effluent, 2 - Irradiated Fuel Event RG2.1 CU1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CU1.1 CU1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CU1.2 CU2 1 C - Cold SD/ Refueling System Malfunction, 2 - Loss of AC Power CU2.1 CU3 1 C- Cold SD/ Refueling System Malfunction, 3- RCS Temperature CU3.1 CU3 2 C- Cold SD/ Refueling System Malfunction, 3- RCS Temperature CU3.2 CU4 1 C - Cold SD/ Refueling System Malfunction, 4 - Loss of DC Power CU4.1 CU5 1,2,3 C - Cold SD/ Refueling System Malfunction, 5 - Loss of Communications CU5.1 CA1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CA1.1 CA1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCSV Level CA1.2 CA2 1 C - Cold SD/ Refueling System Malfunction, 1 - Loss of AC Power CA2.1 CA3 1, 2 C- Cold SD/ Refueling System Malfunction, 3 - RCS Temperature CA3.1

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 10 of 126 Table 2- NEI / MPS2 EAL Identification Cross-Reference NEI MPS2 Example IC Category and Subcategory EAL EAL CA6 1 C - Cold SD/ Refueling System Malfunction, 6 - Hazardous Event Affecting Safety Systems CA6.1 CS1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CS1.1 CS1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level N/A CS1 3 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CS1.2 CG1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CG1.1 CG1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CG1.2 E-HU1 1 E - ISFSI, 1 - Confinement Boundary EU1.1 FA1 1 F - Fission Product Barrier FA1.1 FS1 1 F - Fission Product Barrier FS1.1 FG1 1 F - Fission Product Barrier FG1.1 HU1 1, 2, 3 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HU1.1 HU2 1 H - Hazards and Other Conditions Affecting Plant Safety, 2 - Seismic Event HU2.1 HU3 1 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technology Hazard HU3.1 HU3 2 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technology Hazard HU3.2 HU3 3 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technology Hazard HU3.3 HU3 4 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technology Hazard HU3.4 HU3 5 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technology Hazard N/A

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 11 of 126 Table 2 - NEI / MPS2 EAL Identification Cross-Reference NEI MPS2 Example IC Category and Subcategory EAL EAL HU4 1 H - Hazards and Other Conditions Af.fecting Plant Safety, 4 - Fire HU4.1 HU4 2 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire HU4.2 HU4 3 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire HU4.3 HU4 4 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or E HU4.4 HU? 1 H - Hazards and Other Conditions Affecting Plant Safety, 7 - DSEOIADTS Judgment HU7.1 HA1 1, 2 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HA1.1 HA5 1 H - Hazards and Other Conditions Affecting Plant Safety, 5 - Hazardous Gases HA5.1 HA6 1 H - Hazards and Other Conditions Affecting Plant Safety, 6 - Control Room Evacuation HA6.1 HA? 1 H - Hazards and Other Conditions Affecting Plant Safety, 7 - DSEOIADTS Judgment HA7.1 HS1 1 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HS1.1 HS6 1 H - Hazards and Other Conditions Affecting Plant Safety, 6 - Control Room Evacuation HS6.1 HS? 1 H - Hazards and Other Conditions Affecting Plant Safety, 7 - DSEOIADTS Judgment HS7.1 HG1 1 NIA NIA HG? 2 H - Hazards and Other Conditions Affecting Plant Safety, 7 - DSEOIADTS Judgment HG7.1 SU1 1 S - System Malfunction, 1 - Loss of AC Power MU1.1 SU2 1 S - System Malfunction, 3 - Loss of Control Room Indications MU3.1 SU3 1 S - System Malfunction, 4- RCS Activity MU4.1

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1 B Page 12 of 126 Table 2 - NEI / MPS2 EAL Identification Cross-Reference NEI MPS2 Example IC Category and Subcategory EAL EAL SU3 2 S - System Malfunction, 4 - RCS Activity MU4.2 SU4 1, 2, 3 S - System Malfunction, 5 - RCS Leakage MU5.1 SU5 1 S - System Malfunction, 6 - RPS Failure MU6.1 SU5 2 S - System Malfunction, 6 - RPS Failure MU6.2 SU6 1, 2, 3 S - System Malfunction, 7 -Loss of Communications MU7.1 SU? 1, 2 S - System Malfunction, 8 - Containment Failure MUB.1 SA1. 1 S - System Malfunction, 1 - Loss of AC Power MA1.1 SA2 1 S - System Malfunction, 3 - Loss of Control Room Indications MA3.1 SA5 1 S - System Malfunction, 6 - RPS Failure MA6.1 SA9 1 S - Hazardous Event Affecting Safety Systems MA9.1 881 1 S - System Malfunction, 1 - Loss of AC Power MS1.1 885 1 S - System Malfunction, 6 - RPS Failure MS6.1 888 1 S - System Malfunction, 2 - Loss of DC Power MS2.1 SG1 1 S - System Malfunction, 1 - Loss of AC Power MG1.1 8GB 2 S - System Malfunction, 2 - Loss of DC Power MG2.1

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 13 of 126 Table 3 - Summary of Deviations NEI MPS2 Description EAL(s)

IC Example EAL AU1 1, 2, 3 RU1.1, RU1.2, Generic IC AU1 has been split to address gaseous and liquid releases RU1 .3, RU1 .4, separately.

RU1.5 The basis for the gaseous UE IC and associated thresholds has been revised to correspond to any unplanned release of gaseous effluent radioactivity to the environment that will result in greater than 1 mrem TEDE.

This UE gaseous release criterion is being used consistently at all operating Dominion Energy nuclear stations (Millstone, North Anna and Surry). The reason this alternative criterion is required is due to the fact that for some effluent gaseous release pathways, the resulting calculated UE threshold following the NEI 99-01 guidance of two times the site specific effluent release limit would result in a UE threshold value greater than the corresponding calculated ALERT threshold based on exceeding 1O mrem TEDE. For the other gaseous release pathways that did not show an

' incongruent relationship when compared to the ALERT threshold, many showed UE values essentially equivalent to 1 mrem TEDE when applying the guidance in NEI 99-01 of a value set at two times the site specific effluent release limit. The fact that, (1) many of the gaseous release pathway UE values following NEI 99-01 guidance were essentially equivalent to 1 mrem TEDE, (2) application of an alternative definition set at a value of 1 mrem TEDE results in a more limiting value for those release paths that showed incongruent comparison to the corresponding ALERT threshold, and (3) UE criterion set at a value ten (10) times lower than the ALERT threshold provides a logical and consistent escalation between each classification level, provides justification for the UE criterion of 1 mrem TEDE. This single Initiating Condition (IC) definition for gaseous releases at the UE level is being applied to maintain consistency across the Dominion Energy nuclear fleet and to reduce confusion and human error potential if two different (IC) definitions were applied. Due to the fact that there are no ODCM limits on

- steam safeties or auxiliary feedwater exhausts and the limited ability for these respective radiation monitors to detect low level radioactivity in these steam line confiaurations, the UE classification thresholds for the steam

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IC Example EAL safeties and auxiliary feedwater exhaust are being labeled N/A (not applicable).

This revised IC and associated thresholds is a deviation from the NEI 99-01, Revision 6 AU1 generic wording and bases but is deemed acceptable consistent with the above justification.

HG1 1 N/A IC HG1 and associated example EAL is not implemented in the MPS2 scheme.

There are several other ICs that are redundant with this IC, and are better suited to ensure timely and effective emergency declarations. In addition, the development of new spent fuel pool level EALs, as a result of NRC Order EA-12-051, clarified the intended emergency classification level for spent fuel pool level events. This deviation is justified because:

1. Hostile Action in the Protected Area is bounded by ICs HS1 and HS7.

Hostile Action resulting in a loss of phy~ical control is bounded by EAL HG?, as well as any event that may lead to radiological releases to the public in excess of Environmental Protection Agency (EPA) Protective

,. Action Guides (PAGs).

a. If, for whatever reason, the Control Room must be evacuated, and control of safety functions (e.g., reactivity control, core cooling, and RCS heat removal) cannot be reestablished, then IC HS6 would apply, as well as IC HS7 if desired by the EAL decision-maker.

b. Also, as- stated above, any event (including Hostile Action) that could reasonably be expected to have a release exceeding EPA PAGs would be bounded by IC HG?,

C. From a Hostile Action perspective, ICs HS1, HS7 and HG? are appropriate, and therefore, make this part of HG1 redundant and unnecessary.

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IC Example EAL

d. From a loss of physical control perspective, ICs HS6, HS7 and HG?

are appropriate, and therefore, make this part of HG1 redundant and unnecessary.

2. Any event which causes a loss of spent fuel pool level will be bounded by ICs AA2, AS2 and AG2, regardless of whether it was based upon a Hostile Action or not, thus making this part of HG1 redundant and unnecessary.

a. An event that leads to a radiological release will be b.ounded by ICs AU1, AA1, AS1 and AG1. Events that lead to radiological releases in excess of EPA PAGs will be bounded by EALs AG1 and HG?, thus making this part of HG1 redundant and unnecessary.

1cs AA2, AS2, AG2, AS1, AG1, HS1, HS6, HS7 and HG? have been implemented consistent with NEI 99-01, Revision 6 and thus HG1 is adequately bounded as described above.

This exclusion of the generic HG1 guidance is a deviation from the NEI 99-01, Revision 6 generic guidance but is deemed acceptable consistent with endorsed NRC EP FAQ 2015-013.

HS6 1 HS6.1 Deleted defueled mode applicability. Control of the cited safety functions are not critical for a defueled reactor as there is no energy source in the reactor vessel or RCS.

The Mode applicability for the reactivity control safety function has been limited to Modes 1, 2, and 3 (hot operating conditions). In the cold operating modes adequate shutdown margin exists under all conditions.

This revised mode applicability is a deviation from the NEI 99-01, Revision 6 HS6 generic guidance but is deemed acceptable consistent with endorsed NRC EP FAQ 2015-014.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1 B Page 16 of 126 Table 3 - Summary of Deviations NEI MPS2 Description EAL(s)

IC Example EAL CA6 1 CA6.1 The proposed MPS2 CA6.1 and MA9.1 wording is intended to ensure that an Alert should be declared only when actual or potential performance issues SA9 1 MA9.1 with SAFETY SYSTEMS have occurred as a result of a hazardous event.

The occurrence of certain hazardous events may result in an Unusual Event classification at a minimum. In order to warrant escalation to the Alert classification, the hazardous event may cause indications of degraded performance to one train of a SAFETY SYSTEM with either an indication of degraded performance on the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second SAFETY SYSTEM train, such that the operability or reliability of the second train is a concern. In addition, escalation to the Alert classification should not occur if the damage from the hazardous event is limited to a SAFETY SYSTEM that was inoperable, or out of service, prior to the event occurring. As such, the proposed EALs will reduce the potential of declaring an Alert when events are in progress that do not involve an actual or potential substantial degradation of the level of safety of the plant, (i.e.,

does not cause significant concern with shutting down or cooling down the plant).

EALs CA6.1 and MA9.1 do not directly escalate to a Site Area Emergency or a General Emergency due to a hazardous event. The Fission Product Barrier and/or Abnormal Radiation Levels/Radiological Effluent recognition categories would provide an escalation path to a Site Area Emergency or a General Emergency.

The EALs and the Basis sections have been revised to ensure potential escalations from an Unusual Event to an Alert, due to a hazardous event, is appropriate as the concern with these EALs is: (1) a hazardous event. This has occurred, (2) one SAFETY SYSTEM train is having performance issues as a result of the hazardous event, and (3) either the second SAFETY SYSTEM train is having performance issues or the VISIBLE DAMAGE indicates that the second SAFETY SYSTEM train may have operability or reliability issues.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 17 of 126 Table 3 - Summary of Deviations NEI MPS2 Description EAL(s)

IC Example EAL The definition of VISIBLE DAMAGE has been revised to reflect the fact that the EALs are based upon SAFETY SYSTEM trains rather than individual components or structures.

"Note 9 has been added to CA6.1 and MA9.1 as it meets the intent of the EALs, is consistent with other EALs (e.g., EAL HA5.1 which was previously endorsed by the NRG), and ensures that declared emergencies are based upon unplanned events with the potential to pose a radiological risk to the public.

Note 10 has been added to CA6.1 and MA9.1 to help reinforce and succinctly capture the more detailed information from the revised basis section related to when conditions would require the declaration of an Alert.

CA6.1 and MA9.1 are consistent with NRG FAQ 2016-002 requiring degraded performance or visible damage to more than one safety system train caused by the specified events.

This revised wording is-a deviation from the NEI 99-01, Revision 6 CA6 and SA9 generic wording and bases but is deemed acceptable consistent with endorsed NRC EP FAQ 2016-002.

SG1 1 MG1.1 The proposed MPS2 MG1 .1 omits the Station Blackout (SBO) coping time threshold. As proposed, the General Emergency classification would be based on a loss of all onsite and offsite AC power to the emergency buses with indications of degraded core cooling. The MPS2 SBO analysis and derived coping time was determined in accordance with 10CFR50.63 and Regulatory Guide 1.155. This analysis does not take credit for plant capabilities in place to mitigate the effects of an extended loss of AC power (ELAP). These capabilities were developed and implemented to meet the requirements of NRG Orders EA-12-049 and EA-12-051, and pending regulations in 10 CFR 50.155 (per SECY-16-0142).

In accordance with plant EOPs, operators will declare an ELAP within 45

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IC Example EAL min. of the loss of all AC power to the emergency buses and direct implementation of FLEX Support Guidelines, including the deployment of dedicated portable equipment and performance of DC load shedding. Even if no AC emergency bus is energized, these actions will maintain or restore core cooling, containment, and spent fuel pool cooling capabilities indefinitely. Therefore, the underlying basis for the generic EAL coping time statement, that power must be restored to an AC emergency bus within a fixed amount of time to avoid a severe challenge to one or more fission product barriers, is not valid for MPS2.

Additionally, the omission of the SBO coping time threshold does not remove the attribute of a likely General Emergency declaration prior to meeting the IC FG1 thresholds for ELAP events in which the RCS barrier has not been lost.

This revised wording is a deviation from the NEI 99-01, Revision 6 SG1 generic wording and bases but is deemed appropriate and acceptable.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 18 Page 19 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent NEI IC Wording and Mode MPS2 MPS2 IC Wording and Mode NEI IC# Difference/Deviation Justification Applicability IC#(s) Applicability AU1 Release of gaseous or liquid RU1a Release of liquid radioactivity greater Generic IC AU1 has been split to address gaseous and radioactivity greater than 2 times than 2 times the allocated REMO DCM liquid releases separately.

the (site-specific effluent release limits for 60 minutes or longer The REMODCM is the site-specific effluent release controlling document) limits for controlling document.

60 minutes or longer. MODE:AII MODE: All RU1b Release of gaseous radioactivity Generic IC AU1 has been split to address gaseous and resulting in offsite dose greater than 1 liquid releases separately.

mremTEDE The basis for the gaseous UE IC and associated thresholds MODE:AII has been revised to correspond to any unplanned release of gaseous effluent radioactivity to the environment that will result in greater than 1 mrem TEDE. This UE gaseous release criterion is being used consistently at all operating Dominion Energy nuclear stations (Millstone, North Anna and Surry). The reason this alternative criterion is required is due to the fact that for some effluent gaseous release pathways, the resulting calculated UE threshold following the NEI 99-01 guidance of two times the site specific effluent release limit wo1,1ld result in a UE threshold value greater than the corresponding calculated ALERT threshold based on exceeding 10 mrem TEDE. For the other gaseous release pathways that did not show an incongruent relationship when compared to the ALERT threshold, many showed UE values essentially equivalent to 1 mrem TEDE when applying the guidance in NEI 99-01 of a value set at two times the site specific effluent release limit. The fact that, (1) many of the gaseous release pathway UE values following NEI 99-01 guidance were essentially equivalent to 1 mrem TEDE, (2) application of an alternative definition set at a value of 1 mrem TEDE results in a more limiting value for those release paths that showed incongruent

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 20 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent comparison to the corresponding ALERT threshold, and (3)

UE criterion set at a value ten (10) times lower than the ALERT threshold provides a logical and*consistent escalation between each classification level, provides justification for the UE criterion of 1 mrem TEDE. This single Initiating Condition (IC) definition for gaseous ,

releases at the UE level is being applied to maintain consistency across the Dominion Energy nuclear fleet and to reduce confusion and human error potential if two different (IC) definitions were applied. Due to the fact that there are no ODCM limits on steam safeties or auxiliary feedwater exhausts and the limited ability for these respective radiation monitors to detect low level radioactivity in these steam line configurations, the UE classification thresholds for the steam safeties and auxiliary feedwater exhaust are being labeled N/A (not applicable).

This revised IC and associated thresholds is a deviation from the NEI 99-01, Revision 6 AU1 generic wording and bases but is deemed acceptable consistent with the above justification.

NEI Ex. MPS2 Difference/Deviation Justification NEI Example EAL Wording MPS2 EAL Wording EAL# EAL#

1 Reading on ANY effluent Reading on RM4262 SG Slowdown The NEI phrase " ... effluent radiation monitor greater than 2 radiation monitor greater than 2 radiation monitor > 2x the "alarm" times the (site-specific effluent release controlling times the (site-specific effluent setpoint for ~ 60 min. (Notes 1, 2, 3). document)" has been replaced with "Reading on RM4262 release controlling document) SG Slowdown radiation mo"nitor > 2x thellalarm" RU1.1 limits for 60 minutes or longer: setpoint. .. ". Consistent with the above justification,. liquid (site-specific monitor list and and gaseous effluent thresholds have been split. The SG threshold values corresponding

blowdown monitor is the liquid release pathway not to 2 times the controlling associated with discharge permits.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 18 Page 21 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent document limits)

Reading on any Table R-1 effluent The NEI phrase" ... effluent radiation monitor greater than 2 radiation monitor> column "UE" for times the (site-specific effluent release controlling

=:: 60 min. (Notes 1, 2, 3) document)" has been replaced with "... any Table R-1 effluent radiation monitor> column "UE ... ".

UE thresholds for all MPS2 continuously monitored RU1.4 gaseous release pathways are listed in Table R-1 to consolidate the information in a single location and, thereby, simplify identification of the thresholds by the EAL user. The values shown in Table R-1 column "UE", consistent with the revised IC bases, corresponds to releases resulting in a 1 mrem dose at the site boundary for a 1-hour release.

2 Reading on ANY effluent Reading on any of the following > 2 x the alarm setpoint on the listed monitors represent two radiation monitor greater than 2 effluent radiation monitors > 2 x the times the REMODCM release limits tor liquid releases times the alarm setpoint "alarm" setpoint established by a controlled by discharge permit.

established by a current current radioactivity discharge permit radioactivity discharge permit for tor=:: 60 min.

60 minutes or longer.

RU1.2

RM9049 Clean Liquid Radwaste Effluent

RM9116 Aerated Liquid Radwaste Effluent

CND245 CPF Neut Sump Effluent (Notes 1, 2, 3) 3 Sample analysis for a gaseous Sample analysis for a liquid release The REMODCM is the site-specific effluent release or liquid release indicates a indicates a concentration or release controlling document.

RU1.3 concentration or release rate rate > 2 x the allocated REMODCM greater than 2 times the (site- limits for =:: 60 min. (Notes 1, 2)

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 22 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent specific effluent release Sample analysis for a gaseous The REMODCM is the site-specific effluent release controlling document) limits for release indicates a concentration or controlling document.

60 minutes or longer.

RU1.5 release rate > 2 x the allocated REMODCM limits for .!: 60 min. (Notes 1, 2)

Notes

The Emergency Director should declare the Unusual N/A Note 1: The DSEO/ADTS should declare the event promptly The classification timeliness note has been standardized across the MPS2 EAL scheme by referencing the "time Event promptly upon upon determining that the limit" specified within the EAL wording.

determining that 60 minutes time limit has been has been exceeded, or will exceeded, or will likely be likely be exceeded. exceeded.

The, classification timeliness note has been standardized

If an ongoing release is detected and the release Note 2: If an ongoing release is detected and the release across the MPS2 EAL scheme by referencing the "time start time is unknown, limit" specified within the EAL wording.

start time is unknown, assume that the release assume that the release duration has exceeded 60 duration has exceeded the minutes. specified time limit.

None

If the effluent flow past an effluent monitor is known to Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions have stopped due to actions to isolate the release path, to isolate the release path, then the effluent monitor then the effluent monitor reading is no longer valid for reading is no longer VALID classification purposes. for classification purposes.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1 B Page 23 of 126 Table R-1 Unit 2 Gaseous Effluent Monitor Classification Thresholds Release Point & Monitor GE SAE Alert UE Unit 2 Stack Gaseous Normal RangeRM-81328 N/A N/A N/A 3.7E+05 cpm Mid/High Range RM-8168 1.~E+01 µCi/cc 1.6E+OO µCi/cc 1.6E-01 µCi/cc 1.6E-02 µCi/cc Millstone Stack (WRGM)

RM-8169 3.6E+02 µCi/cc 3.6E+01 µCi/cc 3.6E+OO µCi/cc 3.6E-01 µCi/cc Main Steam Line Rad RM-4299 A/C 3.5E+01 R/hr 3.SE+OO R/hr 3.SE-01 R/hr N/A RM-4299 B 1.7E+01 R/hr 1.7E+OO R/hr 1.7E-01 R/hr N/A

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 24 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent NEI IC Wording and Mode MPS2 MPS2 IC Wording and Mode NEI IC# Difference/Deviation Justification Applicability IC#(s) Applicability AU2 UNPLANNED loss of water level RU2 UNPLANNED loss of water level None above irradiated fuel. above irradiated fuel MODE: All MODE: All NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1

a. UNPLANNED water level UNPLANNED water level drop in the RU2.1 Site-specific level indications incorporated.

drop in the REFUELING REFUELING PATHWAY as indicated PATHWAY as indicated by by any of the following: Site-specific area radiation monitors incorporated.

ANY of the following:

SFP LEVEL LO alarm C-06/7 (site-specific level B-14 indications).

CTMT NORM SUMP LEVEL AND HI/LO alarm C-06/7 BA-21

b. UNPLANNED rise in area

Report of dropping level in RFP or radiation levels as indicated SFP by ANY of the following

SFP CLG PUMP SUCTION radiation monitors. FLOW LO alarm C-06/07 D-13 (site-specific list of area AND radiation monitors) UNPLANNED rise in corresponding area radiation levels as indicated by any of the following radiation monitors:

RM-7890 Personnel Access Area

RM-7891 Containment Refuel Floor

RM-8139 SFP SW Area

RM-8142 SFP NW Area

RM-8156 SFP NE Area

RM-8157 SFP SE Area

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 25 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

M1 Release of gaseous or liquid RA1 Release of gaseous or liquid The thyroid CDE dose component has been eliminated as radioactivity resulting in offsite radioactivity resulting in offsite dose allowed by the 2017 EPA-400, PAG Manual: Protective Action dose greater than 10 mrem greater than 10 mrem TEDE Guides and Planning Guidance for Radiological TEDE or 50 mrem thyroid CDE. Incidents. This is consistent with protective action decision-MODE:AII making criteria provided by the States of Connecticut and MODE: All New York.

This revised threshold is considered a difference from the NEI 99-01, Revision 6 AA 1 generic wording and bases and is deemed acceptable consistent with NRC endorsed EP-FAQ 2017-01.

NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

Reading on ANY of the following The MPS2 radiation monitors that detect radioactivity effluent 1 RA1.1 Reading on any Table R-1 effluent radiation monitors greater than release to the environment are listed in Table R-1. UE, Alert, radiation monitor > column "ALERT" the reading shown for 15 minutes for ;.: 15 min. (Notes 1, 2, 3, 4) SAE and GE thresholds for all MPS2 continuously monitored or longer: gaseous and liquid release pathways are listed in Table R-1 to consolidate the information in a single location and, (site-specific monitor list and thereby, simplify identification of the thresholds by the EAL-threshold values) user.

2 Dose assessment using actual RA1.2 Dose assessment using actual The site boundary area is the site-specific receptor point.

meteorology indicates doses meteorology indicates doses > 10 The thyroid CDE dose component has been eliminated as greater than 10 mrem TEDE or mrem TEDE at or beyond the SITE allowed by EPA-400, PAG Manual: Protective Action Guides 50 mrem thyroid CDE at or BOUNDARY (Note 4) and Planning Guidance for Radiological Incidents. See IC beyond (site-specific dose justification above.

receptor point).

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 26 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent 3 Analysis of a liquid effluent RA1.3 Analysis of a liquid effluent sample The site boundary area is the site-specific receptor point.

sample indicates a concentration indicates a concentration or release The thyroid COE dose component has been eliminated as or release rate that would result rate that would result in doses > 1O allowed by EPA-400, PAG Manual: Protective Action Guides in doses greater than 10 mrem mrem TEDE at or beyond the SITE and Planning Guidance for Radiological Incidents. See IC TEDE or 50 mrem thyroid COE at BOUNDARY for 60 min. of exposure justification above.

or beyond (site-specific dose (Notes 1, 2) receptor point) for one hour of exposure.

4 Field survey results indicate RA1.4 Field survey results indicate closed The site boundary is the site-specific field survey recept~r EITHER of the following at or window dose rates > 1O mR/hr point.

beyond (site-specific dose expected to continue for~ 60 min. at The thyroid COE dose component has been eliminated as receptor point):

or beyond the SITE BOUNDARY

Closed window dose rates greater than 10 mR/hr (Notes 1, 2) allowed by EPA-400, PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents. See IC expected to continue for 60 justification above.

minutes or longer.

Analyses of field survey samples indicate thyroid COE greater than 50 mrem for one hour of inhalation.

Notes

The Emergency Director should declare the Alert N/A Note 1: The DSEO/ADTS should declare the event promptly The classification timeliness note has been standardized across the MPS2 EAL scheme by referencing the "time limit" promptly upon determining upon determining that the specified within the EAL wording.

that the applicable time has time limit has been been exceeded, or will likely exceeded, or will likely be be exceeded. exceeded.

The classification timeliness note has been standardized

If an ongoing release is detected and the release Note 2: If an ongoing release is detected and the release across the MPS2 EAL scheme by referencing the "time limit" start time is unknown, start time is unknown, specified within the EAL wording.

assume that the release assume that the release duration has exceeded 15 duration has exceeded the

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 27 of 126 Table 4 - MPS2 Comparison .Matrix Category A: Abnormal Rad Levels/ Radiological Effluent minutes. specified time limit.

If the effluent flow past an effluent monitor is known to Note 3: If the effluent flow past an effluent monitor is known to None have stopped due to actions have stopped due to actions to isolate the release path, to isolate the release path, then the effluent monitor then the effluent monitor reading is no longer valid for reading is no longer valid for classification purposes. classification purposes.

Incorporated site-specific EAL numbers associated with Note 4: The pre-calculated effluent generic EAL#1.

The pre-calculated effluent monitor values presented in

_monitor values presented in EALs RA1.1, RS1.1 and EAL #1 should be used for RG1 .1 should be used for emergency classification emergency classification assessments until the results assessments until the from a dose assessment results from a dose using actual meteorology are assessment using actual ava.ilable. meteorology are available.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 28 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent ,

MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

AA2 Significant lowering of water level RA2 Significant lowering of water level None above, or damage to, irradiated above, or damage to, irradiated fuel fuel.

MODE:AII MODE: All NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Uncovery of irradiated fuel in the RA2.1 IMMINENT uncovery of irradiated fuel Added the term "IMMINENT" consistent with the generic REFUELING PATHWAY. in the REFUELING PATHWAY bases.

2 Damage to irradiated fuel RA2.2 Damage to irradiated fuel resulting in a Deleted the words" ... from the fuel. .. " as that is implied by the resulting in a release of release of radioactivity determination that irradiated fuel has been damaged.

radioactivity from the fuel as AND Site-specific list of radiation monitors are incorporated.

indicated by ANY of the following radiation monitors: VALID alarm on any of the following Radiation monitor alarms specified.

radiation monitors:

Added the word "VALID" to reinforce generic bases that the (site-specific listing of radiation

RM-7890 Personnel Access high radiation be associated with the damaged fuel.

monitors, and the associated Area readings, setpoints and/or

RM-7891 Containment Refuel alarms) Floor

RM-81238 or RM-82628 Containment Gaseous

RM-8139 SW SFP Area

RM-8142 NW SFP Area

RM-8156 NE SFP Area

RM-8157 SE SFP Area

RM-81458 SFP Exhaust Gaseous

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 29 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent 3 Lowering of spent fuel pool level Lowering of spent fuel pool level to 10 RA2.3 For MPS2, Level 2, which corresponds to 1Oft. above the top to (site-specific Level 2 value). ft. (Level 2) on LI-7013 or of the fuel racks in the SFP, is an indicated level of 10 ft. on

[ See Developer Notes] Ll-7014 Ll-7013 or LI-7014 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

AA3 Radiation levels that impede RA3 Radiation levels that IMPEDE access Limited mode applicability of RA3.2 modes specified in Table access to equipment necessary to equipment necessary for normal R-2.

for normal plant operations, plant operations, cooldown or cooldown or shutdown shutdown MODE: All MODE: All (except RA3.2 Modes 3 -

Hot Standby, 4 - Hot Shutdown, 5 -

Cold Shutdown only)

NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Dose rate greater than 15 mR/hr RA3.1 Dose rates > 15 mR/hr in EITHER of No other site-specific areas requiring continuous occupancy in ANY of the following areas:

the following: exist at MPS2.

Control Room

Central Alarm Station

Control Room

(other site-specific

Central Alarm Station areas/rooms) 2 An UNPLANNED event results in RA3.2 An UNPLANNED event results in The site-specific list of plant rooms or areas with entry-related

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 30 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent radiation levels that prohibit or radiation levels that prohibit or mode applicability are tabularized in Tables R-2.

impede access to any of the IMPEDE access to any Table R-2 following plant rooms or areas: room or area (Note 5)

(site-specific list of plant rooms or areas with entry-related mode applicability identified)

Note If the equipment in the listed N/A Note 5: If the equipment in the listed room None room or area was already or area was already inoperable or inoperable or out-of-service out-of-service before the event before the event occurred, then occurred, then no emergency no emergency classification is classification is warranted.

warranted.

Table R-2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux. Building El -5'6" West Area Aux. Building El -5'6" East Near SFP Cooling Aux. Building El 14'6" 851 & 861 Enclosures 3

Aux. Building El 14'6" Boric Acid Batching Tank Aux. Building El -25'6" RB Hx Area Enc. Building El -5'6" East Pipe Penetration Aux. Building El 14'6" By 861 Enc. Building El -45'6" "A" & "B" ESF Rooms 3,4 Aux. Building El -45'6" General Area Enc. Building El -5'6" West Pipe Penetration 3,5 Aux. Building El 14'6" SE Across From MCC 851 4 Aux. Building El -5'6" VCT Block Wall Area 5

Enc. Building El -45'6" "A" ESF Room

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 31 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

AS1 Release of gaseous radioactivity RS1 Release of gaseous radioactivity The thyroid COE dose component has been eliminated as resulting in offsite dose greater resulting in offsite dose greater than allowed by the 2017 EPA-400, PAG Manual: Protective Action than 100 mrem TEDE or 500 100 mrem TEDE Guides and Planning Guidance for Radiological mrem thyroid COE Incidents. This is consistent with protective action decision-MODE:AII making criteria provided by the States of Connecticut and New MODE: All York.

This revised threshold is considered a difference from the NEI 99-01, Revision 6 AS1 generic wording and bases and is deemed acceptable consistent with NRC endorsed EP-FAQ 2017-01.

NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Reading on ANY of the following RS1.1 Reading on any Table R-1 effluent The MPS2 radiation monitors that detect radioactivity effluent radiation monitors greater than radiation monitor > column "SAE" for release to the environment are listed in Table R-1. UE, Alert, the reading shown for 15 2! 15 min. SAE and GE thresholds tor all MPS2 continuously monitored minutes or longer: (Notes 1, 2, 3, 4) gaseous and liquid release pathways are listed in Table R-1 to consolidate the information in a single location and, thereby, (site-specific monitor list and simplify identification of the thresholds by the EAL-user.

threshold values) 2 Dose assessment using actual RS1.2 Dose assessment using actual The site boundary area is the site-specific receptor point.

meteorology indicates doses meteorology indicates doses > 100 The thyroid COE dose component has been eliminated as greater than 100 mrem TEDE or mrem TEDE at or beyond the SITE allowed by EPA-400, PAG Manual: Protective Action Guides 500 mrem thyroid COE at or BOUNDARY (Note 4) and Planning Guidance for Radiological Incidents. See IC beyond (site-specific dose justification above.

receptor point)

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 32 of 126 Table 4 - MPS2 Comparison Matrix '

Category A: Abnormal Rad Levels/ Radiological Effluent 3 Field survey results indicate RS1.3 Field survey results indicate closed The site boundary area is the site-specific receptor point.

EITHER of the following at or window dose rates > 100 mR/hr beyond (site-specific dose expected to continue for The thyroid COE dose component has been eliminated as receptor point): 2! 60 min. at or beyond the SITE allowed by EPA-400, PAG Manual: Protective Action Guides BOUNDARY (Notes 1, 2) and Planning Guidance for Radiological Incidents. See IC

Closed window dose rates justification above.

greater than 100 mR/hr expected to continue for 60 minutes or longer.

Analyses of field survey samples indicate thyroid COE greater than 500 mrem for one hour of inhalation.

Notes

The Emergency Director Note 1: The DSEO/ADTS should The classification timeliness note has been standardized should declare the Site Area declare the event promptly across the MPS2 EAL scheme by referencing the "time limit" Emergency promptly upon upon determining that the specified within the EAL wording.

determining that the time limit has been applicable time has been exceeded, or will likely be exceeded, or will likely be exceeded.

exceeded. The classification timeliness note has been standardized Note 2: If an ongoing release is

If an ongoing release is detected and the release across the MPS2 EAL scheme by referencing the "time limit" detected and the release specified within the EAL wording.

start time is unknown, start time is unknown, assume that the release assume that the release duration has exceeded the duration has exceeded 15 specified time limit.

minutes.

If the effluent flow past an Note 3: If the effluent flow past an effluent monitor is known to effluent monitor is known to None have stopped due to actions have stopped due to actions to isolate the release path, to isolate the release path, then the effluent monitor then the effluent monitor reading is no longer valid for reading is no longer VALID classification purposes. for classification purposes.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 33 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent Note 4: The pre-calculated effluent

The pre-calculated effluent monitor values presented in monitor values presented in Incorporated site-specific EAL numbers associated with EAL #1 should be used tor* EALs RA1 .1, RS1 .1 and generic EAL#1 .

emergency classification RG 1.1 should be used for emergency classification assessments until the results from a dose assessment assessments until the results using actual meteorology are from a dose assessment available. using actual meteorology are available.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 34 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

AS2 Spent fuel pool level at (site- RS2 Spent fuel pool level at the top of the Top of the fuel racks is the site-specific Level 3 description.

specific Level 3 description) fuel racks MODE: All MODE:AII NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Lowering of spent fuel pool level RS2.1 Lowering of spent fuel pool level to For MPS2, Level 3, which corresponds to 1 ft. above the top of to (site-specific Level 3 value) 1 ft. on Ll-7013 or Ll-7014 the fuel racks in the SFP, is a reading of 1 ft. on Ll-7013 or LI-7014

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 35 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

AG1 Release of gaseous radioactivity RG1 Release of gaseous radioactivity The thyroid CDE dose component has been eliminated as allowed resulting in offsite dose greater resulting in offsite dose greater by the 2017 EPA-400, PAG Manual: Protective Action Guides and than 1,000 mrem TEDE or than 1,000 mrem TEDE Planning Guidance for Radiological Incidents. This is consistent with 5,000 mrem thyroid CDE. protective action decision-making criteria provided by the States of MODE: All Connecticut and New York.

MODE: All This revised threshold is considered a difference from the NEI 99-01, Revision 6 AG1 generic wording and bases and is deemed acceptable consistent with NRG endorsed EP-FAQ 2017-01.

NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Reading on ANY of the following RG1.1 Reading on any Table R-1 The MPS2 radiation monitors that detect radioactivity effluent radiation monitors greater than effluent radiation monitor > release to the environment are listed in Tables R-1.

the reading shown for 15 column "GE" for .:: 15 min. UE, Alert, SAE and GE thresholds for all MPS2 continuously minutes or longer: (Notes 1, 2, 3, 4) monitored gaseous and liquid release pathways are listed in Table (site-specific monitor list and R-1 to consolidate the information in a single location and, thereby, threshold values) simplify identification of the thresholds by the EAL-user.

Dose assessment using actual The site boundary area is the site-specific receptor point.

2 . Dose assessment using actual RG1.2 meteorology indicates doses meteorology indicates doses > The thyroid CDE dose component has been eliminated as allowed greater than 1,000 mrem TEDE 1,000 mrem TEDE at or beyond by EPA-400, PAG Manual: Protective Action Guides and Planning or 5,000 mrem thyroid CDE at or the SITE BOUNDARY (Note 4) Guidance for Radiological Incidents. See IC justification above.

beyond (site-specific dose receptor point).

3 Field survey results indicate RG1.3 Field survey results indicate The site boundary is the site-specific field survey receptor point.

EITHER of the following at or closed window dose rates > 1,000 The thyroid CDE dose component has been eliminated as allowed beyond (site-specific dose mR/hr expected to continue for by EPA-400, PAG Manual: Protective Action Guides and Planninq

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 18 Page 36 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent receptor point): .:: 60 min. at or beyond the SITE Guidance for Radiological Incidents. See IC justification above .

BOUNDARY (Notes 1, 2)

Closed window dose rates greater than 1,000 mR/hr expected to continue for 60 minutes or longer.

Analyses of field survey samples indicate thyroid COE greater than 5,000 mrem for one hour of inhalation.

Notes

The Emergency Director Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the should declare the Site Area should declare the MPS2 EAL scheme by referencing the "time limit" specified within Emergency promptly upon event promptly upon the EAL wording.

determining that the determining that the applicable time has been time limit has been exceeded, or will likely be exceeded, or will likely exceeded. be exceeded.

If an ongoing release is Note 2: If an ongoing release is The classification timeliness note has been standardized across the detected and the release detected and the MPS2 EAL scheme by referencing the "time limit" specified within start time is unknown, release start time is assume that the release the EAL wording.

unknown, assume that duration has exceeded 15 the release duration has minutes. exceeded the specified time limit.

If the effluent flow past an effluent monitor is known to Note 3: If the effluent flow past have stopped due to actions an effluent monitor is None to isolate the release path, known to have stopped then the effluent monitor due to actions to isolate reading is no longer valid for the release path, then classification purposes. the effluent monitor reading is no longer

The pre-calculated effluent

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 37 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent monitor values presented in VALID for classification EAL #1 should be used for purposes for emergency classification classification purposes.

assessments until the results Incorporated site-specific EAL numbers associated with generic Note 4 The pre-calculated from a dose assessment EAL#1.

effluent monitor values using actual meteorology are presented in EALs available.

RA 1.1 , RS 1. 1 and

RG1 .1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 38 of 126 Table 4 - MPS2 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

AG2 Spent fuel pool level cannot be RG2 Spent fuel pool level cannot be Top of the fuel racks is the site-specific Level 3 description.

restored to at least (site-specific restored to at least the top of the fuel Level 3 description) for 60 racks for 60 minutes or longer minutes or longer MODE: All MODE: All NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Spent fuel pool level cannot be RG2.1 Spent fuel pool level cannot be For MPS~, Level 3, which corresponds to 1 ft. above the top of restored to at least (site-specific restored to at least 1 ft. on Ll-7013 or the fuel racks in the SFP, is a reading of 1 ft. on Ll-7013 or LI-Level 3 value) for 60 minutes or Ll-7014 for~ 60 min. (Note 1) 7014 longer Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized declare the General Emergency declare the event promptly across the MPS2 EAL scheme by referencing the "time limit" promptly upon determining that upon determining that the time specified within the EAL wording.

60 minutes has been exceeded, limit has been exceeded, or or will likely be exceeded. will likely be exceeded.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 39 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS2 Difference/Deviation Justification NEI IC# NEI IC Wording MPS2 IC Wording IC#(s)

CU1 UNPLANNED loss of (reactor CU1 UNPLANNED loss of RCS Deleted the words " ... for 15 minutes or longer" as the 15 minute vessel/RCS [PWR] or RPV inventory criteria only applies to EAL #1

[BWR]) inventory for 15 minutes MODE: 5 - Cold Shutdown, 6 -

or longer. Refueling MODE: Cold Shutdown, Refueling NEI Ex. MPS2 Difference/Deviation Justification NEI Example EAL Wording MPS2 EAL Wording EAL# EAL#

1 UNPLANNED loss of reactor CU1.1 UNPLANNED loss of reactor None coolant results in (reactor coolant results in RCS water vessel/RCS [PWR] or RPV level < a required lower limit for

[BWR]) level less than a ~ 15 min. (Note 1) required lower limit for 15 minutes or longer.

RCS water level cannot be Added the words " ... due to loss of RCS inventory to be consistent 2 a. (Reactor vessel/RCS [PWR] CU1.2 monitored with the IC wording.

or RPV [BWR]) level cannot be monitored. AND EITHER The Table C-1 sumps & tanks are the site-specific applicable sumps and tanks.

AND

UNPLANNED rise in any Table C-1 sump or tank level Added bulleted criteria "Visual observation ... " to Table C-1 to include

b. UNPLANNED increase in due to a loss of RCS direct observation of significant unisolable RCS leakage.

(site-specific sump and/or tank) inventory levels.

Visual observation of UNISOLABLE RCS leakaqe

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 18 Page 40 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction Note Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the The Emergency Director should N/A should declare the event MPS2 EAL scheme by referencing the "time limit" specified within the declare the Unusual Event promptly upon EAL wording.

promptly upon determining that determining that the 15 minutes has been exceeded, time limit has been or will likely be exceeded.

exceeded, or will likely be exceeded.

Table C-1 Sumps/Tanks

Containment Sump

RWST

PDT

Quench Tank

EDST (L9736)

'A' CWRT (letdown line CH-345 or SDC line Sl-468) (Panel C-63)

SIT 1, 2, 3, 4

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 41 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

CU2 Loss of all but one AC power CU2 Loss of all but one AC power None source to emergency buses for source to emergency buses for 15 minutes or longer. 15 minutes or longer.

MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, 6 -

Refueling, Defueled Refueling, DEF - Defueled NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 CU2.1 AC power capability, Table C-3, 4.16 kV emergency buses 24C and 24D are the MPS2-specific

a. AC power capability to (site-to 4.16 kV emergency buses emergency buses.

specific emergency buses) is 24C and 24D reduced to a single reduced to a single power Table C-3 provides a consolidated list of AC power sources credited power source for;;: 15 min.

source for 15 minutes or for this EAL.

(Note 1) longer.

AND AND Any additional single power

b. Any additional single power source failure will result in loss of source failure will result in loss all AC power to SAFETY of all AC power to SAFETY SYSTEMS SYSTEMS.

Note The Emergency Director should Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the N/A declare the Unusual Event declare the event MPS2 EAL scheme by referencing the "time limit" specified within promptly upon determining that promptly upon the EAL wording.

15 minutes has been exceeded, determining that the time or will likely be exceeded. limit has been exceeded, or will likely be exceeded.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 42 of 126 Table C-3 AC Power Sources Offsite

Unit 2 Reserve Station Service Transformer (RSST)

Unit 2 Normal Station Service Transformer (NSST) back-fed via the Main Transformer (if already aligned)

Unit 3 Normal Station Service Transformer (NSST) via Buses 34A/B to Unit 2 emergency bus 24E (if already aligned)

Unit 3 .Reserve Station Service Transformer (RSST) via Buses 34A/B to Unit 2 emergency bus 24E (if already aligned)

Onsite

Diesel Generator 15G-12U

Diesel Generator 15G-13U

SBO Diesel Generator (if already aligned)

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 43 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

CU3 UNPLANNED increase in RCS CU3 UNPLANNED increase in RCS None temperature temperature MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, 6 -

Refueling Refuelinq NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 UNPLANNED increase in RCS CU3.1 UNPLANNED rise in RCS 200°F is the site-specific Tech. Spec. cold shutdown temperature temperature to greater than temperature to > 200°F limit.

(site-specific Technical Specification cold shutdown temperature limit) 2 Loss of ALL RCS temperature CU3.2 Loss of all RCS temperature and None and (reactor vessel/RCS [PWRj RCS water level indication for 2:

or RPV [BWRJ) level indication 15 min. (Note 1) for 15 minutes or longer.

Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the declare the Unusual Event declare the event MPS2 EAL scheme by referencing the "time limit" specified within promptly upon determining that promptly upon the EAL wording.

15 minutes has been exceeded, determining that the time or will likely be exceeded limit has been exceeded, or will likely be exceeded.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 44 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

CU4 Loss of Vital DC power for 15 CU4 Loss of vital DC power for 15 None minutes or longer. minutes or longer.

MODE: Cold Shutdown, MODE 5 - Cold Shutdown, 6 -

Refueling Refueling NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Indicated voltage is less than CU4.1 Indicated voltage is < 105 VDC on The specified bus voltage indications are the minimum voltage (site-specific bus voltage value) required vital 125 VDC buses requirements for operability of the 125 VDC buses.

on required Vital DC buses for 15 201 A OR 201 B for ~ 15 min. (Note Safety-related DC bus operability requirements are specified minutes or longer. 1) consistent with Technical Specifications.

Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the declare the Unusual Event declare the event MPS2 EAL scheme by referencing the "time limit" specified within promptly upon determining that promptly upon the EAL wording.

15 minutes has been exceeded, determining that the time or will likely be exceeded. limit has been exceeded, or will likely be exceeded.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 45 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown I Refueling System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

GUS Loss of all onsite or offsite GUS Loss of all onsite or offsite None communications capabilities. communications capabilities.

MODE: Cold Shutdown, MODE: S - Cold Shutdown, 6 -

Refueling, Defueled Refueling, DEF - Defueled NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

Loss of ALL of the following Loss of all Table C-5 onsite 1 CUS.1 Example EALs #1 , 2 and 3 have been combined into a single EAL communication methods onsite communication methods: for simplification of presentation.

(site specific list of OR Table C-5 provides a site-specific list of onsite, offsite (ORO) and communications methods) Loss of all Table C-5 State and NRG communications methods.

local agency communication 2 Loss of ALL of the following ORO methods communications methods:

OR (site specific list of communications methods) Loss of all Table C-5 NRG communication methods 3 Loss of ALL of the following NRG communications methods:

(site specific list of communications methods)

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 46 of 126 Table C-5 Communication Methods State/

System Onsite NRC Local ENRS/ARCOS X Station Radio System X X Plant Phone Syste.m X X Public Address System X Gaitronics / Maintenance Jacks X Federal Telephone System (ENS) X Commercial Telephone System X X Satellite Phones X X Dedicated Hotlines X

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 47 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS2 NEI IC# NEI ICWording MPS2 IC Wording Difference/Deviation Justification IC#(s)

CA1 Loss of (reactor vessel/RCS CA1 Significant loss of RCS inventory Added the word "Significant..." to differentiate the Alert loss of RCS

[PWR] or RPV [BWR]) inventory inventory IC from the Unusual Event IC which* is "Unplanned loss of MODE: 5 - Cold Shutdown, 6 -

MODE: Cold Shutdown, RCS inventory."

Refueling Refueling NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification '

EAL# EAL#

1 Loss of (reactor vessel/RCS CA1.1 Loss of RCS inventory as RCS hot leg level of 4 in. below centerline is the lowest RCS level

[PWR] or RPV [BWR]) inventory indicated by RCS water level that supports continued decay heat removal pump operations (SOC).

as indicated by level less than < - 4 in. on Ll-112 (CCTV) or The specified level instruments can measure the specified RCS hot (site-specific level). L-122 (PPC) leg level.

2 a. (Reactor vessel/RCS [PWR] CA1.2 RCS water level cannot be The Table C-1 sumps/tanks are the site-specific applicable sumps or RPV [BWR]) level cannot monitored for .:: 15 min. (Note 1) and tanks.

be monitored for 15 minutes AND EITHER Added bulleted criteria "Visual observation ... " to Table C-1 to include or longer direct observation of significant unisolable RCS leakage.

UNPLANNED rise in any AND Table C-1 sump or tank level

b. UNPLANNED increase in due to a loss of RCS inventory (site-specific sump and/or

Visual observation of tank) levels due to a loss of UNISOLABLE RCS leakage (reactor vessel/RCS [PWR]

or RPV [BWR]) inventory.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1 B Page 48 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the declare the Alert promptly upon declare the event MPS2 EAL scheme by referencing the "time limit" specified within the determining that 15 minutes has promptly upon EAL wording.

been exceeded, or will likely be determining that the time exceeded limit has been exceeded, or will likely be exceeded.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 49 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

CA2 Loss of all offsite and all onsite CA2 Loss of all offsite and all onsite None AC power to emergency buses AC power to emergency buses for for 15 minutes or longer 15 minutes or longer.

MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, 6 -

Refueling, Defueled Refueling, DEF - Defueled NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Loss of ALL offsite and ALL Loss of all offsite and all onsite 4.16 kV emergency buses 24C and 24D are the MPS2-specific CA2.1 AC power to 4.16 kV emergency emergency buses.

onsite AC Power to (site-specific emergency buses) for 15 buses 24C and 24D for.:: 15 min.

minutes or longer. (Note 1)

Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the declare the Unusual Event declare the event MPS2 EAL scheme by referencing the "time limit" specified within the promptly upon determining that promptly upon EAL wording.

15 minutes has been exceeded, determining that the time or will likely be exceeded. limit has been exceeded, or will likely be exceeded.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 50 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS2 Difference/Deviation Justification NEI IC# NEI IC Wording MPS2 IC Wording IC#(s)

CA3 Inability to maintain the plant in CA3 Inability to maintain plant in cold None cold shutdown. shutdown.

MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, 6 -

Refueling Refueling NEI Ex. MPS2 Difference/Deviation Justification NEI Example EAL Wording MPS2 EAL Wording EAL# EAL#

UNPLANNED rise in RCS Example EALs #1 and #2 have been combined into a single EAL as 1 UNPLANNED increase in RCS temperature to > 200°F for EAL #2 is the altern.ative threshold based on a loss of RCS temperature to greater than

> Table C-4 duration temperature indication.

(site-specific Technical (Notes 1, 13)

Specification cold shutdown 200°F is the site-specific Tech. Spec. cold shutdown temperature temperature limit) for greater OR limit.

than the duration specified in UNPLANNED RCS pressure rise Tabl!3 C-4 is the site-specific implementation of the generic RCS the following table.

CA3.1 > 10 psig Reheat Duration Threshold table.

2 UNPLANNED RCS pressure 10 psig is the site-specific RCS pressure increase readable by increase greater than (site- Control Room indications. RCS pressure instruments PT-103 and specific pressure reading). PT-103-1 are capable of measuring a 10 psi RCS p~essure rise.

(This EAL does not apply during water-solid plant conditions. Deleted "(This EAL does not apply during water-solid plant

[PWR]) conditions.)" MPS2 does not establish solid plant conditions during Cold Shutdown mode.

Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the Note The Emergency Director should N/A declare the event MPS2 EAL scheme by referencing the "time limit" specified within declare the Unusual Event promptly upon the EAL wording.

promptly upon determining that determining that the time 15 minutes has been exceeded, limit has been exceeded, or will likely be exceeded.

or will likely be

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 51 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction exceeded.

Note 13: If an RCS heat removal Added Note 13 consistent with the asterisk note provided in the N/A N/A N/A system is in operation generic RCS Heat-up Duration Threshold table.

within the applicable Table C-4* heat-up duration and RCS temperature is being reduced, the EAL is not aoolicable.

Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Status Heat-up Duration Intact (but not at reduced Not applicable 60 minutes*

inventory [PWR])

Not intact (or at reduced Established 20 minutes*

inventory [PWR]) Not Established 0 minutes

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

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 52 of 126 Table C-4 RCS Heat-up Duration Thresholds CONTAINMENT CLOSURE RCS Status Heat-up Duration Intact AND not reduced 60min.

inventory Established 20min.

Not intact OR reduced inventory Not established* Omin.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 53 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

CA6 Hazardous event affecting a CA6 Hazardous event affecting Revised wording from " ... affecting a SAFETY SYSTEM ... " to read SAFETY SYSTEM needed for SAFETY SYSTEMS needed for " ... affecting SAFETY SYSTEMS ... " to align with changes made the current operating mode. the current operating mode. consistent with NRC EP FAQ 2016-002.

MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, 6 -

Refueling Refueling NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

I 1 a. The occurrence of ANY of CA6.1 The occurrence of any Table C-6 The hazardous events have been tabularized in Table C-6.

the following hazardous hazardous event The proposed MPS2 CA6.1 and SA9.1 wording is intended to events:

AND ensure that an Alert should be declared only when actual or

Seismic event potential performance issues with SAFETY SYSTEMS have Event damage has caused (earthquake) occurred as a result of a hazardous event. The occurrence of indications of degraded

Internal or external certain hazardous events may result in an Unusual Event performance on one train of a flooding event classification at a minimum. In order to warrant escalation to the SAFETY SYSTEM needed for the

High winds or tornado Alert classification, the hazardous event should cause indications current operating mode of degraded performance to one train of a SAFETY SYSTEM with strike

FIRE AND EITHER: either indications of degraded performance on the second

EXPLOSION SAFETY SYSTEM train or VISIBLE DAMAGE to the second

Event damage has caused SAFETY SYSTEM train, such that the operability or reliability of

(site-specific hazards) indications of degraded

Other events with the second train is a concern. In addition, escalation to the Alert performance to the second classification should riot occur if the damage from the hazardous similar hazard train of the SAFETY event is limited to a SAFETY SYSTEM that was inoperable, or out characteristics as SYSTEM needed for the of service, prior to the event occurring. As such, the proposed determined by the Shift current operating mode EALs will reduce the potential of declaring an Alert when events Manager

Event damage has are in progress that do not involve an actual or potential AND resulted in VISIBLE substantial degradation of the level of safety of the plant, (i.e.,

S~rial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 54 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction DAMAGE to the second does not cause significant concern with shutting down or cooling train of the SAFETY down the plant).

b. EITHER of the following:

SYSTEM needed for the

1. Event damage has EALs GA6.1 and SA9.1 do not directly escalate to a Site Area current operating mode caused indications of Emergency or a General Emergency due to a hazardous event.

degraded performance (Notes 9, 1O) The Fission Product Barrier and/or Abnormal Radiation in at least one train of a Levels/Radiological Effluent recognition categories would provide SAFETY SYSTEM an escalation path to a Site Area Emergency or a General needed for the current Emergency.

operating mode.

The EALs and the Basis sections have been revised to ensure OR potential escalations from an Unusual Event to an Alert, due to a hazardous event, is appropriate as the concern with these EALs

2. The event has caused is: (1) a hazardous event has occurred, (2) one SAFETY VISIBLE DAMAGE to a SYSTEM train is having performance issues as a result of the SAFETY SYSTEM hazardous event, and (3) either the second SAFETY SYSTEM component or structure train is having performance issues or the VISIBLE DAMAGE is needed for the current enough to indicate that the second SAFETY SYSTEM train may operating mode. have operability or reliability issues.

The definition for VISIBLE DAMAGE has been revised to reflect the fact that the EALs are based upon SAFETY SYSTEM trains rather than individual components or structures.

Note 9 has been added to GA6.1 and SA9.1 as it meets the intent of the EALs, is consistent with other EALs (e.g., EAL HA5.1 which was previously endorsed by the NRG), and ensures that declared emergencies are based upon unplanned events with the potential to pose a radiological risk to the public.

Note 10 has been added to GA6.1 and SA9.1 to help reinforce and succinctly capture the more detailed information from the revised basis section related to when conditions would require the declaration of an Alert.

GA6.1 and SA9.1 are consistent with NRG FAQ 2016-002 requirinq deoraded performance or visible damaqe to more than

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 55 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction one safety system train caused by the specified events.

This revised wording is a deviation from the NEI 99-01, Revision 6 CA6 and SA9 generic wording and bases but is deemed acceptable consistent with endorsed NRC EP FAQ 2016-002.

N/A N/A N/A Note 9: If the aftected SAFETY Added Note 9 consistent with the recommendation of NRG EP SYSTEM train was FAQ 2016-002.

already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted.

Note 1O: If the hazardous event Added Note 1O consistent with the recommendation of NRG EP only resulted in VISIBLE FAQ 2016-002.

DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 56 of 126 Table C-6 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 DSEO/ADTS

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CS1 Loss of (reactor vessel/RCS CS1 Loss of RCS inventory affecting None

[PWR] or RPV [BWR]) inventory core decay heat removal affecting core decay heat capability removal capability. MODE: 5 - Cold Shutdown, 6 -

MODE: Cold Shutdown, Refueling Refueling NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 a. CONTAINMENT CLOSURE Millstone 2 includes in its Inadequate Core Cooling instrumentation a not established. reactor vessel leve_l monitoring system (RVLMS) that is displayed to the operators and can measure discrete reactor vessel water levels AND from the top of the reactor vessel head to the top of the core plate

b. (Reactor vessel/RCS [PWR] (string #8 - approximately 10 inches above the top of the active fuel).

or RPV [BWR]) level less The bottom of this instrument's span in the reactor vessel plenum is than (site-specific level). the lowest available reactor vessel level indicator and is used in this EAL to represent approximately the top of active fuel.

RVLMS reading 0% (#8)

CS1.1 There is no RVLMS level indication representative of 6 in. below the (Note 12) bottom of the RCS hot leg. Therefore Example EALs #1 and #2 have been combined into a single EAL based on water level approximately 1O inches above the top of active fuel regardless of the status of containment closure.

RVLMS is only required to be operable in modes 1, 2 and 3. For plant conditions in which RVLMS is disconnected or otherwise inoperable, such as in the Refueling mode, classification should be made based on CS1 .2 when RCS water level cannot be monitored.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 58 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction 2 a. CONTAINMENT CLOSURE established.

AND

b. (Reactor vessel/RCS [PWR]

or RPV [BWR]) level less than (site-specific level}.

3 a. (Reactor vessel/RCS [PWR] CS1.2 RCS level cannot be monitored Site-specific applicable sumps and tanks are listed in Table C-1 to or RPV [BWR]) level cannot for ~ 30 min. (Note 1) improve the readability of the EAL.

be monitored for 30 minutes Although "Visual observation ... " in Table C-1 is neither a sump nor or longer.

AND tank, it is included in order to implement the intent of the NEI basis Core uncovery is indicated by AND any of the following:

which states: " ... operators may determine that an inventory loss is occurring by observing changes ... "

b. Core uncovery is indicated by ANY of the following:

UNPLANNED rise in any Containment area radiation monitors are those ARMs that would be Table C-1 sump or tank indicative of core uncovery in the Refueling operating condition. A

(Site-specific radiation level of sufficient magnitude reading > 4 R/hr is indicative of likely core uncovery while in the monitor) reading greater to indicate core uncovery Refueling mode.

than (site-specific value)

Visual observation of UNISOLABLE RCS leakage No other site-specific indications of core uncovery have been

Erratic source range of sufficient magnitude to identified for MPS2 .

monitor indication [PWR]

indicate core uncovery

UNPLANNED increase in

Erratic source range (site-specific sump and/or monitor indications tank) levels of sufficient

Any containment area magnitude to indicate radiation monitor reading >

core uncovery 4 R/hr (Refueling mode)

(Other site-specific indications)

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1 B Page 59 of 126 Table 4- MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction Note N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the The Emergency Director should should declare the MPS2 EAL scheme by referencing the "time limit" specified within the declare the Site Area event promptly upon EAL wording.

Emergency promptly upon determining that the determining that 30 minutes has time limit has been been exceeded, or will likely be exceeded, or will likely exceeded be exceeded.

N/A N/A Note 12: This EAL is only Added note 12 to ensure user adheres to operability requirements for N/A applicable if a RVLMS use of the RVLMS indicator.

channel #8 string is operable

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1 B Page 60 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

CG1 Loss of (reactor vessel/RCS CG1 Loss of RCS inventory affecting None

[PWR] or RPV [BWR]) inventory fuel clad integrity with affecting fuel clad integrity with containment challenged containment challenged MODE: 5 - Cold Shutdown, 6 -

MODE: Cold Shutdown, Refueling Refueling NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 RVLMS reading 0% (#8) for~ 30 Millstone 2 includes in its Inadequate Core Cooling

a. (Reactor vessel/RCS [PWR] CG1.1 min. (Notes 1, 12) instrumentation a reactor vessel level monitoring system or RPV [BWR]) level less than (site-specific level) for 30 AND (RVLMS) that is displayed to the operators and can measure minutes or longer. discrete reactor vessel water levels from the top of the reactor Any Containment Challenge vessel head to the top of the core plate (string #8 -

AND indication, Table C-2 approximately 10 inches above the top of the active fuel). The

b. ANY indication from the bottom of this instrument's span in the reactor vessel plenum is Containment Challenge Table the lowest available reactor vessel level indicator and is used in (see below). this EAL to represent approximately the top of active fuel.

RVLMS is only required to be operable in Modes 1, 2 and 3. For plant conditions in which RVLMS is disconnected or otherwise inoperable, such as in the Refueling Mode, classification should be made based on CG1 .2 when RCS water level cannot be monitored.

2 a. (Reactor vessel/RCS [PWR] CG1.2 RCS level cannot be monitored Site-specific applicable sumps and tanks are listed in Table C-1 or RPV [BWR]) level cannot for~ 30 min. (Note 1) to improve the readability of the EAL.

be monitored for 30 minutes Although "Visual observation ... " in Table C-1 is neither a sump AND

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 61 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction or longer. Core uncovery is indicated by any nor tank, it is included in order to implement the intent of the NEI of the following: basis which states: " ... operators may determine that an AND inventory loss is occurring by observing changes ... "

b. Core uncovery is indicated by

UNPLANNED rise in any Table C-1 sump or tank level Containment area radiation monitors are those ARMs that would ANY of the following:

of sufficient magnitude to be indicative of core uncovery in the Refueling operating

(Site-specific radiation indicate core uncovery condition. A reading > 4 R/hr is indicative of likely core uncover monitor) reading greater while in the Refueling mode.

than (site-specific value)

Visual observation of UNISOLABLE RCS leakage No other site-specific indications of core uncovery have been

Erratic source range of sufficient magnitude to identified for MPS2.

monitor indication [PWRJ indicate core uncovery 4% hydrogen concentration in the presence of oxygen is the

UNPLANNED increase in

Erratic source range monitor minimum necessary to support a hydrogen explosion .

(site-specific sump and/or indications tank) levels of sufficient magnitude to indicate

Any containment area radiation monitor reading core uncovery > 4 R/hr (Refueling mode)

(Other site-specific AND indications)

Any Containment Challenge AND indication, Table C-2

c. ANY indication from the Containment Challenge Table (see below).

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 62 of 126 Table 4 - MPS2 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction Note The Emergency Director should N/A Note 1: The DSEO/ADTS.should The classification timeliness .note has been standardized across declare the General Emergency declare the event promptly the MPS2 EAL scheme by referencing the "time limit" specified promptly upon determining that upon determining that the within the EAL wording.

30 minutes has been exceeded, time limit has been ..

or will likely be exceeded .. . exceeded, or will likely be exceeded.

Note 6: If CONTAINMENT Note 6 implements the asterisked note associated with the CLOSURE is re- Containment Closure requirement.

N/A established prior to exceeding the 30-min.

tir:ne limit, declaration of a General Emergency is not

.required.

Note 12:This EAL is only Added note 12 to ensure user adheres to operability applicable if a RVLMS requirements tor use of the RVLMS indicator.

. channel #8 string is operable.

Containment Challenge Table

CONTAINMENT CLOSURE not established*

(Explosive mixture) exists inside containment

UNPLANNED increase in containment pressure

Secondary containment radiation monitor reading above (site-specific value) [BWR]

If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, tlilen declaration of a General Emergency is not required.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 63 of 126 Table C-2 Containment Challenge Indications

CONTAINMENT CLOSURE not established (Note 6)

CTMT hydrogen concentration > 4%

UNPLANNED increase in CTMT pressure

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 64 of 126 Table 4 - MPS2 Comparison Matrix Category D: Permanently Defueled Station Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

PD-AU1 Recognition Category D N/A NIA NEI Recognition Category PD ICs and EALs are applicable only to PD-AU2 Permanently Defueled Station permanently defueled stations. MPS2 is not a defueled station.

PD-SU1 PD-HU1 PD-HU2 PD-HU3 PD-AA1 PD-AA2 PD-HA1 PD-HA3

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 65 of 126 Table 4 - MPS2 Comparison Matrix Category E: Independent Spent Fuel Storage Installation MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

E-HU1 Damage to a loaded cask EU1 Damage to a loaded cask None CONFINEMENT BOUNDARY CONFINEMENT BOUNDARY MODE: All MODE: All NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Damage to a loaded cask EU1.1 Damage to a loaded cask The specified dose rates represent 2 times the site-specific cask CONFINEMENT BOUNDARY as CONFINEMENT BOUNDARY technical specification allowable levels per the ISFSI Technical indicated by an on-contact as indicated by an on-contact Specifications.

radiation reading greater than (2 radiation reading on the surface times the site-specific cask of a loaded spent fuel cask specific technical specification (HSM) > any of the following:

allowable radiation level} on the surface of the spent fuel cask.

1,700 mrem/hr on the HSM front bird screen

400 mrem/hr on the outside HSM door

12 mrem/hr on the HSM end shield wall

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 66 of 126 Table 4 - MPS2 Comparison Matrix Category F: Fission Product Barrier Degradation Fuel Clad Fission Product Barrier Degradation Thresholds NEI MPS2 NEI Threshold Wording MPS2 FPB Wording Difference Justification FPB# FPB #(s)

FC Loss RCS or SG Tube Leakage N/A N/A N/A 1 Not Applicable FC Loss Inadequate Heat Removal FC Loss 1. CETs > 1200°F The MPS2 SAMGs use a GET temperature of 1200 °F as an entry condition and the temperature indicative of a badly damaged core.

2 A. Core exit thermocouple B.1 readings greater than (site- .

specific temperature value).

FC Loss RCS Activity/CMNT Rad FC Loss 2. CTMT high range radiation RE-8240/8241 are the Containment High Range area radiation C.2 monitor RE-8240/8241 monitors. The threshold values specified in Table F-2 have been 3 A. Containment radiation reading > Table F-2 column calculated assuming the instantaneous release and dispersal of monitor reading greater than Fuel Clad Loss the reactor coolant noble gas and iodine inventory associated (site-specific value) with approximately 5% fuel clad damage.

OR FC Loss 3. Coolant activity > 300 None B. (Site-specific indications C.3 µCi/gm dose equivalent I-that reactor coolant activity is 131 greater than 300 µCi/gm dose equivalent 1-131)

FC Loss 4. Dose rate at t ft. from an Per Engineering Calculation RA-0059, the specified Table F-3 C.4 unpressurized RCS sample dose rates are assumed to result from radioactive iodines (l-131 2: Table F-3 thru 1-135) in RCS in concentrations corresponding to the loss of 5% of gap radioactivity of the core.

FC Loss 5. Sample line dose rate 2: Per Engineering Calculation RA-0079, the specified Table F-4 C.5 Table F-4 dose rates are assumed to result from radioactive iodines (1-131 thru 1-135) in RCS.in concentrations corresponding to the loss of 5% of gap radioactivity of the core.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 67 of 126 Table 4 - MPS2 Comparison Matrix Category F: Fission Product Barrier Degradation FC Loss 6. . Core damage estimate As determined per MP-26-EPI-FAP11 Core Damage Assessment C.6 > 5% clad damage procedure.

FC Loss CNMT Integrity or Bypass N/A N/A N/A 4 Not Applicable FC Loss Other Indications N/A N/A No other site-specific Fuel Clad Loss indication has been identified 5 for MPS2.

A. (site-specific as applicable)

FC Loss ED Judgment FC Loss 5. Any condition in the opinion None E.7 of the DSEO/ADTS that 6 A. ANY condition in the indicates loss of the Fuel opinion of the Emergency*

Clad barrier Director that indicates Loss of the Fuel Clad Barrier.

FC RCS or SG Tube Leakage FC Pot. 1. RVLMS reading 0% (#8) Millstone 2 includes in its Inadequate Core Cooling instrumentation P-Loss Loss (Note 12) a reactor vessel level monitoring system (RVLMS) that is displayed A. RCS/reactor vessel level to the operators and can measure discrete reactor vessel water A.1 1 less than (site-specific level) levels from the top of the reactor vessel head to the top of the core plate (string #8 - approximately 10 inches above the top of the active fuel). The bottom of this instrument's span in the reactor vessel plenum is the lowest available reactor vessel level indicator and is used in this EAL to represent approximately the top of active fuel.

Added note 12 to ensure user adheres to operability requirements for use of the RVLMS indicator.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 68 of 126 Table 4 - MPS2 Comparison Matrix Category F: Fission Product Barrier Degradation FC Inadequate Heat Removal FC Pot. 2. CETs > 700°F Consistent with the generic developers note options, a GET P-Loss Loss temperature of 700°F is used.

A. Core exit thermocouple 8.2 2 readings greater than (site-specific temperature value) \

OR FC Pot. 3. Applicable RCS and Core Failure to meet the applicable HR acceptance criteria indicates an B. Inadequate RCS heat Loss Heat Removal (HR) Safety extreme challenge to the ability to remove RCS heat using the removal capability via steam 8.3 Function Status Check steam generators (i.e., loss of an effective secondary-side heat generators as indicated by acceptance criteria not met sink).

(site-specific indications).

FC RCS Activity/CMNT Rad N/A N/A N/A P-Loss Not Applicable 3

FC CNMT Integrity or Bypass N/A N/A N/A P-Loss Not Applicable 4

FC Other Indications N/A N/A No other site-specific Fuel Clad Potential Loss indication has been P-Loss identified for MPS2.

A. (site-specific as applicable) 5 FC Emergency Director FC Pot. 4. Any condition in the opinion None P-Loss Judgment Loss of the DSEO/ADTS that E.4 indicates potential loss of the 6 A. Any condition in the opinion Fuel Clad barrier.

of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 69 of 126 Table 4 - MPS2 Comparison Matrix Category F: Fission Product Barrier Degradation RCS Fission Product Barrier Degradation Thresholds NEI MPS2 FPB NEI IC Wording MPS2 FPB Wording Difference Justification FPB# #(s)

RCS RCS or SG Tube Leakage RCS Loss 1. An automatic or manual None Loss A.1 SIAS actuation required by A. An automatic or manual 1 EGGS (SI) actuation is EITHER:

required by EITHER of the

UNISOLABLE RCS following: leakage

1. UNISOLABLE RCS leakage

SG tube RUPTURE OR

2. SG tube RUPTURE.

RCS Inadequate Heat Removal N/A N/A N/A Loss Not Applicable ,

2 RCS RCS Activity/CMNT Rad RCS Loss 2. CTMT high range radiation RE-8240/8241 are the Containment High Range area radiation Loss C.2 monitor RE-8240/8241 monitors. A reading > 5 R/hr (minimum practical reading) on RM-A. Containment radiation 3 reading > Table F-2 column 8240 or 8241 is indicative of a breach in the RCS barrier.

monitor reading greater than RCS Loss (site-specific value).

RCS CNMT Integrity or Bypass N/A N/A N/A Loss Not Applicable 4

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 70 of 126 Table 4 - MPS2 Comparison Matrix Category F: Fission Product Barrier Degradation RCS Other Indications N/A N/A No other site-specific RCS Loss indication has been identified for Loss MPS2.

A. (site-specific as applicable) 5 RCS Emergency Director Judgment RCS Loss 3. Any condition in the None Loss E.3 opinion of the A. ANY condition in the opinion DSEO/ADTS that 6 of the Emergency Director that indicates loss of the RCS indicates Loss of the RCS barrier Barrier.

RCS RCS or SG Tube Leakage RCS Pot. 1. UNISOLABLE RCS or SG MPS2 does not start a standby charging pump if inventory cannot Loss tube leakage > 50 gpm be maintained with operating makeup, rather SI would be initiated.

P-Loss 1 A. Operation of a standby A.1 excluding normal MPS2 has implemented the alternative threshold wording charging (makeup) pump is reductions in RCS consistent with NEI 99-01, Rev. 6 RCS Potential Loss 1 required by EITHER of the inventory (e.g. letdown, Developers Notes.

following:

RCP seal leakage)

1. UNISOLABLE RCS leakage OR A RCS cooldown greater than 100°F/hr below 500°F is the RCS Pot. 2. Uncontrolled RCS cooldown temperature that requires implementation of Pressurized Thermal

2. SG tube leakage. Loss > 100°F/hr and RCS Shock (PTS) guidance.

A.2 pressure and temperature OR are to the left of the 200°F The 200°F maximum subcooling limit ensures PTS and brittle B. RCS cooldown rate greater Subcooling (PTS) Curve fracture of the reactor vessel will not occur following an RCS than (site-specific (EOP Figure 1) overcooling transient (defined as an uncontrolled cooldown to less pressurized thermal shock than 500°F).

criteria/limits defined by site-specific indications).

Serial No.18-364 MPS2 - EAL Comparison Ma~rix Document Docket No. 50-336 Enclosure 3; Attachment 1 B Page 71 of 126 Table 4 - MPS2 Comparison Matrix Category F: Fission Product Barrier Degradation RCS Inadequate Heat Removal RCS Pot. 3. Applicable RCS and Core Failure to meet the applicable HR acceptance criteria indicates an Loss Heat Removal (HR) Safety extreme challenge to the ability to remove RCS heat using the P-Loss 2 A. Inadequate RCS heat B.3 Function Status Check steam generators (i.e., loss of an effective secondary-side heat removal capability via steam acceptance criteria not met sink).

generators as indicated by (site-specific indications). .

RCS CS Activity/CMNT Rad N/A N/A N/A P-Loss 3 Not Applicable RCS CNMT Integrity or Bypass N/A N/A N/A P-Loss 4 Not Applicable RCS Other Indications N/A N/A No other site-specific RCS Potential Loss indication has been identified for MPS2.

P-Loss 5 A. (site-specific as applicable)

RCS Emergency Director Judgment RCS Pot. 4. Any condition in the opinion None Loss of the DSEO/ADTS that P-Loss 6 A. ANY condition in the opinion E:4 indicates potential loss of of the Emergency Director that the RCS barrier indicates Potential Loss of the RCS Barrier..

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 72 of 126 Table 4 - MPS2 Comparison Matrix Category F: Fission Product Barrier Degradation Containment Fission Product Barrier Degradation Thresholds NEI MPS2 FPB NEI IC Wording MPS2 FPB Wording Difference Justification FPB# #(s)

CNMT RCS or SG Tube Leakage CTMT Loss 1. A leaking or RUPTURED None Loss A.1 SG is FAULTED outside of A. A leaking or RUPTURED SG CTMT 1 is FAULTED outside of containment.

CNMT Inadequate Heat Removal N/A N/A N/A Loss Not Applicable 2

CNMT RCS Activity/CMNT Rad N/A N/A N/A Loss Not applicable 3

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 73 of 126 Table 4 - MPS2 Comparison Matrix Category F: Fission Product Barrier Degradation

2. CTMT isolation is required CNMT CNMT Integrity or Bypass CTMT Loss Added the word "atmosphere" to the second bulleted threshold to Loss D.2 AND EITHER: reinforce the generic bases that the intent is an unisolable A. Containment isolation is pathway from the containment atmosphere, not RCS. RCS 4 required

CTMT integrity has leakage outside containment is addressed under CTMT Loss D.3 AND been lost base_d on below.

DSEO/ADTS judgment EITHER of the following:

1. Containment integrity

UNISOLABLE pathway from CTMT atmosphere has been lost based on to the environment Emergency Director exists judgment.

OR

2. UNISOLABLE pathway from the containment to the environment exists.

OR B. Indications of RCS leakage outside of containment.

3. Indications of RCS leakage CTMT Loss None outside of CTMT D.3 N/A CNMT Other Indications N/A No other site-specific containment Loss indication has been Loss identified for MPS2.

A. (site-specific as applicable) 5

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336

Enclosure 3; Attachment 1B Page 74 of 126 Table 4 .:.. MPS2 Comparison Matrix Category F: Fission Product Barrier Degradation

4. Any condition in the CNMT Emergency Director Judgment CTMT Loss None opinion of the DSEO/ADTS Loss E.4 ANY condition in the opinion of that indicates loss of the 6

the Emergency Director that CTMT barrier indicates Loss of the Containment Barrier.

N/A N/A CNMT RCS or SG Tube Leakage N/A P-Loss Not Applicable 1

CNMT Inadequate Heat Removal CTMT Pot. 1. CETs > 1200°F The MPS2 SAMGs use a GET temperature of 1200°F as an entry P-Loss Loss condition and the temperature indicative of a badly damaged core.

A. 1. (Site-specific criteria for . AND 8.1 2 entry into core cooling Restoration procedures restoration procedure) not effective within 15 AND min. (Note 1)

2. Restoration procedure not effective within 15 minutes.

CNMT RCS Activity/CMNT Rad CTMT Pot. 2. CTMT high range radiation RE-8240/8241 are the containment High Range area radiation P-Loss Loss monitor RE-8240/8241 monitors. The radiation monitor readings specified in Table F-2 A. Containment radiation C.2 reading > Table F-2 column column CTMT Potential Loss correspond to an instantaneous 3 monitor reading greater release of all reactor coolant mass into the containment, assuming CTMT Potential Loss than (site-specific value).

that 20% of the fuel cladding has failed.

CNMT CNMT Integrity or Bypass CTMT Pot. 3. CTMT pressure > 54 psig If containment pressure exceeds the design pressure of 54 psig, P-Loss Loss there exists a potential to lose the containment barrier A. Containment pressure D.3

4 greater than (site-specific A containment hydrogen concentration of 4% conservatively value) represents the lowest threshold for flammability in the presence of oxygen.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 75 of 126 Table 4 - .MPS2 Comparison Matrix Category F: Fission Product Barrier Degradation OR The containment pressure setpoint (9.48 psig rounded to 10 psig for readability) is the pressure at which the containment B. Explosive mixture exists CTMT Pot. 4. CTMT hydrogen depressurization equipment should actuate and begin performing inside containment Loss concentration its function.

D.4 >4%

OR Added Note 1 consistent with other thresholds with a timing C. 1. Containment pressure CTMT Pot. 5. CTMT pressure > 10 psig component.

greater than (site- Loss with Added Note 11 to define what constitutes a full train of specific pressure D.5 < one full train of CTMT containment heat removal systems.

setpoint) heat removal systems (Note

11) operating per design for AND

.:: 15 min. (Note 1)

2. Less than one full train of (site-specific system or equipment) is operating per design for 15 minutes or longer.

CNMT Other Indications N/A N/A N/A P-Loss A. (site-specific as applicable) 5 CNMT Emergency Director Judgment CTMT Pot. 6. Any condition in the opinion None P-Loss Loss of the DSEO/ADTS that A. ANY condition in the E.6 indicates potential loss of 6 opinion of the Emergency the CTMT barrier Director that indicates Potential Loss of the Containment Barrier.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 76 of 126 Table 4 - MPS2 Comparison Matrix Category F: Fission Product Barrier Degradation Table F-2 CTMT High Range Radiation Monitor Barrier Thresholds RE.,.8240/8241 Time > Shutdown Fuel Clad Loss RCS Loss CTMT Potential Loss (hrs) (R/hr) (R/hr) (R/hr)

S2 56 5 224

>2-S4 35 5 140

>4-S8 16 5 65

> 8 - S 12 10 5 40

>12 7 5 20 Table F-3 FC Loss Coolant Activity Dose Rates Time> Shutdown (hrs) mR/hr/ml S2 15

>2-S8 8

>8 3 Table F-4 FC Loss RCS Sample Line Dose Rates Time > Shutdown (hrs) R/hr S2 4

>2-S8 2

>8 1

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 77 of 126 Table 4 - MPS2 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

HU1 Confirmed SECURITY HU1 Confirmed SECURITY None CONDITION or threat CONDITION or threat.

MODE: All MODE: All NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 A SECURITY CONDITION that HU1.1 A SECURITY CONDITION that Example EALs #1 , 2 and 3 have been combined into a single EAL does not involve a HOSTILE does not involve a HOSTILE for ease of presentation and use.

ACTION as reported by the (site- ACTION as reported by MPS The "MPS Security Shift Supervision" is the site-specific "security specific security shift Security Shift Supervision shift supervision."

supervision).

OR 2 Notification of a credible security Notification of a credible security threat directed at the site. threat directed at the site 3 A validated notification from the OR NRG providing information of an A validated notification from the aircraft threat.

NRG providing information of an aircraft threat

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 78 of 126 Table 4 - MPS2 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

HU2 Seismic event greater than OBE HU2 Seismic event greater than OBE None levels levels MODE: All MODE: All NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Seismic event greater than HU2.1 Notification by the MPS3 Control For both MPS2 and MPS3, the OBE ground acceleration thresholds Operating Basis Earthquake Room that a seismic event are > 0.09g horizontal or> 0.6g vertical. The MPS3 Control Room (OBE) as indicated by: > OBE has occurred has real time OBE exceedance alarm indications. Therefore classification shall be based upon the receipt of the MPS3 OBE (site-specific indication that a alarm light on MPS3 Panel 3ERS-PNLSM1 C. The MPS3 Control seismic event met or exceeded Room will notify MPS2 if the seismic event exceeded the OBE OBE limits) threshold.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 79 of 126 Table 4 - MPS2 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

HU3 Hazardous event. HU3 Hazardous event None MODE: All MODE: All NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 A tornado strike within the HU3.1 A tornado strike within the None PROTECTED AREA. PROTECTED AREA 2 Internal room or area flooding of a HU3.2 Internal room or area Changed the word "needed" to "required by Technical Specification".

magnitude sufficient to require FLOODING of a magnitude Plant Technical Specifications specify the needed safety systems for manual or automatic electrical sufficient to require manual or the current operating mode.

isolation of a SAFETY SYSTEM automatic electrical isolation of a component needed for the current SAFETY SYSTEM component operating mode. required by Technical Specifications for the current operating mode 3 Movement of personnel within the HU3.3 Movement of personnel within Replaced the phrase " ... due to an offsite event..." to " ... due to an PROTECTED AREA is impeded the PROTECTED AREA is event external to the PROTECTED AREA ... " The impact of a due to an offsite event involving IMPEDED due to an event hazardous material originating from offsite (outside the OCA) would hazardous materials (e.g., an external to the PROTECTED be the same as one originating from onsite but outside the offsite chemical spill or toxic gas AREA involving hazardous Protected Area.

release). materials (e.g., an offsite chemical spill or toxic gas release)

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 80 of 126 Table 4 - MPS2 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety

4 A hazardous event that results in HU3.4 A hazardous event that results in Added reference to Note 7.

on-site conditions sufficient to on-site conditions sufficient to prohibit the plant staff from prohibit the plant staff from accessing the site via personal accessing the site via personal vehicles. vehicles (Note 7) 5 (Site-specific list of natural or N/A N/A No other site-specific hazard has been identified for MPS2.

technological hazard events)

Note EAL #3 does not apply to routine N/A Note 7: This EAL does not This note, designated Note #7, is intended to apply to generic traffic impediments such as fog, apply to routine traffic example EAL #4, not #3 as specified in the generic guidance.

snow, ice, or vehicle breakdowns impediments such as or accidents. fog, snow, ice, or vehicle breakdowns or accidents.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 81 of 126 Table 4 - MPS2 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS2 Difference/Deviation Justification NEI IC# NEI IC Wording MPS2 IC Wording IC#(s)

HU4 FIRE potentially degrading the HU4 FIRE potentially degrading the None level of safety of the plant. level of safety of the plant MODE: All MODE:AII NEI Ex. MPS2 Difference/Deviation Justification NEI Example EAL Wording MPS2 EAL Wording EAL# EAL#

1 a. A FIRE is NOT extinguished HU4.1 A FIRE is not extinguished Table H-1 provides a list of site-specific fire areas.

within 15-minutes of ANY of the within 15 min. of any of the following FIRE detection following FIRE detection indications: indications (Note 1):

Report from the field (i.e.,

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

Receipt of multiple (more

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

1) fire alarms or indications indications

Field verification of a single

Field verification of a single fire alarm fire alarm AND AND The FIRE is located within any

b. The FIRE is located within Table H-1 area ANY of the following plant rooms or areas:

(site-specific list of plant rooms or areas)

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 82 of 126 Table 4 - MPS2 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety 2 a. Receipt of a single fire alarm HU4.2 Receipt of a single fire alarm Table H-1 provides a list of site-specific fire areas.

(i.e., no other indications of a (i.e., no other indications of a With regard to Containment Building fire alarms, there is constant FIRE). FIRE) air movement in the enclosed containment due to the operation of AND AND the containment ventilation system. The operating cooling units are drawing air to the units past the smoke detectors. It can be

b. The FIRE is located within The fire alarm is indicating a reasonably expected that a fire that burns for 15 minutes would ANY of the following plant rooms FIRE within any Table H-1 area produce sufficient products of combustion to cause fire detectors in or areas: (excluding Containment Building) multiple zones to alarm. Therefore a single containment fire alarm is (site-specific list of plant rooms or AND not considered VALID.

areas)

The existence of a FIRE is not Added Note 14 to clarify validation of a single fire zone alarm in the AND verified within 30 min. of alarm Containment Building.

receipt (Notes 1, 14)

C. The existence of a FIRE is not verified within 30-minutes of alarm receipt.

3 A FIRE within the plant or ISFSI HU4.3 A FIRE within the PROTECTED MPS2 has an ISFSI located inside the plant Protected Area.

[for plants with an ISFSI outside

AREA not extinguished within 60 the plant Protected Area] min. of the initial report, alarm or PROTECTED AREA not indication (Note 1) extinguished within 60-minutes of the initial report, alarm or indication.

4 A FIRE within the plant or ISFSI . HU4.4 A FIRE within the PROTECTED MPS2 has an ISFSI located inside the plant Protected Area.

[for plants with an ISFSI outside AREA that requires an offsite fire r Reworded example EAL #4 to better reflect the bases intent that the the plant Protected Area] department to assist with classification is based on a fire that requires an offsite fire PROTECTED AREA that requires extinguishment department to assist with fire extinguishment.

firefighting support by an offsite fire response agency to extinguish.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 83 of 126 Table 4 - MPS2 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety Note Note: The Emergency Director N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the should declare the Unusual Event should declare the MPS2 EAL scheme by referencing the "time lim.it" specified within promptly upon determining that event promptly upon the EAL wording.

the applicable time has been determining that the exceeded, or will likely be time limit has been exceeded. exceeded, or will likely be exceeded.

Note N/A N/A Note 14: A Containment Building See justification above.

fire alarm is considered VALID upon receipt of multiple (more than one) fire zone alarms.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 84 of 126 Table H-1 MPS2 Fire Areas

Containment Building

Control Room

Auxiliary Building Areas:

o Penetration Areas o RBCCW Pump Rooms o Diesel Generator Rooms o Diesel Generator Day Tank Rooms o Charging Pump Cubicles o SI Pump Rooms o DC Equipment and Battery Rooms o East 480 VAC Switchgear Room

Intake Structure

Turbine Building Areas:

o Cable Vaults o West 480 VAC Switchgear Room o 4.16 KV Switchgear Rooms o Steam Driven Aux Feedwater Room o Motor Driven Aux Feedwater Room

Yard Areas:

o RWST o CST o Unit 3 SBO DG

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HU7 Other conditions exist which in the HU7 Other conditions existing that in None judgment of the Emergency the judgment of the DSEO Director warrant declaration of a warrant declaration of a UE (NO)UE MODE:AII MODE: All NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Other conditions exist which in the HU7.1 Other conditions exist which, in None judgment of the Emergency the judgment of the DSEO, Director indicate that events are in indicate that events are in progress or have occurred which progress or have occurred which indicate a potential degradation of indicate a potential degradation the level of safety of the plant or of the level of safety of the plant indicate a security threat to facility or indicate a security threat to protection has been initiated. No facility protection has been releases of radioactive material initiated. No releases of requiring offsite response or radioactive material requiring monitoring are expected unless offsite response or monitoring further degradation of safety are expected unless further systems occurs. degradation of SAFETY SYSTEMS occurs.

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MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

HA1 HOSTILE ACTION within the HA1 HOSTILE ACTION within the None OWNER CONTROLLED AREA OWNER CONTROLLED AREA or or airborne attack threat within 30 airborne attack threat within 30 minutes. minutes MODE: All MODE: All NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 A HOSTILE ACTION is occurring or HA1.1 A HOSTILE ACTION is Example EALs #1 and #2 have been combined into a single EAL has occurred within the OWNER occurring or has occurred within for ease of use.

CONTROLLED AREA as reported the OCA as reported by MPS The "MPS Security Shift Supervision" is the site-specific "security by the (site-specific security shift Security Shift Supervision shift supervision."

supervision).

OR 2 A validated notification from NRC of A validated notification from an aircraft attack threat within 30 NRC of an aircraft attack threat minutes of the site. within 30 min. of the site

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HA5 Gaseous release impeding HA5 Gaseous release IMPEDING Limited mode applicability to the modes specified in Table H-2.

access to equipment necessary access to equipment necessary for normal plant operations, for normal plant operations, cooldown or shutdown. cooldown or shutdown MODE: All MODE: 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown NEI Ex. MPS2 Difference/Deviation Justification NEI Example EAL Wording MPS2 EAL Wording EAL# EAL#

1 a. Release of a toxic, HA5.1 Release of a toxic, corrosive, The site-specific list of plant rooms or areas with entry-related mode corrosive, asphyxiant or asphyxiant or flammable gas into applicability are tabularized in Table H-2.

flammable gas into any of the any Table H-2 room or area following plant rooms or areas:

AND (site-specific list of plant rooms Entry into the room or area is or areas with entry-related mode prohibited or IMPEDED (Note 5) applicability identified)

AND

b. Entry into the room or area is prohibited or impeded.

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1 B Page 88 of 126 Table 4 - MPS2 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety Note Note: If the equipment in the N/A Note 5: If the equipment in the None listed room or area was already listed room or area was inoperable or out-of-service already inoperable or before the event occurred, then out-of-service before the no emergency classification is event occurred, then no warranted. emergency classification is warranted.

Table H-2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux. Building El -5'6" West Area Aux. Building El -5'6" East Near SFP Cooling Aux. Building El 14'6" B51 & B61 Enclosures 3

Aux. Building El 14'6" Boric Acid Batching Tank Aux. Building El -25'6" RB HxArea Enc. Buildinq El -5'6" East Pipe Penetration Aux. Building El 14'6" By 861 Enc. Building El -45'6" "A" & "B" ESF Rooms 3,4 Aux. Buildinq El -45'6" General Area Enc. Building El -5'6" West Pipe Penetration 3,5 Aux. Buildinq El 14'6" SE Across From MCC B51 4 Aux. Building El -5'6" VCT Block Wall Area Enc. Building El -45'6" "A" ESF Room 5

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Category H: Hazards and Other Conditions Affecting Plant Safety MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s)

HA6 Control Room evacuation HA6 Control Room evacuation None resulting in transfer of plant resulting in transfer of plant control to alternate locations. control to alternate locations

-MODE: All MODE:AII NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 An event has resulted in plant HA6.1 An event has resulted in plant The Hot Shutdown Panel (C-21} or Fire Shutdown Panel (C-10) are control being transferred from the control _being transferred from the the site-specific remote shutdown panels and local control stations.

Control Room to (site-specific Control Room to the Hot remote shutdown panels and Shutdown Panel (C-21) or Fire local control stations). Shutdowri Panel (C-10)

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HA? Other conditions exist which in the HA? Other conditions exist that in the None judgment of the Emergency Director judgment of the DSEO/ADTS warrant warrant declaration of an Alert. declaration of an Alert MODE: All MODE: All NEI Ex. MPS2 Difference/Deviation Justification NEI Example EAL Wording MPS2 EAL Wording EAL# EAL#

1 Other conditions exist which, in the HA7.1 Other conditions exist which, in the None judgment of the Emergency Director, judgment of the DSEO/ADTS, indicate indicate that events are in progress or that events are in progress or have have occurred which involve an actual or occurred which involve an actual or potential substantial degradation of the potential substantial degradation of the level of safety of the plant or a security level of safety of the plant or a security event that involves probable life event that involves probable life threatening risk to site personnel or threatening risk to site personnel or damage to site equipment because of damage to site equipment because of HOSTILE ACTION. Any releases are HOSTILE ACTION. Any releases are expected to be limited to small fractions expected to be limited to small fractions of the EPA Protective Action Guideline of the EPA Protective Action Guideline exposure levels. exposure levels.

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HS1 HOSTILE ACTION within the HS1 HOSTILE ACTION within the None PROTECTED AREA PROTECTED AREA MODE: All MODE: All NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 A HOSTILE ACTION is occurring HS1.1 A HOSTILE ACTION is occurring or has The "MPS Security Shift Supervision" is the site-specific or has occurred within the occurred within the PROTECTED "security shift supervision."

PROTECTED AREA as reported AREA as reported by MPS Security by the (site-specific security shift Shift Supervision supervision).

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HS6 Inability to control a key safety HS6 Inability to control a key safety function j Deleted defueled mode applicability. Control of the cited function from outside the Control from outside the Control Room safety functions are not critical for a defueled reactor as Room. there is no energy source in_the RPV or RCS.

MODE: 1 - Power Operation, 2 - Startup, MODE: All 3 - Hot Standby, 4 - Hot Shutdown, 5 - This revised mode applicability is a deviation from the Cold Shutdown, 6 - Refueling NEI 99-01, Revision 6 HS6 generic guidance but is deemed acceptable consistent with endorsed NRC EP FAQ 2015-014.

NEI Ex. MPS2 Difference/Deviation Justification NEI Example EAL Wording MPS2 EAL Wording EAL# EAL#

1 a. An event has resulted in plant HS6.1 An event has resulted in plant control The Hot Shutdown Panel (C-21) or Fire Shutdown Panel control being transferred from the being transterred from the Control Room (C-10) are the site-specific remote shutdown panels and Control Room to (site-specific to the Hot Shutdown Panel (C-21) or Fire local control stations.

remote shutdown panels and local Shutdown Panel (C-10)

Added the words " ... of the last licensed operator leaving control stations).

AND the Control Room" to provide criteria for when the 15 AND minutes control clock begins.

Control of any of the following key safety

b. Control of ANY of the functions is not re-established within 15 The Mode applicability for the reactivity control safety following key s~fety functions is min. of the last licensed operator leaving function has been limited to Modes 1, 2, and 3. In Modes 4, not reestablished within (site- the Control Room (Note 1): 5 and 6, adequate shutdown margin exists un~er all specific number of minutes).

Reactivity (Modes 1, 2 and 3 conditions.

only)

Reactivity control

Core Cooling This revised mode applicability is a deviation from the

Core cooling [PWR] I RPV

RCS heat *removal NEI 99-01, Revision 6 HS6 generic guidance but is water level [BWR]

deemed acceptable consistent with endorsed NRC EP

RCS heat removal FAQ 2015-014 .

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HS7 Other conditions exist which in HS? Other conditions existing that in the None the judgment of the Emergency judgment of the DSEO/ADTS warrant Director warrant declaration of a declaration of a Site Area Emergency Site Area Emergency. MODE: All MODE: All NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Other conditions exist which in HS7.1 Other conditions exist which in the None the judgment of the Emergency judgment of the DSEO/ADTS'indicate Director indicate that events are that events are in progress or have in progress or have occurred occurred which involve actual or likely which involve actual or likely major failures of plant functions needed major failures of plant functions for protection of the public or HOSTILE needed for protection of the ACTION that results in intentional damage public or HOSTILE ACTION that or malicious acts, (1) toward site results in intentional damage or personnel or equipment that could lead to malicious acts, (1) toward site the likely failure of or, (2) that prevent personnel or equipment that could effective access to equipment needed for lead to the likely failure of or, (2) the protection of the public. Any releases that prevent effective access to are not expected to result in exposure equipment needed for the levels which exceed EPA Protective protection of the public. Any Action Guideline exposure levels beyond releases are not expected to the SITE BOUNDARY.

result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

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HG1 HOSTILE ACTION resulting in N/A N/A IC HG1 and associated example EAL are not implemented in loss of physical control of the the MPS2 scheme.

facility.

There are several other ICs that are redundant with this IC, MODE: All and are better suited to ensure timely and effective emergency declarations. In addition, the development of new spent fuel pool level EALs, as a result of NRC Order EA 051, clarified the intended emergency classification level for spent fuel pool level events.

This exclusion of the generic HG1 guidance is a deviation from the NEI 99-01, Revision generic guidance but is deemed acceptable consistent with endorsed NRC EP FAQ 2015-013.

NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 a. A HOSTILE ACTION is N/A N/A IC HG1 and associated example EAL is not implemented in occurring or has occurred within the MPS2 scheme.

the PROTECTED AREA as There are several other ICs that are redundant with this IC, reported by the (site-specific and are better suited to ensure timely and effective security shift supervision).

emergency declarations. In addition, the development of new AND spent fuel pool level EALs, as a result of NRC Order EA 051, clarified the intended emergency classification level for

b. EITHER of the following has spent fuel pool level events. This deviation is justified occurred: because:

1. ANY of the following safety 1. Hostile Action in the Protected Area is bounded by ICs functions cannot be HS1 and HS7. Hostile Action resultina in a loss of ohvsical

r ,*

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Reactivity control Environmental Protection Agency (EPA) Protective Action

Core cooling [PWR]/RPV Guides (PAGs).

water level [BWR]

a. If, for whatever reason, the Control Room must be

RCS heat removal evacuated, and control of safety functions (e.g.,

reactivity control, core cooling, and RCS heat OR removal) cannot be reestablished, then IC HS6 would Damage to spent fuel has apply, as well as IC HS7 if desired by the EAL occurred or is IMMINENT. decision-maker.

b. Also, as stated above, any event (including Hostile Action) that could reasonably be expected to have a release exceeding EPA PAGs would be bound by IC HG7.

c. From a Hostile Action perspective, ICs HS1, HS7 and HG7 are appropriate, and therefore, make this part of HG1 redundant and unnecessary.

d. From a loss of physical control perspective, ICs HS6, HS7 and HG7 are appropriate, and therefore, make this part of HG1 redundant and unnecessary.

2. Any event which causes a loss of spent fuel pool level will be bounded by ICs AA2, AS2 and AG2, regardless of whether it was based upon a Hostile Action or not, thus making this part of HG1 redundant and unnecessary.

a. An event that leads to a radiological release will be bounded by ICs AU 1, AA 1, AS 1 and AG 1. Events that lead to radiological releases in excess of EPA PAGs will be bounded by EALs AG1 and HG7, thus making this part of HG1 redundant and unnecessary.

ICs AA2, AS2, AG2, AS1, AG1, HS1, HS6, HS7 and HG7 have been implemented consistent with NEI 99-01 Revision

Serial No.18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 96 of 126 Table 4 - MPS2 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety 6 and thus HG1 is adequately bounded as described above.

This exclusion of the generic HG1 guidance is a deviation from the NEI 99-01, Revision 6 generic guidance but is deemed acceptable consistent with endorsed NRC EP FAQ 2015-013.

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HG7 Other conditions exist which in HG7 Other conditions exist which in the None the judgment of the Emergency judgment of the DSEO/ADTS warrant Director warrant declaration of a declaration of a General Emergency General Emergency MODE: All MODE:AII NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Other conditions exist which in HG7.1 Other conditions exist which in the None the judgment of the Emergency judgment of the DSEO/ADTS indicate Director indicate that events are that events are in progress or have in progress or have occurred occurred which involve actual or which involve actual or IMMINENT substantial core degradation IMMINENT substantial core or melting with potential for loss of degradation or melting with containment integrity or HOSTILE potential for loss of containment ACTION that results in an actual loss of integrity or HOSTILE ACTION physical control of the facility. Releases that results in an actual loss of can be reasonably expected to exceed physical control of the facility. EPA Protective Action Guideline Releases can be reasonably exposure levels offsite for more than the expected to exceed EPA immediate site area.

Protective Action Guideline exposure levels offsite for more than the immediate site area.

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SU1 Loss of all offsite AC power MU1 Loss of all offsite AC power None capability to emergency buses for capability to emergency buses for 15 minutes or longer. 15 minutes or longer MODE: Power Operation, Startup, MODE: 1 - Power Operation, 2 -

Hot Standby, Hot Shutdown Startup, 3 - Hot Standby, 4 - Hot Shutdown NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 Loss of ALL offsite AC power MU1.1 Loss of all offsite AC power 4.16 kV emergency buses 24C and 24D are the site-specific capability to (site-specific capability, Table M-1, to 4.16 kV emergency buses.

emergency buses) for 15 minutes emergency buses 24C and 24D Table M-1 lists credited offsite 4.16 kV emergency bus AC power or longer. for;;: 15 min. (Note 1) sources.

Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the declare the Unusual Event declare the event MPS2 EAL scheme by referencing the "time limit" specified within the promptly upon determining that 15 promptly upon EAL wording.

minutes has been exceeded, or determining that the time will likely be exceeded. limit has been exceeded, or will likely be exceeded.

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Unit 2 Reserve Station Service Transformer (RSST)

Unit 2 Normal Station Service Transformer (NSST)

Unit 3 Normal Station Service Transformer (NSST) via Buses 34A/B to Unit 2 emergency bus 24E (if already aligned)

Unit 3 Reserve Station Service Transformer (RSST) via Buses 34A/B to Unit 2 emergency bus 24E (if already aligned)

Onsite

Diesel Generator 15G-12U

Diesel Generator 15G-13U

880 Diesel Generator (if already aligned)

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SU2 UNPLANNED loss of Control MU3 UNPLANNED loss of Control None Room indications for 15 minutes Room indications for 15 minutes or longer. or longer.

MODE: Power Operation, MODE: 1 - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 An UNPLANNED event results in MU3.1 An UNPLANNED event results in The site-specific Safety System Parameter list is tabulated in Table the inability to monitor one or the inability to monitor one or M-2.

more of the following parameters more Table M-2 parameters from from within the Control Room for within ttie Control Room for~ 15 15 minutes or longer. min. (Note 1)

Note The Emergency Director should NIA Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the declare the Unusual Event declare the event MPS2 EAL scheme by referencing the "time limit" specified within promptly upon determining that promptly upon the EAL wording.

15 minutes has been exceeded, determining that the time or will likely be exceeded. limit has been exceeded, or will likely be exceeded.

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[BWR parameter lisfj [PWR parameter lisfj Reactor Power Reactor Power RPV Water Level RCS Level RPV Pressure RCS Pressure Primarv Containment Pressure In-Core/Core Exit Temperature Suppression Pool Level Levels in at least (site-specific number) steam aenerators Suppression Pool Temperature Steam Generator Auxiliary or Emergency Feed Water Flow Table M-2 Safety System Parameters

Reactor power

RCS level

RCS pressure

CET temperature

Level in at least one SG

Auxiliary feedwater flow to at least one SG

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SU3 Reactor coolant activity greater MU4 Reactor coolant activity greater None than Technical Specification than Technical Specification allowable limits. allowable limits MODE: Power Operation, Startup, MODE: 1 - Power Operation, 2 -

Hot Standby, Hot Shutdown Startup, 3 - Hot Standby, 4 - Hot Shutdown NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 (Site-specific radiation monitor) MU4.1 Dose rate at 1 ft. from an Per Engineering Calculation RA-0059, dose rate is assumed to reading greater than (site-specific unpressurized RCS sample result from radioactive iodines (l-131 thru 1-135) in RCS in value). .:: Table M-4 cqncentrations corresponding to 60 µCi/gm DEl-131. This value corresponds to the Technical Specification coolant activity limit for iodine spike at full power operations. The values contained in Table M-4 (Tech. Spec. Coolant Activity Dose Rates) represent expected one foot dose rates per ml of sample based on time since reactor shutdown to the time when the sample is taken.

2 Sample analysis indicates that a MU4.2 Sample analysis indicates that a MPS2 Technical Specification 3.4.8, RCS Specific Activity provides reactor coolant activity value is reactor coolant activity value is > the Technical Specification allowable coolant activity limits.

greater than an allowable limit an allowable limit specified in specified in Technical Technical Specification 3.4.8 Specifications.

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>2-SB 0.5

>8 0.3

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SU4 RCS leakage for 15 minutes or MUS RCS leakage for 15 minutes or None longer. longer MODE: Power Operation, MODE: 1 - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 RCS unidentified or pressure MU5.1 RCS unidentified or pressure Example EALs #1 , 2 and 3 have been combined into a single EAL for boundary leakage greater than boundary leakage > 1O gpm for usability.

(site-specific value) for 15 ;:: 15 min.

minutes or longer. OR 2 RCS identified leakage greater RCS identified leakage > 25 gprh than (site-specific value) for 15 for;:: 15 min.

minutes or longer.

OR Leakage from the RCS to a Leakage from the RCS to a 3 location outside containment location outside containment greater than 25 gpm for 15 > 25 gpm for;:: 15 min.

minutes or longer.

(Note 1)

Note The Emergency Director should N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the declare the Unusual Event should declare the event MPS2 EAL scheme by referencing the "time limit" specified within the promptly upon determining that promptly upon EAL wording.

15 minutes has been exceeded, determining that the or will likely be exceeded. time limit has been exceeded, or will likely be exceeded.

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Included Startup mode applicability because the Startup mode is SUS Automatic or manual (trip MU6 Automatic or manual trip fails to

[PWR] / scram [BWR]) fails to shut down the reactor defined as reactor power ~ 5%.

shutdown the reactor. MODE: 1 - Power Operation, 2 -

MODE: Power Operation Startup NEI Ex. MPS2 Difference/Deviation Justification NEI Example EAL Wording MPS2 EAL Wording EAL# EAL#

1 a. An automatic (trip [PWR] / MU6.1 An automatic trip did not shut As specified in the generic developers guidance "Developers may scram [BWR]) did not shutdown down the reactor as indicated by include site-specific EOP criteria indicative of a successful reactor the reactor. reactivity control Safety Function shutdown in an EAL statement, the Basis or both (e.g., a reactor Status Check acceptance criteria power level)." Consistent with the GEOG Emergency Procedure AND not met after any RPS setpoint is Guidelines, a successful shutdown is defined by Safety Function

b. A subsequent manual exceeded Status Check acceptance criteria being met.

action taken at the reactor AND Added the words" ... after any RPS setpoint is exceeded" to clarify control consoles is successful in that it is a failure of the automatic trip when a valid trip signal has shutting down the reactor. A subsequent automatic trip or EITHER manual trip (RX TRIP been exceeded.

TCBS BUTTONS OR MG Set Added the words "A subsequent automatic trip ... " to the second Output Breakers (80505 and condition consistent with Example EAL #2 and the generic bases B0608 are successful in shutting which states "This IC addresses a failure of the RPS to initiate or down the reactor as indicated by complete an automatic or manual trip that results in reactor reactivity control Safety Function shutdown, and either a subsequent operator manual action ... or Status Check acceptance criteria automatic trip is successful. .. " met (Note 8). Added the word "EITHER" to the second condition associated with subsequent manual trip actions. MPS2 has two means (manual trip pushbuttons or MG Set Output Breakers) of initiating a manual trip from the reactor control consoles.

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 106 of 126 Table 4 - MPS2 Comparison Matrix Category S: System Malfunction 2 a. A manual trip ([PWR] / MU6.2 A manual trip (RX TRIP TCBS As specified in the generic developers guidance "Developers may scram [BWR]) did not shutdown BUTTONS OR MG Set Output include site-specific EOP criteria indicative of a successful reactor the reactor. Breakers (80505 and B0608)) did shutdown in an EAL statement, the Basis or both (e.g., a reactor not shut down the reactor as power level)." Consistent with the GEOG Emergency Procedure AND indicated by reactivity control Guidelines, a successful shutdown is defined by Safety Function

b. EITHER of the following: Safety Function Status Check Status Check acceptance criteria being met.

acceptance criteria not met

1. A subsequent manual Manual trip pushbuttons OR MG Set Output Breakers are the means action taken at the AND of initiating a manual trip from the reactor control consoles.

reactor control consoles A subsequent manual trip OR is successful in shutting automatic trip is successful in down the reactor. shutting down the reactor as OR indicated by reactivity control Safety Function Status Check 2 A subsequent automatic acceptance criteria met (Note 8) (trip [PWR] / scram [BWR]) is successful in shutting down the reactor. Notes Note: A manual action is any N/A Note 8: A manual action is any None operator action, or set of operator action, or set of actions, which causes the actions, which causes the control rods to be rapidly control rods to be rapidly inserted into the core, and does inserted into the core, not include manually driving in and does not include control rods or implementation manually driving in of boron injection strategies. control rods or implementation of boron injection strategies.

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1 B Page 107 of 126 Table 4 - MPS2 Comparison Matrix Category S: System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s) i SU6 Loss of all onsite or offsite MU7 Loss of all onsite or offsite None communications capabilities. communications capabilities. MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Loss of ALL of the following MU7.1 Loss of all Table M-5 onsite Example EALs #1, 2 and 3 have been combined into a single EAL onsite communication methods: communication methods for simplification of presentation. (site-specific list of OR Table M-5 provides a site-specific list of onsite, offsite (ORO) and communications methods) NRC communications methods. Loss of all Table M-5 offsite 2 Loss of ALL of the following communication methods ORO communications methods: OR (site-specific list of Loss of all Table M-5 NRC communications methods) communication methods 3 Loss of ALL of the following NRC communications methods: (site-specific list of communications methods)

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 108 of 126 Table M-5 Communication Methods State/ System Onsite NRC Local ENRS/ARCOS X Station Radio System X X Plant Phone System X X Public Address System X Gaitronics / Maintenance Jacks X Federal Telephone System (ENS) X Commercial Telephone System X X Satellite Phones X X Dedicated Hotlines X

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 109 of 126 Table 4- MPS2 Comparison Matrix Category S: System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s) SU? Failure to isolate containment or MUS Failure to isolate containment or None loss of containment pressure loss of containment pressure control. [PWR] control MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL# 1 a. Failure of containment to MUB.1 Any penetration is not closed Example EAL~ #1 and #2 have been combined for usability. isolate when required by an within 15 min. of a VALID CIAS Containment isolation actuation is initiated by the Containment actuation signal. actuation signal Isolation Actuation Signal (CIAS). AND OR Containment pressure greater than 9.48 psig (rounded to 10 psig

b. ALL required penetrations CTMT pressure> 10 psig with for readability) is the pressure at which containment energy (heat) are not closed within 15 minutes < one full train of CTMT heat removal systems are designed to automatically actuate.

of the actuation signal. removal systems (Note 11) operating per design for ;:: 15 min. (Note 1) 2 a. Containment pressure greater than (site-specific pressure). AND

b. Less than one full train of

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 110 of 126 Table 4 - MPS2 Comparison Matrix Category S: System Malfunction (site-specific system or equipment) is operating per design for 15 minutes or longer. N/A N/A Note 1: The DSEO/ADTS N/A Added note 1 consistent with other EALs with a timing component. should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. N/A N/A Note 11: One full train of N/A Added note 11 to clarify what constitutes a full train of containment containment heat heat removal systems. removal systems consist of one Containment Spray pump and two containment air recirculation units in the Containment Air Recirculation and Cooling System Spray train in service

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 111 of 126 Table 4 - MPS2 Comparison Matrix Category S: System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s) SA1 Loss of all but one AC power MA1 Loss of all but one AC power None source to emergency buses for source to emergency buses for 15 minutes or longer. 15 minutes or longer MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS2 NEI Example EAL Wording

MPS2 EAL Wording Difference/Deviation Justification EAL# EAL#

1 a. AC power capability to (site- MA1.1 AC power capability, Table M-1, 4.16 kV emergency buses 24C and 24D are the site-specific specific emergency buses) is to 4.16 kV emergency buses 24C emergency buses. reduced to a single power source and 24D reduced to a single Table M-1 lists credited offsite and onsite 4.16 kV emergency bus for 15 minutes or longer. power source for ~ 15 min. AC power sources. (Note 1) AND AND

b. Any additional single power source failure will result in a loss Any additional single power of all AC power to SAFETY source failure will result in loss of SYSTEMS. all AC power to SAFETY SYSTEMS Note The Emergency Director should NIA Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the declare the Alert promptly upon declare the event MPS2 EAL scheme by referencing the "time limit" specified within determining that 15 minutes has promptly upon the EAL wording.

been exceeded, or will likely be determining that the time exceeded. limit has been exceeded, or will likely be exceeded.

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 112 of 126 Table 4 - MPS2 Comparison Matrix Category S: System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s) SA2 UNPLANNED loss of Control MA3 UNPLANNED loss of Control None Room indications for 15 minutes Room indications for 15 minutes or longer with a significant or longer with a significant transient in progress. transient in progress. MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL# 1 An UNPLANNED event results MA3.1 An UNPLANNED event results in The site-specific Safety System Parameter list is in Table M-2. in the inability to monitor one or the inability to monitor one or more Table M-2 parameters from The significant transient list has been tabularized in Table M-3 for more of the following parameters within the Control Room for ~ 15 ease of use. from within the Control Room for 15 minutes or longer. min. (Note 1) Deleted "Automatic turbine runback > 25% thermal reactor power AND, from the transient list. MPS2 does not have runbacks. AND ANY of the following transient Any significant transient is in events in progress. progress, Table M-3

Automatic or manual runback greater than 25%

thermal reactor power

Electrical load rejection greater than 25% full electrical load
Reactor scram rBWR] I trio

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 113 of 126 [PWR]

ECCS (SI) actuation
Thermal power oscillations greater than 10% [BWR]

Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the declare the Unusual Event declare the event MPS2 EAL scheme by referencing the "time limit" specified within promptly upon determining that promptly upon the EAL wording. 15 minutes has been exceeded, determining that the time or will likely be exceeded. limit has been exceeded, or will likely be exceeded. fBWR parameter list] fPWR parameter list] Reactor Power Reactor Power RPV Water Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In-Core/Core Exit Temperature Suooression Pool Level Levels in at least (site-specific number) steam aenerators Suooression Pool Temperature Steam Generator Auxiliary or Emeri:iencv Feed Water Flow Table M-2 Safety System Parameters

Reactor power
RCS level
RCS pressure
GET temperature
Level in at least one SG
Auxiliary feedwater flow to at least one SG

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 114 of 126 Table M-3 Significant Transients

Electrical load rejection > 25% full electrical load
Reactor Trip
SIAS actuation

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 115 of 126 Table 4 - MPS2 Comparison Matrix Category S: System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s) SAS Automatic or man_ual (trip [PWR] MA6 Automatic or manual trip fails to Included Startup mode applicability because the Startup mode is I scram [BWR]) fails to shutdown shut down the reactor and defined as reactor power ::;;; 5%. the reactor, and subsequent subsequent manual actions manual actions taken at the taken at the reactor control reactor control consoles are not consoles are not successful in successful in shutting down the shutting down the reactor reactor. MODE: 1 - Power Operation, 2 - MODE: Power Operation Startup NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL# 1 a. An automatic or manual (trip MA6.1 An automatic or manual trip (RX As specified in the generic developers guidance "Developers may [PWR] I scram [BWR]) did TRIP TCBS BUTTONS OR MG include site-specific EOP criteria indicative of a successful reactor not shutdown the reactor.

Set Output Breakers (80505 and shutdown in an EAL statement, the Basis or both (e.g., a reactor 80608)) did not shut down the power level)." Consistent with the GEOG Emergency Procedure AND reactor as indicated by reactivity Guidelines, a successful shutdown is defined by Safety Function

b. Manual actions taken at the control Safety Function Status Status Check acceptance criteria being met.

reactor control consoles are Check acceptancl? criteria not met MPS2 has two means (RX TRIP TCBS BUTTONS or MG Set Output not successful in shutting Breakers (80505 and 80608)) of initiating a manual trip from the down the reactor. AND reactor control consoles. Subsequent automatic or manual trip actions (RX TRIP TCBS BUTTONS AND MG Set Output Breakers (80505 and 80608)) are not successful in shutting down the reactor as indicated by reactivity control Safety Function

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 116 of 126 Table 4 - MPS2 Comparison Matrix Category S: System Malfunction Status Check acceptance criteria not met (Note 8) Notes Note: A manual action is any N/A Note 8: A manual trip action is None operator action, or set of actions, any operator action, or which causes the control rods to set of actions, which be rapidly inserted into the core, causes the control rods and does not include manually to be rapidly inserted driving in control rods or into the core, and does implementation of boron injection not include manually strategies. driving in control rods or implementation of boron injection strategies

Serial No. 18-364 MPS2 - EAL Comparison Matrix DocLJment Docket No. 50-336 Enclosure 3; Attachment 1B Page 117 of 126 Table 4 - MPS2 Comparison Matrix Category S: System Malfunction MPS2 Difference/Deviation Justification NEI IC# NEI IC Wording MPS2 IC Wording IC#(s) SA9 Hazardous event affecting a MA9.1 Hazardous event affecting Revised wording from " ... affecting a SAFETY SYSTEM ... " to read SAFETY SYSTEM needed for SAFETY SYSTEMS needed for II

                                                                                       ... affecting SAFETY SYSTEMS ... " to align with changes made the current operating mode.             the current operating mode        consistent with NRC EP FAQ 2016-002.

MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS2 Difference/Deviation Justification NEI Example EAL Wording MPS2 EAL Wording EAL# EAL# 1 a. The occurrence of ANY of MA8.1 The occurrence of any Table The hazardous events have been tabularized in Table M-6. the following hazardous M-6 hazardous event The proposed MPS2 CA6.1 and MA9.1 wording is intended to ensure events: that an Alert should be declared only when actual or potential AND

Seismic event (earthquake) performance issues with SAFETY SYSTEMS have occurred as a
Internal or external flooding Event damage has caused result of a hazardous event. The occurrence of certain hazardous event indications of degraded events may result in an Unusual Event classification at a minimum. In
High winds or tornado strike performance on one train of a order to warrant escalation to the Alert classification, the hazardous
FIRE SAFETY SYSTEM needed for event should cause indications of degraded performance to one train
EXPLOSION the current operating mode of a SAFETY SYSTEM with either indications of degraded

           * (site-specific hazards)                                                 performance on the second SAFETY SYSTEM train or VISIBLE AND EITHER:

Other events with similar DAMAGE to the second SAFETY SYSTEM train, such that the hazard characteristics as
Event damage has caused operability or reliability of the second train is a concern. In addition, determined by the Shift indications of degraded escalation to the Alert classification should not occur if the damage Manager performance to the second from the hazardous event is limited to a SAFETY SYSTEM that was train of the SAFETY inoperable, or out of service, prior to the event occurring. As such, the AND SYSTEM needed for the proposed EALs will reduce the potential of declaring an Alert when

b. EITHER of the following: current operating mode events are in progress that do not involve an actual or potential

1. Event damage has

Event damage has substantial degradation of the level of safety of the plant, i.e., does not

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 118 of 126 Table 4 - MPS2 Comparison Matrix Category S: System Malfunction caused indications of resulted in VISIBLE cause significant concern with shutting down or cooling down the degraded performance in DAMAGE to the second plant. at least one train of a train of the SAFETY EALs GA6.1 and MA9.1 do not directly escalate to a Site Area SAFETY SYSTEM SYSTEM needed for the Emergency or a General Emergency due to a hazardous event. The needed for the current current operating mode Fission Product Barrier and/or Abnormal Radiation operating mode. Levels/Radiological Effluent recognition categories would provide an (Notes 9, 10) OR escalation path to a Site Area Emergency or a General Emergency. The EALs and the Basis sections have been revised to ensure

2. The event has caused potential escalations from an Unusual Event to an Alert, due to a VISIBLE DAMAGE to a hazardous event, is appropriate as the concern with these EALs is: (1)

SAFETY SYSTEM a hazardous event has occurred, (2) one SAFETY SYSTEM train is component or structure having performance issues as a result of the hazardous event, and (3) needed for the current either the second SAFETY SYSTEM train is having performance operating mode. issues or the VISIBLE DAMAGE is enough to be concerned that the second SAFETY SYSTEM train may have operability or reliability issues. The definition for VISIBLE DAMAGE has been revised to reflect the fact that the EALs are based upon SAFETY SYSTEM trains rather than individual components or structures. Note 9 has been added to GA6.1 and MA9.1 as it meets the intent of the EALs, is consistent with other EALs (e.g., EAL HA5.1 which was previously endorsed by the NRG), and ensures that declared emergencies are based upon unplanned events with the potential to pose a radiological risk to the public. Note 10 has been added to GA6.1 and MA9.1 to help reinforce and succinctly capture the more detailed information from the revised basis section related to when conditions would require the declaration of an Alert. GA6.1 and MA9.1 are consistent with NRG FAQ 2016-002 requiring degraded performance or visible damage to more than one safety system train caused by the specified events. This revised wordin~ is a deviation from the NEI 99-01, Revision

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 119 of 126 Table 4 - MPS2 Comparison Matrix Category S: System Malfunction 6 CA6 and SA9 generic wording and bases but is deemed acceptable consistent with endorsed NRC EP FAQ 2016-002. N/A N/A Note 9: If the affected SAFETY Added Note 9 consistent with the recommendation of NRG EP FAQ N/A SYSTEM train was 2016-002. already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted. Note 10: If the hazardous event Added Note 10 consistent with the recommendation of NRG EP FAQ only resulted in 2016-002. VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 120 of 126 Table M-6 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 DSEO/ADTS

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 121 of 126 Table 4 - MPS2 Comparison Matrix Category S: System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s) SS1 Loss of all offsite and all onsite MS1 Loss of all offsite power and all None AC power to emergency buses onsite AC power to emergency for 15 minutes or longer. buses for 15 minutes or longer MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Loss of ALL offsite and ALL MS1.1 Loss of all offsite and all onsite 4.16 kV emergency buses 24C and 240 are the site-specific onsite AC power to (site-specific AC power to 4.16 kV emergency buses. emergency buses) for 15 minutes emergency buses 24C and 240 or longer. for 2: 15 min. (Note 1) Note The Emergency Director should N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the declare the Unusual Event should declare the MPS2 EAL scheme by referencing the "time limit" specified within promptly upon determining that event promptly upon the EAL wording. 15 minutes has been exceeded, determining that the or will likely be exceeded. time limit has been exceeded, or will likely be exceeded.

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 122 of 126 Table 4- MPS2 Comparison Matrix Category S: System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s) SS5 Inability to shutdown the reactor MS6 Inability to shut down the Included Startup mode applicability because the Startup mode is causing a challenge to (core reactor causing a challenge to defined as reactor power :S 5%. cooling [PWR] I RPV water level core cooling or RCS heat [BWR]) or RCS heat removal. removal MODE: Power Operation MODE: 1 - Power Operation, 2 - Startup NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL# 1 a. An automatic or manual (trip MS6.1 An automatic or manual trip did As specified in the generic developers guidance "Developers may [PWR] / scram [BWR]) did not shut down the reactor as include site-specific EOP criteria indicative of a successful reactor not shutdown the reactor. indicated by reactivity control shutdown in an EAL statement, the Basis or both (e.g., a reactor AND Safety Function Status Check power level)." Consistent with the GEOG Emergency Procedure

b. All manual actions to acceptance criteria not met Guidelines, a successful shutdown is defined by Safety Function shutdown the reactor have AND Status Check acceptance criteria being met.

been unsuccessful. All actions taken to shut down Added the word "taken" to the second condition to emphasize the AND the reactor are not successful as intent that it's all actions taken up to the point of either core cooling C. EITHER of the following indicated by reactivity control or heat sink is challenged are not successful and to not wait until all conditions exist: Safety Function Status Check possible actions have been completed.

              * (Site-specific indication of         acceptance criteria not met CETs >1200°F is the site-specific indication of inadequate core an inability to adequately             AND EITHER:                    cooling' remove heat from the

CETs >1200°F Applicable RCS and Core Heat Removal (HR) Safety Function core)
Applicable RCS and Core Status Check acceptance criteria not met is the site-specific

              * (Site-specific indication of                 Heat Removal (HR) an inability to adequately                                            indicatio.n of inadequate heat sink.

Safety Function Status remove heat from the Check acceptance criteria RCS) not met

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 123 of 126 Table 4 - MPS2 Comparison Matrix Category S: System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s) SSB Loss of all Vital DC power for 15 MS2 Loss of all vital DC power for 15 None minutes or longer. minutes or longer. MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Indicated voltage is less than MS2.1 Indicated voltage is < 105 VDC 105 VDC is the site-specific minimum vital 125V DC bus voltage. (site-specific bus voltage value) on both vital 125 voe buses 201A and 201 Bare the site-specific vital DC buses. on ALL (site-specific Vital DC 201A AND 2018 for~ 15 min. busses) for 15 minutes or longer. (Note 1) Note The Emergency Director should N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the declare the Unusual Event should declare the MPS2 EAL scheme by referencing the "time limit" specified within the promptly upon determining that event promptly upon EAL wording. 15 minutes has been exceeded, determining that the or will likely be exceeded. time limit has been exceeded, or will likely be exceeded.

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 124 of 126 Table 4 - MPS2 Comparison Matrix Category S: System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s) SG1 Prolonged loss of all offsite and MG1 Prolonged loss of all offsite and None all onsite AC power to all onsite AC power to emergency buses. emergency buses MODE: Power Operation, MODE: 1 - Power Operation, Startup, Hot Standby, Hot 2 - Startup, 3 - Hot Shutdown Sh.utdown NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL# 1 a. Loss of ALL offsite and ALL MG1.1 Loss of all offsite and all onsite 4.16 kV emergency buses 24C and 240 are the site-specific onsite AC power to (site- AC power to 4.16 kV emergency emergency buses. specific emergency buses). buses 24C and 240 CETs > 1200°F is the site-specific indication of an inability to AND AND adequately remove heat from the core.

b. EITHER of the following: CETs > 1200°F The proposed MPS2 MG1 .1 omits the Station Blackout (SBO) coping time threshold. As proposed, the General Emergency

Restoration of at least classification would be based a loss of all onsite and offsite AC one AC emergency bus power to the emergency buses with indications of degraded core in less than (site-specific cooling. The MPS2 SBO analysis and derived coping time was hours) is not likely. determined in accordance with 10CFR50.63 and Regulatory Guide 1.155. This analysis does not take credit for plant capabilities in

               *   (Site-specific indication of place to mitigate the effects of an extended loss of AC power an inability to adequately (ELAP). These capabilities were developed and implemented to remove heat from the meet the requirements of NRG Orders EA-12-049 and EA-12-051, core) and pending regulations in 10 CFR 50.155 (per SECY-16-0142).

In accordance with plant EOPs, operators will declare an ELAP within 45 min. of the loss of all AC power to the emergency buses

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 125 of 126 Table 4..:.. MPS2 Comparison Matrix Category S:. System Malfunction and direct implementati9n of FLEX Support Guidelines, including the deployment of dedicated portable equipment and performance of DC load shedding. Even if no AC emergency bus is energized, these actions will maintain or restore core cooling, containment, and spent fuel pool cooling capabilities indefinitely. Therefore, the underlying basis for the generic EAL coping time statement, that power must be restored to an AC emergency bus within a fixed amount of time to avoid a severe challenge to one or more fission product barriers, is not valid for MPS2. This revised wording is a deviation from the NEI 99-01, Revision 6 SG1 generic wording and bases but is deemed appropriate and acceptable. -- Note The Emergency Director should N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the declare the General Emergency should decl~re the MPS2 EAL scheme by referencing the "time limit" specified within promptly upon determining that event promptly upon the EAL wording. (site-specific hours) has been determining that the exceeded, or will likely be time limit has been exceeded. exceeded, or will likely be exceeded.

Serial No. 18-364 MPS2 - EAL Comparison Matrix Document Docket No. 50-336 Enclosure 3; Attachment 1B Page 126 of 126 Table 4 - MPS2 Comparison Matrix Category S: System Malfunction MPS2 NEI IC# NEI IC Wording MPS2 IC Wording Difference/Deviation Justification IC#(s) SGS Loss of all AC and Vital DC MG2 Loss of all emergency AC and None power sources for 15 minutes or vital DC power sources for 15 longer. minutes or longer MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS2 NEI Example EAL Wording MPS2 EAL Wording Difference/Deviation Justification EAL# EAL# 1 a. Loss of ALL offsite and ALL MG2.1 Loss of all offsite and all onsite 4.16 kV emergency buses 24C and 240 are the site-specific onsite AC power to (site- AC power to 4.16 kV emergency buses. specific emergency buses) for emergency buses 24C and 240 105 VDC is the site-specific minimum vital 125V DC bus voltage. 15 minutes or longer. for;.:; 15 min. (Note 1) 201 A and 201 8 are the site-specific vital DC buses. AND AND

b. Indicated voltage is less than Indicated voltage is < 105 voe (site-specific bus voltage on both vital 125 voe buses value) on ALL (site-specific 201A AND 2018 for Vital DC busses) for 15 ;.:; 15 min. (Note 1) minutes or longer.

Note The Emergency Director should N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the declare the Unusual Event should declare the MPS2 EAL scheme by referencing the "time limit" specified within promptly upon determining that 15 event promptly upon the EAL wording. minutes has been exceeded, or determining that the will likely be exceeded. time limit has been exceeded, or will likely be exceeded.

Serial No.: 18-364 Docket No.: 50-423; 72-47 Enclosure 3 ATTACHMENT 1C MPS3 EAL COMPARISON MATRIX DOCUMENT Dominion Energy Nuclear Connecticut, Inc. (DENC) Millstone Power Station Unit 3 and ISFSI

Serial No. 18-364

Docket No. 50-423 Enclosure 3, Attachment 1C Page 1 of 123 Millstone Power Station Unit 3 NEI 99-01, Revision 6 EAL Comparison Matrix Document

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 2 of 123 Table of Contents Section Introduction .................................................................................................................................................... 3 Comparison Matrix Format ............................................................................................................................ 3 EAL Wording ............................................. :................................................................................................... 3 EAL Emphasis Techniques ........................................................................................................................... 3 Global Differences ......................................................................................................................................... 4 Differences and Deviations ........................................................................................................................... 5 Table 1 - MPS3 EAL Categories/Subcategories .......................................................................................... 7 Table 2 - NEI / MPS3 EAL Identification Cross-Reference .......................................................................... 8 Table 3 - Summary of Deviations ............................................................................................................... 13 Table 4 - MPS3 Comparison Matrix ........................................................................................................... 18 Category A - Abnormal Rad Levels / Rad Effluents ................................................................................... 18 Category C - Cold Shutdown / Refueling System Malfunction ................................................................... 38 Category D - Permanently Defueled Station Malfunction ........................................................................... 60 Category E - Events Related to Independent Speht Fuel Storage Installations ........................................ 61 Category F - Fission Product Barrier Degradation ..................................................................................... 62 Category H - Hazards and Other Conditions Affecting Plant Safety .......................................................... 75 Category S - System Malfunction ............................................................................................................... 95

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 3 of 123 Introduction terminology, etc. Meeting this goal will result in a shorter and less cumbersome NRC review and approval process, closer alignment with the A comparison of the Initiating Conditions (ICs), Mode Applicability and schemes of other nuclear power plant sites and better positioning to adopt Emergency Action Levels (EALs) in NEI 99-01 Rev. 6 Final, Development of future industry-wide scheme enhancements" Emergency Action Levels for Non-Passive Reactors, (ADAMS Accession No. ML12326A805) and Millstone Power Station Unit 3 (MPS3) ICs, MODE To assist the Director of Station Emergency Operations (DSEO)/Assistant Applicability and EALs are provided in this document. The results of the Director Technical Support (ADTS), the MPS3 EALs have been written in a comparison are provided in Table 4, MPS3 Comparison Matrix. This clear and concise style (to the extent that the differences from the NEI EAL document provides a means of assessing MPS3 differences and deviations wording could be reasonably documented and justified). This supports timely from the NRC endorsed guidance given in NEI 99-01. Discussion of MPS3 and accurate classification in the tense atmosphere of an emergency event. EAL bases and lists of source document references are given in the EAL The EAL differences introduced to reduce reading burden comprise almost Technical Bases Document. It is, therefore, advisable to reference the EAL all of the differences justified in this document. Technical Bases Document for background information while using this document. EAL Emphasis Techniques Due to the width of the table columns and table formatting constraints in this Comparison Matrix Format document, line breaks and indentation may differ slightly from the appearance of comparable wording in the source documents. NEI 99-01 The ICs and EALs discussed in the MPS3 Comparison Matrix are grouped Rev. 6 is the source document for the NEI EALs; the MPS3 EAL Technical according to NEI 99-01 Recognition Category and presented alphabetically Bases Document is the source document for the MPS3 EALs. by group. Within each Recognition Category group, the ICs and EALs are listed in tabular format according to the order in which they are given in NEI Development of the MPS3 IC/EAL wording has attempted to minimize 99-01, Rev. 6. Generally, each row of the comparison matrix provides the inconsistencies and apply sound human factors principles. As a result, following information: differences occur between NEI and MPS3 ICs/EALs for these reasons alone. When such difference may infer a technical difference in the associated NEI

NEI IC/Ex. EAL identifier IC/EAL, the difference is identified and a justification is provided.
NEI IC/Example EAL wording and mode applicability The print and paragraph formatting conventions summarized below guide
MPS3 IC/EAL identifier presentation of the MPS3 EALs in accordance with the EAL writing criteria.

Space restrictions in the EAL table of this document sometimes override this

MPS3 IC/EAL wording and mode applicability criteria in cases when following the criteria would introduce undesirable
Justification of any difference or deviation complications in the EAL layout.
Upper case-bold underline print is used for the logic terms AND, OR EAL Wording and EITHER.

NEI 99-01, Section 4.1, NEI recommends the following: "The guidance in NEI

Bold print is also used for certain logic terms, negative terms (not, 99-01 is not intended to be applied to plants "as-is"; however, developers cannot, etc.), any, all.

should attempt to keep their site-specific schemes as close to the generic ** Upper case print is reserved for defined terms, acronyms, system guidance as possible. The goal is to meet the intent of the generic Initiating abbreviations, logic terms (and, or, etc. when not used as a Conditions (ICs) and Emergency Action Levels (EALs) within the context of conjunction), and annunciator window engravings. site-specific characteristics - locale, plant design, operating features,

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 4 of 123

Three or more items in a list are normally introduced with "Any of the 7. IC/EAL identification:

following ... " or -"All of the following ... " Items of the list begin with bullets when a priority or sequence is not inferred.

NEI Recognition Category A, "Abnormal Radiation Levels/

Radiological Effluents," has been changed to Category R,

The use of and/or logic within the same EAL 'has been avoided "Abnormal Rad Levels / Rad Effluents." The designator "R" is when possible. When such logic cannot be avoided, indentation and more intuitively associated with radiation (rad) or radiological separation of subordinate contingent phrases is employed. events. NEI IC designators beginning with "A" have likewise been changed to "R."

Global Differences

NEI Recognition Category S, "System Malfunctions," has been The differences listed below generally apply throughout the set of EALs and changed to Category M, "System Malfunctions." The designator "M" precludes possible interpretation of "SA" as Site Area are not repeated in the Justification sections of this document. The global differences do not change the intent of NEI 99-01. Emergency.

1. The NEI phrase "Notification of Unusual Event" has been changed to

NEI 99-01 defines the thresholds requiring emergency "Unusual Event" or abbreviated "UE" to reduce EAL-user reading classification (example EALs) and assigns them to ICs which, in burden. turn, are grouped in "Recognition Categories." MPS3 endeavors to optimize the NEI EAL organization and identification scheme

2. The title "Emergency Director is replaced with the MPS3-specific to enhance usability of the plant-specific EAL set. To this end, title "Director of Station Emergency Operation/Assistant Director the MPS3 IC/EAL scheme includes the following features:

Technical Support (DSEO/ADTS}"

a. Division of the NEI EAL set into three groups:

3. NEI 99-01 IC Example EALs are implemented in separate plant EALs to improve clarity and readability. For example, NEI lists all IC o EALs applicable under all plant operating conditions -

HU3 Example EALs under one IC. The corresponding MPS3 EALs This group would be reviewed by the EAL-user any appear as unique EALs (e.g., HU3.1 through HU3.4). time emergency classification is considered.

4. Operational Condition (MODE) applicability identifiers o EALs applicable only under hot operating conditions -

(numbers/letter) modify the NEI 99-01 mode applicability names as This group would only be reviewed by the EAL-user follows: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot when the plant is in Power Operation, Startup, Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling, DEF - Defueled. NEI Standby or Hot Shutdown mode. 99-01 defines Defueled as follows: "All reactor fuel removed from o EALs applicable only under cold operating conditions - RPV. (Full core off load during refueling or extended outage)." This group would only be reviewed by the EAL-user

5. NEI 99-01 uses the terms greater than, less than, greater than or when the plant is in Cold Shutdown, Refueling or equal to, etc. in the wording of some example EALs. For consistency Defueled mode.

and to reduce EAL-user reading burden, MPS3 has adopted use of The purpose of the groups is to avoid review of hot condition boolean symbols in place of the NEI 99-01 text modifiers within the EALs when the plant is in a cold condition and avoid review EAL wording. of cold condition EALs when the plant is in a hot condition.

6. "min." is the standard abbreviation for "minutes" and is used to This approach significantly minimizes the total number of reduce EAL user reading burden. EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and,

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 5 of 123 thereby, speeds identification of the EAL that applies to the o Uniqueness - The EAL identifier ensures that there emergency. can be no contusion over which EAL is driving the

b. Within each of the above three groups, assignment of need for emergency classification.

EALs to categories/subcategories - Category and o Speed in locating the EAL of concern - When the subcategory titles are selected to represent conditions EALs are displayed in a matrix format, knowledge that are operationally significant to the EAL-user. of the EAL identifier alone can lead the EAL-user to Subcategories are used as necessary to further divide the the location of the EAL within the classification EALs of a category into logical sets of possible matrix. The identifier conveys the category, emergency classification thresholds. The MPS3 EAL subcategory and classification level. This assists categories/subcategories and their relationship to NEI ERO responders (who may not be in the same Recognition Categories are listed in Table 1. facility as the DSEO/ADTS) to find the EAL of

c. Unique identification of each EAL - Four characters concern in a timely manner without the need for a comprise the EAL identifier as illustrated in Figure 1. word description of the classification threshold.

o Possible classification upgrade The category/subcategory/identifier scheme helps the Figure 1 - EAL Identifier EAL-user find higher emergency classification EALs EAL Identifier that may become active if plant conditions worsen. xxx.x Table 2 lists the MPS3 ICs and EALs that correspond to Category (R, H, E, M, F, C) _J II L Sequential number within subcategory/classification the NEI !Cs/Example EALs when the above EAUIC Emergency classification (G, S, A, U) _J L Subcategory number (1 if no subcategory) organization and identification scheme is implemented. The first character is a letter associated with the category in which the EAL is located. The second character is a Differences and Deviations letter associated with the emergency classification level In accordance NRC Regulatory Issue Summary (RIS) 2003-18, "Use of (G for General Emergency, S for Site Area Emergency, A Nuclear Energy Institute (NEI) 99-01, Methodology for Development of for Alert, and U for Unusual Event). The third character is Emergency Action Levels" Supplements 1 and 2, a "difference" is an EAL a number associated with one or more subcategories change in which the basis scheme guidance differs in wording but agrees in within a given category. Subcategories are sequentially meaning and intent, such that classification of an event would be the same, numbered beginning with the number "1". If a category whether using the basis scheme guidance or the MPS3 EAL. A "deviation" is does not have a subcategory, this character is assigned an EAL change in which the basis scheme guidance differs in wording and is the number "1". The fourth character is a number altered in meaning or intent, such that classification of the event could be preceded by a period for each EAL within a subcategory. different between the basis scheme guidance and the MPS3 proposed EAL. EALs are sequentially numbered within the emergency classification level of a subcategory beginning with the Administrative changes that do not actually change the textual content are number "1". neither differences nor deviations. Likewise, any format change that does not alter the wording of the IC or EAL is not considered a difference or a The EAL identifier is designed to fulfill the following deviation. objectives:

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 6 of 123 The following are examples of differences:

Changing words of physical reference (protected area, safety-related equipment, etc.).
Choosing the applicable EAL based upon plant type (i.e., BWR vs.

PWR).

Eliminating an IC. This includes the removal of an IC from the Fission Product Barrier Degradation category as this impacts the
Using a numbering scheme other than that provided in NEI 99-01 logic of Fission Product Barrier ICs.
that does not change the intent of the overall scheme.
Changing a Fission Product Barrier from a Loss to a Potential Loss
Where the NEI 99-01 guidance specifically provides an option to not or vice-versa.

include an EAL, if equipment for the EAL does not exist at MPS3 (e.g., automatic real-time dose assessment capability).

Not using NEI 99-01 definitions. The intent is for all NEI 99-01 users to have a standard set of defined terms as delineated in NEI 99-01.
Pulling information from the bases section up to the actual EAL that Differences due to plant types are permissible (BWR or PWR).

does not change the intent of the EAL. Verbatim compliance to the wording of defined terms in NEI 99-01 is

Choosing to state ALL Operating Modes are applicable instead of not necessary as long as the intent of the defined word is stating N/A, or listing each mode individually under the Abnormal maintained. Use of the wording provided in NEI 99-01 is encouraged Rad Level/Radiological Effluent and Hazard and Other Conditions since the intent is for all users to have a standard set of terms as Affecting Plant Safety sections. delineated in NEI 99-01.
Using synonymous wording (e.g., greater than or equal to vs. at or
Any change to the IC and/or EAL, and/or basis wording as stated in above, less than or equal vs. at or below, greater than or less than NEI 99-01 that does alter the intent of the IC and/or EAL (For vs. above or below, etc.) example, the IC and/or EAL):
Adding MPS3 equipment/instrument identification and/or noun o Does not classify at the classification level consistent with names to EALs. NEI 99-01.
Combining like ICs that are exactly the same but have different a Is not logically integrated with other EALs in the EAL operating modes as long as the intent of each IC is maintained and scheme.

the overall progression of the EAL scheme is not affected. o Results in an incomplete EAL scheme (i.e., does not classify

Any change to the IC and/or EAL, and/or basis wording, as stated in all potential emergency conditions).

NEI 99-01, that does not alter the intent of the IC and/or EAL, i.e., The "Difference/Deviation Justification" identifies each difference between the IC and/or EAL continues to: the NEI 99-01 IC/EAL wording and the MPS3 IC/EAL wording. Justification o Classify at the correct classification level. for each difference is then provided. If the difference is determined to be a deviation, a statement is made to that affect and an explanation is provided o Logically integrate with other EALs in the EAL scheme. as to why classification may be different from the NEI 99-01 , Rev. 6 IC/EAL o Ensure that the resulting EAL scheme is complete (i.e., and the reason for it is acceptable. In all cases, the differences and classifies all potential emergency conditions). deviations do not change the intent of NEI 99-01. A summary list of MPS3 The following are examples of deviations: EAL deviations from NEI 99-01, Rev. 6 is provided in Table 3.

Use of altered mode applicability.
Altering key words or time limits.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 7 of 123 Table 1 - MPS3 EAL Categories/Subcategories MPS3 EALs 1 - Radiological Effluent Abnormal Rad Levels/Radiological Effluent 2 - Irradiated Fuel Event R - Abnormal Rad Levels/Rad Effluent ICs/EALs 3 - Area Radiation Levels H - Hazards and Other Conditions Affecting 1 - Security Hazards and Other Conditions Affecting Plant Safety 2 - Seismic Event Plant Safety ICs/EALs 3 - Natural or Technological Hazard 4- Fire 5 - Hazardous Gas 6 - Control Room Evacuation 7- DSEO/ADTS Judgment E- ISFSI 1 - Confinement Boundary ISFSI ICs/EALs 1- Loss of Emergency AC Power System Malfunction ICs/EALs 2- Loss of Vital DC Power 3- Loss of Control Room Indications 4- RCS Activity M - System Malfunction 5- RCS Leakage 6- RPS Failure 7- Loss of Communications 8- Containment Failure 9- Hazardous Event Affecting Safety Systems F - Fission Product Barrier None Fission Product Barrier ICs/EALs

           .et6~****:lctiict':ctihditi 1 - RCS Level                                Cold Shutdown./ Refueling System 2 - Loss of Emergency AC Power               Malfunction ICs/EALs C - Cold Shutdown/Refueling System            3- RCS Temperature Malfunction                               4 - Loss of Vital DC Power 5 - Loss of Communications 6 - Hazardous Event Affecting Safety Systems

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 8 of 123 Table 2- NEI / MPS3 EAL Identification Cross-Reference NEI MPS3 Example IC Category and Subcategory EAL EAL AU1 1 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RU1.1 RU1.4 AU1 2 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RU1.2 AU1 3 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RU1.3 RU1.5 AU2 1 A-Abnormal Rad Levels/ Rad Effluent, 2 - Irradiated Fuel Event RU2.1 AA1 1 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.1 AA1 2 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.2 AA1 3 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.3 AA1 4 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.4 AA2 1 A - Abnormal Rad Levels/ Rad Effluent, 2 - Irradiated Fuel Event RA2.1 AA2 2 A - Abnormal Rad Levels/ Rad Effluent, 2 - Irradiated Fuel Event RA2.2 AA2 3 A - Abnormal Rad Levels/ Rad Effluent, 2 - Irradiated Fuel Event RA2.3 AA3 1 A - Abnormal Rad Levels / Rad Effluent, 3 - Area Radiation Levels RA3.1 AA3 2 A - Abnormal Rad Levels / Rad Effluent, 3 - Area Radiation Levels RA3.2 AS1 1 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RS1.1 AS1 2 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RS1.2 AS1 3 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RS1.3

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 9 of 123 Table 2 - NEI / MPS3 EAL Identification Cross-Reference NEI MPS3 Example IC Category and Subcategory EAL EAL AS2 1 A-Abnormal Rad Levels/ Rad Effluent, 2 - Irradiated Fuel Event HS2.1 AG1 1 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RG1.1 AG1 2 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RG1.2 AG1 3 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RG1.3 AG2 1 A - Abnormal Rad Levels/ Rad Effluent, 2 - Irradiated Fuel Event RG2.1 CU1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CU1.1 CU1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CU1.2 CU2 1 C - Cold SD/ Refueling System Malfunction, 2 - Loss of AC Power CU2.1 CU3 1 C- Cold SD/ Refueling System Malfunction, 3- RCS Temperature CU3.1 CU3 2 C - Cold SD/ Refueling System Malfunction, 3 - RCS Temperature CU3.2 CU4 1 C """ Cold SD/ Refueling System Malfunction, 4 - Loss of DC Power CU4.1 CU5 1,2,3 C - Cold SD/ Refueling System Malfunction, 5 - Loss of Communications CU5.1 CA1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CA1.1 CA1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCSV Level CA1.2 CA2 1 C - Cold SD/ Refueling System Malfunction, 1 - Loss of AC Power CA2.1 CA3 1, 2 C - Cold SD/ Refueling System Malfunction, 3 - RCS Temperature CA3.1 CA6 1 C - Cold SD/ Refueling System Malfunction, 6 - Hazardous Event Affecting Safety Systems CA6.1

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 10 of 123 Table 2 - NEI / MPS3 EAL Identification Cross-Reference NEI MPS3 Example IC Category and Subcategory EAL EAL CS1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CS1.1 CS1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level NIA CS1 3 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CS1.2 CG1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CG1.1 CG1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CG1.2 E-HU1 1 E - ISFSI, 1 - Confinement Boundary EU1.1 FA1 1 F - Fission Product Barrier FA1 .1 FS1 1 F - Fission Product Barrier FS1.1 FG1 1 F - Fission Product Barrier FG1.1 HU1 1, 2, 3 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HU1.1 HU2 1 H - Hazards and Other Conditions Affecting Plant Safety, 2 - Seismic Event HU2.1 HU3 1 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technology Hazard HU3.1 HU3 2 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technology Hazard HU3.2 HU3 3 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technology Hazard HU3.3 HU3 4 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technology Hazard HU3.4 HU3 5 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technology Hazard NIA HU4 1 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.1

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 11 of 123 Table 2 - NEI / MPS3 EAL Identification Cross-Reference NEI MPS3 Example EAL IC Category and Subcategory EAL HU4 2 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.2 HU4 3 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.3 HU4 4 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.4 HU7 1 H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HU7.1 HA1 1, 2 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HA1.1 HA5 1 H - Hazards and Other Conditions Affecting Plant Safety, 5 - Hazardous Gases HA5.1 HA6 1 H - Hazards and Other Conditions Affecting Plant Safety, 6 - Control Room Evacuation HA6.1 HA7 1 H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HA7.1 HS1 1 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HS1.1 HS6 1 H - Hazards and Other Conditions Affecting Plant Safety, 6 - Control Room Evacuation HS6.1 HS7 1 H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HS7.1 HG1 1 N/A N/A HG7 2 H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HG7.1 SU1 1 S - System Malfunction, 1 - Loss of AC Power MU1.1 SU2 1 S - System Malfunction, 3 - Loss of Control Room Indications MU3.1 SU3 1 S - System Malfunction, 4 - RCS Activity MU4.1 SU3 2 S - System Malfunction, 4 - RCS Activity MU4.2

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 12 of 123 Table 2 - NEI / MPS3 EAL Identification Cross-Reference NEI MPS3 Example IC Category and Subcategory EAL EAL SU4 1,2,3 S - System Malfunction, 5 - RCS Leakage MU5.1 SU5 1 S - System Malfunction, 6 - RPS Failure MU6.1 SU5 2 S - System Malfunction, 6 - RPS Failure MU6.2 SU6 1,2,3 S - System Malfunction, 7 -Loss of Communications MU7.1 SU7 1, 2 S - System Malfunction, 8 - Containment Failure MUB.1 SA1 1 S - System Malfunction, 1 - Loss of AC Power MA1.1 SA2 1 S - System Malfunction, 3 - Loss of Control Room Indications MA3.1 SA5 1 S - System Malfunction, 6 - RPS Failure MA6.1 SA9 1 S - Hazardous Event Affecting Safety Systems MA9.1 SS1 1 S - System Malfunction, 1 - Loss of AC Power MS1.1 SS5 1 S - System Malfunction, 6 - RPS Failure MS6.1 SSB 1 S - System Malfunction, 2 - Loss of DC Power MS2.1 SG1 1 S- System Malfunction, 1 - Loss of AC Power MG1.1 8GB 2 S - System Malfunction, 2 - Loss of DC Power MG2.1

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 13 of 123 Table 3 - Summary of Deviations NEI MPS3 Description EAL IC Example EAL AU1 1, 2, 3 RU 1.1, RU 1.2, . Generic IC AU 1 has been split to address gaseous and liquid releases separately. RU1 .3, RU1 .4, The basis for the gaseous UE IC and associated thresholds has been revised to RU1.5 correspond to any unplanned release of gaseous effluent radioactivity to the environment that will result in greater than 1 mrem TEDE. This UE gaseous release criterion is being used consistently at all operating Dominion Energy nuclear stations (Millstone, North Anna and Surry). The reason this alternative criterion is required is due to the fact that for some effluent gaseous release pathways, the resulting calculated UE threshold following the NEI 99-01 guidance of two times the site specific effluent release limit would result in a UE threshold value greater than the corresponding calculated ALERT threshold based on exceeding 1O mrem TEDE. For _the other gaseous release pathways that did not show an incongruent relationship when compared to the ALERT threshold, many showed UE values essentially equivalent to 1 mrem TEDE when applying the guidance in NEI 99-01 of a value set at two times the site specific effluent release limit. The fact that, (1) many of the gaseous release pathway UE values following NEI 99-01 guidance were essentially equivalent to 1 mrem TEDE, (2) application of an alternative definition set at a value of 1 mrem TEDE results in a more limiting value for those release paths that showed incongruent comparison to the corresponding ALERT threshold, and (3) UE criterion set at a value ten (1 O) times lower than the ALERT threshold provides a logical and consistent escalation between each classification level, provides justification for the UE criterion of 1 mrem TEDE. This single Initiating Condition (IC) definition for gaseous releases at the UE level is being applied to maintain consistency across the Dominion Energy nuclear fleet and to reduce confusion and human error potential if two different (IC) definitions were applied. Due to the fact that there are no ODCM limits on steam safeties or auxiliary feedwater exhausts and the limited ability for these respective radiation monitors to detect low level radioactivity in-these steam line configurations, the UE classification thresholds for the steam safeties and auxiliary feedwater exhaust are being labeled N/A (not applicable).

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 14 of 123 Table 3 - Summary of Deviations NEI MPS3 Description EAL IC Example EAL This revised IC and associated thresholds is a deviation from the NEI 99-01, Revision 6 AU1 generic wording and bases but is deemed acceptable consistent with the above justification. HG1 1 N/A IC HG1 and associated example EAL is not implemented in the MPS3 scheme. There are several other ICs that are redundant with this IC, and are better suited to ensure timely and effective emergency declarations. In addition, the development of new spent fuel pool level EALs, as a result of NRG Order EA 051, clarified the intended emergency classification level for spent fuel pool level events. This deviation is justified because:

1. Hostile Action in the Protected Area is bounded by ICs HS1 and HS7. Hostile Action resulting in a loss of physical control is bounded by EAL HG7, as well as any event that may lead to radiological releases to the public in excess of Environmental Protection Agency (EPA) Protective Action Guides (PAGs).

a. If, for whatever reason, the Control Room must be evacuated, and control of safety functions (e.g., reactivity control, core cooling, and RCS heat removal) cannot be reestablished, then IC HS6 would apply, as well as IC HS7 if desired by the EAL decision-maker.

b. Also, as stated above, any event (including Hostile Action) that could reasonably be expected to have a release exceeding EPA PAGs would be bounded by IC HG7.

C. From a Hostile Action perspective, ICs HS1, HS7 and HG7 are appropriate, and therefore, make this part of HG1 redundant and unnecessary.

d. From a loss of physical control perspective, ICs HS6, HS7 and HG7 are appropriate, and therefore, make this part of HG1 redundant and unnecessary.

2. Any event which causes a loss of spent fuel pool level will be bounded by ICs AA2, AS2 and AG2, regardless of whether it was based upon a Hostile Action

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C

Page 15 of 123 Table 3 - Summary of Deviations NEI MPS3 Description EAL IC Example EAL or not, thus making this part of HG1 redundant and unnecessary.

a. An event that leads to a radiological release will be bounded by ICs AU1, AA 1, AS1 and AG1. Events that lead to radiological releases in excess of EPA PAGs will be bounded by EALs AG1 and HG7, thus making this part of HG1 redundant and un_necessary.

ICs AA2, AS2, AG2, AS1, AG1, HS1, HS6, HS7 and HG7 have been implemented consistent with NEI 99-01, Revision 6 and thus HG1 is adequately bounded as described above. This exclusion of the generic HG1 guidance is a deviation from the NEI 99-01, Revision 6 generic guidance but is deemed acceptable consistent with endorsed NRC EP FAQ 2015-013. HS6 1 HS6.1 Deleted defueled mode applicability. Control of the cited safety functions are not critical for a defueled reactor as there is no energy source in the reactor vessel or RCS. The Mode applicability for the reactivity control safety function has been limited to Modes 1, 2, and 3.(hot operating conditions). In the cold operating modes, adequate shutdown margin exists under all conditions. This revised mode applicability is a deviation from the NEI 99-01, Revision 6 HS6 generic guidance bu.t is deemed acceptable consistent with endorsed NRC EP FAQ 2015-014. CA6 1 CA6.1 The proposed MPS3 CA6.1 and MA9.1 wording is intended to ensure that an Alert should be declared only when actual or potential performance issues with SA9 1 MA9.1 SAFETY SYSTEMS have occurred as a result of a hazardous event The occurrence of certain hazardous events may result in an Unusual Event classification at a minimum. In order to warrant escalation to the Alert classification, the hazardous event must cause indications of degraded performance to one train of a SAFETY SYSTEM with either an indication of degraded performance on the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second SAFETY SYSTEM train, such that the operability or

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 16 of 123 Table 3 - Summary of Deviations NEI MPS3 Description EAL IC Example EAL reliability of the second train is a concern. In addition, escalation to the Alert classification should not occur if the damage from the hazardous event is limited to a SAFETY SYSTEM that was inoperable, or out of service, prior to the event occurring. As such, the proposed EALs will reduce the potential of declaring an Alert when events are in progress that do not involve an actual or potential substantial degradation of the level of safety of the plant, (i.e., does not cause significant concern with shutting down or cooling down the plant). I EALs CA6.1 and MA9.1 do not directly escalate to a Site Area Emergency or a General Emergency due to a hazardous event. The Fission Product Barrier and/or Abnormal Radiation Levels/Radiological Effluent recognition categories would provide an escalation path to a Site Area Emergency or a General Emergency. The EALs and the Basis sections have been revised to ensure potential escalations from an Unusual Event to an Alert, due to a hazardous event, is appropriate as the concern with these EALs is: (1) a hazardous event has occurred, (2) one SAFETY SYSTEM train is having performance issues as a result of the hazardous event, and (3) either the second SAFETY SYSTEM train is having performance issues or the VISIBLE DAMAGE indicates that the second SAFETY SYSTEM train may have operability or reliability issues. The definition of VISIBLE DAMAGE has been revised to reflect the fact that the EALs are based upon SAFETY SYSTEM trains rather than individual components or structures. Note 9 has been added to CA6.1 and MA9.1 as it meets the intent of the EALs, is consistent with other EALs (e.g., EAL HA5.1 which was previously endorsed by the NRC), and ensures that declared emergencies are based upon unplanned events with the potential to pose a radiological risk to the public. Note 1O has been added to CA6.1 and MA9.1 to help reinforce and succinctly capture the more detailed information from the revised basis section related to when conditions would require the declaration of an Alert. CA6.1 and MA9.1 are consistent with NRC FAQ 2016-002 requiring degraded performance or visible damaqe to more than one safety svstem train caused bv

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 17 of 123 Table 3 - Summary of Deviations NEI MPS3 Description EAL IC Example EAL the specified events. This revised wording is a deviation from the NEI 99-01, Revision 6 CA6 and SA9 generic wording and bases but is deemed acceptable consistent with endorsed NRC EP FAQ 2016-002. SG1 1 MG1.1 The proposed MPS3 MG1 .1 omits the Station Blackout (SBO) coping time threshold. As proposed, the General Emergency classification would be based on a loss of all onsite and offsite AC power to the emergency buses with indications of degraded core cooling. The MPS3 SBO analysis and derived coping time was determined in accordance with 10CFR50.63 and Regulatory Guide 1.155. This analysis does not take credit for plant capabilities in place to mitigate the effects of an extended loss of AC power (ELAP). These capabilities were developed and implemented to meet the requirements of NRG Orders EA-12-049 and EA 051, and pending regulations in 10 CFR 50.155 (per SECY-16-0142). In accordance with plant EOPs, operators will declare an ELAP within 45 min. of the loss of all AC power to the emergency buses and direct implementation of FLEX Support Guidelines, including the deployment of dedicated portable equipment and performance of DC load shedding. Even if no AC emergency bus is energized, these actions will maintain or restore core cooling, containment, and spent fuel pool cooling capabilities indefinitely. Therefore, the underlying basis for the generic EAL coping time statement, that power must be restored to an AC emergency bus within a fixed amount of time to avoid a severe challenge to one or more fission product barriers, is not valid for MPS3. Additionally, the omission of the SBO coping time threshold does not remove the attribute of a likely General Emergency declaration prior to meeting the IC FG1 thresholds for ELAP events in which the RCS barrier has not been lost. This revised wording is a deviation from the NEI 99-01, Revision 6 SG1 generic wording and bases but is deemed appropriate and acceptable.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 18 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent NEI IC Wording and Mode MPS3 MPS3 IC Wording and Mode NEI IC# Difference/Deviation Justification Applicability IC#(s) Applicability AU1 Release of gaseous or liquid RU1a Release of liquid radioactivity greater Generic IC AU1 has been split to address gaseous and radioactivity greater than 2 times than 2 times the allocated REMODCM liquid releases separately. the (site-specific effluent release limits for 60 minutes or longer The REMODCM is the site-specific effluent release controlling document) limits for MODE:AII controlling document. 60 minutes or longer. MODE:AII RU1b Release of gaseous radioactivity Generic IC AU1 has been split to address gaseous and resulting in offsite dose greater than 1 liquid releases separately. mrem TEDE The basis for the gaseous UE IC and associated thresholds MODE:AII has been revised to correspond to any unplanned release of gaseous effluent radioactivity to the environment that will result in greater than 1 mrem TEDE. This UE gaseous release criterion is being used consistently at all operating Dominion Energy nuclear stations (Millstone, North Anna and Surry). The reason this alternative criterion is required is due to the fact that for some effluent gaseous release pathways, the resulting calculated UE threshold following the NEI 99-01 guidance of two times the site specific effluent release limit would result in a UE threshold value greater than the corresponding calculated ALERT threshold based on exceeding 10 mrem TEDE. For the other gaseous release pathways that did not show an incongruent relationship when compared to the ALERT threshold, many showed UE values essentially equivalent to 1 mrem TEDE when applying the guidance in NEI 99-01 of a value set at two times the site specific effluent release limit. The fact that, (1) many of the gaseous release pathway UE values following NEI 99-01 guidance were essentially equivalent to t mrem TEDE, (2) application of art alternative definition set at a value of 1 mrem TEDE results in a more limiting value for those release paths that showed incongruent comparison to the corresponding ALERT threshold, and (3) UE criterion set at a value ten (10) times lower than the ALERT threshold

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclo~ure 3, Attachment 1C Page 19 of 123 Table 4 - MPS3 _Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent provides a logical and consistent escalation between each classification level, provides justification for the UE criterion of 1 mrem TEDE. This single Initiating Condition (IC) definition for gaseous releases at the UE level is being applied to maintain consistency across the Dominion Energy nuclear fleet and to reduce confusion and human error potential if two different (IC) definitions were applied. Due to the fact that there are no ODCM limits on steam safeties or auxiliary feedwater exhausts and the limited ability for these respective radiation monitors to detect low level radioactivity in these steam line configurations, the UE classification thresholds for the steam safeties and auxiliary feedwater exhaust are being labeled N/A (not applicable). This revised IC and associated thresholds is a deviation from the NEI 99-01, Revision 6 AU1 generic wording and bases but is deemed acceptable consistent with the above justification.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 20 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Reading on ANY effluent Reading on EITHER of the following The NEI phrase" ... effluent radiation monitor greater than 2 radiation monitor greater than 2 radiation monitors > 2x the "alarm" times the (site-specific effluent release controlling times the (site-specific effluent setpoint for o:: 60 min. (Notes 1, 2, 3) document)" has been replaced with "Reading on EITHER of release controlling document) the following radiation monitors> 2x the "alarm" setpoint ... ". limits for 60 minutes or longer: RU1.1

3SSR-RE08 SG Slowdown
3DAS-RE50 Turbine Building Consistent with the above justification, liquid and gaseous (site-specific monitor list and Floor Drain effluent thresholds have been split. The specified monitors threshold values correspondjng are the liquid release pathway not associated with discharge to 2 times the controlling permits.

document limits) Reading on any Table R-1 effluent The NEI phrase " ... effluent radiation monitor greater than 2 radiation monitor> column "UE" for times the (site-specific effluent release controlling o:: 60 min. (Notes 1, 2, 3) document)" has been replaced with "... any Table R-1 effluent radiation monitor> column "UE ... ". UE thresholds for all MPS3 continuously monitored gaseous RU1.4 release pathways are listed in Table R-1 to consolidate the information in a single location and, thereby, simplify identification of the thresholds by the EAL user. The values shown in Table R-1 column "UE", consistent with the revised IC bases, corresponds to releases resulting in a 1 mrem dose at the site boundary for a 1-hour release. 2 Reading on ANY effluent Reading on EITHER of the following The NEI phrase "... ANY effluent radiation monitor greater radiation monitor greater than 2 effluent radiation monitors > 2 x the than 2 times alarm setpoint" has been replaced with times the alarm setpoint "alarm" setpoint established by a "Reading on EITHER of the following radiation effluent established by a current current radioactivity discharge permit monitors> 2x the "alarm" setpoint ... ". radioactivity discharge permit for RU1.2 for o:: 60 min.

                                                                                                > 2 x the alarm setpoint on the listed monitors represent two 60 minutes or longer.

3LWS-RE70 Liquid Waste times the allocated REMODCM release limits for liquid Effluent releases controlled by discharge permit.
3CND-RE07 Waste Neutralization Sump

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 21 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent (Notes 1, 2, 3) 3 Sample analysis for a gaseous Sample analysis for a liquid release The REMODCM is the site-specific effluent release or liquid release indicates a indicates a concentration or release controlling document. concentration or release rate rate > 2 x the allocated REMODCM greater than 2 times the (site- RU1.3 limits for ~ 60 min. (Notes 1, 2) specific effluent release controlling document) limits for 60 minutes or longer. Sample analysis for a gaseous The REMODCM is the site-specific effluent release release indicates a concentration or controlling document. RU1.5 release rate > 2 x the allocated REMODCM limits for 2: 60 min. (Notes 1, 2) Notes

The Emergency Director should declare the Unusual N/A Note 1: The DSEO/ADTS should declare the event promptly The classification timeliness note has been standardized across the MPS3 EAL scheme by referencing the "time limit" Event promptly upon upon determining that the specified within the EAL wording.

determining that 60 minutes time limit has been has been exceeded, or will exceeded, or will likely be likely be exceeded. exceeded. The classification timeliness note has been standardized

If an ongoing release is detected and the release Note 2: If an ongoing release is detected and the release across the MPS3 EAL scheme by referencing the "time limit" start time is unknown, start time is unknown, specified within the EAL wording.

assume that the release assume that the release duration has exceeded 60 duration has exceeded the minutes. specified time limit. If the effluent flow past an Note 3: If the effluent flow past an effluent monitor is known to effluent monitor is known to None have stopped due to actions to have stopped due to isolate the release path, then actions to isolate the the effluent monitor reading is release path, then the no longer valid for classification effluent monitor reading is no lonaer VALID for

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 22 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent I purposes. classification purposes. I I - I Table R-1 Unit 3 Gaseous Effluent Monitor Classification Thresholds I Release Point & Monitor I GE I SAE I Alert I UE I Ventilation Vent Normal/High Range 5.9E+OO µCi/cc 5.9E-01 µCi/cc 5.9E-02 µCi/cc 5.9E-03 µCi/cc (HVR10A/B) Stack (SLCRS) Normal/High Range 3.6E+02 µCi/cc 3.6E+01 µCi/cc 3.6E+OO µCi/cc 3.6E-01 µCi/cc (HVR19A/B) Main Steam Release 5.3E+01 µCi/cc 5.3E+OO µCi/cc 5.3E-01 µCi/cc N/A (MSS75-78) ( Aux FDWTR Pump Mntr 1.6E+01 µCi/cc 1.6E+OO µCi/cc 1.6E-01 µCi/cc N/A (MSS79)

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 23 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent NEI IC Wording and Mode MPS3 MPS3 IC Wording and Mode NEI IC# Difference/Deviation Justification Applicability IC#(s) Applicability AU2 UNPLANNED loss of water level RU2 UNPLANNED loss of water level None above irradiated fuel. above irradiated fuel MODE: All MODE:AII NEI Ex. MPS3 Difference/Deviation Justification NEI Example EAL Wording MPS3 EAL Wording EAL# EAL# 1 a. UNPLANNED water level RU2.1 UNPLANNED water level drop in the Site-specific level indications incorporated. drop in the REFUELING REFUELING PATHWAY as indicated Site-specific area radiation monitors incorporated. PATHWAY as indicated by by any of the following: ANY of the following:

FUEL POOL LEVEL LO alarm (site-specific level MB1A 3-4 indications).
FUEL POOL WATER LEVEL LO alarm FP 1-3 AND
Report of dropping level in

b. UNPLANNED rise in area refueling cavity or SFP radiation levels as indicated by ANY of the following AND radiation monitors. UNPLANNED rise in corresponding (site-specific list of area area radiation levels as indicated by radiation monitors) any of the following radiation monitors:

RMS01 Manipulator Crane
RMS41/42 Fuel Drop
RMSOB SFP Bridge
RMS36 Fuel Pool

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 24 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) AA1 Release of gaseous or liquid RA1 Release of gaseous or liquid The thyroid COE dose component has been eliminated as radioactivity resulting in offsite radioactivity resulting in offsite dose allowed by the 2017 EPA-400, PAG Manual: Protective Action dose greater than 1O mrem greater than 1O mrem TEDE Guides and Planning Guidance for Radiological TEDE or 50 mrem thyroid COE. Incidents. This is consistent with protective action decision-MODE: All MODE: All making criteria provided by the States of Connecticut and New York. This revised threshold is considered a difference from the NEI 99-01, Revision 6 AA 1 generic wording and bases and is deemed acceptable consistent with NRC endorsed EP-FAQ 2017-01. NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Reading on ANY of the following The MPS3 radiation monitors that detect radioactivity effluent RA1.1 Reading on any Table R-1 effluent radiation monitors greater than release to the environment are listed in Table R-1. UE, Alert, radiation monitor> column "ALERT" the reading shown for 15 minutes SAE and GE thresholds for all MPS3 continuously monitored for ;;: 15 min. (Notes 1, 2, 3, 4) or longer: gaseous and liquid release pathways are listed in Table R-1 to consolidate the information in a single location and, thereby, (site-specific monitor list and simplify identification of the thresholds by the EAL-user. threshold values) 2 Dose assessment using actual RA1.2 Dose assessment using actual The site boundary area is the site-specific receptor point. meteorology indicates doses meteorology indicates doses > 1O The thyroid COE dose component has been eliminated as greater than 10 mrem TEDE or mrem TEDE at or beyond the SITE allowed by EPA-400, PAG Manual: Protective Action Guides 50 mrem thyroid COE at or BOUNDARY (Note 4) and Planning Guidance for Radiological Incidents. See IC beyond (site-specific dose justification above. receptor point). 3 Analysis of a liquid effluent RA1.3 Analysis of a liquid effluent sample The site boundary area is the site-specific receptor point. samole indicates a concentration indicates a concentration or release The thvroid COE dose comoonent has been eliminated as

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 25 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent or release rate that would result rate that would result in doses > 10 allowed by EPA-400, PAG Manual: Protective Action Guides in doses greater than 10 mrem mrem TEDE at or beyond the SITE and Planning Guidance for Radiological Incidents. See IC TEDE or 50 mrem thyroid CDE at BOUNDARY for 60 min. of exposure justification above. or beyond (site-specific dose (Notes 1, 2) receptor point) for one hour of exposure. 4 Field survey results indicate Field survey results indicate closed The site boundary is the site-specific field survey receptor RA1.4 EITHER of the following at or window dose rates > 10 mR/hr point. beyond (site-specific dose expected to continue for 2: 60 min. at receptor point): The thyroid COE dose component has been eliminated as or beyond the SITE BOUNDARY

Closed window dose rates greater than 10 mR/hr (Notes 1, 2) allowed by EPA-400, PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents. See IC expected to continue for 60 justification above.

minutes or longer.

Analyses of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.

Notes

The Emergency Director should declare the Alert N/A Note 1: The DSEO/ADTS should declare the event promptly The classification timeliness note has been standardized across the MPS3 EAL scheme by referencing the "time limit" promptly upon determining upon determining that the specified within the EAL wording.

that the applicable time has time limit has been been exceeded, or will likely exceeded, or will likely be be exceeded. exceeded. The classification timeliness note has been standardized

If an ongoing release is detected and the release Note 2: If an ongoing release is detected and the release across the MPS3 EAL scheme by referencing the "time limit" start time is unknown, start time is unknown, specified within the EAL wording.

assume that the release assume that the release duration has exceeded 15 duration has exceeded the minutes. specified time limit.

If the effluent flow past an effluent monitor is known to Note 3: If the effluent flow past an effluent monitor is known to None have stopped due to actions have stopped due to actions to isolate the release path, to isolate the,release path,

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 26 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent then the effluent monitor then the effluent monitor reading is no longer valid for reading is no longer valid for classification purposes. classification purposes. Note 4: The pre-calculated effluent

The pre-calculated effluent monitor values presented in monitor values presented in EA Ls RA 1.1 , RS 1.1 and Incorporated site-specific EAL numbers associated with generic EAL#1.

EAL #1 should be used for RG 1.1 should be used for emergency classification emergency classification assessments until the results assessments until the from a dose assessment results from a dose using actual meteorology are assessment using actual available. meteorology are available.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 27 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) AA2 Significant lowering of water RA2 Significant lowering of water level None level above, or damage to, above, or damage to, irradiated fuel irradiated fuel. MODE: All MODE: All NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Uncovery of irradiated fuel in RA2.1 IMMINENT uncovery of irradiated fuel Added the term "IMMINENT" consistent with the generic the REFUELING PATHWAY. in the REFUELING PATHWAY bases. 2 Damage to irradiated fuel RA2.2 Damage to irradiated fuel resulting in a Deleted the words " ... from the fuel. .. " as that is implied by the resulting in a release of release of radioactivity determination that irradiated fuel has been damaged. radioactivity from the fuel as Site-specific list of radiation monitors are incorporated. AND indicated by ANY of the following radiation monitors: VALID alarm on any of the following Added the word "VALID" to reinforce generic bases that the radiation monitors: high radiation be associated with the damaged fuel. (site-specific listing of radiation Radiation monitor alarms specified. monitors, and the associated

CMS22 CTMT GIA readings, setpoints and/or
RM01 Manipulator Crane alarms)
RMS41/42 Fuel Drop
HVR17 Fuel Bldg
RMSOB SFP Bridge
RMS36 Fuel Pool

3 Lowering of spent fuel pool RA2.3 Lowering of spent fuel pool level to For MPS3, Level 2, which corresponds to 10 ft. above the top level to (site-specific Level 2 10 ft. (Level 2) on 3SFC-Ll55A or of the fuel racks in the SFP, is indicated level of 10 ft. on value). [See Developer Notes] 3SFC-Ll55B 3SFC-Ll55A or 3SFC-Ll55B

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 28 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent MPS3 NEI IC# NEI IC Wording" MPS3 IC Wording Difference/Deviation Justification IC#(s) AA3 Radiation levels that impede RA3 Radiation levels that IMPEDE access Limited mode applicability of RA3.2 specified in Table R-2. access to equipment necessary to equipment necessary for normal for normal plant operations, plant operations, cooldown or cooldown or shutdown shutdown MODE: All MODE: All (except RA3.2; Modes 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown only) NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Dose rate greater than 15 mR/hr RA3.1 Dose rates > 15 mR/hr in EITHER of No other site-specific areas requiring continuous occupancy in ANY of the following areas: the following: exist at MPS3.

Control Room
Control Room
Central Alarm Station
Central Alarm Station

              *   (other site-specific areas/rooms) 2       An UNPLANNED event results           RA3.2    An UNPLANNED event results in         The site-specific list of plant rooms or areas with entry-related in radiation levels that prohibit or          radiation levels that prohibit or     mode applicability are tabularized in Tables R-2.

impede access to any of the IMPEDE access to any Table R-2 following plant rooms or areas: room or area (Note 5) (site-specific list of plant rooms or areas with entry-related mode applicability identified)

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 29 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent Note If the equipment in the listed N/A Note 5 If the equipment in the listed None room or area was already room or area was already inoperable or out-of-service inoperable or out-of-service before the event occurred, then before the event occurred, no emergency classification is then no emergency warranted. classification is warranted. Table R-2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux. Building El 43' 1, 2, 3 Aux. Building El 24' East MCC/RCA El 24' 3,4 West MCC/RCA El 24' Aux. Building El 3' 8" 3 Containment ESF Building A RHR Cubicle ESF Building B RHR Cubicle ESF Building El 36' 4 ESF Building El 24' East Switchgear West SwitchQear

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 30 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) AS1 Release of gaseous radioactivity RS1 Release of gaseous radioactivity The thyroid COE dose component has been eliminated as resulting in offsite dose greater resulting in offsite dose greater than allowed by the 2017 EPA-400, PAG Manual: Protective Action than 100 mrem TEDE or 500 100 mrem TEDE Guides and Planning Guidance for Radiological mrem thyroid COE Incidents. This is consistent with protective action decision-MODE:AII MODE: All making criteria provided by the States of Connecticut and New York. This revised threshold is considered a difference from the NEI 99-01, Revision 6 ASt generic wording and bases and is deemed acceptable consistent with NRG endorsed EP-FAQ 2017-01. NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Reading on ANY of the following RS1.1 Reading on any Table R-1 effluent The MPS3 radiation monitors that detect radioactivity effluent radiation monitors greater than radiation monitor > column "SAE" for release to the environment are listed in Table R-1. UE, Alert, the reading shown tor 15 2: 15 min. (Notes 1, 2, 3, 4) SAE and GE thresholds for all MPS3 continuously monitored

          '!}inutes or longer:                                                              gaseous and liquid release pathways are listed in Table R-1 to (site-specific monitor list and                                                   consolidate the information in a single location and, thereby, threshold values)                                                                 simplify identification of the thresholds by the EAL-user.

2 Dose assessment using actual RS1.2 Dose assessment using actual The site boundary area is the site-specific receptor point. meteorology indicates doses meteorology indicates doses > 100 The thyroid COE dose component has been eliminated as greater than 100 mrem TEDE or . mrem TEDE at or beyond the SITE allowed by EPA-400, PAG Manual: Protective Action Guides 500 mrem thyroid COE at or BOUNDARY (Note 4) and Planning Guidance for Radiological Incidents. See IC beyond (site-specific dose justification above. receptor point)

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 31 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent 3 Field survey results indicate RS1.3 Field survey results indicate closed The site boundary area is the site-specific receptor point. EITHER of the following at or window dose rates > 100 mR/hr beyond (site-specific dose The thyroid COE dose component has been eliminated as expected to continue for ~ 60 min. at or receptor point): allowed by EPA-400, PAG Manual: Protective Action Guides beyond the SITE BOUNDARY and Planning Guidance for Radiological Incidents. See IC

Closed window dose rates greater than 100 mR/hr (Notes 1, 2) justification above.

expected to continue for 60 minutes or longer.

Analyses of field survey samples indicate thyroid COE greater than 500 mrem for one hour of inhalation.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 32 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent Notes

The Emergency Director Note 1: The DSEO/ADTS should The classification timeliness note has been standardized should declare the Site Area declare the event promptly across the MPS3 EAL scheme by referencing the "time limit" Emergency promptly upon upon determining that the specified within the EAL wording.

determining that the time limit has been applicable time has been exceeded, or will likely be exceeded, or will likely be exceeded. exceeded. Note 2: If an ongoing release is The classification timeliness note has been standardized

If an ongoing release is detected and the release across the MPS3 EAL scheme by referencing the "time limit" detected and the release start start time is unknown, specified within the EAL wording.

time is unknown, assume that assume that the release the release duration has duration has exceeded the exceeded 15 minutes. specified time limit.

If the effluent flow past an Note 3: If the effluent flow past an effluent monitor is known to effluent monitor is known to have stopped due to actions None have stopped due to actions to isolate the release path, to isolate the release path, then the effluent monitor then the effluent monitor reading is no longer valid for reading is no longer VALID classification purposes. for classification purposes.
The pre-calculated effluent Note 4: The pre-calculated effluent monitor values presented in monitor values presented in Incorporated site-specific EAL numbers associated with EAL #1 should be used for EALs RA1.1, RS1.1 and generic EAL#1.

emergency classification RG1 .1 should be used for assessments until the results emergency classification from a dose assessment assessments until the using actual meteorology are results from a dose available. assessment using actual meteoroloav are available.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 33 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) AS2 Spent fuel pool level at (site- RS2 Spent fuel pool level at the top of the Top of the fuel racks is the site-specific Level 3 description. specific Level 3 description) fuel racks MODE: All MODE: All NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Lowering of spent fuel pool level RS2.1 Lowering of spent fuel pool level to 1 For MPS3, Level 3 corresponds to the 1 ft. above the top of to (site-specific Level 3 value) ft. on 3SFC-Ll55A or 3SFC-Ll55B the fuel racks in the SFP, indicated by 1 ft. on 3SFC-Ll55A or 3SFC-Ll55B

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 34 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels/ Radiological Effluent MPS3 - NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) AG1 Release of gaseous radioactivity RG1 Release of gaseous radioactivity The thyroid COE dose component has* been eliminated as allowed resulting in offsite dose greater resulting in offsite dose greater by the 2017 EPA-400, PAG Manual: Protective Action Guides and than 1,000 mrem TEDE or than 1,000 mrem TEDE Planning Guidance for Radiological Incidents. This is consistent with 5,000 mrem thyroid COE. protective action decision-making criteria provided by the States of MODE:"AII MODE: All Connecticut and New York.

                            -                                                           This revised threshold is considered a difference from the NEI 99-01, Revision 6 AG1 generic wording and bases and is deemed acceptable consistent with NRC endorsed EP-FAQ 2017-01.

NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Reading on ANY of the RG1.1 R~ading on any Table R-1 effluent The MPS3 radiation monitors that detect radioactivity effluent release following radiation monitors radiation monitor> column "GE" to the environment are listed in Tables R-1. greater than the reading shown for ~ 15 min. UE, Alert, SAE and GE thresholds for all MPS3 continuously for 15 minutes or longer: (Notes 1, 2, 3, 4) monitored gaseous and liquid release pathways are listed in Table R-(site-specific monitor list and 1 to consolidate the information in a single location and, thereby, threshold values) simplify identification of the thresholds by the EAL~user. 2 Dose assessment using actual RG1.2 Dose assessment using actual The site boundary area is the site-specific receptor point. meteorology indicates doses meteorology indicates doses > The thyroid CDE dose component has been eliminated as allowed by greater than 1,000 mrem TEDE 1,000 mrem TEDE at or beyond

EPA-400, PAG Manual: Protective Action Guides and Planning or 5,000 mrem thyroid COE at the SITE BOUNDARY (Note 4)
Guidance for Radiological Incidents. See IC justification above.

or beyond (site-specific dose receptor point).

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 35 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent 3 Field survey results indicate RG1.3 Field survey results indicate The site boundary is the site-specific field survey receptor point. EITHER of the following at or closed window dose rates > 1,000 The thyroid CDE dose component has been eliminated as allowed by beyond (site-specific dose mR/hr expected to continue for EPA-400, PAG Manual: Protective Action Guides and Planning receptor point): .:: 60 min. at or beyond the SITE Guidance for Radiological Incidents. See IC justification above.

Closed window dose rates BOUNDARY (Notes 1, 2) greater than 1,000 mR/hr expected to continue for 60 minutes or longer.
Analyses of field survey samples indicate thyroid CDE greater than 5,000 mrem for one hour of inhalation.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 36 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent Notes

The Emergency Director Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the should declare the Site Area should declare the MPS3 EAL scheme by referencing the "time limit" specified within the Emergency promptly upon event promptly upon EAL wording.

determining that the determining that the applicable time has been time limit has been exceeded, or will likely be exceeded, or will likely exceeded. be exceeded.

If an ongoing release is Note 2: If an ongoing release is The classification timeliness note has been standardized across the detected and the release detected and the MPS3 EAL scheme by referencing the "time limit" specified within the start time is unknown, release start time is EAL wording.

assume that the release unknown, assume that duration has exceeded 15 the release duration has minutes. exceeded the specified

If.the effluent flow past an time limit.

effluent monitor is known to Note 3: If the effluent flow past None have stopped due to actions an effluent monitor is to isolate the release path, known to have stopped then the effluent monitor due to actions to isolate reading is no longer valid for the release path, then classification purposes. the effluent monitor

The pre-calculated effluent reading is no longer monitor values presented in VALID for classification EAL #1 should be used for purposes for emergency classification classification purposes.

assessments until the results Note 4: The pre-calculated Incorporated site-specific EAL numbers associated with generic from a dose assessment effluent monitor values EAL#1. using actual meteorology are presented in EALs available. RA1.1, RS1.1 and RG1 .1 should be used for el'!lergency classification assessments until the results from a dose assessment using actual meteorology are available.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 37 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) AG2 Spent fuel pool level cannot be RG2 Spent fuel pool level cannot be Top of the fuel racks is the site-specific Level 3 description. restored to at least (site-specific restored to at least the top of the fuel Level 3 description) for 60 racks for 60 minutes or longer minutes or longer MODE: All MODE:AII NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Spent fuel pool level cannot be RG2.1 Spent fuel pool level cannot be For MPS3, Level 3 corresponds to the 1 ft. above the top of restored to at least (site-specific restored to at least 1 ft. (Level 3) on the fuel racks in the SFP, indicated by 1 ft. on 3SFC-Ll55A or Level 3 value) for 60 minutes or 3SFC-Ll55A or 3SFC-Ll55B for ~ 60 3SFC-Ll55B longer min. (Note 1) Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized declare the General Emergency declare the event promptly across the MPS3 EAL scheme by referencing the "time limit" promptly upon determining that upon determining that the time specified within the EAL wording. 60 minutes has been exceeded, limit has been exceeded, or or will likely be exceeded. will likely be exceeded.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 38 of 123 Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) CU1 UNPLANNED loss of (reactor CU1 UNPLANNED loss of RCS Deleted the words " ... for 15 minutes or longer as the 15 minute vessel/RCS [PWR] or RPV inventory criteria only applies to EAL #1 [BWR]) inventory for 15 minutes MODE: 5 - Cold Shutdown, 6 - or longer. Refueling MODE: Cold Shutdown, Refueling. NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 UNPLANNED loss of reactor CU1.1 UNPLANNED loss of reactor None coolant results in (reactor coolant results in RCS water vessel/RCS [PWR] or RPV level < a required lower limit for [BWR]) level less than a ;.: 15 min. (Note 1) required lower limit for 15 minutes or longer. 2 RCS water level cannot be Added the words " ... due to loss of RCS inventory to be consistent

a. (Reactor vessel/RCS [PWR] CU1.2 monitored with the IC wording.

or RPV [BWR]) level cannot be monitored. AND EITHER The Table C-1 sumps & tanks are the site-specific applicable sumps AND

UNPLANNED rise in any and tanks.

Table C-1 sump or tank level Added bulleted criteria "Visual observation ... " to Table C-1 to include

b. UNPLANNED increase in due to a loss of RCS direct observation of significant unisolable RCS leakage.

(site-specific sump and/or inventory tank) levels.

Visual observation of UNISOLABLE RCS leakage

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 39 of 123 Table 4 - MPS3 Comparison Matrix Category C: Abnormal Rad Levels/ Radiological Effluent Note The Emergency Director should N/A Note 1: The OSEO/AOTS The classification timeliness note has been standardized across the* declare the Unusual Event should declare the MPS3 EAL scheme by referencing the "time limit" specified within the promptly upon determining that event promptly upon EAL wording. 15 minutes has been exceeded, determining that the or will likely be exceeded. time limit has been exceeded, or will likely be exceeded. Table C-1 Sumps/Tanks

PRT
COTT
POTT
Containment Sump
Unidentified Leakage Sump
Auxiliary Bldg. Sump
ESF Bldg. Sump

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 40 of 123. Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) CU2 Loss of all but one AC power CU2 Loss of all but one AC power None source to emergency buses for source to emergency buses tor 15 minutes or longer. 15 minutes or longer. MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, 6 - Refueling, Defueled Refueling, D - Defueled NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 AC power capability, Table C-3,

a. AC power capability to (site- CU2.1 4.16 kV emergency buses 34C and 34D are the MPS3-specific to 4.16 kV emergency buses specific emergency buses) is emergency buses.

34C and 34D reduced to a single reduced to a single power Table C-3 provides a consolidated list of AC power sources credited power source for~ 15 min. source for 15 minutes or for this EAL. (Note 1) longer. AND AND Any additional single power

b. Any additional single power source failure will result in loss of source failure will result in all AC power to SAFETY loss of all AC power to SYSTEMS SAFETY SYSTEMS.

Note The Emergency Director should N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the declare the Unusual Event should declare the MPS3 EAL scheme by referencing the "time limit" specified within promptly upon determining that event promptly upon the EAL wording. 15 minutes has been excee~ed, determining that the or will likely be exceeded. time limit has been exceeded, or will likely be exceeded.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 41 of 123 Table C-3 AC Power Sources Offsite

Unit 3 Normal Station Service Transformer A (NSST)
Unit 3 Reserve Station Service Transformer (RSST)

Onsite

EDGA
EOG B
SBO Diesel Generator (if already aligned)

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 42 of 123 Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS3 Difference/Deviation Justification NEI IC# NEI IC Wording MPS3 IC Wording IC#(s) CU3 UNPLANNED increase in RCS CU3 UNPLANNED increase in RCS None temperature temperature MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, 6 - Refueling RefuelinQ NEI Ex. MPS3 Difference/Deviation Justification NEI Example EAL Wording MPS3 EAL Wording EAL# EAL# 1 UNPLANNED increase in RCS CU3.1 UNPLANNED rise in RCS 200°F is the site-specific Tech. Spec. cold shutdown temperature temperature to greater than (site- temperature to > 200°F limit. specific Technical Specification cold shutdown temperature limit) 2 Loss of ALL RCS temperature CU3.2 Loss of all RCS temperature and None and (reactor vessel/RCS [PWR] RCS water level indication for ;;: or RPV [BWR]) level indication 15 min. (Note 1) for 15 minutes or longer. Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the declare the Unusual Event declare the event MPS3 EAL scheme by referencing the "time limit" specified within promptly upon determining that promptly upon the EAL wording. 15 minutes has been exceeded, determining that the time or will likely be exceeded limit has been exceeded, or will likely be exceeded.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 43 of 123 Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) CU4 Loss of Vital DC power for 15 CU4 Loss of vital DC power for 15 None minutes or longer. minutes or longer. MODE: Cold Shutdown, MODE 5 - Cold Shutdown, 6 - Refueling Refueling NEI Ex. MPS3 NEI Example EAL VI.fording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Indicated voltage is less than CU4.1 Indicated voltage is < 105 VDC on The specified bus voltage indications are the minimum voltage (site-specific bus voltage value) required vital 125 VDC battery requirements for operability of the 125 VDC buses. on required Vital DC buses for 15 bus 1 OR 2 for 2: 15 min. (Note 1) Vital 125 VDC battery bus 1 and 2 are the vital DC buses credited minutes or longer. for the EAL. Safety-related DC bus operability requirements are specified consistent with Technical Specifications. Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the declare the Unusual Event declare the event promptly MPS3 EAL scheme by referencing the "time limit" specified within promptly upon determining that upon determining that the the EAL wording. 15 minutes has been exceeded, time limit has been or will likely be exceeded. exceeded, or will likely be exceeded.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 44 of 123 Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) CU5 Loss of all onsite or offsite CU5 Loss of all onsite or offsite None communications capabilities. communications capabilities. MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, 6 - Refueling, Defueled Refueling, D - Defueled NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Loss of ALL of the following CUS.1 Loss of all Table C-5 onsite Example EALs #1, 2 and 3 have been combined into a single EAL onsite communication methods: communication methods for simplification of presentation. (site specific list of OR Table C-5 provides a site-specific list of onsite, offsite (ORO) and communications methods) NRG communications methods. Loss of all Table C-5 State and 2 Loss of ALL of the following ORO local agency communication communications methods: methods (site specific list of OR communications methods) Loss of all Table C-5 NRG 3 Loss of ALL of the following NRG communication methods communications methods: (site specific list of communications methods)

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 45 of 123 Table C-5 Communication Methods State/ System Onsite NRC Local ENRS/ARCOS X Station Radio System X X Plant Phone System X X Public Address System X Gaitronics / Maintenance Jacks X Federal Telephone System (ENS) X Commercial Telephone System X X Satellite Phones X X Dedicated Hotlines X

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 46 of 123 Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) CA1 Loss of (reactor vessel/RCS CA1 Significant loss of RCS Added the word "Significant..." to differentiate the Alert loss of RCS [PWRJ or RPV [BWRJ) inventory inventory inventory IC from the Unusual Event IC which is "Unplanned loss of RCS inventory." MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, 6 - Refueling Refueling NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Loss of (reactor vessel/RCS CA1.1 Loss of RCS inventory as RCS hot leg level of 82% RVLMS or 15 in. above centerline of hotleg [PWRJ or RPV [BWRJ) inventory indicated by EITHER: on tygon tube indictor is the lowest RCS level that supports as indicated by level less than continued decay heat removal pump operations (SOC). (site-specific level). * < 82% RVLMS plenum level

                                                         * ::; 15 in above centerline of
                                             .             hotleg on tygon tu~e                                        -

indicator 2 a. (Reactor vessel/RCS [PWRJ CA1.2 RCS water level cannot be The Table C-1 sumps/tanks are the site-specific applicable sumps or RPV [BWRJ) level cannot monitored for 2! 15 min. (Note 1) and tanks.

   '         be monitored for 15 minutes                 AND EITHER                       Added bulleted criteria "Visual observation ... " to Table C-1 to include or longer                                                                   direct observation of significant unisolable RCS leakage.

UNPLANNED rise in any AND Table .C-1 sump or tank level

b. UNPLANNED increase in due to a loss of RCS (site-specific sump and/or inventory tank) levels due to a loss of

Visual observation of 1 (reactor vessel/RCS [PWRJ UNISOLABLE RCS leakage or RPV [BWRJ) inventory.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 47 of 123 Table 4 - MPS3 Comparison Matrix Category C: Abnormal Rad Levels / Radiological Effluent Note The Emergency Director should N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the declare the Alert promptly upon should declare the MPS3 EAL scheme by referencing the "time limit" specified within the determining that 15 minutes has event promptly upon EAL wording. been exceeded, or will likely be determining that the exceeded time limit has been exceeded, or will likely be exceeded.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 48 of 123 Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) CA2 Loss of all offsite and all onsite CA2 Loss of all offsite and all onsite None AC power to emergency buses AC power to emergency buses for 15 minutes or longer for 15 minutes or longer. MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, 6 - Refueling, Defueled Refueling, D - Defueled NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Loss of ALL offsite and ALL CA2.1 Loss of all offsite and all onsite 4.16 kV emergency buses 34C and 34D are the MPS3-specific onsite AC Power to (site-specific AC power to 4.16 kV emergency emergency buses. emergency buses) for 15 buses 34C and 340 for ~ 15 minutes or longer. min. (Note 1) Note The Emergency Director should N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the declare the Unusual Event should declare the MPS3 EAL scheme by referencing the "time limit" specified within the promptly upon determining that event promptly upon EAL wording. 15 minutes has been exceeded, determining that the or will likely be exceeded. time limit has been exceeded, or will likely be exceeded.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 49 of 123 Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) CA3 Inability to maintain the plant in CA3 Inability to maintain plant in cold None cold shutdown. shutdown. MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, 6 - Refueling Refueling NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 UNPLANNED increase in RCS UNPLANNED rise in RCS Example EALs #1 and #2 have been combined into a single EAL temperature to greater than temperature to > 200°F for as EAL #2 is the alternative threshold based on a loss of RCS (site-specific Technical > Table C-4 duration temperature indication. Specification cold shutdown (Notes 1, 13) temperature limit) for greater 200°F is the site-specific Tech. Spec. cold shutdown temperature than the duration specified in OR limit. the following table. UNPLANNED RCS pressure Table C-4 is the site-specific implementation of the generic RCS CA3.1 rise > 1O psi (This pressure Reheat Duration Threshold table. 2 UNPLANNED RCS pressure threshold does not apply during increase greater than (site- 10 psi is the site-specific RCS pressure increase readable by water-solid plant conditions) specific pressure reading). Control Room indications. (This EAL does not apply during Revised the parenthetical to read "This pressure threshold ... " vs. water-solid plant conditions. "This EAL ... " to clarify that the statement only applies to the 10 psi [PWR]) RCS pressure increase. Note The Emergency Director should NIA Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the declare the Unusual Event should declare the MPS3 EAL scheme by referencing the "time limit" specified within promptly upon determining that event promptly upon the EAL wording. 15 minutes has been exceeded, determining that the or will likely be exceeded. time limit has been exceeded, or will likely be exceeded.

Serial No. 18-364

MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 50 of 123 Table 4 - MPS3 Comparison Matrix Category A: Abnormal Rad Levels / Radiological Effluent N/A N/A N/A Note 13: If an RCS heat Added Note 13 consistent with the asterisk note provided in the removal system is in generic RCS Heat-up Duration Threshold table.

operation within the applicable Table C-4 heat-up duration and RCS temperature is being reduced, the EAL is not applicable. Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Status Heat-up Duration Intact {but not at reduced Not applicable 60 minutes* inventory [PWR]) Not intact (or at reduced Established 20 minutes* inventory [PWR]) Not Established O minutes

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

Table C-4 RCS Heat-up Duration Thresholds Heat-up RCS Status Duration Intact AND not reduced 60 min. inventory Established 20 min. Not intact OR reduced inventory Not established Omin.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 51 of 123 Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction NEI MPS3 NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC# IC#(s) CA6 Hazardous event affecting a CA6 Hazardous event affecting Revised wording from " ... affecting a SAFETY SYSTEM ... " to read II SAFETY SYSTEM needed for SAFETY SYSTEMS needed ... affecting SAFETY SYSTEMS ... " to align with changes made the current operating mode. for the current operating consistent with NRC EP FAQ 2016-002. MODE: Cold Shutdown, mode. Refueling MODE: 5 - Cold Shutdown, 6

                                                        - Refuelinq NEI Ex.                                        MPS3 NEI Example EAL Wording                         MPS3 EAL Wording                             Difference/Deviation Justification EAL#                                          EAL#

1 a. The occurrence of ANY of the CA6.1 The occurrence of any Table The hazardous events have been tabularized in Table C-6. following hazardous events: C-6 hazardous event The proposed MPS3 CA6.1 and SA9.1 wording is intended to ensure that an* Alert should be declared only when actual or potential

Seismic event (earthquake) AND performance issues with SAFETY SYSTEMS have occurred as a
event Internal or external flooding Event damage has caused result of a hazardous event. The occurrence of certain hazardous indications of degraded events may result in an Unusual Event classification at a minimum.
High winds or tornado

_ _) performance on one train of a In order to warrant escalation to the Alert classification, the strike SAFETY SYSTEM needed for hazardous event should cause indications of degraded performance

FIRE the current operating mode to one train of a SAFETY SYSTEM with either indications of
EXPLOSION degraded performance on the second SAFETY SYSTEM train or

             *   (site-specific hazards)                   AND EITHER:

VISIBLE DAMAGE to the second SAFETY SYSTEM train, such that

Other events with similar hazard characteristics as
Event damage has the operability or reliability of the second train is a concern. In caused indications of addition, escalation to the Alert classification should not occur if the determined by the Shift Manager degraded performance damage from the hazardous event is limited to a SAFETY SYSTEM to the second train of that was inoperable, or out of service, prior to the event occurring. As AND the SAFETY SYSTEM such, the proposed EALs will reduce the potential of declaring an

b. EITHER of the following: needed for the current Alert when events are in progress that do not involve an actual or

1. Event damage has caused operating mode potential substantial degradation of the level of safety of the plant, indications of degraded i.e., does not cause significant concern with shutting down or cooling performance in at least one

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 52 of 123 Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction train of a SAF_ETY down the plant. CA6.1

Event damage has SYSTEM needed for the cesulted in VISIBLE EALs CA6.1 and SA9.1 do not directly escalate to a Site Area current operating mode.

DAMAGE to the second Emergency or a General Emergency due to a hazardous event. The OR train of the SAFETY Fission Product Barrier and/or Abnormal Radiation SYSTEM needed for Levels/Radiological Effluent recognition categories would provide an

2. The event has caused the current operating escalation path to a Site Area Emergency or a General Emergency.

VISIBLE DAMAGE to a SAFETY SYSTEM mode The EALs and the Basis sections have been revised to ensure component or structure (Notes 9, 10) potential escalations from an Unusual Event to an Alert, due to a needed for .the current hazardous event, is appropriate as the concern with these EALs is: operating mode. (1) a hazardous event has occurred, (2) one SAFETY SYSTEM train is having performance issues as a result of the hazardous event, and (3) either the second SAFETY SYSTEM train is having performance issues or the VISIBLE DAMAGE is enough to indicate that the second SAFETY SYSTEM train may have operability or reliability issues. The definition for VISIBLE DAMAGE has been revised to reflect the fact that the EALs are based upon SAFETY SYSTEM trains rather than individual components or structures. Note 9 has been added to CA6.1 and SA9.1 as it meets the intent of

                          -                                                   the EALs, is consistent with other EALs (e.g., EAL HA5.1 which was previously endorsed by the NRC), and ensures that declared emergencies are based upon unplanned events with the potential to pose a radiological risk to the public.

Note 10 has been added to CA6.1 and SA9.1 to help reinforce and succinctly capture the more detailed information from the revised basis section related to when conditions would require the declaration of an Alert. CA6.1 and SA9.1 are consistent with NRC FAQ 2016-002 requiring degraded performance or visible damage to more than one safety system train caused by the specified events. This revised wording is a deviation from the NEI 99-01, Revision 6 CA6 and SA9 generic wording and bases but is deemed acceptable consistent with endorsed NRC EP FAQ 2016-002.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 53 of 123 Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction N/A N/A N/A Note 9: If the affected Added Note 9 consistent with the recommendation of NRC EP FAQ SAFETY SYSTEM 2016-002. train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted. Added Note 10 consistent with the recommendation of NRC EP FAQ Note 10: If the hazardous 2016-002. 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.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 54 of 123 Table C-6 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 DSEO/ADTS

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 55 of 123 Table 4 - MPS3 Comparison Matrix " Category C: Cold Shutdown / Refueling System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) CS1 Loss of (reactor vessel/RCS CS1 Loss of RCS inventory affecting None [PWR] or RPV [BWR]) inventory core decay heat removal affecting core decay heat capability removal capability. MODE: 5 - Cold Shutdown, 6 - MODE: Cold Shutdown, Refueling Refueling NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 a. CONTAINMENT CLOSURE Millstone 3 includes in its Inadequate Core Cooling instrumentation a not established. reactor vessel level monitoring system (RVLMS) that is displayed to the operators and can measure discrete reactor vessel water levels AND from the top of the reactor vessel head to the top of the core plate

b. (Reactor vessel/RCS [PWR] (19% sensor - approximately 1O inches above the top of the active or RPV [BWR]) level less than fuel). The bottom of this instrument's span in the reactor vessel (site-specific level). plenum is the lowest available reactor vessel level indicator and is RVLMS plenum level reading used in this EAL to represent approximately the top of active fuel.

CS1.1 19% (Note 12) 2 a. CONTAINMENT CLOSURE - RVLMS is only required to be operable in Modes 1, 2 and 3. For plant established. conditions in which RVLMS is disconnected or otherwise inoperable, AND such as in the Refueling mode, classification _should be made based on CS1 .2 when RCS water level cannot be monitored.

b. (Reactor vessel/RCS [PWR]

or RPV [BWR]) level less than (site-specific level).

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 56 of 123 Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction 3 a. (Reactor vessel/RCS [PWR] CS1.2 RCS level cannot be monitored Site-specific applicable sumps and tanks are listed in Table C-1 to or RPV [BWR]) level cannot for 2! 30 min. (Note 1) improve the readability of the EAL. be monitored for 30 minutes AND Although "Visual observation ... " in Table C-1 is neither a sump nor or longer. Core uncovery is indicated by tank, it is included in order to implement the intent of the NEI basis any of the following: AND which states: " ... operators may determine that an inventory loss is

b. Core uncovery is indicated by

UNPLANNED rise in any occurring by observing changes ... "

ANY of the following: Table C-1 sump or tank The site-specific radiation monitor readings are those that would be level of sufficient magnitude indicative of core uncovery in the Refueling operating condition.

             *    (Site-specific radiation monitor) reading greater to indicate core uncovery      Radiation monitors such as RMS-4A and RMS-5A detect containment

Visual observation of dose rate.

than (site-specific value) UNISOLABLE RCS The radiation monitor reading is any CTMT ARM that would be

Erratic source range monitor indication [PWR]

leakage of sufficient magnitude to indicate core indicative of core uncovery in the Refueling operating condition. A reading > 3 R/hr is indicative of likely core uncovery while in the uncovery

UNPLANNED increase in (site-specific sump and/or Refueling mode.
Any CTMT area radiation No other site-specific indications of core uncovery have been tank) levels of sufficient monitor reading > 3 R/hr identified for MPS3.

magnitude to indicate (Refueling Mode) core uncovery

Erratic source range

             *    (Other site-specific indications) monitor indications Note      The Emergency Director should       N/A   Note 1: The DSEO/ADTS               The classification timeliness note has been standardized across the declare the Site Area                               should declare the        MPS3 EAL scheme by referencing the "time limit" specified within the Emergency promptly upon                             event promptly upon       EAL wording.

determining that 30 minutes has determining that the been exceeded, or will likely be time limit has been exceeded exceeded, or will likely be exceeded. N/A N/A N/A Note 12: This EAL is only Added note 12 to ensure user adheres to operability requirements for applicable if a RVLMS use of the RVLMS indicator. 19% sensor is operable.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C _Page 57 of 123 Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown I Refueling System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) CG1 Loss of (reactor vessel/RCS CG1 Loss of RCS inventory affecting None [PWR] or RPV [BWR]) inventory fuel clad integrity with affecting fuel clad integrity with containment challenged containment challenged MODE: 5 - Cold Shutdown, 6 - MODE: Cold Shutdown, Refueling Refueling NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 a. (Reactor vessel/RCS [PWR] CG1.1 RVLMS plenum level reading Millstone 3 includes in its Inadequate Core Cooling or RPV [BWR]) level less than 19% for ;;: 30 min. (Notes 1, 12) instrumentation a reactor vessel level monitoring system (site-specific level) for 30 (RVLMS) that is displayed to the operators and can measure AND minutes or longer. discrete reactor vessel water levels from the top of the reactor Any Containment Challenge vessel head to the top of the core plate (19% sensor - AND indication, Table C-2 approximately 10 inches above the top of the active fuel). The

b. ANY indication from the bottom of this instrument's span in the reactor vessel plenum is Containment Challenge Table the lowest available reactor vessel level indicator and is used in (see below). this EAL to represent approximately the top of active fuel.

RVLMS is only required to be operable in Modes 1, 2 and 3. For plant conditions in which RVLMS is disconnected or otherwise inoperable, such as in the Refueling Mode, classification should be made based on CG1 .2 when RCS wate"r level cannot be monitored.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 58 of 123 Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction 2 a. (Reactor vessel/RCS [PWR] CG1.2 RCS level cannot be monitored Site-specific applicable sumps and tanks are listed in Table C-1 or RPV [BWR]) level cannot for~ 30 min. (Note 1) to improve the readability of the EAL. be monitored for 30 minutes Although "Visual observation ... " in Table C-1 is neither a sump AND or longer. nor tank, it is included in order to implement the intent of the NEI AND Core uncovery is indicated by basis which states:" ... operators may determine that an inventory any of the following: loss is occurring by observing changes ... "

b. Core uncovery is indicated by

           . ANY of the following:

UNPLANNED rise in any Table C-1 sump or tank The site-specific radiation monitor readings are those that would be indicative of core uncovery in the Refueling operating

             *    (Site-specific radiation monitor) reading greater level of sufficient magnitude to indicate condition. Radiation monitors RMS-4A and RMS-5A detect containment dose rate.

than (site-specific value) core uncovery The radiation monitor reading is any CTMT ARM that would be

Erratic source range monitor indication [PWR]
Visual observation of UNISOLABLE RCS indicative of core uncovery in the Refueling operating condition.

A reading > 3 R/hr is indicative of likely core uncover while in the leakage of sufficient

UNPLANNED increase in (site-specific sump and/or magnitude to indicate Refueling mode approximately 3 R/hr when water level is at the top of active fuel.

core uncovery tank) levels of sufficient No other site-specific indications of core uncovery have been magnitude to indicate core uncovery

Any CTMTarea radiation monitor reading > 3 R/hr identified for MPS3 .

4% hydrogen concentration in the presence of oxygen is the (Refueling Mode)

             *    (Other site-specific                                                   minimum necessary to support a hydrogen explosion .

indications)

Erratic source range monitor indications AND AND c: ANY indication from the Containment Challenge Table Any Containment Challenge (see below). indication, Table C-2 Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across declare the General Emergency declare the event the MPS3 EAL scheme by referencing the "time limit" specified promptly upon determining that promptly upon within the EAL wording.

30 minutes has been exceeded, determining that the time or will likely be exceeded. limit has been exceeded, or will likely be exceeded.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 59 of 123 Table 4 - MPS3 Comparison Matrix Category C: Cold Shutdown / Refueling System Malfunction Note 6: If CONTAINMENT Note 6 implements the asterisked note associated with the CLOSURE is re- Containment Closure requirement. N/A established prior to exceeding the 30-min. time limit, declaration of a General Emergency is not required. Note 12: This EAL is only Added note 12 to ensure user adheres to operability applicable if a RVLMS requirements for use of the RVLMS indicator. channel #8 string is operable. Containment Challenge Table

CONTAINMENT CLOSURE not established*

                             *  (Explosive mixture) exists inside containment

UNPLANNED increase in containment pressure
Secondary containment radiation monitor reading above (site-specific value) [BWR]
If CONTAINMENT CLOSURE is. re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

Table C-2 Containment Challenge Indications

CONTAINMENT CLOSURE not established (Note 6)
CTMT hydrogen concentration > 4%
UNPLANNED increase in CTMT pressure

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 60 of 123 Table 4 - MPS3 Comparison Matrix Category D: Permanently Defueled Station Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) PD-AU1 Recognition Category D N/A N/A NEI Recognition Category PD ICs and EALs are applicable only to PD-AU2 Permanently Defueled Station permanently defueled stations. MPS3 is not a defueled station. PD-SU1 PD-HU1 PD-HU2 PD-HU3 PD-AA1 PD-AA2 PD-HA1 PD-HA3

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 61 of 123 Table 4 - MPS3 Comparison Matrix Category E: Independent Spent Fuel Storage Installation MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) E-HU1 Damage to a loaded cask EU1 Damage to a loaded cask None CONFINEMENT BOUNDARY CONFINEMENT BOUNDARY MODE: All MODE:All NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Damage to a loaded cask EU1.1 Damage to a loaded cask The specified dose rates represent 2 times the site-specific cask CONFINEMENT BOUNDARY as CONFINEMENT BOUNDARY technical specification allowable levels per the ISFSI Technical indicated by an on-contact as indicated by an on-contact Specifications. ' radiation reading greater than (2 radiation reading on the surface times the site-specific cask of a loaded spent fuel cask . specific technical specification (HSM) > any of the following: allowable radiation level) on the surface of the spent fuel cask.

1,700 mrem/hr on the HSM front bird screen
400 mrem/hr on the outside HSM door
12 mrem/hr on the HSM end shield wall

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 62 of 123 Table 4 - MPS3 Comparison Matrix Category F: Fission Product Barrier Degradation NEI MPS3 NEI Threshold Wording MPS3 FPB Wording Difference Justification FPB# FPB #(s) PWR Fuel Clad Fission Product Barrier Degradation Thresholds FC Loss RCS or SG Tube Leakage N/A N/A N/A 1 Not Applicable FC Loss Inadequate Heat Removal FC Loss 1. Core Cooling-RED Path Consistent with the generic developers note options CSFST Core conditions met Cooling Red Path is used in lieu of CET temperatures. 2 A. Core exit thermocouple 8.1 readings greater than (site-specific temperature value). FC Loss, RCS Activity/CMNT Rad FC Loss 2. Sustained CTMT high range RE-04Af05A are the Containment High Range area radiation C.2 radiation monitor RE- monitors. The threshold values specified in Table F-2 have been 3 A. Containment radiation 04Af05A reading > Table F- calculated assuming the instantaneous release and dispersal of monitor reading greater 2 column Fuel Clad Loss the reactor coolant noble gas and iodine inventory associated than (site-specific value) (Note 14) with approximately 5% fuel clad damage. OR Added the word "sustained" and new Note 14 to provide B. (Site-specific indications guidance on the effect of thermally induced currents (TIC) on that reactor coolant activity post-LOCA containment radiation monitor reading. is greater than 300 µCi/gm "Note 14: Readings are considered sustained when effects of dose equivalent 1-131) TIC have dissipated." FC Loss 3. Coolant activity > 300 None C.3 µCi/gm dose equivalent 1-131 FC Loss 4. Dose rate at 1 ft. from an Per Engineering Calculation RA-0059, the specified Table F-3 C.4 unpressurized RCS sample dose rates are assumed to result from radioactive iodines (l-131

                                                           ;;: Table F-3              thru 1-135) in RCS in concentrations corresponding to the loss of 5% of gap radioactivity of the core.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 63 of 123 Table 4 - MPS3 Comparison Matrix Category F: Fission Product Barrier Degradation NEI MPS3 Difference Justification NEI Threshold Wording MPS3 FPB Wording FPB# FPB #(s) FC Loss 5. Sample line dose rate Per Engineering Calculation RA-0079, dose rate is assumed to C.5 threshold ;;: Table F-4 result from radioactive iodines in the RCS in concentrations corresponding to the loss of 5% of gap radioactivity of the core. FC Loss CNMT Integrity or Bypass N/A N/A N/A 4 Not Applicable FC Loss Other Indications N/A N/A No other site-specific Fuel Clad Loss indication has been identified 5 for MPS3. A. (site-specific as applicable) FC Loss ED Judgment FC Loss 6. Any condition in the opinion None E.6 of the DSEO/ADTS that 6 A. ANY condition in the indicates loss of the Fuel opinion of the Emergency Clad barrier Director that indicates Loss of the Fuel Clad Barrier. FC RCS or SG Tube Leakage FC Pot. N/A See FC Pot Loss 8.1. The RCS level threshold is implemented as P-Loss Loss CSFST Core Cooling Orange Path conditions met. A. RCS/reactor vessel level A.1 1 less than (site-specific level) FC Inadequate Heat Removal FC Pot. 2. Core Cooling-ORANGE Consistent with the generic developers note options CSFST Core P-Loss Loss Path conditions met Cooling Orange Path is used in lieu of CET temperatures. A. Core exit thermocouple B.1 2 readings greater than (site-

Serial No. 18-364 MPS3 - EAL Comparison Matr\x Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 64 of 123 Table 4 - MPS3 Comparison Matrix Category F: Fission Product Barrier Degradation NEI MPS3 NEI Threshold Wording MPS3 FPB Wording Difference Justification FPB# FPB #{s) specific temperature value) FC Pot. 3. Heat Sink-RED Path Consistent with the generic developers note options CSFST Heat OR Loss conditions met Sink Red Path is used. 8.2 AND B. Inadequate RCS heat Added the phrase "Required feedwater flow cannot be established Required feedwater flow removal capability via within 15 min. (Note 1)"This precludes the need for classification cannot be established within steam generators as for conditions that indicate the feed flow requirements have been 15 min. (Note 1) indicated by (site-specific satisfied in accordance with FR-H.1. For example, FR-H.1 is indications). entered from CSFST Heat Sink-Red. Step-1 tells the operator to determine if heat sink is required by checking that RCS pressure is greater than any non-faulted SG pressure and RCS T hot is greater than 350°F. If these conditions exist, Heat Sink is required. Otherwise, the operator is to either go to the procedure and step in

                                     -                                               effect or place RHR in service for heat removal. For large LOCA events inside the Containment, the SGs are irrelevant because heat removal through the containment heat removal systems takes place. Therefore, Heat Sink Red is not applicable and should not be assessed for EAL classification because a LOCA event alone should not require higher than an Alert classification.

However, required feed flow may be less than 530 gpm (Heat Sink Red Path entry criteria) and still be acceptable based on the exit criteria from FR-H.1. Per FR-H.1, feed flow can be less than 530 gpm and be considered acceptable if reduced feed flow is due to operator action or if WR level in at least one SG is increasing and Core Exit TCs are stable or decreasing. The 15 minute allowance provides time for equipment actuation, operator action to restore feedwater flow, and verification hat adequate feedwater flow has been established. Added Note 1 consistent with thresholds with timing components.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 65 of 123 Table 4 - MPS3 Comparison Matrix Category F: Fission Product Barrier Degradation NEI MPS3 NEI Threshold Wording MPS3 FPB Wording Difference Justification FPB# FPB #(s) FC RCS Activity/CMNT Rad N/A N/A N/A P-Loss Not Applicable 3 FC CNMT Integrity or Bypass N/A N/A N/A P-Loss Not Applicable 4 FC Other Indications N/A N/A No other site-specific Fuel Clad Potential Loss indication has been P-Loss identified for MPS3. A. (site-specific as applicable) 5 FC Emergency Director FC Pot. 4. Any condition in the opinion None P-Loss Judgment Loss of the DSEO/ADTS that E.3 indicates potential loss of the 6 A. Any condition in the Fuel Clad barrier. opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 66 of 123 Table 4 - MPS3 Comparison Matrix Category F: Fission Product Barrier Degradation MPS3 FPB NEI FPB# NEI IC Wording MPS3 FPB Wording Difference Justification

                                                #(s)

PWR RCS Fission* Product Barrier Degradation Thresholds RCS Loss RCS or SG Tube Leakage RCS Loss 1. An automatic or manual None A.1 Safety Injection (SI) 1 A. An automatic or manual ECCS (SI) actuation is actuation required by required by EITHER of the EITHER: following:

UNISOLABLE RCS

1. UNISOLABLE RCS leakage leakage *

SG tube RUPTURE OR

2. SG tube RUPTURE.

RCS Loss Inadequate Heat Removal N/A N/A N/A 2 Not Applicable RCS RCS Activity/CMNT Rad RCS Loss 2. Sustained CTMT high RE-04A/05A are the Containment High Range area radiation Loss C.2 range radiation monitor RE- monitors. A reading > 5 R/hr (minimum practical reading) on A. Containment radiation 3 04A/05A reading > Table F- RE-04A/05A is indicative of a brea.ch in the RCS barrier. monitor reading greater 2 column RCS Loss than (site-specific value). Added the word "sustained" and new Note 14 to provide (Note 14) guidance on the effect of thermally induced currents (TIC) on post-LOCA containment radiation monitor reading.

                                                                                         "Note 14: Readings are considered sustained when effects of TIC have dissipated."

RCS Loss CNMT Integrity or Bypass N/A N/A N/A 4 Not Applicable

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 67 of 123 Table 4 - MPS3 Comparison Matrix Category F: Fission Product Barrier Degradation MPS3 FPB NEI FPB# NEI IC Wording MPS3 FPB Wording Difference Justification

                                                  #(s)

RCS Other Indications N/A N/A No other site-specific RCS Loss indication has been identified Loss for MPS3. A. (site-specific as applicable) 5 RCS Loss Emergency Director RCS Loss 3. Any condition in the None Judgment E.3 opinion of the 6 DSEO/ADTS that A. ANY condition in the indicates loss of the RCS

        -         opinion of the Emergency barrier Director that indicates Loss of the RCS Barrier.

RCS RCS or SG Tube Leakage RCS Pot. 1. Operation of a second Changed the word "standby to "second" charging pump to Loss charging pump is required align with MPS3 terminology. P-Loss 1 A. Operation of ;:i. standby A.1 by EITHER: charging (makeup) pump is required by EITHER of the

UNISOLABLE RCS following: leakage

1. UNISOLABLE RCS

SG tube leakage leakage OR RCS Pot. 2. Integrity-RED Path Consistent with the generic developers note options CSFST

2. SG tube leakage. Loss conditions met Integrity Red Path is used.

A.2 OR B. RCS cooldown rate greater than (site-specific pressurized thermal shock criteria/limits defined by site-specific indications).

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 68 of 123 Table 4 - MPS3 Comparison Matrix Category F: Fission Product Barrier Degradation MPS3 FPB NEI FPB# NEI IC Wording MPS3 FPB Wording Difference Justification

                                                 #(s)

RCS Inadequate Heat Removal RCS Pot. 3. Heat Sink-RED Path Consistent with the generic developers note options CSFST Loss conditions met Heat Sink Red Path is used. P-Loss 2 A. Inadequate RCS heat B.3 AND removal capability via steam Added the phrase "Required feedwater flow cannot be Required feedwater flow generators as indicated by established within 15 min. (Note 1)"This precludes the need for cannot be established (site-specific indications). classification for conditions that indicate the feed flow within 15 min. (Note 1) requirements have been satisfied in accordance with FR-H.1. For example, FR-H.1 is entered from CSFST Heat Sink-Red. Step 1 tells the operator to determine if heat sink is required by checking that RCS pressure is greater than any non-faulted SG pressure and RCS Thot is greater than 350°F. If these conditions exist, Heat Sink is required. Otherwise, the operator is to either go to the procedure and step in effect or place RHR in service for heat removal. For large LOCA events inside the Containment, the SGs are irrelevant because heat removal through the containment heat removal systems takes place. Therefore, Heat Sink Red is not applicable and should not be assessed for EAL classification because a LOCA event alone should not require higher than an Alert classification. However, required feed flow may be less than 530 gpm (Heat Sink Red Path entry criteria) and still be acceptable based on the exit criteria from FR-H.1. Per FR-H.1, feed flow can be less than 530 gpm and be considered acceptable if reduced feed flow is due to operator action or if WR level in at least one SG is increasing and Core Exit TCs are stable or decreasing. The 15 minute allowance provides time for equipment actuation, operator action to restore feedwater flow, and verification hat adequate feedwater flow has been established. Added Note 1 consistent with thresholds with timing components.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 69 of 123 Table 4 - MPS3 Comparison Matrix Category F: Fission Product Barrier Degradation MPS3 FPB NEI FPB# NEI IC Wording MPS3 FPB Wording Difference Justification

                                                #(s)

RCS CS Activity/CMNT Rad N/A N/A N/A P-Loss 3 Not Applicable RCS CNMT Integrity or Bypass N/A N/A N/A P-Loss 4 Not Applicable RCS Other Indications N/A N/A No other site-specific RCS Potential Loss indication has been identified for MPS3. P-Loss 5 A. (site-specific as applicable) RCS Emergency Director RCS Pot. 4. Any condition in the opinion None Judgment Loss of the DSEO/ADTS that P-Loss 6 E.4 indicates potential loss of A. ANY condition in the the RCS barrier opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 70 of 123 Table 4 - MPS3 Comparison Matrix Category F: Fission Product Barrier Degradation MPS3 FPB NEI FPB# NEI IC Wording MPS3 FPB Wording Difference Justification

                                               #(s)

PWR Containment Fission Product Barrier Degradation Thresholds CNMT Loss RCS or SG Tube Leakage CTMT 1. A leaking or RUPTURED None Loss SG is FAULTED outside of 1 A. A leaking or RUPTURED A.1 CTMT SG is FAULTED outside of containment. CNMT Loss Inadequate Heat Removal N/A N/A N/A 2 Not Applicable CNMT Loss RCS Activity/CMNT Rad N/A N/A N/A 3 Not applicable

2. CTMT isolation (CIA)

CNMT Loss CNMT Integrity or Bypass CTMT CTMT isolation (CIA) Phase A is the MSP3 specific Phase A is required Loss terminology for containment isolation actuation. 4 A. Containment isolation is AND EITHER: D.2 required

CTMT integrity has Added the word "atmosphere" to the second bulleted threshold been lost based on to reinforce the generic bases that the _intent is an unisolable AND DSEO/ADTS pathway from the containment atmosphere, not RCS. RCS EITHER of the following: -. judgment leakage outside containment is addressed under CTMT Loss 0.3 below.

1. Containment integrity

UNISOLABLE has been lost based on pathway from CTMT Emergency Director atmosphere to the environment exists

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 71 of 123 Table 4 - MPS3 Comparison Matrix Category F: Fission Product Barrier Degradation MPS3 FPB NEI FPB# NEI IC Wording MPS3 FPB Wording Difference Justification

                                               #(s) judgment.

CTMT 3. Indications of RCS leakage None Loss outside of CTMT OR D.3

2. UNISOLABLE pathway from the containment to the environment exists.

OR B. Indications of RCS leakage outside of containment. CNMT Loss Other Indications N/A N/A No other site-specific containment Loss indication has been identified for MPS3. 5 A. (site-specific as applicable) CNMT Emergency Director CTMT 4. Any condition in the None Loss Judgment Loss opinion of the DSEO/ADTS 6 E.4 that indicates loss of the ANY condition in the opinion of CTMT barrier the Emergency Director that indicates Loss of the Containment Barrier. CNMT P- RCS or SG Tube Leakage N/A N/A N/A Loss Not Applicable 1

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 72 of 123 Table 4 - MPS3 Comparison Matrix Category F: Fission Product Barrier Degradation MPS3 FPB Difference Justification NEI FPB# NEI IC Wording MPS3 FPB Wording

                                                      #(s)

CNMT Inadequate Heat Removal CTMT Pot. 1. Core Cooling-RED Path Consistent with the generic developers note options CSFST P-Loss Loss conditions met Core Cooling Red Path is used. A. 1. (Site-specific criteria for B.1 AND 2 entry into core cooling restoration procedure) Restoration procedures not AND. effective within 15 min. (Note 1)

2. Restoration procedure not effective within 15 minutes.

CNMT P- RCS Activity/CMNT Rad CTMT Pot. 2. Sustained CTMT high RE-04A/05A are the containment High Range area radiation Loss Loss range radiation monitor monitors. The radiation monitor readings specified in Table F-2 A. Containment radiation C.2 RE-04A/05A reading > column CTMT Potential Loss correspond to an instantaneous 3 monitor reading greater than release of all reactor coolant mass into the containment, Table F-2 column CTMT (site-specific value). assuming that 20% of the fuel cladding has failed. Potential Loss (Note 14) Added the word "sustained" and new Note 14 to provide guidance on the effect of thermally induced currents (TIC) on post-LOCA containment radiation monitor reading.

                                                                                                "Note 14: Readings are considered sustained when effects of TIC have dissipated."

CNMT P- CNMT Integrity or Bypass CTMT Pot. 3. CTMT pressure > 60 psia If containment pressure exceeds the design pressure of 60 Loss Loss psia, there exists a potential to lose the containment barrier A. Containment pressure D.3 4 greater than (site-specific

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 73 of 123 Table 4 - MPS3 Comparison Matrix Category F: Fission Product Barrier Degradation MPS3 FPB NEI FPB# NEI IC Wording MPS3 FPB Wording Difference Justification

                                                   #(s) value)                                                                     A containment hydrogen concentration of 4% conservatively CTMT Pot. 4. CTMT hydrogen OR                               Loss        concentration                 represents the lowest threshold for flammability in the presence 0.4        >4%                           of oxygen.

B. Explosive mixture exists inside containment OR C. 1. Containment pressure greater than (site- CTMT Pot. 5. CTMT pressure > 25 psia The containment pressure setpoint (25 psia) is the pressure at specific pressure Loss with < one full train of which the containment depressurization equipment should setpoint) 0.5 CTMT heat removal actuate and begin performing its function. systems (Note 11) AND Added Note 1 consistent with other thresholds with a timing operating per design for ~ component.

2. Less than one full train 15 min. (Note 1) of (site-specific system Added Note 11 to define what constitutes a full train of or equipment) is containment heat removal systems.

operating per design for 15 minutes or longer. CNMT Other Indications N/A N/A N/A P-Loss A. (site-specific as applicable) 5 CNMT Emergency Director CTMT Pot. 6. Any condition in the None P-Loss Judgment Loss opinion of the DSEO/ADTS E.6 that indicates potential loss 6 A. ANY condition in the opinion of the CTMT barrier of the Emergency Director that indicates Potential Loss of the Containment Barrier.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 74 of 123 Table F-2 CTMT High Range Radiation Monitor Barrier Thresholds RE-04A/05A Time > Shutdown Fuel Clad Loss RCS Loss CTMT Potential Loss (hrs) (R/hr) (R/hr) (R/hr) S2 140 5 560

                                     >2-S4                    90                    5                 360
                                     >4-S8                   50                     5                 200
                                   > 8 - s 14                25                     5                 100
                                      >14                     12                    5                  48 Table F-3      FC Loss Coolant Activity Dose Rates Time> Shutdown (hrs)                     mR/hr/ml S2                                 15
                                                   >2-S8                                  8
                                                      >8                                 3 Table F-4      FC Loss RCS Sample Line Dose Rates Time> Shutdown (hrs)                       R/hr S2                                  4
                                                   >2-SB                                 2
                                                      >8                                  1

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 75 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) HU1 Confirmed SECURITY HU1 Confirmed SECURITY None CONDITION or threat CONDITION or threat. MODE: All MODE:AII NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 A SECURITY CONDITION that HU1 .1 A SECURITY CONDITION that Example EALs #1, 2 and 3 have been combined into a single EAL does not involve a HOSTILE does not involve a HOSTILE for ease of presentation and use. ACTION as reported by the (site- ACTION as reported by MPS The "MPS Security Shift Supervision" is the site-specific "security specific security shift Security Shift Supervision shift supervision." supervision). OR 2 Notification of a credible security Notification of a credible security threat directed at the site. threat directed at the site 3 A validated notification from the OR NRC providing information of an A validated notification from the aircraft threat. NRC providing information of an aircraft threat

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 76 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#{s) HU2 Seismic event greater than OBE HU2 Seismic event greater than OBE None levels levels MODE: All MODE:AII NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Seismic event greater than HU2.1 Seismic event > OBE as For both MPS3 and MPS2, the QBE ground acceleration thresholds Operating Basis Earthquake indicated by OBE alarm light on are > 0.09g horizontal or > 0.06g vertical. The MPS3 Control Room (OBE) as indicated by: Panel 3ERS-PNLSM1 C has real time OBE exceedance alarm indications. Therefore classification shall be based upon the receipt of the MPS3 OBE (site-specific indication that a alarm light on MPS3 Panel 3ERS-PNLSM1 C. The MPS3 Control seismic event met or exceeded Room will notify MPS2 if the seismic event exceeded the OBE OBE limits) threshold. '

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 77 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) HU3 Hazardous event. HU3 Hazardous event None MODE: All MODE: All NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 A tornado strike within the HU3.1 A tornado strike within the None PROTECTED AREA. PROTECTED AREA 2 Internal room or area flooding of a HU3.2 Internal room or area FLOODING Changed the word "needed" to "required by Technical magnitude sufficient to require of a magnitude sufficient to Specification". Plant Technical Specifications specify the needed manual or automatic electrical require manual or automatic safety systems for the current operating mode. isolation of a SAFETY SYSTEM electrical isolation of a SAFETY component needed for the current SYSTEM component required by operating mode. Technical Specifications for the current operating mode 3 Movement of personnel within the HU3.3 Movement of personnel within the Replaced the phrase " ... due to an offsite event..." to " ... due to an PROTECTED AREA is impeded PROTECTED AREA is event external to the PROTECTED AREA ... " The impact of a due to an offsite event involving IMPEDED due to an event hazardous material originating from offsite (outside the OCA) would hazardous materials (e.g., an external to the PROTECTED be the same as one originating from onsite but outside the offsite chemical spill or toxic gas AREA involving hazardous Protected Area. release). materials (e.g., an offsite chemical spill or toxic gas release)

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 78 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety 4 A hazardous event that results in HU3.4 A hazardous event that results in Added reference to Note 7. on-site conditions sufficient to on-site conditions sufficient to prohibit the plant staff from prohibit the plant staff from accessing the site via personal accessing the site via personal vehicles. vehicles (Note 7) 5 (Site-specific list of natural or N/A N/A No other site-specific hazard has been identified for MPS3. technological hazard events) Note EAL #3 does not apply to routine N/A Note 7: This EAL does not This note, designated Note #7, is intended to apply to generic traffic impediments such as fog, apply to routine traffic example EAL #4, not #3 as specified in the generic guidance. snow, ice, or vehicle breakdowns impediments such as or accidents. fog, snow, ice, or vehicle breakdowns or accidents.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 79 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) - HU4 FIRE potentially degrading the HU4 FIRE potentially degrading the None level of safety of the plant. level of safety of the plant MODE: All MODE: All NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 a. A FIRE is NOT extinguished HU4.1 A FIRE is not extinguished within Table H-1 provides a list of site-specific fire areas. within 15-minutes of ANY of 15 min. of any of the following the following FIRE detection FIRE detection indications (Note indications: 1):

Report from the field (i.e.,

visual observation)

visual Report from the field (i.e.,

observation)

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

1) fire alarms or indications indications

Field verification of a single fire alarm
Field verification of a single fire alarm AND AND

b. The FIRE is located within The FIRE is located within any ANY of the following plant Table H-1 area rooms or areas:

(site-specific list of plant rooms or areas)

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 80 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety 2 a. Receipt of a single fire alarm HU4.2 Receipt of a single fire alarm Table H-1 provides a list of site-specific fire areas. (i.e., no other indications of a (i.e., no other indications of a With regard to Containment Building fire alarms, there is constant air FIRE). FIRE) movement in the enclosed containment due to the operation of the AND AND containment ventilation system. The operating cooling units are drawing air to the units past the smoke detectors. It can be

b. The FIRE is located within The fire alarm is indicating a reasonably expected that a fire that burns for 15 minutes would ANY of the following plant rooms FIRE within any Table H-1 area produce sufficient products of combustion to cause fire detectors in or areas: (excluding Containment Building) multiple zones to alarm. Therefore a single containment fire alarm is (site-specific list of plant rooms or AND not considered VALID.

areas) The existence of a FIRE is not Added Note 14 to clarify validation of a single fire zone alarm in the AND verified within 30 min. of alarm Containment Building. receipt (Notes 1, 14) C. The existence of a FIRE is not verified within 30-minutes of alarm receipt. 3 A FIRE within the plant or ISFSI HU4.3 A FIRE within the PROTECTED MPS has an ISFSI located inside the MPS2 plant Protected Area. [for plants with an ISFSI outside AREA not extinguishedwithin 60 the plant Protected Area] min. of the initial report, alarm or PROTECTED AREA not indication (Note 1) extinguished within 60-minutes of the initial report, alarm or indication. 4 A FIRE within the plant or ISFSI HU4.4 A FIRE within the PROTECTED MPS has an ISFSI located inside the MPS2 plant Protected Area. [for plants with an ISFSI outside AREA that requires an offsite fire Reworded example EAL #4 to better reflect the bases intent that the the plant Protected Area] department to assist with classification is based on a fire that requires an offsite fire PROTECTED AREA that requires extinguishment department to assist with fire extinguishment. firefighting support by an offsite fire response agency to extinguish. Note: The Emergency Director Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the Note N/A should declare the Unusual Event declare the event MPS3 EAL scheme by referencing the "time limit" specified within promptly upon determining that promptly upon the EAL wording. the applicable time has been determining that the time

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 81 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety exceeded, or will likely be limit has been exceeded, exceeded. or will likely be exceeded. N/A See justification above. N/A N/A Note 14:A Containment Building . fire alarm is considered VALID upon receipt of multiple (more than one) fire zone alarms. Table H-1 MPS3 Fire Areas

Containment Building
Auxiliary Building
Control Building
Emergency Generator Enclosure
ESF Building
Main Steam Valve Building
A & B Train Service Water Cubicles
North & South Cable Tunnels
Yard Areas o RWST o DWST

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document . Docket No. 50-423 Enclosure 3, Attachment 1C Page 82 of 123 Table 4 - __MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) HU? Other conditions exist which in the HU? Other conditions existing that in None judgment of the Emergency the judgment of the DSEO Director warrant declaration of a warrant declarati,on of a U E (NO)UE MODE:AII MODE: All NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording ' Difference/Deviation Justification EAL# EAL# 1 OthE;lr conditions exist which in the HU7.1 Other conditions exist which in None judgment of the Emergency the judgment of the DSEO Director indicate that events are in ,,, indicate that events are in progress or have occurred which progress or have occurred which indicate a potential degradation of indicate a potential degradation the level of safety of the plant or of the level of safety of the plant indicate a security threat to facility or indicate a security threat to protection has been initiated. No facility protection has been releases of radioactive material initiated. No releases of requiring offsite response o*r radioactive material requiring monitoring are expected unless offsite response or monitoring further degradation of safety are expected unless further systems occurs. degradation of SAFETY SYSTEMS occurs. ;

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 83 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) HA1 HOSTILE ACTION within the HA1 HOSTILE ACTION within the None OWNER CONTROLLED AREA OWNER CONTROLLED AREA or or airborne attack threat within 30 airborne attack threat within 30 minutes. minutes MODE: All MODE: All NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 A HOSTILE ACTION is occurring or HA1.1 A HOSTILE ACTION is Example EALs #1 and #2 have been combined into a single EAL for has occurred within the OWNER occurring or has occurred within ease of use. CONTROLLED AREA as reported the OCA as reported by MPS The "MPS Security Shift Supervision" is the site-specific "security by the (site-specific security shift Security Shift Supervision shift supervision." supervision). OR 2 A validated notification from NRC of A validated notification from an aircraft attack threat within 30 NRC of an aircraft attack threat minutes of the site. within 30 min. of the site

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 84 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS3 Difference/Deviation Justification NEI IC# NEI IC Wording MPS3 IC Wording IC#(s) HAS Gaseous release impeding HAS Gaseous release IMPEDING Limited mode applicability to the modes specified in Table H-2. access to equipment necessary access to equipment necessary for normal plant operations, for normal plant operations, cooldown or shutdown. cooldown or shutdown MODE: All MODE: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown only) NEI Ex. MPS3 Difference/Deviation Justification NEI Example EAL Wording MPS3 EAL Wording EAL# EAL# 1 a. Release of a toxic, HA5.1 Release of a toxic, corrosive, The site-specific list of plant rooms or areas with entry-related mode corrosive, asphyxiant or asphyxiant or flammable gas into applicability are tabularized in Table H-2. flammable gas into any of the any Table H-2 room or area following plant rooms or areas: AND (site-specific list of plant rooms Entry into the room or area is or areas with entry-related mode prohibited or IMPEDED (Note 5) applicability identified) AND

b. Entry into the room or area is prohibited or impeded.

Note Note: If the equipment in the N/A Note 5: If the equipment in the None listed room or area was listed room or area was already inoperable or already inoperable or out-out-of-service before of-service before the the event occurred, event occurred, then no then no emergency emergency classification classification is is warranted. warranted.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 85 of 123 Table H-2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux. Building El 43' 1, 2, 3 Aux. Building El 24' East MCC/RCA El 24' 3,4 West MCC/RCA El 24' Aux. Building El 3' 8" 3 Containment ESF Building A RHR Cubicle ESF Building B RHR Cubicle ESF Building El 36' 4 ESF Building El 24' East Switchgear West Switchgear

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 86 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) HA6 Control Room evacuation HA6 Control Room evacuation None resulting in transfer of plant resulting in transfer of plant control to alternate locations. control to alternate locations MODE: All MODE: All NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 An event has resulted in plant HA6.1 An event has resulted in plant Auxiliary Shutdown Panel is the site-specific remote shutdown control being transferred from the control being transferred from the panels and local control stations. Control Room to (site-specific Control Room to the Auxiliary remote shutdown panels and Shutdown Panel local control stations).

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 87 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) HA? Other conditions exist which in the HA? Other conditions exist that in the None judgment of the Emergency Director judgment of the DSEO/ADTS warrant warrant declaration of an Alert. declaration of an Alert MODE: All MODE: All NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Other conditions exist which, in the HA7.1 Other conditions exist which, in the None judgment of the Emergency Director, judgment of the DSEO/ADTS, indicate indicate that events are in progress or that events are in progress or have have occurred which involve an actual or occurred which involve an actual or potential substantial degradation of the potential substantial degradation of the level of safety of the plant or a security level of safety of the plant or a security event that involves probable life event that involves probable life threatening risk to site personnel or threatening risk to site personnel or damage to site equipment because of damage to site equipment because of HOSTILE ACTION. Any releases are HOSTILE ACTION. Any releases are expected to be limited to small fractions expected to be limited to small fractions of the EPA Protective Action Guideline of the EPA Protective Action Guideline exposure levels. exposure levels.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 88 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) HS1 HOSTILE ACTION within the HS1 HOSTILE ACTION within the None PROTECTED AREA PROTECTED AREA MODE: All MODE:All NEI Ex. MPS3 Difference/Deviation Justification NEI Example EAL Wording

MPS3 EAL Wording EAL# EAL#

1 A HOSTILE ACTION is occurring HS1.1 A HOSTILE ACTION is occurring or has The "MPS Security Shift Supervision" is the site-specific or has occurred within the occurred within the PROTECTED AREA "security shift supervision." PROTECTED AREA as reported as reported by MPS Security Shift by the (site-specific security shift Supervision supervision).

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 89 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) HS6 Inability to control a key safety HS6 Inability to control a key safety function Deleted defueled mode applicability. Control of the cited function from outside the Control from outside the Control Room safety functions are not critical for a defueled reactor as there Room. is no energy source in the RPV or RCS. MODE: 1 - Power Operation, 2 - Startup, MODE: All 3 - Hot Standby, 4 - Hot Shutdown, 5 - This revised mode applicability is a deviation from the Cold Shutdown, 6 - Refueling NEI 99-01, Revision 6 HS6 generic guidance but is deemed acceptable consistent with endorsed NRC EP FAQ 2015-014. NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 a. An event has resulted in HS6.1 An event has resulted in plant control The Auxiliary Shutdown Panel is the site-specific remote plant control being being transferred from the Control Room shutdown panels and local control stations. transferred from the Control to the Auxiliary Shutdown Panel Added the words " ... of the last licensed operator leaving the Room to (site-specific AND Control Room" to provide criteria for when the 15 minutes remote shutdown panels control clock begins. and local control stations). Control of any of the following key safety functions is not re-established The Mode applicability for the reactivity control safety function AND within 15 min. of the last licensed has been limited to Modes 1, 2, and 3. In Modes 4, 5 and 6,

b. Control of ANY of the operator leaving the Control Room adequate shutdown margin exists under all conditions.

following key safety (Note 1): This revised mode applicability is a deviation from the functions is not

Reactivity (Modes 1, 2 and 3 only) NEI 99-01, Revision 6 HS6 generic guidance but is reestablished within (site-deemed acceptable consistent with endorsed NRC EP specific number of
Core Cooling FAQ 2015-014.

minutes).

RCS heat removal
Reactivity control
Core cooling [PWRJ I RPV water level [BWRJ
RCS heat removal

Serial No. 18-364 MPS3 - EAL Comparison Matrix Do,cument Docket No. 50-423 Enclosure 3, Attachment 1C Page 90 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) . HS? Other conditions exist which in HS? Other conditions existing that in the None the judgment of the Emergency judgment of the DSEO/ADTS warrant Director warrant declaration of a declaration of a Site Area Emergency Site Area Emergency. MODE: All MODE: All NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Other conditions exist which in HS7.1 Other conditions exist which in the None the judgment of the Emergency judgment of the DSEO/ADTS indicate Director indicate that events are that events are in progress or have in progress or have occurred occurred which involve actual or likely which involve actual or likely major failures of plant functions needed major failures of plant functions for protection of the public or HOSTILE needed for protection of the ACTION that results in intentional damage public or HOSTILE ACTION that or malicious acts, (1) toward site results in intentional damage or personnel or equipment that could lead to malicious acts, (1) toward site ! I the likely failure of or, (2) that prevent personnel or equipment that effective access to equipment needed for could lead to the likely failure of the protection of the public. Any releases or, (2) that prevent effective are not expected to result in exposure access to equipment needed for levels which exceed EPA Protective the protection of the public. Any Action Guideline exposure levels beyond releases are not expected to the SITE BOUNDARY. result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 91 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) HG1 HOSTILE ACTION resulting in N/A N/A IC HG1 and associated example EAL are not implemented in loss of physical control of the the MPS3 scheme. facility. There are several other ICs that are redundant with this IC, MODE: All and are better suited to ensure timely and effective emergency declarations. In addition, the development of new spent fuel pool level EALs, as a result of NRC Order EA 051, clarified the intended emergency classification level for sp~nt fuel pool level events. This exclusion of the generic HG1 guidance is a deviation from the NEI 99-01, Revision generic guidance but is deemed acceptable consistent with endorsed NRC EP FAQ 2015-013. NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 a. A HOSTILE ACTION is NIA N/A IC HG1 and associated example EAL is not implemented in occurring or has occurred the MPS3 scheme. within the PROTECTED There are several other IC.s that are redundant with this IC, AREA as reported by the and are better suited to ensure timely and effective (site-specific security shift emergency declarations. In addition, the development of new supervision). spent fuel pool level EALs, as a result of NRC Order EA AND 051, clarified the intended emergency classification level for spent fuel pool level events. This deviation is justified

b. EITHER of the following has because:

occurred:

1. Hostile Action in the Protected Area is bounded by ICs

1. ANY of the following safety HS1 and HS?. Hostile Action resulting in a loss of physical functions cannot be control is bound by EAL HG?, as well as any event that controlled or maintained.

may lead to radiological releases to the public in excess of

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 92 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety

Reactivity control Environmental Protection Agency (EPA) Protective Action Guides (PAGs).
Core cooling

[PWR]/RPV water a. If, for whatever reason, the Control Room must be level [BWR] evacuated, and control of safety functions (e.g., reactivity control, core cooling, and RCS heat

RCS heat removal removal) cannot be reestablished, then IC HS6 would OR apply, as well as IC HS? if desired by the EAL decision-maker.

Damage to spent fuel has occurred or is IMMINENT. b. Also, as stated above, any event (including Hostile Action) that could reasonably be expected to have a release exceeding EPA PAGs would be bound by IC HG?.

c. From a Hostile Action perspective, ICs HS1, HS? and HG? are appropriate, and therefore, make this part of HG1 redundant and unnecessary.

d. From a loss of physical control perspective, ICs HS6, HS? and HG? are appropriate, and therefore, make this part of HG1 redundant and unnecessary.

2. Any event which causes a loss of spent fuel pool level will be bounded by ICs AA2, AS2 and AG2, regardless of whether it was based upon a Hostile Action or not, thus making this part of HG1 redundant and unnecessary.

a. An event that leads to a radiological release will be bounded by ICs AU1, AA1, AS1 and AG1. Events that lead to radiological releases in excess of EPA PAGs will be bounded by EALs AG1 and HG?, thus making this part of HG1 redundant and unnecessary.

ICs AA2, AS2, AG2, AS1, AG1, HS1, HS6, HS? and HG? have been implemented consistent with NEI 99-01 Revision 6 and thus HG1 is adequately bounded as described above. This exclusion of the generic HG1 guidance is a deviation from the NEI 99-01, Revision generic guidance

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 93 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety but is deemed acceptable consistent with endorsed NRC EP FAQ 2015-013.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document DocketNo. 50-423 Enclosure 3, Attachment 1C Page 94 of 123 Table 4 - MPS3 Comparison Matrix Category H: Hazards and Other Conditions Affecting Plant Safety MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) HG? Other conditions exist which in HG? Other conditions exist which in the None the judgment of the Emergency judgment of the DSEO/ADTS warrant Director warrant declaration of a declaration of a General Emergency General Emergency MODE:AII MODE: All NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Other conditions exist which in HG7.1 Other conditions exist which in the None the judgment of the Emergency . judgment of the DSEO/ADTS indicate Director indicate that events are that events are in progress or have in progress or have occurred occurred which involve actual or which involve actual or IMMINENT substantial core degradation IMMINENT substantial core or melting with potential for loss of degradation or melting with containment integrity .or HOSTILE potential for loss of containment ACTION that results in an actual loss of integrity or HOSTILE ACTION physical control of the facility. Releases that results in an actual loss of can be reasonably expected to exceed

physical control of the facility. EPA Protective Action Guideline Releases can be reasonably exposure levels offsite for more than the expected to exceed EPA immediate site area.

Protective Action Guideline exposure levels offsite for more than the immediate site area.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 95 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) SU1 Loss of all offsite AC power MU1 Loss of all offsite AC power None capability to emergency buses for capability to emergency buses for 15 minutes or longer. 15 minutes or longer MODE: Power Operation, Startup, MODE: 1 - Power Operation, 2 - Hot Standby, Hot Shutdown Startup, 3 - Hot Standby, 4 - Hot Shutdown NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Loss of ALL offsite AC power MU1.1 Loss of all offsite AC power 4.16 kV emergency buses 34C and 34D are the site-specific capability to (site-specific capability, Table M-1, to 4.16 kV emergency buses. emergency buses) for 15 minutes emergency buses 34C and 34D Table M-1 lists credited offsite 4.16 kV emergency bus AC power or longer. for ;;: 15 min. (Note 1) sources. Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the declare the Unusual Event declare the event MPS3 EAL scheme by referencing the "time limit" specified within the promptly upon determining that 15 promptly upon EAL wording. minutes has been exceeded, or determining that the time will likely be exceeded. limit has been exceeded, or will likely be I exceeded.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 96 of 123 Table M-1 AC Power Sources Offsite

Unit 3 Normal Station Service Transformer (NSST)
Unit 3 Reserve Station Service Transformer (RSST)

Onsite

EDGA
EDG B
SBO Diesel Generator (if already aligned)

Serial No. 18-364

MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 97 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s)

SU2 UNPLANNED loss of Control MU3 UNPLANNED loss of Control None Room indications for 15 minutes Room indications for 15 minutes or longer. or longer. MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 An UNPLANNED event results in MU3.1 An UNPLANNED event results in The site-specific Safety System Parameter list is tabulated in Table the inability to monitor one or the inability to monitor one or M-2. more of the following parameters more Table M-2 parameters from from within the Control Room for within the Control Room for~ 15 15 minutes or longer. min. (Note 1) Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the declare the Unusual Event declare the event MPS3 EAL scheme by referencing the "time limit" specified within promptly upon determining that promptly upon the EAL wording. 15 minutes has been exceeded, determining that the time or will likely be exceeded. limit has been exceeded, or will likely be exceeded.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 98 of 123 [BWR parameter /is~ rPWR parameter list] Reactor Power Reactor Power RPV Water Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In-Core/Core Exit Temperature Suppression Pool Level Levels in at least (site-specific number) steam qenerators Suppression* Pool Temperature Steam Generator Auxiliary or Emergency Feed Water Flow Table M-2 Safety System Parameters

Reactor power
RCS level
RCS pressure
CET temperature
Level in at least one SG
Auxiliary feedwater flow to at least one SG

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 99 of 123 Tab_le 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 NEI IC# NEl IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) SU3 Reactor coolant activity greater MU4 Reactor coolant activity greater None than Technical Specification than Technical Specification allowable limits. allowable limits MODE: Power Operation, Startup, MODE: 1 - Power Operation, 2 - Hot Standby, Hot Shutdown Startup, 3 - Hot Standby, 4 - Hot Shutdown NEI Ex. MPS3 Difference/Deviation Justification NEI Example EAL Wording MPS3 EAL Wording EAL# EAL# 1 (Site-specific radiation monitor) MU4.1 Dose rate at 1 ft. from an Per Engineering Calculation RA-0059, dose rate is assumed to reading greater than (site-specific unpressurized RCS sample result from radioactive iodines (1-131 thru 1-135) in RCS in value). ~ Table M-4 concentrations corresponding to 60 µCi/gm DEl-131. This value corresponds to the Technical Specification coolant activity limit for iodine spike at full power operations. The values contained in Table M-4 (Tech. Spec. Coolant Activity Dose Rates) represent expected one foot dose rates per ml of sample based on time since reactor shutdown to the time when the sample is taken. 2 Sample analysis indicates that a MU4.2 Sample analysis indicates that a MPS3 Technical Specification 3.4.8, RCS Specific Activity, provides reactor coolant activity value is reactor coolant activity value is > the Technical Specification allowable coolant activity limits. greater than an allowable limit an allowable limit specified in specified in Technical Technical Specification 3.4.8 Specifications.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 100 of 123 Table M-4 Tech. Spec. Coolant Activity Dose Rates Time > Shutdown (hrs) mR/hr/ml

2 0.7

                                            >2-:;; 8                             0.5
                                              >8                                 0.3

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 101 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) SU4 RCS leakage for 15 minutes or MU5 RCS leakage for 15 minutes or None longer. longer MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 RCS unidentified or pressure MU5.1 RCS unidentified or pressure Example EALs #1, 2 and 3 have been combined into a single EAL boundary leakage greater than boundary leakage > 10 gpm for for usability. (site-specific value) for 15 .:: 15 min. minutes or longer. OR 2 RCS identified leakage greater RCS identified leakage > 25 gpm than (site-specific value) for 15 for.:: 15 min. minutes or longer. OR 3 Leakage from the RCS to a Leakage from the RCS to a location outside containment location outside containment greater than 25 gpm for 15 > 25 gpm for.:: 15 min. minutes or longer. (Note 1) Note The Emergency Director should N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the declare the Unusual Event should declare the MPS3 EAL scheme by referencing the "time limit" specified within promptly upon determining that event promptly upon the EAL wording. 15 minutes has been exceeded, determining that the or will likely be exceeded. time limit has been exceeded, or will likely be exceeded.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 102 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) SU5 Automatic or manual (trip MU6 Automatic or manual trip fails to None [PWR] / scram [BWR]) fails to shut down the reactor shutdown the reactor. MODE: 1 - Power Operation MODE: Power Operation NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL#

a. An automatic (trip [PWR] / An automatic trip did not shut As specified in the generic developers guidance "Developers may 1 MU6.1 scram [BWR]) did not down the reactor as indicated by include site-specific EOP criteria indicative of a successful reactor shutdown the reactor. reactor power > 5% after any shutdown in an EAL statement, the Basis or both (e.g., a reactor RPS setpoint is exceeded power level)." Consistent with the MNP3 Emergency Operating AND AND Procedures, a successful shutdown is defined by reactor power

b. A subsequent manual S5%.

action taken at the reactor A subsequent automatic trip or . Added the words" ... after any RPS setpoint is exceeded" to clarify control consoles is EITHER manual trip (Rx Trip that it is a failure of the automatic trip when a valid trip signal has successful in shutting down Switches OR opening breakers been exceeded. the reactor. 32B and 32N) are successful in shutting down the reactor as Added the words "A subsequent automatic trip ... " to the second indicated by reactor powers 5% condition consistent with Example EAL #2 and the generic bases (Note 8) which states "This IC addresses a failure of the RPS to initiate or complete an automatic or manual trip that results in reactor shutdown, and either a subsequent operator manual action ... or automatic trip is successful. .. " Added the word "EITHER" to the second condition associated with subsequent manual trip actions. MPS3 has two means (Rx Trip Switches OR opening breakers 32B and 32N) of initiating a manual trip from the reactor control consoles.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 103 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction 2 a. A manual trip ([PWR] /

MU6.2 A manual trip (Rx Trip Switches As specified in the generic developers guidance "Developers may scram [BWR]) did not OR opening breakers 328 and include site-specific EOP criteria indicative of a successful reactor shutdown the reactor. 32N) did not shut down the shutdown in an EAL statement, the Basis or both (e.g., a reactor reactor as indicated by reactor power level)." Consistent with the MNP3 Emergency Operating AND power> 5% Procedures, a successful shutdown is defined by reactor power

b. EITHER of the following: AND S5%.

1. A subsequent manual A subsequent manual trip OR Rx Trip Switches OR opening breakers 328 and 32N are the means action taken at the automatic trip is successful in of initiating a manual trip from the reactor control consoles.

reactor control consoles shutting down the reactor as 1 is successful in shutting indicated by reactor power down the reactor.

s 5% (Note 8)

OR 2 A subsequent automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor. Note: A manual action is any Notes N/A Note 8: A manual action is any None operator action, or set of operator action, or set of actions, which causes actions, which causes the control rods to be the control rods to be rapidly inserted into the rapidly inserted into the core, and does not core, and does not* include manually driving include manually driving in control rods or in control rods or implementation of boron implementation of boron injection strategies. injection strategies.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 104 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 Difference/Deviation Justification NEI IC# NEI IC Wording MPS3 IC Wording IC#(s) SU6 Loss of all onsite or offsite MU7 Loss of all onsite or offsite None communications capabilities. communications capabilities. MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Loss of ALL of the following MU7.1 Loss of all Table M-5 onsite Example EALs #1 , 2 and 3 have been combined into a single EAL onsite communication methods: communication methods for simplification of presentation. (site-specific list of OR Table M-5 provides a site-specific list of onsite, _offsite (ORO) and communications methods) NRC communications methods. Loss of all Table M-5 offsite communication methods 2 Loss of ALL of the following ORO communications methods: OR (site-specific list of Loss of all Table M-5 NRG communications methods) communication methods 3 Loss of ALL of the following NRC communications methods: (site-specific list of communications methods)

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 105 of 123 Table M-5 Communication Methods State/ System Onsite NRC Local ENRS/ARCOS X Station Radio System X X Plant Phone System X X Public Address System X Gaitronics / Maintenance Jacks X Federal Telephone System (ENS) X Commercial Telephone System X X Satellite Phones X X Dedicated Hotlines X

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 106 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) SU7 Failure to isolate containment or MUS Failure to isolate containment or None loss of containment pressure loss of containment pressure control. [PWR] control MODE: Power Operation, MODE: 1 - Power Operation, 2 - *- Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 a. Failure of containment to MUB.1 Any penetration is not closed Example EALs #1 and #2 have been combined for .usability. isolate when required by an within 15 min. of a VALID P.hase Containment isolation actuation is initiated by either the Phase A or actuation signal. A or B isolation signal B Containment Isolation. AND OR Containment pressure greater than 25 psia is the pressure at which

b. ALL required penetrations CTMT pressure> 25 psia with containment energy (heat) removal systems are designed to are not closed within 15 minutes < one full train of CTMT heat automatically actuate.

of the actuation signal. removal systems (Note 11) / operating per design for .:: 15 min. 2 a. Containment pressure (Note 1) greater than (site-specific pressure). AND

b. Less than one full train of (site-specific system or equipment) is operating per design for 15 minutes or longer.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 107 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction NIA NIA NIA Note 1: The DSEOIADTS should Added note 1 consistent with other EALs with a timing component. declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. NIA NIA NIA Note 11: One full train of Added note 11 to clarify what constitutes a full train of containment containment heat heat removal systems. removal systems consist of one train of Recirculation Spray System (RSS) and one train of Quench Spray System (QSS)

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 108 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) SA1 Loss of all but one AC power MA1 Loss of all but one AC power None source to emergency buses for source to emergency buses for 15 minutes or longer. 15 minutes or longer MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS3 Difference/Deviation Justification NEI Example EAL Wording MPS3 EAL Wording EAL# EAL# 1 a. AC power capability to (site- MA1.1 AC power capability, Table M-1, 4.16 kV emergency buses 34C and 34D are the site-specific specific emergency buses) is to 4.16 kV emergency buses 34C emergency buses. reduced to a single power source and 340 reduced to a single Table M-1 lists credited offsite and onsite 4.16 kV emergency bus for 15 minutes or longer.. power source for ;;: 15 min. AC power sources. (Note 1) AND AND

b. Any additional single power source failure will result in a loss Any additional single power of all AC power to SAFETY source failure will result in loss of SYSTEMS. all AC power to SAFETY SYSTEMS Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the declare the Alert promptly upon declare the event MPS3 EAL scheme by referencing the "time limit" specified within determining that 15 minutes has promptly upon the EAL wording.

been exceeded, or will likely be determining that the time exceeded. limit has been exceeded, or will likely be exceeded.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document *Docket No. 50-423 Enclosure 3, Attachment 1C Page 109 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) SA2 UNPLANNED loss of Control MA3 UNPLANNED loss of Control None Room indications for 15 minutes Room indications for *15 minutes or longer with a significant or longer with a significant transient in progress. transient in progress. MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 An UNPLANNED event results in MA3.1 An UNPLANNED event results in The site-specific Safety System Parameter list is in Table M-2. the inability to monitor one or the inability to monitor one or more Table M-2 parameters from The significant transient list has been tabularized in Table M-3 for more of the following parameters within the Control Room for;.: 15 ease of use. from within the Control Room for 15 minutes or longer. min. (Note 1) AND AND ANY of the following transient Any significant transient is in events in progress. progress, Table M-3

Automatic or manual runback greater than 25%

thermal reactor power -

Electrical load rejection greater than 25% full electrical load I
Reactor scram [BWR] I trip

[PWR]

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 110 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction

ECCS '{SI) actuation Thermal power oscillations greater than 10% [BWR]

Note The Emergency Director should N/A Note 1: The DSEO/ADTS should The classification timeliness note has been standardized across the declare the Unusual Event declare the event promptly upon MPS3 EAL scheme by referencing the "time limit" specified within promptly upon determining that determining that the time limit has the EAL wording. 15 minutes has been exceeded, been exceeded, or will likely be or will likely be exceeded. exceeded. rBWR parameter /is~ [PWR parameter /is~ Reactor Power Reactor Power RPV Water Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In-Core/Core Exit Temperature Suooression Pool Level Levels in at least (site-specific number) steam qenerators Suooression Pool Temperature Steam Generator Auxiliary or Emeraencv Feed Water Flow Table M-2 Safety System Parameters

Reactor power
RCS level
RCS pressure
CET temperature
Level in at least one SG
Auxiliary feedwater flow to at least one SG

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 111 of 123 Table M-3 Significant Transients

Automatic turbine runback > 25% reactor power
Electrical load rejection > 25% full electrical load
Reactor Trip
SIAS Actuation

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 112 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) SA5 Automatic or manual (trip [PWR] MA6 Automatic or manual trip fails to None

          / scram [BWR]) fails to shutdown         shut down the reactor and the reactor, and subsequent              subsequent manual actions manual actions taken at the              taken at the reactor control reactor control consoles are not         consoles are not successful in successful in shutting down the          shutting down the reactor reactor.

MODE: 1 - Power Operation MODE: Power Operation NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 a. An automatic or manual (trip MA6.1 An automatic or manual trip (Rx As specified in the generic developers guidance "Developers may [PWR] / scram [BWR]) did not Trip Switches or opening include site-specific EOP criteria indicative of a successful reactor shutdown the reactor. breakers 328 and 32N) did not shutdown in an EAL statement, the Basis or both (e.g., a reactor shut down the reactor as power level)." Consistent with the MNP3 Emergency Operating AND indicated by reactor power > 5% Procedures, a successful shutdown is defined by reactor power

b. Manual actions taken at the AND ::;;s%.

reactor control consoles are not Subsequent automatic or manual M.PS3 has two means (Rx Trip Switches OR opening breakers 328 successful in shutting down the trip actions (Rx Trip Switches and 32N) of initiating a manual trip from the reactor control consoles. reactor. and opening breakers 328 and 32N) are not successful in shutting down the reactor as indicated by reactor power > 5% (Note B)

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 113 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction Notes Note: A manual action is any N/A Note 8: A manual trip action is None operator action, or set of actions, any operator action, or which causes the control rods to set of actions, which be rapidly inserted into the core, causes the control rods and does not include manually to be rapidly inserted driving in control rods or into the core, and does t implementation of boron injection not include manually strategies. driving in control rods or implementation of boron injection strategies

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 114 of 123 Tabl.e 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) SA9 Hazardous event aft ecting a MA9.1 Hazardous event affecting Revised wording from" ... affecting a SAFETY SYSTEM ... " to read SAFETY SYSTEM needed for SAFETY SYSTEMS needed for "... affecting SAFETY SYSTEMS ... " to align with changes made the current operating mode. the current operating mode consistent with NRC EP FAQ 2016-002. MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL#* 1 a. The occurrence of ANY of MAB.1 The occurrence of any Table The hazardous events have been tabularized in Table M-6. the following hazardous events: M-6 hazardous event The proposed MPS3 CA6.1 and MA9.1 wording is intended to ensure

Seismic event (earthquake) AND that an Alert should be declared only when actual or potential performance issues with SAFETY SYSTEMS have occurred as a
Internal or external flooding Event damage has caused result of a hazardous event. The occurrence of certain hazardous event indications of degraded events may result in an Unusual Event classification at a minimum. In performance on one train of a order to warrant escalation to the Alert classification, the hazardous
High winds or tornado strike SAFETY SYSTEM needed for event should cause indications of degraded performance to one train
FIRE the current operating mode of a SAFETY SYSTEM with either indications of degraded
EXPLOSION AND EITHER: performance on the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second SAFETY SYSTEM train, such that the

           *  (site-specific hazards)

Event damage has operability or reliability of the second train is a concern. In addition, caused indications of escalation to the Alert classification should not occur if the damage
Other events with similar degraded performance to from the hazardous event is limited to a SAFETY SYSTEM that was hazard characteristics as the second train of the inoperable, or out of service, prior to the event occurring. As such, the determined by the Shift SAFETY SYSTEM proposed EALs will reduce the potential of declaring an Alert when Manager needed for the current events are in progress that do not involve an actual or potential AND operating mode substantial degradation of the level of safety of the plant, i.e., does not cause significant concern with shutting down or cooling down the

b. EITHER of the following:

Event damage has resulted in VISIBLE plant.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 115 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction DAMAGE to the second EALs CA6.1 and MA9.1 do not directly escalate to a Site Area

1. Event damage has train of the SAFETY Emergency or a General Emergency due to a hazardous event. The caused indications of SYSTEM needed for the Fission Product Barrier and/or Abnormal Radiation degraded performance in current operating mode - Levels/Radiological Effluent recognition categories would provide an at least one train of a SAFETY SYSTEM (Notes 9, 10) escalation path to a Site Area Emergency or a General Emergency.

needed for the current The EALs and the Basis sections have been revised to ensure operating mode. potential escalations from an Unusual Event to an Alert, due to a OR hazardous event, is appropriate as the concern with these EALs is: (1) a hazardous event has occurred, (2) one SAFETY SYSTEM train

2. The event has caused is having performance issues as a result of the hazardous event, and VISIBLE DAMAGE to a (3) either the second SAFETY SYSTEM train is having performance SAFETY SYSTEM issues or the VISIBLE DAMAGE is enough to be concerned that the component or structure second SAFETY SYSTEM train may have operability or reliability needed for the current issues.

operating mode. The definition for VISIBLE DAMAGE has been revised to reflect the fact that the EALs are based upon SAFETY SYSTEM trains rather than individual components or structures. Note 9 has been added to CA6.1 and MA9.1 as it meets the intent of the EALs, is consistent with other EALs (e.g., EAL HA5.1 which was previously endorsed by the NRC), and ensures that declared emergencies are based upon unplanned events with the potential to pose a radiological risk to the public. Note 10 has been added to CA6.1 and MA9.1 to help reinforce and succinctly capture the more detailed information from the revised basis section related to when conditions would require the declaration of an Alert. CA6.1 and MA9.1 are consistent with NRG FAQ 2016-002 requiring degraded performance or visible damage to more than one safety system train caused by the specified events. This revised wording is a deviation from the NEI 99-01, Revision 6 CAS and SA9 generic wording and bases but is deemed acceptable consistent with endorsed NRC EP FAQ 2016-002.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 116 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction N/A N/A N/A Note 9: If the affected SAFETY Added Note 9 consistent with the recommendation of NRC EP FAQ SYSTEM train was 2016-002. already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted. Note 1O: If the hazardous event Added Note 10 consistent with the recommendation of NRC EP FAQ only resulted in 2016-002. VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 117 of 123 Table M-6 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 DSEO/ADTS

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 118 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) SS1 Loss of all offsite and all onsite MS1 Loss of all offsite power and all None AC power to emergency buses onsite AC power to emergency for 15 minutes or longer. buses for 15 minutes or longer MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS3 ' NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Loss of ALL offsite and ALL MS1.1 Loss of all offsite and all onsite 4.16 kV emergency buses 34C and 34D are the site-specific onsite AC power to (site-specific AC power to 4.16 kV emergency buses. emergency buses) for 15 minutes emergency buses 34C and 340 or longer. for~ 15 min. (Note 1) Note The Emergency Director should N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the declare the Unusual Event should declare the MPS3 EAL scheme by referencing the "time limit" specified within promptly upon determining that event promptly upon the EAL wording. 15 minutes has been exceeded, determining that the or will likely be exceeded. time limit has -been exceeded, or will likely be exceeded.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 119 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) SS5 Inability to shutdown the reactor MS6 Inability to shut down the None causing a challenge to (core reactor causing a challenge to cooling [PWR] I RPV water level core cooling or RCS heat [BWR]) or RCS heat removal. removal MODE: Power Operation MODE: 1 - Power Operation NEI Ex. MPS3 Difference/Deviation Justification NEI Example EAL Wording MPS3 EAL Wording EAL# EAL# The time the EAL is assessed 1 a. An automatic or manual (trip MS6.1 An automatic or manual trip did As specified in the generic developers guidance "Developers may [PWR] / scram [BWR]) did not not shut down the reactor as include site-specific EOP criteria indicative of a successful reactor shutdown the reactor. indicated by reactor power shutdown in an EAL statement, the Basis or both (e.g., a reactor

                                                    >5%                             power level)." Consistent with the MNP3 Emergency Operating AND Procedures, a successful shutdown is defined by reactor power AND

b. All manual actions to S5%.

shutdown the reactor have All actions taken to shut down Added the word "taken" to the second condition to emphasize the been unsuccessful. the reactor are not successful intent that its all actions taken up to the point of either core cooling or as indicated by reactor power AND heat sink is challenged are not successful and to not wait until all

>5%

possible actions have been completed. C. EITHER of the following AND EITHER: conditions exist: CSFST Core Cooling-RED Path is the site-specific indication of

Core Cooling-RED Path inadequate core cooling'

              * (Site-specific indication of conditions met             CSFST Heat Sink-RED Path is the site-specific indication of an inability to adequately remove heat from the core)

Heat Sink-RED Path inadequate heat sink.

conditions met

              * (Site-specific indication of an inability to adequately remove heat from the RCS)

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 120 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#(s) 888 Loss of all Vital DC power for 15 MS2 Loss of all vital DC power for 15 None minutes or longer. minutes or longer. MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 Indicated voltage is less than MS2.1 Indicated voltage is < 105 VDC 105 VDC is the site-specific minimum vital 125V DC bus voltage. (site-specific bus voltage value) on both vital 125 VDC battery Vital 125 VDC battery buses 1 and 2 are the site-specific vital DC on ALL (site-specific Vital DC buses 1 AND 2 for 2:: 15 min. buses credited in this EAL. busses) for 15 minutes or longer. (Note 1) Note The Emergency Director should N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the declare the Unusual Event should declare the MPS3 EAL scheme by referencing the "time limit" specified within the promptly upon determining that event promptly upon EAL wording. 15 minutes has been exceeded, determining that the or will likely be exceeded. time limit has been exceeded, or will likely be exceeded.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 121 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction

            -                                  MPS3 NEI IC#              NEI IC Wording                           MPS3 IC Wording                               Difference/Deviation Justification IC#(s)

SG1 Prolonged loss of all offsite and MG1 Prolonged loss of all offsite and None all onsite AC power to all onsite AC power to emergency buses. emergency buses MODE: Power Operation, MODE: 1 - Power Operation, Startup, Hot Standby, Hot 2 - Startup, 3 - Hot Shutdown Shutdown NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 a. Loss of ALL offsite and ALL MG1.1 Loss of all offsite and all onsite 4. ~ 6 kV emergency buses 34C and 340 are the site-specific onsite AC power to (site-specific AC power to 4.16 kV emergency emergency buses. emergency buses). buses 34C and 34D CSFST Core Cooling-RED Path is the site-specific indication of an AND AND inability to adequately remove heat from the core.

b. EITHER of the following: Core Cooling-RED Path The proposed MPS3 MG1 .1 omits the Station Blackout (SBO) conditions met coping time threshold. As proposed, the General Emergency

Restoration of at least classification would be based a loss of all onsite and offsite AC one AC emergency bus power to the emergency buses with indications of degraded core in less than (site-specific cooling. The MPS3 SBO analysis and derived coping time was hours) is not likely. determined in accordance with 10CFR50.63 and Regulatory Guide (Site-specific indication of an 1.155. This analysis does not take credit for plant capabilities in inability to adequately remove place to mitigate the effects of an extended loss of AC power heat from the core) (ELAP). These capabilities were developed and implemented to meet the requirements of NRG Orders EA-12-049 and EA-12-051, and pending regulations in 10 CFR 5Q.155 (per SECY-16-0142).

In accordance with plant EOPs, operators will declare an ELAP within 45 min. of the loss of all AC power to the emergency buses and direct implementation of FLEX Support Guidelines, including the deployment of dedicated portable equipment and performance of DC

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 122 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction load shedding. Even if no AC emergency bus is energized, these actions will maintain or restore core cooling, containment, and spent fuel pool cooling capabilities indefinitely. Therefore, the underlying basis for the generic EAL coping time statement, that power must be restored to an AC emergency bus within a fixed amount of time to avoid a severe challenge to one or more fission product barriers, is not valid for MPS3. This revised wording is a deviation from the NEI 99-01, Revision 6 SG1 generic wording and bases but is deemed appropriate and acceptable. Note The Emergency Director should N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the declare the General Emergency should declare the MPS3 EAL scheme by referencing the "time limit" specified within promptly upon determining that event promptly upon the EAL wording. (site-specific hours) has been determining that the exceeded, or will likely be time limit has been exceeded. exceeded, or will likely be exceeded.

Serial No. 18-364 MPS3 - EAL Comparison Matrix Document Docket No. 50-423 Enclosure 3, Attachment 1C Page 123 of 123 Table 4 - MPS3 Comparison Matrix Category M: System Malfunction MPS3 NEI IC# NEI IC Wording MPS3 IC Wording Difference/Deviation Justification IC#{s) SGS Loss of all AC and Vital DC MG2 Loss of all emergency AC and None power sources for 15 minutes or vital DC power sources for 15 longer. minutes or longer MODE: Power Operation, MODE: 1 - Power Operation, 2 - Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. MPS3 NEI Example EAL Wording MPS3 EAL Wording Difference/Deviation Justification EAL# EAL# 1 a. Loss of ALL offsite and ALL MG2.1 Loss of all offsite and all onsite 4.16 kV emergency buses 34C and 340 are the site-specific onsite AC power to (site- AC power to 4.16 kV emergency buses. specific emergency buses) for emergency buses 34C and 340 105 VDC is the site-specific minimum vital 125V DC bus voltage. 15 minutes or longer. for ~ 15 min. (Note 1) Vital 125 VDC battery buses 1 and 2 are the site-specific vital DC AND AND buses credited in this EAL.

b. Indicated voltage is less than Indicated voltage is< 105 voe (site-specific bus voltage on both vital 125 VDC battery value) on ALL (site-specific buses 1 AND 2 for ~ 15 min.

Vital DC busses) for 15 (Note 1) minutes or longer. Note The Emergency Director should N/A Note 1: The DSEO/ADTS The classification timeliness note has been standardized across the declare the Unusual Event should declare the MPS3 EAL scheme by referencing the "time limit" specified within promptly upon determining that 15 event promptly upon the EAL wording. minutes has been exceeded, or determining that the will likely be exceeded. time limit has been exceeded, or will likely be exceeded.

Serial No.: 18-364 Docket No.: 50-245 Enclosure 3 ATTACHMENT 2A MPS1 EAL TECHNICAL BASES DOCUMENT (Marked-up) Dominion Energy Nuclear Connecticut, Inc. (DENC) Millstone Power**Station Unit 1.

Serial No. 18-364 Docket No. 50-245 Enclosure 3: Attachment 2A Emergency Action Level Technical Bases Document Millstone Power Station - Unit 1 {Marked-up)

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A Table of Contents

1.0 INTRODUCTION

........................................................................... ;............................ 3 2.0     DISCUSSION .............................................................................................................3 2.1 Background ...........................................................................................................3 2.2 EAL Organization and Technical Bases Information .......*.................................... .4 3.0     GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS .................................. 7 3.1 General Considerations ........................................................................................ 7 3.2Classification Methodology ............................................................._...................... 8

4.0 REFERENCES

......................................................................................................... 11 4.1 Developmental .................................................................................................... 11 4.2 Implementing ....................................................................................................... 11 5.0     DEFINITIONS, ACRONYMS & ABBREVIATIONS ................................................... 12 5.1 Definitions (ref. 4.1.1 except as noted) .... : ........................................................... 12 5.2Abbreviations/Acronyms .'.: .................................................................................. 16 6.0     MPS1-TO-NEI 99-01, Rev. 6 EAL CROSS-REFERENCE ....................................... 18 7 .0    ATTACHMENTS ....................................................................................................... 19 7 .1 Attachment 1, Emergency Action Level Technical Bases ................................... 19 Category R-Abnormal Rad Levels/ Rad Effluent ............................................................. 20 Category H - Hazards .........................................................................................................38 Category M - System Malfunctions .................................. :*************************************************.43 Page 2 of 44

MillstorJe Power Station Unh 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A

1.0 INTRODUCTION

This document provides an explanation and rationale for each Emergency Action Level (EAL) included in the NEI 99-01, Revision 6, EAL Upgrade Project for Millstone Power Station Unit 1 (MPS1 ). It should be used to facilitate review of the MPS1 EALs and provide historical documentation for future reference. Decision-makers responsible for implementation of MP EPI-FAP06, Classification and PARs, may use this document as a technical reference in support of EAL interpretation. This information may assist the Director of Station Emergency Operations (DSEO)/Assistant Director Technical Support (ADTS) in making classifications, particularly those involving judgment or multiple events. The basis information may also be useful in training and for explaining event classifications to off-site officials. The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present. Use of this document for assistance is not intended to delay the emergency classification. Since the information in a basis document can affect emergency classification decision-making (e.g., the DSEO/ADTS refers to it during an event), the NRC staff expects that changes to the basis document will be evaluated in accordance with the provisions of 10 CFR 50.54(q). For Dominion Energy sites, a 10 CFR 50.54(q)(3) screening/evaluation will be performed to evaluate changes to this document. Dominion Energy fleet procedure CM-AA-400, "10 CFR 50.59 and 10 CFR 72.48 - Changes, Tests and Experiments," provides a method to determine the impacts to licensing basis docyments when changes are proposed to procedures, including changes to Abnormal Operating Procedures (AOPs) and Emergency Operating Procedures (EOPs). The 50.59/72.48 applicability review specifically requires that the effect of a proposed procedure change on the Emergency Plan (and associated EALs) be reviewed/assessed. When impacts to the Emergency Plan are identified, a separate review in accordance to 10 CFR 50.54(q) will be performed to determine the acceptability of the proposed procedure change. 2.0 DISCUSSION 2.1 Background EALs are the plant-specific indications, conditions or instrument readings that are utilized to classify emergency conditions defined in the Millstone Power Station (MPS) Emergency Plan. In 2012, the NRC endorsed NEI 99-01, Revision 6, "Methodology for the Development of Emergency Actio'n Levels for Non-Passive Reactors." This methodology includes guidance for development of EAL schemes for a Permanently D~fueled station. This is a station that has generated spent fuel under a 10 CFR 50 license, has permanently ceased operations and stores the spent fuel onsite for an extended period of time. The emergency classification levels applicable to this type of station are consistent with the requirements of 10 CFR 50 and the guidance in NUREG 0654/FEMA-REP-1. NEI 99-01, Revision 6, Recognition Category PD (Permanently Defueled) provides a stand-alone set oflnitiating Conditions (ICs)/EALs for a Permanently Defueled station to consider for use in developing a site-specific emergency classification scheme. For development, it was Page 3 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A assumed that the station had operated under a 10 CFR 50 license and that the licensee has permanently ceased power operations. Further, the licensee intends to store the spent fuel within the plant for some period of time.

When in a permanently defueled condition, a licensee receives approval from the NRC for exemption from specific emergency planning requirements. These exemptions reflect the lowered radiological source term and risks associated with spent fuel pool storage relative to reactor at-power operation. Source terms and accident analyses associated with plausible accidents are documented in the station's Defueled Safety Analysis Report (DSAR), as updated. As a result, a licensee with a permanently defueled station must develop a site-specific emergency classification scheme using the NRC-approved exemptions, revised source terms, and revised accident analyses as documented in the station's DSAR.

Recognition Category PD uses the same Emergency Classification Levels (ECLs) as operating reactors; however, the source term and accident analyses typically limit the ECLs to an Unusual Event and Alert. The Unusual Event ICs provide for an increased awareness of abnormal conditions while the Alert ICs are specific to actual or potential impacts to spent fuel. The source terms and release motive forces associated with a permanently defueled station would not be sufficient to require de_claration of a Site Area Emergency or General Emergency. A permanently defueled station is essentially a spent fu*e1 storage facility with the spent fuel stored in a pool of water that serves as both a cooling medium (i.e., removal of decay heat) and shield from direct radiation. These primary functions of the spent fuel storage pool are the focus of the Recognition Category PD ICs and EALs. Radiological effluent IC and EALs were included to provide a basis for classifying events that cannot be readily classified based on an observable event or plant conditions alone. Appropriate ICs and EALs were included in Recognition Category PD to address a spectrum of events that may affect a spent fuel pool. The Recognition Category PD ICs and EALs reflect the relevant guidance in Section 3.0 of this document (e.g., the importance of avoiding both over-classification and under-classification). MPS1 has developed an emergency classification scheme using the NRG-approved exemptions and the source terms and accident analyses specific to the MPS1. While security-related events are also considered in the generic guidance, classification of security-related events impacting MPS1 are classified under the operating units (Millstone Power Station Units 2 and 3) security EALs. 2.2 EAL Organization and Technical Bases Information EAL technical bases are provided. in Attachment 1, grouped by EAL. A summary is given at the beginning of each group, which provides a brief description of the Category. For each EAL, the following information is provided: EAL Category designator and Title See Table 2.2-1 below for the Category designators and associated titles that are used at MPS1. EAL Subcategory designator and Title See Table 2.2-1 below for the Subcategory designators and associated titles that are used at MPS1. Page 4 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A Initiating Condition (IC) wording Site:-specific description of the generic IC given in NEI 99-01, Rev. 6 and the EAL Classification Matrix EAL identifier (enclosed in rectangle) Each EAL is assigned a unique identifier to support accurate communication of the emergency classification to onsite and offsite personnel. Four characters define each EAL identifier as indicated below:

1. First character (letter): Corresponds to the EAL category as described above

2. Second character (letter): The emergency classification (A or U)

A= Alert U = Unusual Event

3. Third character (number): Subcategory number within the given category.

Subcategories are sequentially numbered beginning with the number one (1 ). If a category does not have a subcategory, this character is assigned the number one (1 ). Subcategories are used in the MPS1 scheme as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The MPS1 EAL categories and subcategories are listed below.

4. Fourth character (number): The numerical sequence of the EAL within the EAL subcategory. If the subcategory has only one EAL, it is given the number one (1 ).

Classification (enclosed in rectangle): Alert (A) or Unusual Event (U) EAL wording (enclosed in rectangle) Exact wording of the EAL as it appears in the EAL Classification Matrix Notes (as applicable) Definition(s ): If the EAL wording contains a defined term, the definition of the term is included in this section. These definitions can also be found in Section 5.1. Basis: An EAL basis section that provides MPS1-relevant information concerning the EAL as well as a description of the rationale for the EAL as provided in NEI 99-01, Rev. 6. Reference(s): Source documentation from which the EAL is derived. Page 5 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A Table 2.2-1: EAL Categories and Subcategories EAL Category EAL Subcategory R - Abnormal Rad Levels / Rad 1 - Radiological Effluent

          *Effluent                          2 - Area Radiation Levels H - Hazards                            1 - Hazardous Events Affecting Plant Safety 2- DSEO/ADTS Judgment M - System Malfunction                 1 - Loss of SFP Cooling Page 6 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A 3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 3.1 General Considerations When making an emergency classification, the DSEO/ADTS must consider all information having a bearing on the proper assessment of an Initiating Condition (IC). This includes the EAL plus any associated Notes and the informing basis information. 3.1.1 Classification Timeliness NRC regulations require the licensee to establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and to promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. The NRC staff has provided guidance on implementing this requirement in NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants" (ref. 4.1. 7). 3.1.2 Valid Indications All emergency classification assessments shall be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicator's operability, the condition's existence, or the report's accuracy. An indication, report, or condition is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt is removed related to the indicator's operability, the condition's existence, or the report's accuracy. Implicit in this definition is the need for timely assessment. 3.1.3 IMMINENT Conditions For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 60 minutes, etc.), the DSEO/ADTS should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary. 3.1.4 Planned vs. Unplanned Events A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that: 1) the activity proceeds as planned, and 2) the plant remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain or modify a system or component. In these cases, the controls associated with the planning, preparation and execution of the work will ensure that compliance is maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10 CFR 50.72 (ref. 4.1.4). 3.1.5 Classification Based on Analysis Page 7 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A The assessment of some EALs is based on the results* of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., dose assessments, chemistry sampling, etc.). For these EALs, the wording of the EAL or 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 threshold to be exceeded (i.e., this is the time that the EAL information is first available). The NRC expects licensees to establish the capability to initiate and complete EAL-related analyses within a reasonable period of time (e.g., maintain the necessary expertise on-shift). 3.1.6 DSEO/ADTS Judgment While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 EAL scheme provides the DSEO/ADTS with the ability to classify events and conditions based upon judgment using EALs that are consistent with the Emergency Classification Level (ECL) definitions (refer to Category H). The DSEO/ADTS will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition. 3.2 Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e., the relevant plant indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL must be consistent with the related Notes. If an EAL has been met or exceeded, the associated IC is likewise. met, the emergency classification process "clock" starts, and the ECL must be declared in accordance with plant procedures no later than 15 minutes after the process "clock" started. When assessing an EAL that specifies a time duration for the potentially classifiable condition, the "clock" for the EAL time duration runs concurrently with the emergency classification process "clock." For a full discussion of this timing requirement, refer to NSIR/DPR-ISG-01 (ref. 4.1.7). 3.2.1 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared. There is no "additive" effect from multiple EALs meeting the same ECL. Related guidanGe concerning classification of rapidly escalating events or conditions is provided in Regulatory Issue Summary (RIS) 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events (ref. 4.1.2). 3.2.2 Classification of IMMINENT Conditions Although EALs provide specific thresholds, the DSEO/ADTS must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the DSEO/ADTS, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all emergency classification levels, this approach is particularly Page 8 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bal\>es Document Docket No. 50-245 Enclosure 3, Attachment 2A important at the higher emergency classification levels since it provides additional time for implementation of protective measures. 32.3 Emergency Classification Level Upgrading and Downgrading Afl ECL may be downgraded when the event or condition that meets the highest IC and EAL no longer exists, and other site-specific downgrading requirements are met. If downgrading the ECL is deemed appropriate, the new ECL would then be based on a lower applicable IC(s) and EAL(s). The ECL may also simply be terminated. As noted above, guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02 (ref. 4.1.2). 3.2.4 Classification of Short-Lived Events Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration. Examples of such events include an earthquake or security event. 3.2.5 Classification of Transient Conditions Some radiological effluent based EALs employ time-based criteria. These criteria will require that the IC/EAL conditions be present for a defined period of time b~fore an emergency declaration is warranted. In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes). The following guidance should be applied to the classification of these conditions. EAL momentarily met during expected plant response - In instances in which an EAL is briefly met during an expected (normal) plant response, an emergency declaration is not warranted provided that associated systems and components are operating as expected, and operator actions are performed in accordance with procedures. EAL momentarily met but the condition is corrected prior to an emergency declaration - If an operator takes prompt manual action to address a condition, and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required. It is important to stress that the 15-minute emergency classification assessment period (process clock) is not a "grace period" during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event. Emergency classification assessments must be deliberate and timely, with no undue delays. The provision discussed above addresses only those rapidly evolving situations when an operator is able to take a successful corrective action prior to the DSEO/ADTS completing the review and steps necessary to make the emergency declaration. This provision is included to ensure that any public protective actions resulting from the emergency classification are truly warranted by the plant conditions. Page 9 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A 3.2.6 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery. This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process. In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022 (ref. 4.1.3) is applicable. Specifically, the event should be reported to the NRC in accordance with 10 CFR 50. 72 (ref. 4.1.4) within one hour of the discovery of the undeclared event or condition. The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements. 3.2.7 Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022 (ref. 4.1.3). Page 10 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A

4.0 REFERENCES

4.1 Developmental 4.1.1 NEI 99-01, Revision 6, "Methodology for the Development of Emergency Action Levels for Non-Passive Reactors" (ADAMS Accession No. ML12326A805) 4.1.2 RIS 2007-02, "Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events," February 2, 2007. 4.1.3 NUREG-:1022," Event Reporting Guidelines: 10CFR50.72 and 50.73" 4.1.4 10 CFR 50. 72," "Immediate Notification Requirements for Operating Nuclear Power Reactors" 4.1.5 10 CFR 50. 73, "License Event Report System" 4.1.6 MP-22-REC-BAP01," "Radiological Effluent Monitoring and Offsite Dose Calculation Manual" 4.1.7 NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants" 4.1.8 MPS Emergency Plan 4.2 Implementing 4.2.1 MP-26-EPI-FAP06, "Classification and PARs" 4.2.2 MPS1 EAL Comparison Matrix 4.2.3 MPS1 EAL Matrix

Page 11 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS 5.1 Definitions (ref. 4.1 .1 except as noted) Selected terms used in Initiating Condition, EAL statements and EAL bases are set in all capital letters (e.g., ALL CAPS). These are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below. ALERT Events are in progress, oi- 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. CONFINEMENT BOUNDARY The barrier(s) behveen spent fuel and the environment once the spent fuel is processed for dry storage. CONTAINMENT CLOSURE The procedurally defined conditions or actions taken to secure containment (Primary or Secondary) and associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. 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. 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:

Notification of Unusual Event (-NGUE)
Alert
Site Area Emergency (SAE)
General Emergency (GE)

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 require a post-event inspection to determine if the attributes of an explosion are present. FAULTED Page 12 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized. 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. FISSION PRODUCT BARRIER THRESHOLD /\ pre determined, site specific, observable threshold indicating the loss or potential loss of a fission product b';lrrier. FLOODING A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area. HOSTAGE /\ person(s) held as leverage against the station to ensure that demands will be met by the station. HOSTILE ACTION An act toward a NPP MPS 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 NPPMPS. 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 One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable vveapons 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. IMPEDE(D) Personnel access to a room or area is hindered to an extent that 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). INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) /\ complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated 1.vith spent fuel storage. Page 13 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A 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. 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 area within the SITE BOUNDARY including the PROTECTED AREA (ref. 4.1.8). PROJECTILE /\n object directed tovvard a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety. PROTECTED AREA The area within the Millstone Power Station security fence (ref. 4.1.8). RUPTURED I The condition of a steam generator in which primary to secondary leakage is of sufficient magnitude to require a safety injection. 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 (as defined in 10CFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. SECURITY CONDITION /\ny 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./\ Security Condition does not involve a HOSTILE ACTION. SITE BOUNDARY That line beyond which the land is not owned, leased or otherwise controlled by MPS. Also see OWNER CONTROLLED AREA (ref. 4.1.8). UNISOLABLE /\n open or breached system line that cannot be isolated, remotely or locally. Page 14 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A 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. UNUSUAL EVENT Events are in progress or have occurred which indicate a potential degradation in 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. VALID An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. VISIBLE DAMAGE Damage to a component or structure 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 component or structure. Page 15 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A 5.2 Abbreviations/Acronyms ~F ...................................................................................:................... Degrees Fahrenheit 0

***************************************************************************** *********************************************** Degrees ADTS .......................................................................Assistant Director Technical Support ARM ...............................................................................................Area Radiation Monitor COE ...................................................................................... Committed Dose Equivalent CFR ...................................................................................... Code of Federal Regulations CPM ..................................................................................................... Counts Per Minute CTMT ............................................................................................................ Containment OBA .......................................................................................*........ Design Basis Accident DSAR ............................................................................. Defueled Safety Analysis Report DSEO .............................................................. Director of Station Emergency Operations EAL ............................................................................................. Emergency Action Level ECL ......_. .................................................. :........................ Emergency Classification Level EOF ..... .'............................................................................. Emergency Operations Facility EOP .............................................................................. Emergency Operating Procedure EPA .............................................................................. Environmental Protection Agency EPI .................................................................................... Emergency Plan Implementing FEMA .............................................................. Federal Emergency Management Agency GPM .................................................................................................... Gallons Per Minute Hr.................... .1 ***************************************************************************** ***************************** Hour IC ......................................................................................................... Initiating Condition ISFSI ............................................................ Independent Spent Fuel Storage Installation LCO .................................................................................. Limiting Conditiod of Operation LRW ........................................................................................................ Liquid Radwaste LWR ...................................................................................................Light Water Reactor MCB ....................................................................................................Main Control Board Min ..........................................................................................................................Minute MPH ........................................................................................................... Miles Per Hour MPS ......................................................... :................................... Millstone Power Station mR, mRem, mrem, mREM ............................................... milli-Roentgen Equivalent Man NEI .............................................................................................. Nuclear Energy Institute NPP ................................................................................................... Nuclear Power Plant Page 16 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A NRG ............................................................................... Nuclear Regulatory Commission NORAD ................................................... North American Aerospace Defense Command I UE .................................................................. :........................................... Unusual Event OBE ...................................................................................... Operating Basis Earthquake OCA .............................................................................................. Owner Controlled Area ONP .................................................. :............................................. Off Normal Procedure PA ............................................................................................................. Protected Area PAG ...................................................................................... : Protective Action Guideline PLC .................................................................................. Programmable Logic Controller PSIG ............................................................................... Pounds per Square Inch Gauge R ........................................................................................................................ Roentgen RCS ............................................................................................ Reactor Coolant System Rem, rem, REM .....................,................................................. Roentgen Equivalent Man REMODCM ... Radiological Effluent Monitoring Manual/Off-site Dose Calculation Manual SCBA ...................................................................... Self-Contained Breathing Apparatus SFP .................................................................................................. Spent Fuel Pool (Pit) SM ............................................................................................................... Shift Manager SRO ........................................................................................... Senior Reactor Operator TEDE : .............................................................................. Total Effective Dose Equivalent TS ............................................................................................... Technical Specifications TSC ........................................................................................... Technical Support Center Page 17 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document 'bocket No. 50-245 Enclosure 3, Attachment 2A .6.0 MPS1-TO-NEI 99-01, Rev. 6 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of a MPS1 EAL within the NEI 99-01 IC/EAL example identification scheme. Further information regarding the development of the MPS1 EALs based on the NEI 99-01, Rev. 6 guidance can be found in the MPS1 EAL Comparison Matrix. MPS1 NEI 99-01, Rev. 6 EAL EAL IC Example RU1.1 PD-AU1 1 RU1.2 PD-AU1 1 RU1.3 PD-AU1 2 RU2.1 PD-AU2 1 RU2.2 PD-AU2 2 RA1.1 PD-M1 1 RA1.2 PD-M1 2 RA1.3 PD-M1 3 RA1.4 PD-M1 4 RA2.1 PD-M2 2 HU1.1 PD-HU2 1 HU2.1 PD-HU3 1 HA2.1 PD-HA3 1 MU1.1 PD-SU1 1 Page 18 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Enclosure 3, Attachment 2A 7.0 ATTACHMENTS 7.1 Attachment 1, Emergency Action Level Technical Bases Page 19 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Category R - Abnormal Rad Levels / Rad Effluent Direct indication of elevated radiological effluents or area radiation levels are appropriate symptoms for emergency classification. Events of this category pertain to the following subcategories:

1. Radiological Effluent Direct indication of effluent radiation monitoring systems provides a rapid assessment mechanism to determine releases in excess of classifiable limits. Projected offsite doses, actual offsite field measurements or measured release rates via sampling indicate doses or dose rates above classifiable limits.

2. Area Radiation Levels Sustained general area radiation levels which may preclude access* to areas needed to maintain spent fuel integrity also warrant emergency classification.

Page 20 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the allocated REMODCM limits for 60 minutes or longer EAL: RU1.1

Unusual Event Reading on RM-SFPl-02 Unit 1 Spent Fuel Pool Island Monitor > 1 .1 E-2 µCi/cc for

~60 min. (Notes 1, 2, 3)

Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Note 3: 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. Definition(s): VALID -An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. Basis: This -lG-EAL 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 fec;3tures 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 incl.usion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. 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. Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL. Page 21 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A EAL #1 This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the station REMODCM limit for 60 minutes or longer. established by a radioactivity discharge permit. This EAL 'Nill typically be associated with planned batch releases from non continuous release pathvvays (e.g., radwaste, waste gas)addresses a continuous gaseous monitored pathway (ref. 1, 2). The basis for the MPS 1* UE value corresponds to the unplanned release of gaseous radioactivity greater than two times the site-specific effluent release limit. This UE gaseous release criterion is consistent with NEI 99-01, Rev. 6 guidance but different from the alternative criterion used for Dominion Energy's other operating nuclear facilities. The operating facilities use a dose-based criterion based on exceeding 1 mrem TEDE for 60 minutes or longer. For a shutdown nuclear facility like MPS 1 which has essentially only Kr-85 as a source term, dose-based criteria would be inappropriate. This is due to fact that the damage to fuel to produce sufficient source to create 1 mrem TEDE would be inconsistent with the Unusual Event definition and basis (represents a loss of plant control and degradation in the level of safety). To create a release that would result in 1 mrem TEDE, nearly 600 irradiated fuel assemblies decayed for over 22 years would need to fail. Setting the UE threshold based on a release greater than two times the site-specific release limit would correlate to the failure of approximately 1.5 irradiated fuel assemblies. This number of fuel assemblies failures would appropriately represent the Unusual Event definition and basis (ref. 2). E/\L #2 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 v,ater systems, etc.). Escalation of the emergency classification level would be via IC PD /\/\1 RA 1. Reference(s):

1. MP-22-REC-BAP01, "Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM)"

2. Calculation RP-18-08, "Millstone Unit 1 Abnormal Rad Release Gaseous EAL Threshold based on NEI 99-01, Rev. 6" *

3. NEI 99-01 IC PD-AU1 Page 22 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the allocated REMODCM limits for 60 minutes or longer EAL: RU1 .2 Unusual Event Reading on RE-M6-110 Liquid Waste Effluent Discharge Monitor> 2 x the "alarm" setpoint established by a current radioactivity discharge permit for >60 min. (Notes 1, 2, 3) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Note 3: 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. Definition(s): VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. Basis: This -IG--EAL 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. 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. Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL. Page 23 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A E/\L #1 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) (ref. 1, 2, 3). E/\L #2 This E/\L addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored path*.vays (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 PD /\/\1 RA 1. Reference(s):

1. MP-22-REC-BAP01, "Millstone Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM)"

2. Calculation RP-17-24, "Millstone Abnormal Rad Release Liquid EAL Thresholds based on NEI 99-01, Rev. 6"

3. NEI 99-01 IC PD-AU1 Page 24 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Attachment 1 EAL Technical Bases Enclosure 3; Attachment 2A Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the allocated REMODCM limits for 60 minutes or longer. EAL: RU1.3 Unusual Event Sample analysis for a liquid or gaseous release indicates a concentration or release rate

 > 2 x the allocated REMODCM limits for ~60 min. (Notes 1, 2)

Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Definition(s): None Basis: This .J.G-EAL 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. 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. Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL. E/\L #1 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., radv:aste, waste gas).

Page 25 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A E/\L #2 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 systemsleakage into ocean water systems, etc.). Escalation of the emergency classification level would be via IC PD /\J\1 RA2. Reference(s):

1. MP-22-REC-BAP01, "Millstone Radiological Effluent Monitoring and Offsite Dose

Calculation Manual (REMODCM)"

2. NEI 99-01 IC PD-AU1 Page 26 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Attachment 1 EAL Technical Bases Enclosure 3; Attachment 2A Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent ,Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE EAL: RA1.1 Alert Reading on RM-SFPl-02 Unit 1 Spent Fuel Pool Island Monitor > 4.0E+01 µCi/cc for ~15 min. (Notes 1, 2, 3, 4) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Note 3: 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. Note 4: The pre-calculated effluent monitor values presented in EAL RA 1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. Definition(s): VALID -An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. Basis: This .J.G--EAL 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 1,000 mrem while the 50 mrem thyroid COE v,as established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid COE. The thyroid COE component has been eliminated from this EAL as allowed by EPA-400 (ref. 2) and consistent with direction provided by the States of Connecticut and New York. 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 Page 27 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes. The basis for the MPS1 ALERT value corresponds to the unplanned release of gaseous radioactivity over 15 minutes to produce 10 mrem TEDE. The damage of spent fuel to produce enough source to create 10 mrem TEDE would require approximately 50% of the irradiated fuel assemblies in the spent fuel pool to fail. Reference(s):

1. Calculation RP-18-08, "Millstone Unit 1 Abnormal Rad Release Gaseous EAL Threshold based on NEI 99-01, Rev. 6" .

2. EPA-400, "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents"

3. NEI 99-01 IC PD-AA 1 Page 28 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 Attachment 1 EAL Technical Bases Enclosure 3; Attachment 2A Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE EAL: RA1.2 Alert Dose assessment using actual meteorology indicates doses > 10 mrem TEDE at or beyond the SITE BOUNDARY (Note 4) Note 4: The pre-calculated effluent monitor values presented in EAL RA 1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. Definition(s): SITE BOUNDARY - That line beyond which the land is not owned, leased or otherwise controlled by MPS. Also see OWNER CONTROLLED AREA. Basis: This .J-G--EAL 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 1,000 mrem 1.vhile the 50 mrem thyroid COE 1.vas established in consideration of the 1 :5 ratio of the EPA PAG for TEOE and thyroid COE. 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 knovm to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes. The thyroid COE component has been eliminated from this EAL as allowed by EPA-400 (ref. 2) and consistent with direction provided by the States of Connecticut and New York. Reference(s):

1. MP-26-EPI-FAP10, "Dose Assessment.

2. EPA-400, "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incident"

3. NEI 99-01 IC PD-AA1 Page 29 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE EAL: RA1.3 Alert Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses > 10 mrem TEDE at or beyond the SITE BOUNDARY for 60 min. of exposure (Notes 1, 2) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Definition(s): SITE BOUNDARY - That line beyond which the land is not owned, leased or otherwise controlled by MPS. Also see OWNER CONTROLLED AREA. Basis: This G--EAL 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. This EAL is assessed per the REMODCM (ref. 2). REMODCM software can be used to produce a dose to the maximum individual. The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem 1Nhile the 50 mrem thyroid COE 1,.vas established in consideration of the 1:5 ratio of the EPA P/\G for TEOE and thyroid COE. The thyroid COE component has been eliminated from this EAL as allowed by EPA-400 (ref. 3) and consistent with direction provided by the States of Connecticut and New York. 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. Page 30 of 44

Millstone Power Station ~nit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Reference(s):

1. MP-26-EPI-FAP10, "Dose Assessment"

2. MP-22-R~C-BAP01, "Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMO DCM)"

3. EPA-400, "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incident"

4. NEI 99-01 ICPD-M1

Page 31 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE EAL: RA1.4 Alert Field survey results indicate closed window dose rates > 10 mR/hr expected to continue for ~60 min. at or beyond the SITE BOUNDARY (Notes 1, 2) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Definition(s): SITE BOUNDARY - That line beyond which the land is not owned, leased or otherwise controlled by MPS. Also see OWNER CONTROLLED AREA. Basis: This .J.G-EAL 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 1,000 mrem while the 50 mrem thyroid GOE '.¥as established in consideration of the 1:5 ratio of the EP/\ P/\G for TEOE and thyroid GOE. The thyroid COE component has been eliminated from this EAL as allowed by EPA-400 (ref. 3) and consistent with direction provided by the States of Connecticut and New York. 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. Reference(s):

1. MP-26-EPI-FAP10, "Dose Assessment"

2. MP-26-EPI-FAP04, "Emergency Operations Facility Activation and Operation" Page 32 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A

3. EPA-400, "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incident"

4. NEI 99-01 IC PD-AA 1 Page 33 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Area Radiation Levels Initiating Condition: UNPLANNED rise in plant radiation levels EAL: RU2.1 Unusual Event UNPLANNED water level drop in the SFP as indicated by any of the following:

SPENT FUEL POOL LEVEL LOW alarm PLC-AL 101
SPENT FUEL POOL LEVEL LOW-LOW alarm PLC-AL 100
Report of dropping level in SFP
Loss of SFP Cooling suction flow AND UNPLANNED rise in area radiation levels as indicated by any of the following radiation monitors:
RM-SFPl-01 Channel 1 Refuel Floor West (Low Range)
RM-SFPl-01 Channel 2 Refuel Floor East
RM-SFPl-01 Channel 3 Refuel Floor West (High Range)

Definition(s): 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. Basis: This .JG-EAL addresses elevated plant radiation levels caused by a decrease in water level above irradiated (spent) fuel or other UNPLANNED events. The increased radiation levels are indicative of a minor loss in the ability to control radiation levels within the plant or radioactive materials. Either condition is a potential degradation in the level of safety of the plant. A water level decrease will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel or video camera observations (if available). A significant drop in the water level may also cause an increase in the radiation levels of adjacent areas that can be detected by monitors in those locations. The effects of planned evolutions should be considered. Note that this EAL #4 is applicable only in cases where the elevated reading is due to an UNPLANNED water level drop. E/\L #2 excludes radiation level increases that result from planned activities such as use of radiographic sources and movement of radioactive 1Naste materials. Escalation of the emergency classification level would be via IC PD /V\1 or PD /\/\2RA2. Page 34 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Reference(s):

1. ARP 230.44, "PLC Alarm Response"

2. ONP 532, "Loss of Spent Fuel Pool Cooling"

3. ONP 509, "Excessive Radioactive Levels"

4. NEI 99-01 IC PD-AU2 Page 35 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Area Radiation Levels Initiating Condition: UNPLANNED rise in plant radiation levels EAL: RU2.2 Unusual Event Area radiation monitor reading or survey result indicates an UNPLANNED rise of 25 mR/hr over NORMAL LEVELS Definition(s): NORMAL LEVELS - As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value. 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. Basis: This G--EAL addresses elevated plant radiation levels caused by a decrease in water level above irradiated (spent) fuel or other UNPLANNED events. The increased radiation levels are indicative of a minor loss in the ability to control radiation levels within the plant or radioactive materials. Either condition is a potential degradation in the level of safety of the plant. A water level decrease will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel or video camera observations (if available). A significant drop in the water level may also cause an increase in the radiation levels of adjacent areas that can be detected by monitors in those locations. The effects of planned evolutions should be considered. Note that El\L #1 is applicable only in cases where the elevated reading is due to an UNPLANNED water level drop. El\L #2This EAL excludes radiation level increases that ~esult from planned activities such as use of radiographic sources and movement of radioactive waste materials. Escalation of the emergency classification level would be via IC PD /V\1 or PD /V\2RA2. Reference(s):

1. ONP 509, "Excessive Radioactive Levels"

2. NEI 99-01 IC PD-AU2 Page 36 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Area Radiation Levels Initiating Condition: UNPLANNED ris'e in plant radiation levels that IMPEDES plant access required to maintain spent fuel integrity EAL: RA2.1 Alert UNPLANNED Area Radiation Monitor readings or survey results indicate a rise by 100 mR/hr over NORMAL LEVELS that IMPEDES access to areas of the Reactor Building needed to maintain control of radioactive material or operation of systems needed to maintain spent fuel integrity

Definition(s):

IMPEDE(D) - Personnel access'to a room or area is hindered to an extent that 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). NORMAL LEVELS - As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value. 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. Basis: This G-EAL addresses increased radiation levels that impede necessary access to *areas containing equipment that must be operated manually or that requires local monitoring, in order to *maintain systems needed to maintain spent fuel integrity. As used here, 'IMPEDE' includes hindering or interfering, provided that the interference or delay is sufficient to significantly threaten necessary plant access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the plant. This G-EAL does not apply to anticipated temporary increases due to planned events. Reference(s):

1. ONP 509, "Excessive Radioactive Levels"

2. NEI 99-01 IC PD-M2 Page 37 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Category H - Hazards Hazards are non-plant, system-related events that can directly or indirectly affect spent fuel integrity.

1. Hazardous Events Affecting Plant Safety Natural events such as earthquakes have potential to cause plant structure or equipment damage of sufficient magnitude to threaten personnel or spent fuel storage safety.

2 DSEO/ADTS Judgment The EALs defined in other categories specify the predetermined symptoms or events that are indicative of emergency or potential emergency conditions and thus warrant classification .. While these EALs have been developed to address the full spectrum of possible emergency conditions which may warrant classification and subsequent implementation of the Emergency Plan, a provision for classification of emergencies based on operator/management experience and judgment is still necessary. The EALs of this category provide the DSEO/ADTS the latitude to classify emergency conditions consistent with the established classification criteria based upon DSEO/ADTS judgment. Security events affecting MPS1 are classified per either the MPS2 or MPS3 EALs. Page 38 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Category: H - Hazards Subcategory: 1 - Hazardous Event Affecting Safety Systems Initiating Condition: Hazardous event affecting SAFETY SYSTEM equipment necessary for spent fuel cooling EAL: HU1.1 Unusual Event The occurrence of any Table H-1 hazardous event AND Event damage (excluding loss of offsite AC power) has caused indications of degraded performance of EITHER:

Spent Fuel Pool Cooling System
Decay Heat Removal System

                      !Table H-1 Hazardous Events

Seismic event (earthquake)
Internal or external FLOODING event
High winds or tornado strike
FIRE (refer to Unit 2/3 EALs for a fire within the Protected Area)
EXPLOSION
Other events with similar hazard characteristics as determined by the Shift Manager Definition(s):

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 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 fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed. FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area. 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 (as defined in 10 CFR 50.2): Page 39 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. Basis: This EAL addresses a hazardous event that causes damage to SAFETY SYSTEMS needed for spent fuel cooling. In order to provide the appropriate context for consideration of an UNUSUAL EVENT classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance. Indications of degraded performance addresses damage to a SAFETY SYSTEM that is in service/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. A loss of offsite AC power is excluded as the loss of power does not result in actual damage to the specified SAFETY SYSTEM. If the hazardous event only resulted in visible damage, with no indications of degraded performance of either SAFETY SYSTEM, then this emergency classification is not warranted . .This IC addresses a hazardous event that causes damage to at least one train of a SAFETY SYSTEM needed for spent fuel cooling. The damage must be of sufficient magnitude that the system(s) train cannot, or potentially cannot, perform its design function. This condition reduces the margin to a loss or potential loss of the fuel clad barrier, and therefore represents a potential degradation of the level of safety of the plant. For EAL 1.c, the first bullet addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it 111ill be readily available. For EAL 1.c, the second bullet addresses damage to a SAFETY SYSTEM train that is not in service/operation or readily apparent through indications alone. Operators 1.vill make this determination 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. Escalation of the emergency classification level could, depending upon the event, be based on any of the Alert ICs; PG-AA 1, P-G-AA2, PD HA1 or PD HA3HA2. Reference(s):

1. EP FAQ 2016-002 Emergency Preparedness Program Frequently Asked Questions

2. NEI 99-01 IC PD-HU2 Page 40 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Category: H- Hazards Subcategory: 2 - DSEO/ADTS Judgment Initiating Condition: Other conditions existing that in the judgment of the DSEO warrant declaration of an Unusual Event EAL: HU2.1 Unusual Event Other conditions exist which in the judgment of the DSEO 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. Definition(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 (as defined in 10CFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down t~e reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. Basis:. This .JG--EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency DirectorDSEO to fall under the emergency classification level description for an Unusual EventNOUE. Reference(s):

1. NEI 99-01 IC PD-HU3 Paqe 41 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Categpry: H - Hazards Subcategory: 2 - DSEO/ADTS Judgment Initiating Condition: Other conditions existing that in the judgment of the DSEO/ADTS warrant declaration of an Alert EAL: HA2.1 Alert Other conditions exist which in the judgment of the DSEO/ADTS 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 Definition(s): HOSTILE ACTION - An act toward MPS 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 MPS. 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). Basis: This .JG-EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency DirectorDSEO/ADTS to fall under the emergency classification level description for an Alert. Reference(s):

1. NEI 99-01 IC PD-HA3 PaQe 42 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Category M - System Malfunctions A single EAL is provided for permanently defueled reactors.

1. Loss of Spent Fuel Cooling Uncontrolled or inadvertent temperature rises in the Spent Fuel Pool are indicative of a potential loss of safety functions. If uncorrected, boiling in the pool will occur, and result in a loss of pool level and increased radiation levels.

Paqe 43 of 44

Millstone Power Station Unit 1 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket No. 50-245 EAL Technical Bases Enclosure 3; Attachment 2A Category: M - System Malfunctions Subcategory: 1 - Loss of SFP Cooling Initiating Condition: UNPLANNED spent fuel pool temperature rise EAL: MU1 .1 Unusual Event UNPLANNED spent fuel pool temperatu_re rise to> 140 °F Definition(s): 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. ' Basis: This -lG--EAL addresses a condition that is a precursor to a more serious event and represents a potential degradation in the level of safety of the plant. If uncorrected, boiling in the pool will occur, and result in a loss of pool level and increased radiation levels; Annunciator alarm PLC-AL 106, "SPENT FUEL POOL BULK lEMPERATURE HIGH," alarms at 125°F (ref. 1).

The maximum allowed bulk SFP water temperature is 140°F. The requirement to *maintain the spent fuel pool bulk water temperature < 140°F ensures that high water temperature will not degrade the resin in the spent fuel pool demineralizer, the fuel pool structure, pool liner, fuel racks, or external cooling system (ref. 3 ).

Spent Fuel Pool temperature is normally maintained well below this point thus allowing time to correct the cooling system malfunction prior to classification. With a complete loss of external cooling and a closed airspace above the pool, it would take approximately 7.5 days to rise to 212°F if starting from the TRM upper temperature limit of 140°F (ref. 4 ). Escalation of the emergency classification level. would be via IC PD /V\1 or PD /\/\2RA2. Reference(s):

1. ARP 230.44, "PLC Alarm Response"

2. ONP 532, "Loss of Spent Fuel Pool Cooling"

3. Unit 1 Defueled Technical Requirements Manual

4. MPS-1 DSAR, Section 3.2.1.3, "Spent Fuel Pool Cooling System"

5. NEI 99-01 IC PD-SU1 Paqe 44 of 44

Serial No.: 18-364 Docket Nos.: 50-336; 72-4 7 Enclosure 3 ATTACHMENT 28 MPS2 EAL TECHNICAL BASES DOCUMENT (Marked-up) Dominion Energy Nuclear Connecticut, Inc. (DENC) Millstone Power Station Unit 2 and ISFSI

Serial No. 18-364 Docket Nos. 50-336; 72-47 Enclosure 3; Attachment 28 Emergency Action Level Technical Bases Document Millstone Power Station - Unit 2 (Marked-up)

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-4 7 Enclosure 3; Attachment 28 Table of Contents

1.0 INTRODUCTION

.........................................................................................................3 2.0    DISCUSSION ............................................................................................................. 3 2.1  Background .......................................................................................................3 2.2  Fission Product Barriers ....................................................................................4 2.3  Fission Product Barrier Classification Criteria ................................................... 4 2.4  EAL C>rganization .............................................................................................. 5 2.5  Technical Bases Information ............................................................................. 7 2.6  Operational Mode Applicability .......................................................................... 8 3.0    GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS .................................. 9 3.1  General Considerations .................................................................................... 9 3.2  Classification Methodology ............................................................................. 10

4.0 REFERENCES

......................................................................................................... 13 4.1  Developmental ................................................................................................ 13 4.2  Implementing .................................................. :............. :.................... ;............ 13 5.0    DEFINITIONS, ACRONYMS & ABBREVIATIONS ................................................... 14 5.1  Definitions ....................................................................................................... 14 5.2  Abbreviations/Acronyms ................................................................................. 18 6.0    MPS2-TO-NEI 99-01 Rev. 6 EAL CROSS-REFERENCE ........................................ 21 7.0    ATTACHMENTS ................... ~ ...................................................................................25 7.1  Attachment 1, Emergency Action Level Technical Bases ............................... 25 7.2  Attachment 2, Safe Operation & Shutdown Areas Tables R-2 & H-2 Bases ... 25 Category R-Abnormal Rad Release/ Rad Effluent .......................................................... 26 Category C - Cold Shutdown / Refueling System Malfunction ............................................ 73 Category E - Independent Spent Fuel Storage Installation (ISFSI) .................................. 113 Category F - Fission Product Barrier Degradation ..................................... :...................... 116 Category H - Hazards and Other Conditions Affecting Plant Safety ................................. 171 Category M - System Malfunction ...................................................................................,213 Page 2 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-4 7 Enclosure 3; Attachment 2B

1.0 INTRODUCTION

This document provides an explanation and rationale for each Emergency Action Level (EAL) included in the NEI 99-01, Revision 6, EAL Upgrade Project for Millstone Power Station Unit 2 (MPS2). It should be used to facilitate review of the MPS2 EALs and provide historical documentation for future reference. Decision-makers responsible for implementation of MP EPI-FAP06, Classification and PARs, may use this document as a technical reference in support of EAL interpretation. This information may assist the Director of Station Emergency Operations/Assistant Director Technical Support (DSEO/ADTS) in making classifications, particularly those involving judgment or multiple events. The basis information may also be useful in training and for explaining event classifications to off-site officials. The expectation is that emergency classifications are to be made as soon as conditions are present and recpgnizable for the classification, but within 15 minutes or less in all cases of conditions present. Use of this document for assistance is not intended to delay the emergency classification. Since the information in a basis document can affect emergency classification decision-making (e.g., the DSEO/ADTS refers to it during an event), the NRC staff expects that changes to the basis documeht will be evaluated in accordance with the provisions of 10 CFR 50.54(q). For Dominion Energy sites, a 10 CFR 50.54(q)(3) screening/evaluation will be performed to evaluate changes to this document. Dominion Energy fleet procedure CM-M-400, "10 CFR 50.59 and 10 CFR 72.48 - Changes, Tests and Experiments" provides a method to determine the impacts to licensing basis documents when changes are proposed to procedures, including changes to Abnormal Operating Procedures (AOPs) and Emergency Operating Procedures (EOPs). The 50.59/72.48 applicability review specifically requires that the effect of a proposed procedure change on the Emergency Plan (and associated EALs) be reviewed/assessed. When impacts to the Emergency Plan are identified, a separate review in accordance to 10 CFR 50.54(q) will be performed to determine the acceptability of the p~opo_sed procedure change. 2.0 DISCUSSION 2.1 Background EALs are the plant-specific indications, conditions or instrument readings that are utilized to classify emergency conditions defined in the Millstone Power Station (MPS) Emergency Plan. In 1992, the NRC endorsed NUMARC/NESP-007, "Methodology for Development of Emergency Action Levels" as an alternative guidance to the original Standard Review Plan and NUREG-0654 EAL schemes. NEI 99-01 (NUMARC/NESP-007), Revisions 4 and 5 were subsequently issued for industry implementation. Enhancements over earlier revisions included:

  ,*   Consolidating the system malfunction initiating conditions and example emergency action levels which address conditions that may be postulated to occur during plant shutdown conditions.

Page 3 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-47

Enclosure 3; Attachment 2B

Initiating conditions and example emergency action levels that fully address conditions that may be postulated to occur at permanently Defueled Stations and Independent Spent Fuel Storage Installations (ISFSls).
Simplifying the fission product barrier EAL threshold for a Site Area Emergency.

Subsequently, Revision 6 of NEI 99-01 has been issued which incorporates resolutions to numerous implementation issues including the NRG EAL Frequently Asked Questions (FAQs). Using NEI 99-01, Revision 6, "Methodology for the Development of Emergency Action Levels for Non-Passive Reactors," November 2012 (ref. 4.1.1 ), MPS2 conducted* an EAL implementation upgrade project that produced the EALs discussed herein. 2.2 Fission Product Barriers Fission product barrier 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. Many of the EALs derived from the NEI methodology are fission product barrier threshold based. That is, the conditions that define the EALs are based upon thresholds that represent the loss or potential loss of one or more of the three fission product barriers. "Loss" and . "Potential Loss" signify the relative damage and threat of damage to the barrier. A "Loss" threshold means the. barrier no lo'nger assures containment of radioactive materials. A "Potential Loss" thres~old implies a greater probability of barrier loss. and reduced certainty of maintaining the barrier. The primary fission product barriers are: A. Fuel Clad Barrier (FC): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets. B. Reactor Coolant System Barrier (RCS): The RCS Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and Jelief valves, and other connections up to and including the primary isolation valves. C. Containment Barrier (CTMT): The Containment Barrier includes the containment building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, ana blowdown line extensions outside the containment building up to and including the outermost secondary side isolation valve. Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency. 2.3 Fission Product Barrier Classification Criteria The following criteria are the bases for event classification related to fission product barrier loss or potential loss: Page 4 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-4 7 Enclosure 3; Attachment 28 Alert: Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency: Loss or potential loss of any two barriers General Emergency: Loss of any two barriers and loss or potential loss of the third barrier 2.4 EAL Organization The MPS2 EAL scheme includes the following features:

Division of the EAL set into three broad groups:

o EALs applicable under any plant operational modes - This group would be reviewed by the EAL-user any time emergency classification is considered. o EALs applicable only under hot operational modes - This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby, Startup, or Power Operation mode. o EALs applicable only under cold operating modes - This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refueling or Defueled mode. The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user tor a given plant condition, reduces*EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency.

Within each group, assignment of EALs to categories and subcategories:

Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. The MPS2 EAL categories are aligned to and represent the NEI 99-01 "Recognition Categories." Subcategories are used in the MPS2 scheme as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The MPS2 EAL categories and subcategories are listed below. The EALs are pre-determined, site-specific, observable thresholds for determining whether an Initiating Condition (IC) has occurred and that an EAL threshold was met or exceeded. Thus failure to evaluate the IC and EAL together could result in an incorrect declaration. The primary tool for determining the emergency classification level is the EAL Classification Matrix. The user' of the EAL Classification Matrix may (but is not required to) consult the EAL technical bases in order to obtain additional information concerning the EALs under classification consideration. The user should consult Section 3.0 and Attachment 1 of this document for such information. Page 5 of 259

Millstone Power Station Unit 2 / Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-47 Enclosure 3; Attachment 28 EAL Groups, Categories and Subcategories EAL Group/Category I EAL Subcategory Any Operating Mode: R - Abnormal Rad Levels / Rad Effluent 1 - Radiological Effluent 2 - Irradiated Fuel Event 3 -Area Radiation Levels H - Hazards and Other Conditions 1 - Security Affecting Plant Safety 2 - Seismic Event 3 - Natural or Technological Hazard 4- Fire 5 - Hazardous Gas 6 - Controi'Room Evacuation 7 - DSEO/ADTS Judgment E - Independent Spent Fuel Storage 1 - Confinement Boundary Installation (ISFSI) Hot Conditions: M - System Malfunction 1- Loss of Emergency AC Power 2- Loss of Vital DC Power 3- Loss of Control Room Indications 4- RCS Activity 5- RCS Leakage 6- RPS Failure 7- Loss of Communications 8- Containment Failure 9- Hazardous Event Affecting Safety Systems F - Fission Product Barrier Degradation None Cold Conditions: C - Cold Shutdown I Refueling System 1 - RCS Level Malfunction 2 - Loss of Emergency AC Power 3- RCS Temperature 4 - Loss of Vital DC Power 5 - Loss of Communications 6 - Hazardous Event Affecting Safety Systems Page 6 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-47 Enclosure 3; Attachment 28 2.5 Technical Bases Information

EAL technical bases are provided in Attachment 1 for each ~AL according to EAL group (Any, Hot, Cold), EAL category (R, C, E, F, Hand M) and EAL subcategory. A summary explanation of each category and subcategory is given at the beginning of the technical bases discussions of the EALs included in the category. For each EAL, the following information is provided:

Category Letter & Title Subcategory Number & Title Initiating Condition (IC) Site-specific description of the generic IC given in NEI 99-01 Rev. 6. EAL Identifier (enclosed in rectangle) Each EAL is assigned a unique identifier to support accurate communication of the emergency classification to onsite and offsite personnel. Four characters define each EAL identifier:

1. First character (letter): Corresponds to the EAL category as described above (R, C, E, F, Hor M)

2.
Second character (letter): The emergency classification (G, S, A or U)

G = General Emergency S = Site Area Emergency A= Alert U = Unusual Event *

3. Third character (number): Subcategory number within the given category.

Subcategories are sequentially numbered beginning with the number one (1 ). If a category does not have a subcategory, this character is assigned the number one (1 ).

4. Fourth character (number): The numerical sequence of the EAL within the EAL subcategory. If the subcategory has only one EAL, it is given the number one (1 ).

Classification (enclosed in rectangle): General Emergency (G), Site ~rea Emergency (S), Alert (A) or Unusual Event (U). EAL (enclosed in rectangle) Exact wording 'Of the EAL as it appears in the EAL Classification Matrix. Notes (as applicable) Mode Applicability One or more of the following plant operating conditions comprise the mode to which each EAL is applicable: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling, DEF - Defueled, or All. (See Section 2.6 for operating mode definitions) Page 7 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-4 7 Enclosure 3; Attachment 2B Definition(s): If the EAL wording contains a defined term, the definition of the term is included in this section. These definitions can also be found in Section 5.1. Basis: An EAL basis section that provides MPS2-relevant information concerning the EAL as well as a description of the rationale for the EAL as provided in NEI 99-01, Rev. 6. Reference(s): Source documentation from which the EAL is derived 2.6 Operational Mode Applicability THERMAL MODE Keff POWER* TAvG

1. Power Operation ~0.99 >5% ~3oo'F

2. Startup ~0.99 :;;;5% ~3oo'F

3. Hot Standby < 0.99 0 ~3oo'F

4. Hot Shutdown < 0.99 0 > 2oo'F & < 3oo'F

5. Cold Shutdown < 0.98 0 :;;;2oo'F

6. Refueling ** :;;;0.95 0 :;;;140°F Defueled NA NA NA - no fuel in reactor vessel

Excluding Decay Heat

              **  Fuel in the reactor vessel with the vessel head closure bolts less than fully tensioned or with the head removed The plant operating mode that exists at the time that the event occurs (prior to any protective system or operator action being initiated in response to the condition) should be compared to the mode applicability of the EALs. If a lower or higher plant operating mode is reached before the emergency classification is made, the declaration shall be based on the mode that existed at the time the event occurred.

Page 8 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-47 Enclosure 3; Attachment 2B 3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 3.1 General Considerations When making an emergency classification, the DSEO/ADTS must consider all information having a bearing on the proper assessment of an Initiating Condition (IC). This includes the EAL plus any associated Operational Mode Applicability, Notes, and the informing basis information. In the Category F matrices, EALs are based on loss or potential loss of Fission Product Barrier thresholds. 3.1.1 Classification Timeliness NRC regulations require the licensee to establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and to promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. The NRC staff has provided guidance on implementing this requirement in NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants" (ref. 4.1.8). 3.1.2 Valid Indications All emergency classification assessments shall be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicator's operability, the condition's existence, or the report's accuracy. An indication, report, or condition is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. 3.1.3 Imminent Conditions For ICs and EALs that have *a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the DSEO/ADTS should. not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, orwill likely exceed, the applicable time. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been* exceeded, absent data to the contrary. 3.1.4 Planned vs. Unplanned Events A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that: 1) the activity proceeds as planned, and 2) the plant remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain or modify a system or component. In these cases, the controls associated with the planning, preparation and execution of the work will ensure that compliance is maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected. Events or Page 9 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-47 Enclosure 3; Attachment 28 conditions of this type may be subject to the reporting requirements of 10CFR 50.72 (ref. 4.1.4). 3.1.5 Classification Based on Analysis The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., dose assessments, chemistry sampling, RCS leak rate calculation, etc.). For these EALs, the wording of the EAL or 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 threshold to be exceeded (i.e., this is the time that the EAL information is first available). The NRG expects licensees to establish the capability to initiate and complete EAL-related analyses within a reasonable period of time (e.g., maintain the necessary expertise on-shift). 3.1.6 DSEO/ADTS Judgment While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 EAL scheme provides the DSEO/ADTS with the ability to classify events and conditions based upon judgment using EALs that are consistent with the Emergency Classification Level (EGL) definitions (refer to Category H). The DSEO/ADTS will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular EGL definition. A similar provision is incorporated in the Fission Product Barrier Tables; judgment may be used to determine the status of a fission product barrier. 3.2 Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e., the relevant plant indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL must be consistent with the related Operating Mode Applicability and Notes. If an EAL has been met or exceeded, the associated IC is likewise met, the emergency classification process "clock" starts, and the EGL must be declared in accordance with plant procedures no later than 15 minutes after the process "clock" started. When assessing an EAL that specifies a time duration for the potentially classifiable condition, the "clock" for the EAL time duration runs concurrently with the emergency classification process "clock." For a full discussion of this timing requirement, refer to NSIR/DPR-ISG-01 (ref. 4.1.8). 3.2.1 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable EGL identified during this review is declared. For 1 example:

If an Alert EAL and a Site Area Emergency EAL are met, whether at one unit or at two units, a Site Area Emergency should be declared.

There is no "additive" effect from multiple EALs meeting the same EGL. For example:

If two Alert EALs are met, whether at one unit or at two units, an Alert should be declared.

Page 1O of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-47 Enclosure 3; Attachment 28 Related guidance concerning classification of rapidly escalating events or conditions is provided in Regulatory Issue Summary (RIS) 2007-02, Clarification of NRG Guidance for

Emergency Notifications During Quickly Changing Events (ref. 4.1.2).

3.2.2 Consideration of Mode Changes During Classification The mode in effect at the time that an event or condition occurred, and prior to any plant or operator response, is the mode that determines whether or not an IC is applicable. If an event or condition occurs, and results in a mode change before the emergency is declared, the emergency classification level is still based on the mode that existed at the time that the event or condition was initiated (and not when it was declared). On6e a different mode is reached, any new event or condition, not related to the original event or condition, requiring emergency classification should be evaluated against the ICs and EALs applicable to the operating mode at the time of the new event or condition. For events that occur in Cold Shutdown or Refueling, escalation is via EALs that are applicable in the Cold Shutdown or Refueling modes, even if Hot Shutdown (or a higher mode) is entered during the subsequent plant response. In particular, the fission product barrier EALs are applicable only to events that .initiate in the Hot Shutdown mode or higher. 3.2.3 Classification of Imminent Conditions Although EALs provide specific thresholds, the DSEO/ADTS must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the DSEO/ADTS, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all emergency classification levels, this approach is particularly important at the higher emergency classification levels since it provides additional time for implementation of protective measures. 3.2.4 Emergency Classification Level Upgrading and Downgrading An ECL may be downgraded when the event or condition that meets the highest IC and EAL no longer exists, and other site-specific downgrading requirements are met. If downgrading the ECL is deemed appropriate, the new ECL would then be based on a lower applicable IC(s) and EAL(s). The ECL may also simply be terminated. As noted above, guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02 (ref. 4.1.2). 3.2.5 Classification of Short-Lived Events Event-based ICs and EALs define a variety ot' specific occurrences that have potential or actual safety significance. By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration. Examples of such events include an earthquake or a failure of the reactor protection system to automatically scram the reactor followed by a successful manual scram. 3.2.6 Classification of Transient Conditions Many of the ICs and/or EALs employ time-based criteria. These criteria will require that the IC/EAL conditions be present for a defined period of time before an emergency declaration is Page 11 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-47 Enclosure 3; Attachment 2B warranted. In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes). The following guidance should be applied to-the classification of these conditions. EAL momentarily met during expected plant response - In instances in which an EAL is briefly met during an expected (normal) plant response, an emergency declaration is not warranted provided that associated systems and components are operating as expected, and operator actions are performed in accordance with procedures. EAL momentarily met but the condition is corrected prior to an emergency declaration - If an operator takes prompt manual action to address a condition, and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required. For illustrative purposes, consider the following example: An ATWS occurs and the high pressure ECCS systems fail to automatically start. The plant enters an inadequate core cooling condition (a potential loss of both the Fuel Clad and RCS Barriers). If an operator manually starts a high pressure ECCS system in accordance with an EOP step and clears the inadequate core cooling condition prior to an emergency declaration, then the classification should be based on the ATWS only. It is important to stress that the 15-minute emergency classification .assessment period (process clock) is not a "grace period" during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event. Emergency classification assessments must be deliberate and timely, with no undue delays. The provision discussed above addresses only those rapidly evolving situations when an operator is able to take a successful corrective action prior to the DSEO/ADTS completing the review and steps necessary to make the emergency declaration. This provision is included to ensure that any public protective actions resulting from the emergency classification are truly warranted by the plant conditions. 3.2.7 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery. This may be due to the event or condition . not being recognized at the time or an error that was made in the emergency classification process. In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022 (ref. 4.1.3) is applicable. Specifically, the event should be reported to the NRC in accordance with 10CFR 50.72 (ref. 4.1.4) within one hour of the discovery of the undeclared event or condition. The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements. 3.2.8 Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022 (ref. 4.1.3). Page 12 of 259

I Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-4 7 Enclosure 3; Attachment 28

4.0 REFERENCES

4.1 Developmental 4.1.1 NEI 99-01, Revision 6, "Methodology for the Development of Emergency Action Levels for Non-Passive Reactors" (ADAMS Accession No. ML12326A805) 4.1.2 RIS 2007-02, "Clarification of NRC Guidance for Emergency Notifications During Quick,ly Changing Events," February 2, 2007. 4.1.3 NUREG-1022, "Event Reporting Guidelines: 10CFR50.72 and 50.73" 4.1.4 10 CFR 50. 72, "Immediate Notification Requirements for Operating Nuclear Power Reactors" 4.1.5 10 CFR 50. 73, "License Event Report System" 4.1.6 Technical Specifications Table 1.1-1, "Operational Modes" 4.1.7 MP-22-REC-BAP01, "Radiological Effluent Monitoring and Offsite Dose Calculation Manual" 4.1.8 NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants" 4.1.9 MPS Emergency Plan 4.1.10 NUH-003, "UFSAR for the Horizontal Modular Storage System for Irradiated Fuel" 4.1.11 MPS2 ETE-NAF-2010-0004, "MPS Unit 2 ISFSI 10 CFR72.212 Evaluation Report" 4.1.12 UFSAR Chapter 9.8, "Fuel and Reactor Component Handling Equipment" 4.1.13 AOP 2577, "Fuel Handling Accident" 4.2 Implementing

    - 4.2.1 MP-26-EPI-FAP06, "Classification and PARs" 4.2.2 NEI 99-01 Rev. 6 to MPS2 EAL Comparison Matrix 4.2.3 MPS2 EAL Matrix r

Page 13 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-4 7 Enclosure 3; Attachment 2B 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS 5.1 Definitions (ref. 4.1.1 except as noted) Selected terms used in Initiating Condition, EAL statements and EAL bases are set in all capital letters (e.g., ALL CAPS). These are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below. 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. CONFINEMENT BOUNDARY The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. Confinement Boundary is defined as the NUHOMS Dry Shielding Canister (DSC) (ref. 4.1.10). CONTAINMENT CLOSURE The procedurally defined conditions or actions taken to secure containment (Primary or Secondary) and associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. Containment Closure is established when all of the following conditions exist (ref. 4.1.13):

The equipment door is closed and held in place by a minimum of four bolts or the outage equipment door is installed.
A minimum of one door in each airlock is closed.
Each penetration providing direct access from the containment atmosphere to the outside atmosphere is closed by an isolation valve, blind flange, manual valve, or special device.

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. 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:

Notification of Unusual Event (NGUE)
Alert
Site Area Emergency (SAE)
General Emergency (GE)

EXPLOSION Page 14 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-47 Enclosure 3; Attachment 2B 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 require a post-event inspection to determine if the attributes of an explosion are present. FAULTED The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized. 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. FISSION PRODUCT BARRIER THRESHOLD A pre-determined, site-specific, observable threshold indicating the loss or potential loss of a -fission product barrier. FLOODING A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area. GENERAL EMERGENCY Events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area. 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 NPP MPS 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 NPPMPS. 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 One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction. IMMINENT Page 15 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level TechnicaLBases Document Docket Nos. 50-366; 72-47 Enclosure 3; Attachment 28 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. IMPEDE{D) Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use bf protective equipment, such as SCBAs, that is not routinely employed). 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. 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.

Normal Levels

       /\s applied to radiological IC/E/\Ls, the highest reading in the past tv,enty four hours excluding the current peak value.

OWNER CONTROLLED AREA (OCA) The area within the SITE BOUNDARY including the PROTECTED AREA (ref. 4.1.9). PROJECTILE An object directed toward a Nuclear Power Plant that could ca,use concern for its continued operability, reliability, or personnel safety. PROTECTED AREA The area within the Millstone Power Station security fence (ref. 4.1.9). REFUELING PATHWAY Refueling pool (RFP), fuel transfer canal; and spent fuel pool (SFP), but not including the reactor vessel, comprise the refueling pathway (ref. 4.1.12). RUPTURED The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection. SAFETY SYSTEM A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the EGGS. These are typically systems classified as safety-related (as defined in 10CFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; Page 16 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-47 Enclosure 3; Attachment 2B (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. 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. SITE AREA EMERGENCY Events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA PAG exposure levels beyond the SITE BOUNDARY. SITE BOUNDARY That line beyond which the land is not owned, leased or otherwise controlled by MPS. Also see OWNER CONTROLLED AREA (ref. 4.1.7) 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. UNUSUAL EVENT Events are in progress or have occurred which indicate a potential degradation in 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. VALID An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. 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. Damage to a component or structure 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 component or structure. Page 17 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-47 Enclosure 3; Attachment 28 5.2 Abbreviations/Acronyms

~F ....................................................................................................... Degrees F~hrenheit 0
  ............................................................................................................................ Degrees
µCi .................................................................................................................... Micro Curie AC ....................................................................................................... Alternating Current ADTS .......................................................................Assistant Director Technical Support AFW ................................................................................................... Auxiliary Feedwater AOP ................................................................................. Abnormal Operating Procedure .

ARM .............................................................................................. Area Radiation Monitor A TWS ...................................................................... Anticipated Transient Without Scram COE ...................................................................................... Committed Dose Equivalent CET ............................................................................................. Core Exit Thermocouple CFR. ..................................................................................... Code of Federal° Regulations CIAS ..................................................................... Containment Isolation Actuation Signal CPM ..................................................................................................... Counts Per Minute CTMT ............................................................................................................. Containment DEF ........................... :......................................................................................... Defueled DBA ..._. ........................ 7................................................................... Design Basis Accident-DC ..................................................................... : ......................................... Direct Current DIG ......................................................................................................... Diesel Generator DSEO .............................................................. Director of Station Emergency Operations EAL ............................................................................................. Emergency Action Level ECCS ............................................................................Emergency Core Cooling System EGL .................................................................................. Emergency Classification Level EOF ................................................................................... Emergency Operations Facility EOP .............................................................................. Emergency Operating Procedure EPA .................. :........................................................... Environmental Protection Agency EPI .................................................................................... Emergency Plan Implementing FAA .................................................................................. Federal Aviation Administration FBI ................................................................................... Federal Bureau of Investigation FC .......................................................................................................... Fuel Clad Barrier FEMA ................................ *.............................. Federal Emergency Management Agency GE .......................................................................................................General Emergency GPM .................................................................................................... Gallons Per Minute HR .......................................................... ;.................................................... Heat Removal Hr............ ;..................................................................................................................Hour HSM ........................................................................................ Horizontal Storage Module IC ......................................................................................................... Initiating Condition Page 18 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-4 7 J Enclosure 3; Attachment 28 ICC ............................................................................................. lnadequate Core Cooling ISFSI ............................................................ Independent Spent Fuel Storage Installation Kett ......................................................................... Effective Neutron Multiplication Factor LCO .................................................................................. Limiting, Condition of Operation LER ......................................... :.......... ,.......................................... Licensee Event Report LOCA ......................................................................................... Loss of Coolant Accident LPSI ............................................................................. :..... Low Pressure Safety Injection I LRW ................................... :.................................................................... Liquid Radwaste LWR ...................................................................................................Light Water Reactor MCB ....................................................................................................Main Control Board Min ..........................................................................................................................Minute MPH ......................................... ;................................................................... Miles Per Hour MPS .. :.......................................................................................... Millstone Power Station mR mRem, mrem, mREM ............................................... mi Iii-Roentgen Equivalent Man MW ..................................................................................................................... Megawatt NEI ....... ,...................................................................................... Nuclear Energy Institute NEIC .................................................................. National Earthquake Information Center NPP ................................................................................................... Nuclear Power Plant NRC ............................................................................... Nuclear Regulatory Commission NSSS ......................................................... :...................... Nuclear Steam Supply Systern NORAD ................................................... North American Aerospace Defense Command OBE ...................................................................................... Operating Basis Earthquake OCA .............................................................................................. Owner Controlled Area PAG ....................................................................................... Protective Action Guideline PORV .................................................................................. Power Operated Relief Valve PSIG ............................................................................... Pounds per Square Inch Gauge PTS ....................................................................................... Pressurized Thermal Shock R ........................................................................................................................ Roentgen RBCCW ............................................................... Reactor Building Closed Coolant Water RCS ............................................................................................. Reactor Coolant System Rem, rem, REM ...................................................................... Roentgen Equivalent Man REMODCM ... Radiological Effluent Monitoring Manual Off-site Dose Calculation Manual RFP ............................................................................................................ Refueling Pool RPS ......................................................................................... Reactor Protection System RVLIS ........................................................ Reactor Vessel Level Instrumentation System RVLMS .............................................................. Reactor Vessel Level Monitoring System SBO .............................................................................................. :......... Station Blackout SCBA ... ... ....... ...... ......... ........... .. ... .............. ........ .... Self-Contained Breathing Apparatus SCIP ............................................... Security Contingency Plan Implementing Procedures Page 19 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-47 Enclosure 3; Attachment 2B SFP .................................................................................................. Spent Fuel Pool (Pit) SFSC .........................................................,. ....................... Safety Function Status Check SG ........................................................................................................... Steam Generator SI ............................................................................................................... Safety Injection SIAS ............................................................................. Safety Injection Actuation System SM ............................................................................................................... Shift Manager SPDS ........................................................................... Safety Parameter Display System SRO ........................................................................................... Senior Reactor Operator SRV ..................................................................................................... Safety Relief Valve TC (T/C) ..................................................................................................... Thermocouple TEDE ................................................ ,.............................. Total Effective Dose Equivalent TAF .......................................................................................................Top of Active Fuel TCBS ................................................................................................ Trip Circuit Breakers TS ............................................................................................... Technical Specifications TSC ........................................................................................... Technical Support Center UE .............................................................................................................. Unusual Event UFSAR ................................................................... Updated Final Safety Analysis Report USGS ............................................................................. United States Geological Survey Page 20 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-4 7 Enclosure 3; Attachment 28 6.0 MPS2-TO-NEI 99-01 Rev. 6 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of a MPS2 EAL within the NEI 99-01 IC/EAL identification scheme. Further information regarding the development of the MPS2 EALs based on the NEI guidance can be found in the EAL Comparison Matrix. MPS2 NEI 99-01, Rev. 6 Example EAL IC EAL RU1.1 AU1 1 RU1.2 AU1 2 RU1.3 AU1 3 RU1.4 AU1 1 RU1.5 AU1 3 RU2.1 AU2 1 RA1.1 AA1 1 RA1.2 AA1 2 RA1.3 AA1 3 RA1.4 AA1 4 RA2.1 AA2 1 RA2.2 AA2 2 RA2.3 AA2 3 RA3.1 AA3 1 RA3.2 AA3 2 RS1.1 AS1 1 RS1.2 AS1 2 RS1.3 AS1 3 RS2.1 AS2 1 RG1.1 AG1 1 RG1.2 AG1 2 Page 21 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-4 7 Enclosure 3; Attachment 28 MPS2 NEI 99-01, Rev. 6 Example EAL IC EAL RG1.3 AG1 3 RG2.1 AG2 1 CU1.1 CU1 1 CU1.2 CU1 2 CU2.1 CU2 1 CU3.1 CU3 1 CU3.2 CU3 2 CU4.1 CU4 1 CU5.1 CU5 1, 2, 3 CA1.1 CA1 1 CA1.2 CA1 2 CA2.1 CA2 1 CA3.1 CA3 1, 2 CA6.1 CA6 1 CS1.1 CS1 1 CS1.2 CS1 2 CS1.3 CS1 3 CG1.1 CG1 1 CG1.2 CG1 2 EUt.1 EU1 1 FA1.1 FA1 1 FS1.1 FS1 1 FG1.1 FG1 1 HU1.1 HU1 1, 2, 3 Page 22 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-47 Enclosure 3; Attachment 28 MPS2 NEI 99-01, Rev. 6 Example EAL IC EAL HU2.1 HU2 1 HU3.1 HU3 1 \ HU3.2 HU3 2 HU3.3 HU3 3 HU3.4 HU3 4 HU4.1 HU4 1 HU4.2 HU4 2 HU4.3 HU4 3 HU4.4 HU4 4 HU7.1 HU? 1 HA1.1 HA1 1, 2 HAS.1 HAS 1 HA6.1 HA6 1 HA7.1 HA? 1 HS1.1 HS1 1 HS6.1 HS6 1 HS7.1 HS? 1 HG?.1 HG? 1 MU1.1 SU1 1 MU3.1 SU2 1 MU4.1 SU3 1 MU4.2 SU3 2 MUS.1 SU4 1, 2, 3 MU6.1 SUS 1 Page 23 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-4 7 Enclosure 3; Attachment 28 MPS2 NEI 99-01, Rev. 6 Example EAL IC EAL MU6.2 SUS 2 MU7.1 SU6 1, 2, 3 MU8.1 SU? 1, 2 MA1.1 SA1 1 MA3.1 SA2 1 MA6.1 SAS 1 MA9.1 SA9 1 MS1.1 SS1 1 MS2.1 SS8 1 MS6.1 SSS 1 MG1.1 SG1 1 MG2.1 SGB 1 Page 24 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-366; 72-47 Enclosure 3; Attachment 2B 7.0 ATTACHMENTS 7 .1 Attachment 1, Emergency Action Level Technical Bases 7.2 Attachment 2, Safe Operation & Shutdown Areas Tables R-2 & H-2 Bases Page 25 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosur~ 3; Attachment 2B Category R - Abnormal Rad Release / Rad Effluent EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.) Many EALs are based on actual or potential degradation of fission product barriers because of the elevated potential for offsite radioactivity release. Degradation of fission product barriers though is not always apparent via non-radiological symptoms. Therefore, direct indication of elevated radiological effluents or area radiation levels are appropriate symptoms for emergency classification. At lower levels, abnormal radioactivity releases may be indicative of a failure of containment systems or precursors to more significant releases. At higher release rates, offsite radiological conditions may result which require offsite protective actions. Elevated area radiation levels in plant may also be indicative of the failure of containment systems or preclude access to plant vital equipment necessary to ensure plant safety. Events of this category pertain to1he following subcategories:

1. Radiological Effluent Direct indication of effluent radiation monitoring systems provides a. rapid assessment mechanism to determine releases in excess of classifiable limits. Projected offsite doses, actual offsite field measurements or measured release rates via sampling indicate doses or dose rates above classifiable limits.

2. Irradiated Fuel Events Conditions indicative of a loss of adequate shielding or damage to irradiated fuel may preclude access to vital plant areas or result in radiological releases that warrant emergency classification.

3. Area Radiation Levels Sustained general area radiation levels which may preclude access to areas required to safely operate and shutdown the plant also warrant emergen.cy classification.

Page 26 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1a - Radiological Effluent (Liquid) Initiating Condition: Release of liquid radioactivity greater than 2 times the allocated REMODCM limits for 60 minutes or longer EAL: RU1.1 Unusual Event Reae:ling on RM4262 SG Slowdown radiation monitor > 2x the "alarm" setpoint for >60 min. (Notes 1, 2, 3) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release patt,, then the effluent monitor reading is no longer VALID for classification purposes. Mode Applicability: All Definition{s): VALID -An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. Basis: This IC addresses a potential decrease in the level of safety of the plant as indicated by low- a 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 environm,ent. 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. 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 Page 27 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachm~nt 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes. 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 This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways (ref. 1). EAL #2 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., rad 11.1aste, \Vaste gas). EAL #3 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 MiRA 1. Reference(s):

1. MP-22-REC-BAP01, "Radiological Effluent Monitoring and Offsite Dose Calculation

Manual"

2. NEI 99-01 AU1 Page 28 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1a - Radiological Effluent (Liquid) Initiating Condition: Release of liquid radioactivity greater than 2 tirnes the allocated REMODCM limits for 60 minutes or longer EAL: Rl)1.2 Unusual Event Reading on any of the following effluent radiation monitors > 2 x the "alarm" setpoint established by a current radioactivity discharge permit for >60 min.

RM9049 Clean Liquid Radwaste Effluent
RM9116 Aerated Liquid Radwaste.Effluent
CND245 CPF Waste Neut Sump Effluent (Notes 1, 2, 3)

Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Note 3: 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. Mode Applicability: All pefinition(s): VALID -An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is"removed. Implicit in this definition is the need for timely assessment. 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 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. Page 29 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B 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. r 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. 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 #2 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-Such releases are typically be-associated with planned batch releases from non-continuous release pathways (e.g., radwaste, 1.vaste gas) (ref. 1). EAL #3 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.). CND245 CPF Waste Neut Sump Effluent monitor is local indication only. Escalation of the emergency classification level would be via IC AM-RA 1. Reference(s):

1. MP-22-REC-BAP01, "Radiological Effluent Monitoring and Offsite Dose Calculation Manual"

2. NEI 99-01 AU1 Page 30 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7

Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1a - Radiological Effluent (Liquid)

Initiating Condition: Release of liquid radioactivity greater than 2 times the allocated REMODCM limits for 60 minutes or longer EAL: RU1.3 Unusual Event Sample analysis for a liquid release indicates a concentration or release rate > 2 x the allocated REMODCM limits for >60 min. (Notes 1, 2) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Mode Applicability: All Definition(s): None 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 ttiose 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. 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 knmNn to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes. Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL. Page 31 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 E/\L #1 This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent path 1Nays. E/\L #2 This E/\L addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This E/\L 'Nill typically be associated 'JVith planned batch releases from non continuous release pathv,ays (e.g., radwaste, \Vasta gas). E/\L #3 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 fivef-ocean water systems, etc.). Escalation of the emergency classification level would be via IC AA4RA 1. Reference(s):

1. MP-22-REC-BAP01, "Radiological Effluent Monitoring and Offsite Dose Calculation Manual"

2. NEI 99-01 AU1 Page 32 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1b - Radiological Effluent (Gaseous) Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1 mrem TEDE EAL: RU1.4 Unusual Event I Reading on any Table R-1 effluent radiation monitor> column "UE" for ~60 min. (Notes 1, 2, 3) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Note 3: 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. Table R-1 Unit 2 Gaseous Effluent Monitor Classification Thresholds I Release Point & Monitor I GE I SAE I Alert I UE I Unit 2 Stack Gaseous Normal Range RM-81328 N/A N/A N/A 3.7E+05 cpm Mid/High Range RM-8168 1.6E+01 µCi/cc 1.6E+OO µCi/cc 1.6E-01 µCi/cc 1.6E-02 *µCi/cc Millstone Stack (WRGM) RM-8169 3.6E+02 µCi/cc 3.6E+01 µCi/cc 3.6E+OO µCi/cc 3.6E-01 µCi/cc Main Steam Line Rad

                       . RM-4299 A/C      3.5E+01 R/hr       3.5E+OO R/hr     3.5E-01 R/hr           N/A RM-4299 B        1.7E+01 R/hr       1.7E+OO R/hr      1.7E-01 R/hr          N/A Mode Applicability:

All Definition(s): VALID -An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. 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 fur *.vhich a radioacth£ity discharge permit is normally prepared. , Page 33 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 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. 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. Releases should not be prorateg or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL. E/\L #1 This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways (ref. 1, 2).E/\L #2 This E/\L addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This E/\L 'Nill typically be associated with planned batch releases from non continuous release path 1Nays (e.g., radwaste, waste gas). E/\L #3 This E/\L addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathvvays (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.) The basis for the gaseous Unusual Event IC and associated thresholds has been revised to correspond to any unplanned release of gaseous effluent radioactivity to the environment that will result in greater than 1 mrem TEDE. This Unusual Event gaseous release criterion is being used consistently across all operating nuclear units at Dominion Energy nuclear stations at Millstone, North Anna and Surry. The reason this alternative criterion is required is due to the fact that for some effluent gaseous release pathways, the resulting calculated Unusual Event threshold following the NEI 99-01 guidance of two times the site-specific effluent release limit would result in a Unusual Event threshold value greater than the corresponding calculated ALERT threshold based on exceeding 10 mrem TEDE. For the other gaseous release pathways that did not show an incongruent relationship when compared to the ALERT threshold, many showed Unusual Event values essentially equivalent to 1 mrem TEDE when applying the guidance in NEI 99-01 of a value set at two times the site-specific effluent release limit. The fact that. {1) many of the gaseous release pathway Unusual Event values following NEI 99-01 guidance were essentially equivalent to 1 mrem TEDE. (2) application of an alternative definition set at a value of 1 mrem TEDE results in a more limiting value for those release paths that showed incongruent comparison to the corresponding ALERT threshold, and (3) Unusual Event criterion set at a value ten (10) times lower than the ALERT threshold provides a logical and consistent escalation between each classification level. provides justification for the Unusual Event criterion of 1 mrem TEDE. This single Initiating Condition {IC) definition for gaseous releases at the Unusual Event level is being applied to maintain consistency across the Dominion Energy nuclear fleet and to reduce confusion and human Page 34 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 error potential if two different (IC) definitions were applied. Classification thresholds within Table R-1 were generated using the MIDAS dose assessment code. Inputs to MIDAS use most prevalent meteorological data and expected release point parameters. An assumed one-hour decay since shutdown and a one-hour release duration are applied. Mitigating reduction mechanisms (e.g., decay, sprays, filters) input into MIDAS for each accident type determined the radiological release source term consistent with the guidance provided in NUREG-1228. Due to the fact that there are no REMODCM limits on main steam line exhausts and the limited ability for these respective radiation monitors to detect low level activity in these steam line configurations, the UE classification threshold for the steam line exhaust is being labeled N/A (not applicable). Escalation of the emergency classification level would be via IC AM-RA1. Reference{s):

1. MP-22-REC-BAP01, "Radiological Effluent Monitoring and Offsite Dose Calculation Manual"

2. RP 18-02, "MP2 Abnormal Rad Release Gaseous EAL Thresholds based on NEI 99-01, Rev. 6"

3. NEI 99-01 AU1 Page 35 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1b - Radiological Effluent (Gaseous) Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1 mrem TEDE EAL: RU1.5 Unusual Event Sample analysis for a gaseous release indicates a concentration or release rate > 2 x the allocated REMODCM limits for >60 min. (Notes 1, 2) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Mode Applicability: All Definition(s): None 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 v,hich 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 control~ 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. Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flmN 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. Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL. Page 36 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Calculation RR 18-02 (ref. 2) demonstrates how a release rate limit based on 2 x the allocated REMODCM limit will produce essentially 1 mrem TEDE assuming most prevalent meteorological dispersion. Most prevalent meteorology represents conditions that would most likely to exist (based on most prevalent stability class and average wind speed within that stability class). Dispersion based on most prevalent meteorology differs from that assumed in the REMODCM which uses annual average meteorology. Dispersion based on actual meteorological conditions at the time of the emergency (most prevalent) can be 10 - 20 times higher than the annual average dispersion prescribed for use in an ODCM. E/\L #1 This E/\L addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways. E/\L #2 This E/\L addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This E/\L will typically be associated v,ith planned batch releases from non continuous release pathways (e.g., radwaste, 'Nasta gas). E/\L #3 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 AM-RA 1. Reference(s):

1. MP-22-REC-BAP01, "Radiological Effluent Monitoring and Offsite Dose Calculation Manual"

2. RP 18-02, "MP2 Abnormal Rad Release Gaseous EAL Thresholds based on NEI 99-01",

Rev. 6

3. NEI 99-01 AU1 Page 37 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE EAL: RA1.1 Alert Reading on any Table R-1 effluent radiation monitor> column "ALERT" for >15 min. (Notes 1, 2, 3, 4) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.' Note 3: 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. Note 4: The pre-calculated effluent monitor values presented in EALs RA1 .1, RS1 .1 and RG1 .1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. Table R-1 Unit 2 Gaseous Effluent Monitor Classification Threshold~ Release Point & Monitor GE SAE Alert UE Unit 2 Stack Gaseous Normal Range RM-81328 N/A N/A N/A 3.7E+05 cpm Mid/High Range RM-8168 1.6E+01 µCi/cc 1.6E+OO µCi/cc 1.6E-01 µCi/cc 1.6E-02 µCi/cc Millstone Stack (WRGM) RM-8169 3.6E+02 µCi/cc 3.6E+01 µCi/cc 3.6E+OO µCi/cc 3.6E-01 µCi/cc Main Steam Line Rad RM-4299A/C 3.5E+01 R/hr 3.5E+OO R/hr 3.SE-01 R/hr N/A RM-4299 8 1.7E+01 R/hr 1. 7E+OO R/hr 1.?E-01 R/hr N/A Mode Applicability: All Definition(s): VALID -An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. 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 Page 38 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Levei Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B 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 1,000 mrem TEDE 1Nhile the 50 mrem thyroid COE v,as established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid GG&. The thyroid COE component has been eliminated from this EAL as allowed.by EPA-400 (ref. 2) and consistent with direction provided by the States of Connecticut and New York. 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. Classification thresholds within Table R-1 were generated using the MIDAS dose assessment code. Inputs to MIDAS use most prevalent meteorological data and expected release point parameters. An assumed one-hour decay since shutdown and a one-hour release duration are applied. Mitigating reduction mechanisms (e.g., decay, sprays, filters) input into MIDAS for each accident type determined the radiological release source term consistent with the guidance provided in NUREG-1228. Since dose assessment is based on actual meteorology whereas the monitor reading EALs are not, the results from these assessments may indicate that the classification is not warranted, or may indicate that a higher classification is warranted. For this reason, emergency implementing procedures call for the timely performance of dose assessments using actual meteorology and release information. If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor readings listed in Table R-1. Escalation of the emergency classification level would be via IC AS4RS1. Reference(s):

1. RP 18-02, "MP2 Abnormal Rad Release Gaseous EAL Thresholds based on NEI 99-01",

Rev. 6

2. EPA-400, "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incident"

3. NEI 99-01 AA1 Page 39 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE EAL: RA1.2 Alert Dose assessment using actual meteorology indicates doses > 10 mrem TEDE at or beyond the SITE BOUNDARY (Note 4) Note 4: The pre-calculated effluent monitor values presented in EALs RA 1.1, RS 1.1 and RG 1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. Mode Applicability: All Definition(s): SITE BOUNDARY - That line beyond which the land is not owned, leased or otherwise controlled by MPS. Also see OWNER CONTROLLED AREA. 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 1,000 mrem TEDEwhile the 50 mrem thyroid COE was established in consideration of the 1:5 ratio of the EPA P/\G for TEDE and thyroid GG&. 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 knovm to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes. The thyroid COE component has been eliminated from this EAL as allowed by EPA-400 (ref. 2) and consistent with direction provided by the States of Connecticut and New York. Since dose assessment is based on actual meteorology whereas the monitor reading EALs are not, the results from these assessments may indicate that the classification is not warranted, or may indicate that a higher classification is warranted. For this reason, Page 40 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 emergency implementing procedures call for the timely performance of dose assessments using actual meteorology and release information. If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor readings listed in Table R-1. Actual meteorology is specifically identified since it gives the most accurate dose assessment. Actual meteorology (including forecasts) should be used whenever possible. Escalation of the emergency classification level would be via IC AS4RS1. Reference(s):

1. MP-26-EPI-FAP10, "Dose Assessment"

2. EPA-400, "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incident"

3. NEI 99-01 M1 Page 41 of 259

Millstone Power Station Unit 2 Serial- No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE EAL: RA1.3 Alert Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses> 10 mrem TEDE at or beyond the SITE BOUNDARY for 60 min. of exposure (Notes 1, 2) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Mode Applicability: All Definition(s): SITE BOUNDARY - That line beyond which the land is not owned, leased or otherwise controlled by MPS. Also see OWNER CONTROLLED AREA. 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 1,000 mrem 1.vhile the 50 mrem thyroid COE

.vas established in consideration of the 1:5 ratio of the EP/\ Pl\G for TEDE and thyroid COE.

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 thyroid COE component has been eliminated from this EAL as allowed by EPA-400 (ref. 3) and consistent with direction provided by the States of Connecticut and New York. Page 42 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B This EAL is assessed per the REMODCM (ref. 2). REMODCM software can be used to produce a dose to the maximum individual. Escalation of the emergency classification level would be via IC AS4-RS1. Reference(s):

1. MP-26-EPI-FAP10, "Dose Assessment"

2. MP-22-REC-BAP01, "Radiological Effluent Monitoring and Offsite Dose Calculation Manual"

3. EPA-400, "PAG Manual: Protective Action Guides ~nd Planning Guidance for Radiological Incident"

4. NEI 99-01 AA 1 Page 43 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B -Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gase,ous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE EAL: RA1.4 Alert Field survey results indicate closed window dose rates > 10 mR/hr expected to continue for ~60 min. at or beyond the SITE BOUNDARY (Notes 1, 2) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Mode Applicability: All Definition(s): SITE BOUNDARY - That line beyond which the land is not owned, leased or otherwise controlled by MPS. Also see OWNER CONTROLLED AREA. 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 1,000 mrem while the 50 mrem thyroid COE .vas established in consideration of the 1:5 ratio of the EPA PAGfor TEDE and thyroid COE. 1 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 knovm to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes. The thyroid COE component has been eliminated from this EAL as allowed by EPA-400 (ref. 3) and consistent with direction provided by the States of Connecticut and New York. Escalation of the emergency classification level would be via IC AS4RS1. Reference(s): Page 44 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; '72-4 7 Emergency Action Level Technical Bases Enclosyre 3; Attachment 28

1. MP-26-EPI-FAP10, "Dose Assessment"

2. MP-26-EPI-FAP04, "Emergency Operations Facility Activation and Operation"

3. EPA-400, "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incident"

4. NEI 99-01 AA 1 Page 45 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE EAL: RS1.1 Site Area Emergency Reading on any Table R-1 effluent radiation monitor> column "SAE" for >15 min. (Notes 1, 2, 3, 4) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Note 3: 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. Note 4: The pre-calculated effluent monitor values presented in EALs RA 1.1, RS1 .1 and RG1 .1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. Table R-1 Unit 2 Gaseous Effluent Monitor Classification Thresholds Release Point & Monitor GE SAE Alert UE Unit 2 Stack Gaseous Normal Range RM-81328 N/A N/A N/A 3.7E+05 cpm Mid/High Range RM-8168 1.6E+01 µCi/cc 1.6E+OO µCi/cc 1.6E-01 µCi/cc 1.6E-02 µCi/cc Millstone Stack (WRGM) RM-8169 3.6E+02 µCi/cc 3.6E+01 µCi/cc 3.6E+OO µCi/cc 3.6E-01 µCi/cc Main Steam Line Rad RM-4299NC 3.5E+01 R/hr 3.5E+OO R/hr 3.5E-01 R/hr N/A RM-4299 B 1.7E+01 R/hr 1. 7E+OO R/hr 1.7E-01 R/hr N/A Mode Applicability: All Definition(s): VALID -An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. Basis: This IC addresses a release of gaseous radioaqtivity 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 Page 46 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 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 1,000 mrem TEDE1Nhile the 500 mrem thyroid COE 'Nas established in consideration of the 1:5 ratio of the EP/\ P/\G for TEOE and thyroid COE. The thyroid COE component has been eliminated from this EAL as allowed by EPA-400 (ref. 2} and consistent with direction provided by the States of Connecticut and New York. 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. Classification thresholds within Table R-1 were generated using the MIDAS dose assessment code. Inputs to MIDAS use most prevalent meteorological data and expected release point parameters. An assumed one-hour decay since shutdown and a one-hour release duration are applied. Mitigating reduction mechanisms (e.g., decay, sprays, filters} input into MIDAS for each accident type determined the radiological release source term consistent with the guidance provided in NUREG-1228. Since dose assessment is based on actual meteorology whereas the monitor reading EALs are not, the results from these assessments may indicate that the classification is not warranted, or may indicate that a higher classification is warranted. For this reason, emergency implementing procedures call for the timely performance of dose assessments using actual meteorology and release information. If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level}, the dose assessment results override the monitor readings listed in Table R-1. Escalation of the emergency classification level would be via IC AG4-RG1. Reference(s):

1. RP 18-02 MP2, "Abnormal Rad Release Gaseous EAL Thresholds based on NEI 99-01",

Rev.6

2. EPA-400, "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incident"

3. NEI 99-01 AS1 Page 4 7 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE EAL: RS1.2 Site Area Emergency Dose assessment using actual meteorology indicates doses > 100 mrem TEDE at or beyond the SITE BOUNDARY (Note 4) Note 4: The pre-calculated effluent monitor values presented in EALs RA 1.1, RS1 .1 and RG1 .1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. Mode Applicability: All Definition(s): SITE BOUNDARY - That line beyond which the land is not owned, leased or otherwise controlled by MPS. Also see OWNER CONTROLLED AREA. 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 monitor.ed 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 1,000 mrem while the 500 mrem thyroid COE

.vas established in consideration of the 1 :5 ratio of the EPA Pl\G for TEDE and thyroid COE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flovv 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 thyroid CDE component has been eliminated from this EAL as allowed by EPA-400 (ref. 2) and consistent with direction provided by the States of Connecticut and New York. Since dose assessment is based on actual meteorology whereas the monitor reading EALs are not, the results from these assessments may indicate that the classification is not warranted, or may indicate that a higher classification is warranted. For this reason, emergency implementing procedures call for the timely performance of dose assessments using actual meteorology and release information. If the results of these dose assessments are Page 48 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor readings listed in Table R-1. Actual meteorology is specifically identified since it gives the most accurate dose assessment. Actual meteorology (including forecasts) should be used whenever possible. Escalation of the emergency classification level would be via IC AG4RG1. Reference(s):

1. MP-26-EPI-FAP10, "Dose Assessment"

2. EPA-400, "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incident" *

3. NEI 99-01 AS1 Page 49 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent I Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE EAL: RS1.3 Site Area Emergency Field survey results indicate closed window dose rates > 100 mR/hr expected to continue for ~60 min. at or beyond the SITE BOUNDARY (Notes 1, 2) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Mode Applicability: All Definition(s): SITE BOUNDARY - That line beyond which the land is not owned, leased or otherwise controlled by MPS. Also see OWNER CONTROLLED AREA. 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 1,000 mrem TEDEv.ihile the 500 mrem thyroid COE 1A1as established in consideration of the 1:5 ratio of the EPA PAG for TEOE and thyroid COE. 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 l<nown to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes. The thyroid COE component has been eliminated from this EAL as allowed by EPA-400 (ref. 3) and consistent with direction provided by the States of Connecticut and New York. Escalation of the emergency classification level would be via IC AG4RG1. Reference(s):

1. MP-26-EPI-FAP10, "Dose Assessment" Page 50 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28

2. MP-26-EPI-FAP04, "Emergency Operations Facility Activation and Operation"

3. EPA-400, "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incident"

4. NEI 99-01 AS1 Page 51 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE EAL: RG1.1 General Emergency Reading on any Table R-1 effluent radiation monitor> column "GE" for ~15 min. (Notes 1, 2, 3, 4) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Note 3: If the effluent flow past an effluent monitor is knm,yn to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes. Note 4: The pre-calculated effluent monitor values presented in EALs RA1 .1, RS1 .1 and RG1 .1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. Table R-1 Unit 2 Gaseous Effluent Monitor Classification Threshold~ Release Point & Monitor GE SAE Alert UE Unit 2 Stack Gaseous Normal Range RM-81328 NIA NIA NIA 3.7E+05 cpm Mid/High Range RM-8168 1.6E+01 µCi/cc 1.6E+OO µCi/cc 1.6E-01 µCi/cc 1.6E-02 µCi/cc Millstone Stack (WRGM) RM-8169 3.6E+02 µCi/cc 3.6E+01 µCi/cc 3.6E+OO µCi/cc 3.6E-01 µCi/cc Main Steam Line Rad RM-4299 A/C 3.5E+01 R/hr 3.5E+OO R/hr 3.5E-01 R/hr NIA RM-4299 B 1.7E+01 R/hr 1.7E+OO R/hr 1. 7E-01 R/hr NIA Mode Applicability: All Definition(s): VALID -An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. Basis: 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 Page 52 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 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 1,000 mrem TEDEwhile the 5,000 mrem thyroid COE was established in consideration of the 1:5 ratio of the EP/\ P/\G for TEDE and thyroid GG. The thyroid COE component has been eliminated from this EAL as allowed by EPA-400 (ref. 2) and consistent with direction provided by the States of Connecticut and New York. 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. Classification thresholds within Table R-1 were generated using the MIDAS dose assessment code. Inputs to MIDAS use most prevalent meteorological data and expected release point parameters. An assumed one-hour decay since shutdown and a one-hour release duration are applied. Mitigating reduction mechanisms (e.g., decay, sprays, filters) input into MIDAS for each accident type determined the radiological release source term consistent with the guidance provided in NUREG-1228. Since dose assessment is based on actual meteorology whereas the monitor reading EALs are not, the results from these assessments may indicate that the classification is not warranted, or may indicate that a higher classification is warranted. For this reason, emergency implementing procedures call for the timely performance of dose assessments using actual meteorology and release information. If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor readings listed in Table R-1. Reference(s):

1. RP 18-02 MP2, "Abnormal Rad Release Gaseous EAL Thresholds based on NEI 99-01 ",

Rev.6

2. EPA-400, PAG, "Manual: Protective Action Guides and Planning Guidance for Radiological Incident"

3. NEI 99-01 AG1 Page 53 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE EAL: RG1.2 General Emergency Dose assessment using actual meteorology indicates doses > 1,000 mrem TEDE at or beyond the SITE BOUNDARY (Note 4) Note 4: The pre-calculated effluent monitor values presented in EALs RA 1.1, RS1 .1 and RG1 .1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. Mode Applicability: All Definition(s): SITE BOUNDARY - That line beyond which the land is not owned, leased or otherwise controlled by MPS. Also see OWNER CONTROLLED AREA. Basis: 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 1,000 mrem TEDE*Nhile the 5,000 mrem thyroid COE 1.Nas established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid GG&. 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 knmNn to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes. The thyroid COE component has been eliminated from this EAL as allowed by EPA-400 (ref. 2) and consistent with direction provided by the States of Connecticut and New York. Since dose assessment is based on actual meteorology whereas the monitor reading EALs are not, the results from these assessments may indicate that the classification is not warranted, or may indicate that a higher classification is warranted. For this reason, emergency implementing procedures call for the timely performance of dose assessments Page 54 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B using actual meteorology and release information. If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor readings listed in Table R-1. Actual meteorology is specifically identified since it gives the most accurate dose assessment. Actual meteorology (including forecasts) should be used whenever possible. Reference(s):

1. MP-26-EPI-FAP10, "Dose Assessment"

2. EPA-400; "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incident"

3. NEI 99-01 AG1 I

Page 55 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE EAL: RG1.3 General Emergency Field survey results indicate closed window dose rates > 1,000 mR/hr expected to continue for >60 min. at or beyond the SITE BOUNDARY (Notes 1, 2) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Mode Applicability: All Definition(s): 1 SITE BOUNDARY - That line beyond which the land is not owned, leased or otherwise controlled by MPS. Also see OWNER CONTROLLED AREA. Basis: 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 1,000 mrem TEDE1Nhile the 5,000 mrem thyroid COE was established in consideration of the 1:5 ratio of the EPA P/\G for TEDE and thyroid GGe. Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flmv past an effluent monitor is l<nown to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes. The thyroid COE component has been eliminated from this EAL as allowed by EPA-400 (ref. 3) and consistent with direction provided by the States of Connecticut and New York. Reference(s):

1. MP-26-EPI-FAP10, "Dose Assessment"

2. MP-26-EPI-FAP04, "Emergency Operations Facility Activation and Operation" Page 56 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28

3. EPA-400, "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incident"

4. NEI 99-01 AG1 Page 57 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Events Initiating Condition: UNPLANNED loss of water level above irradiated fuel EAL: RU2.1 Unusual Event UNPLANNED water level'drop in the REFUELING PATHWAY as indicated by any of the following: *

SFP LEVEL LO alarm C-06/7 8-14
CTMT NORM SUMP LEVEL HI/LO alarm C-06/7 BA-21
Report of dropping level in RFP or SFP
SFP CLG PUMP SUCTION FLOW LO alarm C-06/07 D-13 AND UNPLANNED rise in corresponding area radiation levels as indicated by any of the following radiation monitors:
RM-7890 Personnel Access Area
RM-7891 Containment Refuel Floor
RM-8139 SFP SW Area
RM-8142 SFP NW Area
RM-8156 SFP NE Area
RM-8157 SFP SE Area Mode Applicability:

All Definition(s): 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- Refueling pool (RFP), fuel transfer canal, and spent fuel pool (SFP), but not including the reactor vessel, comprise the refueling pathway. Basis: This IC addresses a decrease 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 decrease will be primarily determined by indications from ava_ilable 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). A significant drop in the water level may also cause a loss of SFP Cooling suction flow and an increase in the radiation levels of adjacent areas that can be detected by monitors in those *1ocations. Page 58 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 The specified radiation monitors are those expected to see increase area radiation levels as a result of a loss of REFUELING PATHWAY inventory (ref. 1, 2, 3). Increasing radiation indications on these monitors in the absence of indications of decreasing REFUELING , PATHWAY level are not classifiable under this EAL. The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may increase 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 AA2:RA2. Reference(s):

1. AOP 2578, "Loss of Refuel Pool and Spent Fuel Pool Level"

2. AOP 2577, "Fuel Handling Accident"

3. OP 23838, "Area Radiation Monitors"

4. NEI 99-01 AU2 Page 59 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Events Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL: RA2.1 Alert IMMINENT uncovery of irradiated fuel in the REFUELING PATHWAY Mode Applicability: All Definition(s): CONFINEMENT BOUNDARY- The barrier(s) between spent fuel and the environment once the spe~t fuel is processed for dry storage. Confinement Boundary is defined as the NUHOMS Dry Shielding Canister (DSC). 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. REFUELING PATHWAY- Refueling pool (RFP), fuel transfer canal, and spent fuel pool (SFP), ~ but not including the reactor vessel, comprise the refueling pathway. Basis: 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 poolREFUELING PATHWAY (see Do'l-el-oporl\1-otes). 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 pla~t. This IC applies toFor irradiated fuel that is licensed for dry storage, this EAL applies 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-1=4U1. Escalation of the emergency would be based on either Recognition Category A-B._or C ICs. EAL#1 This EAL escalates from AY2--RU2.1 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 personnE31 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 an increase 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. Page 60 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance with Recognition Category C during the Cold Shutdown and Refueling modes .. EAL #2 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 vvith in plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident). EAL#3 Spent fuel pool water level at this value is vvithin the lov,er 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. Escalation of the emergency classification level 'Nould be via ICs AS1 or AS2 (see AS2 D0*.,1 e'ope'"

       ,      /\'etas)

r 11 Reference(s):

1. NEI 99-01 M2 Page 61 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Events Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL: RA2.2 Alert Damage to irradiated fuel resulting in a release of radioactivity AND VALi D alarm on any of the following radiation monitors:

RM-7890 Personnel Access Area
RM-7891 Containment Refuel Floor
RM-81238 or RM-82628 Containment Gaseous
RM-8139 SFP SW Area
RM-8142 SFP NW Area
RM-8156 SFP NE Area
RM-8157 SFP SE Area
RM-81458 Spent Fuel Pool Exhaust Gaseous Mode Applicability:

All CONFINEMENT BOUNDARY- The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. Confinement Boundary is defined as the NUHOMS Dry Shielding Canister (DSC). VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. Basis: The specified radiation monitors are those expected to see increased area radiation levels as a result of damage to irradiated fuel (ref. 1, 2, 3, 4). This G--EAL addresses events that have caused imminent or actual damage to an irradiated fuel assembly, or a significant lowering of water level vvithin the spent fuel pool (see De'l-e.loper .'Votes). 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. Page 62 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 This IC applies toFor irradiated fuel that is licensed for dry storage, this EAL applies up to the point that the loaded storage cask is sealed. Once sealed, damage to a lo,aded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-MU1. El\L #This El\L escalates from l\U2 in that the loss of level, in the affected portion of the REFUELING Pl\THVVl\Y, 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 curv'e). Classification of an event using this E/\L should be based on the totality of available indications, reports and observations. While an area radiation monitor could detect an increase in a dose rate due to a lowering of vvater level in some portion of the REFUELING Pl\THVVl\Y, 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 1JVith other available indications of inventory loss. l\ drop in \Nater level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C 'during the Cold Shutdovm and Refueling modes. 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). El\L #3Spent fuel pool 1JVater level at this value is within the 101.ver 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 1JVater 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. Escalation of the emergency would be based on either Recognition Category A-B_or C ICs. Escalation of the emergency classification level would be via ICs l\S1 or l\S2 (see AS2 Develepe.~ .'Votes). Reference(s):

1. AOP 2577, "Fuel Handling Accident"

2. AOP 2578, "Loss of Refuel Pool and Spent Fuel Pool Level"

3. OP 23838, "Area Radiation Monitors"

4. NEI 99-01 AA2 Page 63 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Events Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL: RA2.3 Alert Lowering of spent fuel pool level to 10 ft. (Level 2) on Ll-7013 or Ll-7014 Mode Applicability: All Definition(s): None Basis: This .J.G-.EAL 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 (see Developer Notes). 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 ICE HU1. Escalation of the emergency would be based on either Recognition Category /\_or C ICs. EAL #This EAL escalates from l\U2 in that the loss of *1evel, in the affected portion of the REFUELING Pl\THVV/\Y, 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 111011 as significant changes in ,Nater 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. VVhile an area radiation monitor could detect an increase in a dose rate due to a lowering of 'Nater level in some portion of the REFUELING Pl\THVVl\Y, the reading may not be a reliable indication of 'Nhether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss. l\ drop in 'Nater level above irradiated fuehvithin the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdovvn and Refueling modes. This E/\L 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. /\ r.ise 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). E/\L #3Spent fuel pool water level at this value is within the lower end of the level range Page 64 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases ' Enclosure 3; Attachment 28 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. Escalation of the emergency classification level would be via ICs AS4-RS1 or ARS2 (see AS2 Developer l\lotes). Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication (Ll-7013 and Ll-7014) capable of identifying normal level (Level 1 - EL 36 ft. 3 in.). SFP level 10 ft. above the top of the fuel racks (Level 2 - EL 23 ft. 3 in.) and SFP level at 1 ft. above the top of the fuel racks (Level 3 - EL 14 ft. 3 in.) (ref. 1. 2). Primary level indicator Ll-7013 and display cabinet C547 are located on the 25 ft. 6 in. elevation of the Auxiliary Building in the Cable Vault Room near column lines K.6-15.9. The backup channel level indicator Ll-7014 and display cabinet C548 are located on the 36 ft. 6 in. elevation of the Auxiliary Building in the East 480V Switchgear Room near column line F.8-15.9. Reference(s):

1. ETE-CPR-2012-0009, "Millstone Unit 2 - Beyond Design Basis FLEX Strategy Basis Document and Final Integrated Plan"

2. DC MP2-13-01011 "Beyond Design Basis Spent Fuel Pool Level Instrument Installation, Millstone Unit 2"

3. NEI 99-01" AA2 Page 65 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Events Initiating Condition: Spent fuel pool level at the top of the fuel racks EAL: RS2.1 Site Area Emergency Lowering of spent fuel pool level to 1 ft. (Level 3) on Ll-7013 or Ll-7014 Mode Applicability: All Definition(s): 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. Basis: This -G-EAL 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. 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 AG4-RG1 or ~RG2. Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication (Ll-7013 and Ll-7014) capable of identifying normal level (Level 1 - EL 36 ft. 3 in.), SFP level 10 ft. above the top of the fuel racks (Level 2 - EL 23 ft. 3 in.) and SFP level at 1 ft. above the top of the fuel racks (Level 3 - EL 14 ft. 3 in.) (ref. 1, 2). Primary level indicator Ll-7013 and display cabinet C547 are located on the 25 ft. 6 in. elevation of the Auxiliary Building in the Cable Vault Room near column lines K.6-15.9. The backup channel level indicator Ll-7014 and display cabinet C548 are located on the 36 ft. 6 in. elevation of the Auxiliary Building in the East 480V Switchgear Room near column line F.8-15.9. Reference(s):

1. ETE-CPR-2012-0009, "Millstone Unit 2 - Beyond Design Basis FLEX S~rategy Basis Document and Final Integrated Plan"

2. DC MP2-13-01011 "Beyond Design Basis Spent Fuel Pool Level Instrument Installation, Millstone Unit 2"

3. NEI 99-01 AS2 Page 66 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Events Initiating Condition: Spent fuel pool level cannot be restored to at least the top of the fuel racks for 60 minutes or longer EAL: RG2.1 General Emergency Spent fuel pool level cannot be restored to at least 1 ft. (Level 3) on Ll-7013 or Ll-7014 for ~60 min. (Note 1) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Mode Applicability: All Definition(s): None Basis: This .JG-EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncpvery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment. It is recognized that this .JG-EAL would likely not be met until well after another General Emergency .JG-EAL was met; however, it is inc,luded to provide classification diversity. Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication (Ll-7013 and Ll-7014) capable of identifying normal level (Level 1 - EL 36 ft. 3 in.), SFP level 10 ft. above the top of the fuel racks (Level 2 - EL 23 ft. 3 in.) and SFP level at 1 ft. above the top of the fuel racks (Level 3 - EL 14 ft. 3 in.) (ref. 1, 2). Primary level indicator Ll-7013 and display cabinet C547 are located on the 25 ft. 6 in. elevation of the Auxiliary Building in the Cable Vault Room near column lines K.6-15.9. The backup channel level indicator Ll-7014 and display cabinet C548 are located on the 36 ft. 6 in. elevation of the Auxiliary Building in the East 480V Switchgear Room near column line F.8-15.9. Reference(s):

1. ETE-CPR-2012-0009, "Millstone Unit 2 - Beyond Design Basis FLEX Strategy Basis Document and Final Integrated Plan"

2. DC MP2-13-01011 "Beyond Design Basis Spent Fuel Pool Level Instrument Installation, Millstone Unit 2"

3. NEI 99-01 AG2 Page 67 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 3 - Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL: RA3.1 Alert Dose rate > 15 mR/hr in EITHER of the following areas:

Control Room
Central Alarm Station Mode Applicability:

All Definition(s): IMPEDE(D) - Personnel access to a room or area is hindered to an extent that 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). Basis: This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or IMPEDE personnel from performing actions necessary to maintain normal plant operation, or to perform a normal plant cooldown and shutdown. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency DirectorDSEO/ADTS should consider the cause of the increased radiation levels and determine if another IC may be applicable._For E/\L #2, an /\lert declaration is \varranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the elevated radiation levels. Theremergency 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, requiring use of non routine protective equipment, requesting an extension in dose limits beyond normal administrative limits). /\n emergency declaration is not warranted if any of the follovving conditions apply. The plant is in an operating mode different than the moqe specified for the affected roomtarea (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 increase 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.). Page 68 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds br routine inspections). The access control measures are of a conservative or precautionary nature, and vvould not actually prevent or impede a required action. Areas that meet this threshold include the Control Room {CR} and the Central Alarm Station {GAS). The Control Room is monitored for excessive radiation by one detector, RM-7899 (ref. 1, 2). The GAS is included in this EAL because of its importance to permitting access to areas required to assure safe plant operations. Escalation of the emergency classification level vvould be via Recognition Category /\, C or F ICs. Reference(s):

1. OP 23838, "Area Radiation Monitors"

2. NEI 99-01 AA3 Page 69 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 3 - Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL: RA3.2 Alert An UNPLANNED event results in radiation levels that prohibit or IMPEDE access to any Table R-2 room or area (Note 5) Note 5: 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. Table R-2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux. Building El -5'6" West Area Aux. Building El -5'6" East Near SFP Cooling Aux. Building El 14'6" 851 & 861 Enclosures 3 Aux. Building El 14'6" Boric Acid Batching Tank Aux'. Building El -25'6"

RB HxArea Enc. Building El -5'6" East Pipe Penetration Aux. Building El 14'6" By 861 Enc. Building El -45'6" "A" & "B" ESF Rooms 3,4 Aux. Building El -45'6" General Area Enc. Building El -5'6" West Pipe Penetration 3,5 Aux. Building El 14'6" SE Across From MCC 851 4 Aux. Building El -5'6" VCT Block Wall Area 5

Enc. Building El -45'6." "A" ESF Room Mode Applicability: 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown Definition(s): /MPEDE(D) - Personnel access to a room or area is hindered to an extent that 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). 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. Page 70 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Basis: This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or IMPEDE personnel from performing actions necessary to maintain normal plant operation, or to perform a normal plant cooldown and shutdown. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency DirectorDSEO/ADTS should consider the cause of the increased radiation levels and determine if another IC may be applicable. For EAL #2 RA3.2, 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 at the time of the elevated radiation levels. 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, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits). If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact beyond that already allowed by Technical Specifications at the time of the event. The list of plant rooms or areas with entry-related mode applicability identified specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation. cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g .* an action to address an off-normal or emergency condition such as emergency repairs. corrective measures or emergency operations) are not included. In addition. the list specifies the plant mode(s) during which entry would be required for each room or area (ref 1 ). 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 increase 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.).
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 A, C or F ICs. Reference(s):

1. Attachment 2, "Safe Operation & Shutdown Areas Tables R-2 & H-2 Bases"

2. NEI 99-01 AA3 Page 71 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Page 72 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category C - Cold Shutdown / Refueling System Malfunction EAL Group: Cold Conditions (RCS temperature <200°F); EALs in this category are applicable only in one or more cold operating modes. Category C EALs are directly associated with cold shutdown or refueling system safety functions. Given the variability of plant configurations (e.g., systems out-of-service for maintenance, containment open, reduced AC power redundancy, time since shutdown) during these periods, the consequences of any given initiating event can vary greatly. For example, a loss of decay heat removal capability that occurs at the end of an extended, outage has Jess significance than a similar loss occurring during the first week after shutdown. Compounding these events is the* likelihood that instrumentation necessary for assessment may also be inoperable. The cold shutdown and refueling system malfunction EALs are based on performance capability to the extent possible with consideration given to RCS integrity, CONTAINMENT CLOSURE, and fuel clad integrity for the applicable operating modes (5 - Cold Shutdown, 6 - Refueling, DEF - Defueled). The events of this category pertain .to the following subcategories:

1. RCS Level RCS water level is directly related to the status of adequate core cooling and, therefore, fuel clad integrity.

2. Loss of Emergency AC Power Loss of vital plant electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite power sources for 4.16 KV emergency buses.

3. RCS Temperature Uncontrolled or inadvertent temperature or pressure rises are indicative of a potential loss of safety functions.

4. Loss of Vital DC Power Loss of emergency plant electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of power to or degraded voltage on the 125V DC vital buses.

5. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.

6. Hazardous Event Affecting Safety Systems Certain hazardous natural and technological events may result in VISIBL~ DAMAGE to or degraded performance of safety systems warranting classification.

Page 73 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory EAL: CU1.1 Unusual Event UNPLANNED loss of reactor coolant results in RCS water level < a required lower limit for

 ~15 min. (Note 1)

Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Mode Applicability: 5 - Cold Shutdown, 6 - Refueling Definition(s): 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. Basis: RCS water level less than a required lower limit is meant to be less than the lower end of the level control band being procedurally maintained for the current condition or evolution. With the plant in Cold Shutdown, RCS water level is normally maintained within a pressurizer level control band (ref. 1 ). However, if RCS level is being controlled below the normal pressurizer level control band, or if level is being maintained in a designated band in the reactor vessel it is the inability to maintain level above the low end of the designated control band due to a loss of inventory resulting from a leak in the RCS that is the concern. With the plant in Refueling mode, RCS water level is normally maintained at or above the reactor vessel flange (ref. 2, 3). 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 (reactor vessel/RCS [Pl#R] or RPV [BL"IR]) 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. Refueling evolutions that decrease 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. This EAL-#1- recognizes that the minimum required (reactor vessel/RCS [PLAIR] or RPV [BLAIR]) 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. Page 74 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B 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 addresses a condition where all means to determine (reactor vessel/RCS [PVVR] or RPV [Bv'IR]) level have been lost. In this condition, operators may determine that an inventory loss is occurring by obseNing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of 'Nater flmv to ensure they are indicative of leakage from the (reactor vessel/RCS [Pv'IR] or RPV [Bv'IR]). Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA 1 or CA3. Reference(s):

1. OP 2207, "Plant Cool down"

2. OP 2209B, "RCS Inventory Tracking"

3. OP 2209A, "Refueling Operations"

4. NEI 99-01 CU1 Page 75 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory EAL: CU1.2 Unusual Event RCS water level cannot be monitored AND EITHER:

UNPLANNED rise in any Table C-1 sump or tank level due to a loss of RCS inventory
Visual observation of UNISOLABLE RCS leakage Table C-1 Sumps/Tanks
Containment Sump
RWST
PDT
Quench Tank
EDST (L9736)

                                  *  'A' CWRT (letdown line CH-345 or SOC line Sl-468) (Panel C-63)

SIT 1, 2 3, 4 Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s): UN/SOLABLE - An open or breached system line that cannot be isolated, remotely or locally. UNPLANNED-. A parameter changes 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.

Basis: 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 (reactor vessel/RCS [PVVR] or RPV [BWR]) 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. Refueling evolutions that decrease 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. Page 76 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 E/\L #1 recognizes that the minimum required (reactor vessel/RCS [Pv1/R] or [Bv1/R]) level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This E/\L 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. This EAL #&addresses a condition where all means to determine (reactor vessel/RCS [PVVR] or [BVVR]) 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 (Table C-1) (ref. 1, 2). 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 (reactor vessel/RCS (ref. 2, 3, 4) [PVVR] or [BVVR]). - For indications of increasing water level in the "A" CWRT, sources of RCS inventory is via either letdown line CH-345 or shutdown cooling line Sl-468 on Panel (C-63). ( Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3. - Reference(s):

1. OP 2207, "Plant Cooldown"

2. OP 2209B, "RCS Inventory Tracking"

3. AOP 2572, "Loss of Shutdown Cooling"

4. AOP 2568A," RCS Leak, Mode 4, 5, 6 and Defueled"

5. NEI 99-01 CU1 r

Page 77 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Significant Loss of RCS inventory EAL: CA1.1 Alert Loss of RCS inventory as indicated by RCS water level< - 4 in. on Ll-112 (CCTV) or L-122 (PPC) Mode Applicability: 5 - Cold Shutdown, 6 - Refueling Definition(s): None Basis: 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. For this EAL-#!-, a lowering of RCS water level below (site specific level) ft-4 in. on Ll-112 or L-122 indicates that operator actions have not been successful in restoring and maintaining (reactor vessel/RCS [PVl/R] or RPV [BVVR]) water level. The heat-up rate of the coolant will increase as the available water inventory is reduced. A continuing decrease in water level will lead to core uncovery. RCS hot leg level of 4 in. below centerline is the lowest RCS level that supports continued decay heat removal pump operations (SOC) (ref. 1, 2, 3). Although related, this EAL 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 Decay Heat Removal suction point). An increase in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA3. A decreasing RCS level can be indicated by (ref. 1):

L-112 RCS mid-loop wide range RCS level transmitter (PPC)
L-122 No. 2 hot leg narrow range level transmitter (PPC)
Ll-112 No. 1 hot leg RCS mid-loop level indicator (CCTV)
ICC Reactor Vessel Level Monitoring System (RVLMS)

For EAL #2, the inability to monitor (reactor vessel/RCS [PVVR] or RPV [BVVR]) level may be caused by instrumentation and/or pmver 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 'Nater flow to ensure they are indicative of leal<age from the (reactor vessel/RCS [PVVR] or RPV [B'MR]) rv . Page 78 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B The 15 minute duration for the loss of level indication 1Nas chosen because it is half of the EAL duration specified in IC CS1 If RCS the (reactor vessel/RCS [PVVRJ or RPV [8VVR]) inventory water level continues to lower, then escalation to Site Area Emergency would be via IC CS1. Reference(s):

1. AOP 2572, "Loss of Shutdown Cooling"

2. AOP 2568A, "Res-Leak, Mode 4, 5, 6 and Defueled"

3. OP 2301 E, "Draining the RCS (ICCE)"

4. NEI 99-01 CA 1 Page 79 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Significant Loss of RCS inventory EAL: CA1.2 Alert RCS water level cannot be monitored for ~15 min. (Note 1) AND EITHER

UNPLANNED rise in any Table C-1 sump or tank level due to a loss of RCS inventory
Visual observation of UNISOLABLE RCS leakage Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Table C-1 Sumps/Tanks

Containment Sump
RWST
PDT
Quench Tank
EDST (L973p)

                                    *   'A' CWRT (letdown line CH-345 or SOC line Sl-468) (Panel C-63)

SIT 1, 2 3, 4 Mode' Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s): UN/SOLABLE - 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 kr:iown or unknown. Basis: 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. For EAL #1, a lovvering of ,.vater level belm.v (site specific level) indicates that operator actions have not been successful in restoring and maintaining (reactor vessel/RCS [PL"IR] or RPV [BL"IR]) water level. The heat up rate of the coolant will i,ncrease as the available 1.vater inventory is reduced. A continuing decrease in water level will lead to core uncovery. Page 80 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Although related, E/\L #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). An increase in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA3. For this EAL--#2-, the inability to monitor (reactor vessel/RCS [PVVR] or RPV [BVVR]) 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 (ref. 1. 2). 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 (reactor vessel/RCS [PVVR] or RPV [BVVR]) (ref

2. 3. 4).

The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS1.:. If the (reactor vessel/RCS [PVVR] or RPV [BVVR]) inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS1. Reference(s):

1. OP 2207, "Plant Cooldown"

2. OP 2209B, "RCS Inventory Tracking"

3. AOP 2572, "Loss of Shutdown Cooling"

4. AOP 2568A, "RCS Leak, Mode 4, 5, 6 and Defueled"

5. NEI 99-01 CA 1 Page 81 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability EAL: CS1 .1 Site Area Emergency RVLMS reading 0% (#8) (Note 12) Note 12: This EAL is only applicable if a RVLMS channel #8 string is operable. Mode Applicability: 5 - Cold Shutdown, 6 - Refueling Definition(s): 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. Basis: This IC addresses a significant and prolonged loss of (reactor vessel/RCS [PVVR] or RCS [BVVR]) inventory control and makeup capability leading to IMMINENT fuel damage. 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 RCS level. If RCS/reactor vessel RCS level cannot be restored, fuel damage is probable. Outage/shutdovvn 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 E/\Ls 1.b and 2.b reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment. In E/\L 3.a, 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 allmvs sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring. The inability to monitor (reactor vessel/RCS [PVVR] or RCS [BVVR]) 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 tanl< 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 (reactor vessel/RCS [PWR] or RCS [B'NR]). Page 82 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Millstone 2 includes in its Inadequate Core Cooling instrumentation a reactor vessel level monitoring system (RVLMS) that is displayed to the operators and can measure discrete reactor vessel water levels from the top of the reactor vessel head to the top of the core plate (string #8 - approximately 10 inches above the top of the active fuel). The bottom of this instrument's span in the reactor vessel plenum is the lowest available reactor vessel level indicator and is used in this EAL to represent approximately the top of active fuel (ref. 1). RVLMS is only required to be operable in modes 1, 2 and 3 (ref. 2). For plant conditions in which RVLMS is disconnected or otherwise inoperable, such as in the Refueling mode, classification should be made based on CS1 .2 when RCS water level cannot be monitored. Thisese EALs addresses 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§ CG1 or AG-iRG1. Reference(s):

1. Millstone 2 UFSAR Section 7.5.4.4, "In-Core Instrumentation"

2. Millstone 2 Technical Specifications Section 3.3.3.8, "Instrumentation Accident Monitoring'.'

3. NEI 99-01 CS1 Page 83 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability EAL: CS1.2 Site Area Emergency RCS level cannot be monitored for >30 min. (Note 1) AND Core uncovery is indicated by any of the following:

UNPLANNED rise in any Table C-1 sump or tank level.of sufficient magnitude to indicate core uncovery *
Visual observation of UNISOLABLE RCS leakage of sufficient magnitude to indicate.

core uncovery

Erratic source range monitor indications
Any containment area radiation monitor reading > 4 R/hr (Refueling mode)

Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. TaQle C-1 Sumps/Tanks

Containment Sump
RWST
PDT
Quench Tank
EDST (L9736)

                                    *   'A' CWRT (letdown line CH-345 or SOC line Sl-468) (Panel C-63)

SIT 1, 2 3, 4 Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s): IMMINENT - The trajectory qf events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions. 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. Page 84 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Basis: This IC addresses a significant and prolonged loss of (reactor vessel/RCS RCS_[PVVR] or RP\/ [BVVR]) inventory control and makeup capability leading to IMMINENT fuel damage. 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/shutdovvn 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.b and 2.b reflect the fact that with CONTAINMENT CLOSURE established, there is a lmver probability of a fission product release to the environment. In this EAL~. 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 (reactor vessel/RCS [PWR] or RPV [BVVR]) level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation (ref. 1, 2). 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 (reactor vessel/RCS [PVVR] or RPV [BVVR]) (ref. 2, 3, 1}. If the make-up rate to the RCS unexplainably rises above the pre-established rate, a loss of RCS inventory may be occurring even if the source of the leakage cannot be immediately identified. Visual observation of leakage from systems connected to the RCS that cannot be isolated could also be indicative of a loss of RCS inventory. Post-TMI accident studies indicated that the installed PWR nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations. In the Refueling mode, as water level in the reactor vessel lowers, the dose rate above the core will rise. The dose rate due to this core shine should result in on-scale indications of> 4 R/hr on containment area radiation monitors (ref. 5)., These This EALs addresses 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 CG1 or AG1 Page 85 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Reference(s):

1. OP 2207, "Plant Cooldown"

2. OP 22098, "RCS Inventory Tracking"

3. AOP 2572, "Loss of Shutdown Cooling"

4. AOP 2568A, "RCS Leak, Mode 4, 5, 6 and Defueled"

5. Calculation M2EP-04164R2, "MP2 Rad Monitor Response to Core Uncovery"

6. Millstone Unit 2 Radiation Monitor Manual

7. NEI 99-01 CS1 Page 86 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Erriergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL: CG1 .1 General Emergency RVLMS reading 0% (#8) for ~30 min. (Notes 1, 12) AND Any Containment Challenge indication, Table C-2 Note 1: The DSEO/ADTS should d~clare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required. Note 12: This EAL is only applicable if a RVLMS channel #8 string is operable. Table C-2 Containment Challenge lndfcations

CONTAINMENT CLOSURE not established (Note 6)
CTMT hydrogen concentration > 4 %
UNPLANNED increase in CTMT pressure Mode Applicability: -

5 - Cold Shutdown, 6 - Refueling Definition(s): CONTAINMENT CLOSURE - The actions taken to secure containment (Primary or Secondary) and their associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. Containment Closure is established when all of the following conditions.exist:

The equipment door is closed and held in place by a minimum of four bolts or the outage equipment door is installed.
A minimum of one door in each airlock is closed.
Each penetration providing direct access from the containment atmosphere to the outside atmosphere is closed by an isolation valve, blind flange, manual valve, or special device.

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. Page 87 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 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. Basis: Millstone 2 includes in its Inadequate Core Cooling instrumentation a reactor vessel level monitoring system (RVLMS) that is displayed to the operators and can measure discrete reactor vessel water levels from the top of the reactor vessel head to the top of the core plate (string #8 - approximately 10 inches above the top of the active fuel). The bottom of this instrument's span in the reactor vessel plenum is the lowest available reactor vessel level indicator and is used in this EAL to represent approximately the top of active fuel (ref. 1). RVLMS is only required to be operable in modes 1, 2 and 3 (ref. 2). For plant conditions in which RVLMS is disconnected or otherwise inoperable, such as in the Refueling mode, classification should be made based on CG1 .2 when RCS water level cannot be monitored. This IC addresses the inability to restore and maintain reactor vesselRCS level abo_ve 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 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. Three conditions are associated with a challenge to containment's capability to serve as an effective barrier to fission product release:

1. 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.

2. 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 of 4%). 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. However, containment monitoring and/or sampling should be performed to verify this assumption and a General Emergency declared if it is determined that hydrogen concentration has exceeded the minimum necessary to support a hydrogen burn (4%) (ref. 3, 4). 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. Page 88 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B

3. Any UNPLANNED rise in containment pressure in the Cold Shutdown or Refueling mode indicates a potential challenge of CONTAINMENT CLOSURE capability due to likely reduced pressure capability of the containment (temporary barriers installed for CONTAINMENT CLOSURE). UNPLANNED containment pressure rise indicates CONTAINMENT CLOSURE cannot be assured and the containment cannot be relied upon as a barrier to fission product release.

In EAL 2.b, the 30 minute criterion is tied to c! readily recognizable event start time (i.e., the total loss of ability to monitor level), and allmvs 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 peliormance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring. The inability to monitor (reactor vessel/RCS [P'NR] or RPV [BVVR]) level may be caused by instrumentation and/or pmver 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 (reactor vessel/RCS [PVVR] or RPV [B'NR]). This EAL addresses 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. Reference(s):

1. Millstone 2 UFSAR Section 7.5.4.4, "In-Core Instrumentation"

2. Millstone 2 Technical Specifications Section 3.3.3.8, "Instrumentation Accident Monitoring"

3. EOP 2540, "Functional Recovery"

4. SAMG 4215 Attachment 1, "Calculation Aids, Calculational Aid #7 Containment Challenge Due to Hydrogen Combustion"

5. NEI 99-01 CG1 Page 89 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Leve! Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: C - Cold Shutdown/ Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL: CG1 .2 General Emergency RCS level cannot be monitored for ~30 min. (Note 1) AND Core uncovery is indicated by any of the following:

UNPLANNED rise in any Table C-1 sump or tank level of sufficient magnitude to indicate core uncovery
Visual observation of UNISOLABLE RCS leakage of sufficient magnitude to indicate core uncovery
Erratic source range monito_r indications
Any containment area radiation monitor reading > 4 R/hr (Refueling mode)

AND Any Containment Challenge indication, Table C-2 Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required. Table C-1 Sumps/Tanks

Containment Sump
RWST
PDT
Quench Tank
EDST (L9736)

                                    *   'A' CWRT (letdown line CH-345 or SOC line Sl-468) (Panel C-63)

SIT 1, 2 3, 4 Page 90 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Table C-2 Containment Challenge Indications

CONTAINMENT CLOSURE not established (Note 6)
CTMT hydrogen concentration> 4%
UNPLANNED increase in CTMT pressure Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s): CONTAINMENT CLOSURE - The actions taken to secure containment (Primary or Secondary) and their associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. Containment *closure is established when all of the following conditions exist:

The equipment door is closed and held in place by a minimum of four bolts or the outage equipment door is installed.
A minimum of one door in each airlock is closed.
Each penetration providing direct access from the containment atmosphere to the outside atmosphere is closed by an isolation valve, blind flange, manual valve, or special device.

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. 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. Basis: This IC addresses the inability to restore and maintain reactor vesselRCS 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 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. The inability to monitor (reactor vessel/RCS [PLAIR] or RCS _[BLAIR]) level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation (ref. 1, 2). 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 Page 91 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B they are indicative of leakage from the_ (reactor vessel/RCS [.0111/R] or RP\/ [Bl/1/R]) (ref. 2, 3. 1}. If the make-up rate to the RCS unexplainably rises above the pre-established rate, a loss of RCS inventory may be occurring even if the source of the leakage cannot be immediately identified. Visual observation of leakage from systems connected to the RCS that cannot be isolated could also be indicative of a loss of RCS inventory. Post-TMI accident studies indicated that the installed PWR nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such In the Refueling mode, as water level in the reactor vessel lowers, the dose rate above the core will rise. The dose rate due to this core shine should result in on-scale indications of > 4 R/hr on containment area radiation monitors (ref. 5). In E/\L 2.b, tThe 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. Three conditions are associated with a challenge to containment's capability to serve as an effective barrier to fission product release:

1. 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.

2. 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 of 4%). 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. However, containment monitoring and/or sampling should be performed to verify this assumption and a General Emergency declared if it is determined that hydrogen concentration has exceeded the minimum necessary to support a hydrogen burn (4%) (ref. 7). 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.

3. Any UNPLANNED rise in containment pressure in the Cold Shutdown or Refueling mode indicates a potential challenge of CONTAINMENT CLOSURE capability due to likely reduced pressure capability of the containment (temporary barriers installed for CONTAINMENT CLOSURE). UNPLANNED containment pressure rise indicates Page 92 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 CONTAINMENT CLOSURE cannot be assured and the containment cannot be relied upon as a barrier to fission product release. Thisese EALs addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-14~9, 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. Reference(s):

1. OP 2207, "Plant Cool down"

2. OP 22098, "RCS Inventory Tracking"

3. AOP 2572, "Loss of Shutdown Cooling"

4. AOP 2568A, "RCS Leak, Mode 4, 5, 6 and Defueled"

5. Calculation M2EP-04164R2, "MP2 Rad Monitor Response to Core Uncovery"

6. Millstone Unit 2 Radiation Monitor Manual

7. EOP 2540, "Functional Recovery"

8. NEI 99-01 CG1 Page 93 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 2 - Loss of Emergency AC Power Initiating Condition: Loss of all but one AC power source to em,ergency buses for 15 minutes or longer EAL: CU2.1 Unusual Event AC power capability, Table C-3, to 4.16 kV emergency buses 24C and 240 reduced to a single power source for ~15 min. (Note 1)

  -AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1:   The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Table C-3 AC Power Sources Offsite

Unit 2 Reserve Station Service Transformer (RSST)
Unit 2 Normal Station Service Transformer (NSST) back-fed via the*Main Transformer (if already aligned)
Unit 3 Normal Station Service Transformer (NSST) via Buses 34A/B to Unit 2 emergency bus 24E (if already aligned)
Unit 3 Reserve Station Service Transformer (RSST) via Buses 34A/B to Unit 2 emergency bus 24E (if ~lready aligned)

Onsite

Diesel Generator 15G-12U
Diesel Generator 15G-13U
SBO Diesel Generator (if already aligned)

Mode Applicability: 5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(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 (as defined in 10CFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; Page 94 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. Basis: Table C-3 provides a list of offsite and onsite AC electrical power sources credited for this EAL. The AC power sources annotated "(if already aligned)" require more than 15 minutes to establish and therefore are only credited if the source was already aligned at the time of AC power loss. The SBO Diesel Generator meets the definition for an Alternate AC power source per 10CFR50.2. 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. An "AC power source" is a source recognized in AOPs 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 generatorUnit 3.
A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being fed or 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 CA2. This cold condition EAL is equivalent to the hot condition EAL MA1.1. Under normal conditions, four 345 kV lines will be in service to connect the Millstone Station to the main electric system. The emergency buses powering equipment for safe shutdown are 4.16 kV emergency buses 24C (A3), 240 (A4), and 24E (AS). 4.16 kV emergency bus 24E (AS) may be fed from either 24C or 240. The associated 480 V emergency buses are 22E (fed from 24C) and 22F (fed from 240). MPS2 has the following methods available to provide power to the 4.16 kV emergency buses (ref. 1, 2, 3): Page 95 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B

The Normal Station Service Transformer (NSST). During normal power operation, power is supplied to buses 24A (A 1) and 248 (A2). Bus ties connect to 4.16 kV emergency buses 24C (A3) and 240 (A4 ). Additionally, the NSST may be used during shutdown and when maintenance is being performed on the Reserve Station Service Transformer by removing links for the main generator and providing power through the 15G-8T-2 or 15G-9T-2 breakers.
The Unit 2 Reserve Station Service Transformer (RSST). This is the connection to the utility system for the preferred power supply. During other periods, such as startup and shutdown when the NSST is not used, power is supplied from the Unit 2 RSST directly to 4.16 kV emergency buses 24C (A3) and 240 (A4 ).
Diesel Generator 15G-12U(H7A) supplying 4.16 kV emergency bus 24C(A3).
Diesel Generator 15G-13U(H7B) supplying 4.16 kV emergency bus 24D(A4).
Unit 3 supplying power through bus 34A/34B to emergency bus 24E. This is controlled by procedure. However, there are power limitations when using this method to supply MPS2 buses when Millstone 3 bus 34A/34B is being used.

Reference(s):

1. Technical Specifications Section 3.8.1.2, "Electrical Power Systems Shutdown"

2. UFSAR Section 8.2, "4160-Volt and 6900-Volt Systems"

3. UFSAR Section 8.3, "Emergency Generators"

4. AOP 2580, "Degraded Voltage"

5. AOP 2583, "Loss of All AC Power During Shutdown Conditions"

6. Dwg. No. 25203-30004, "Millstone Nuclear Power Station - Unit No. 2 Single Line Meter &

Relay Diagram 4.16 kV Buses 24A & 248 (A1 &A2)"

7. Dwg. No. 25203-30005, "Millstone Nuclear Power Station - Unit No. 2 Single Line Meter &

Relay Diagram 4.16 kV Emergency Buses 24C, 240 (A3, A4 )"

8. NEI 99-01 CU2 Page 96 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 2 - Loss of Emergency AC Power Initiating Condition: Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer EAL: CA2.1 Alert Loss of all offsite and all onsite AC power to 4.16 kV emergency buses 24C and 240 for

~15 min. (Note 1)

Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. - Mode Applicability: 5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(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 EGGS. These are typically systems classified as safety-related (as defined in 10CFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: * (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. Basis: For this EAL credit can be taken for any AC power source that has sufficient capability to operate equipment necessary to maintain a safe shutdown condition. such as the Unit 3 SBO diesel or FLEX generators. provided it can be aligned within the 15 minute classification criteria. The SBO Diesel Generator meets the definition for an Alternate AC power source per 10CFR50.2. 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 th~ 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. Page 97 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Escalation of the emergency classification level would be via IC§ CS1 or A84RS1. This cold condition EAL is equivalent to the hot condition EAL MS1 .1. Under normal conditions, four 345 kV lines will be in service to connect the Millstone Station to the main electric system. The emergency buses powering equipment for safe shutdown are 4.16 kV emergency buses 24C (A3), 240 (A4), and 24E (A5). 4.16 kV emergency bus 24E (A5) may be fed from either 24C or 240. The associated 480 V emergency buses are 22E (fed from 24C) and 22F (fed from 240). MPS2 has the following methods available to provide power to the 4.16 kV emergency buses (ref. 1, 2, 3):

The Normal Station Service Transformer (NSST). During normal power operation, power is supplied to buses 24A (A 1) and 248 (A2). Bus ties connect to 4.16 kV emergency buses 24C (A3) and 240 (A4 ). Additionally, the NSST may be used during shutdown and when maintenance is being performed on the Reserve Station Service Transformer by removing links for the main generator and providing power through the 15G-8T-2 or 15G-9T-2 breakers.
The Unit 2 Reserve Station Service Transformer (RSST). This is the connection to the utility system for the preferred power supply. During other periods, such as startup and shutdown when the NSST is not used, power is supplied from the Unit 2 RSST directly to 4.16 kV emergency buses 24C (A3) and 240 (A4).
Diesel Generator 15G-12U(H7A) supplying 4.16 kV emergency bus 24C(A3).
Diesel Generator 15G-13U(H7B) supplying 4.16 kV emergency bus 24D(A4).
Unit 3 supplying power through bus 34A/34B to emergency bus 24E. This is controlled by procedure. However, there are power limitations when using this method to supply MPS2 buses when Millstone 3 bus 34A/34B is being used.

Reference(s):

1. Technical Specifications Section 3.8.1.2, "Electrical Power Systems Shutdown"

2. UFSAR Section 8.2, "4160-Volt and 6900-Volt Systems"

3. UFSAR Section 8.3, "Emergency Generators"

4. AOP 2580, "Degraded Voltage"

5. AOP 2583, "Loss of All AC Power During Shutdown Conditions"

6. Dwg. No. 25203-30004, "Millstone Nuclear Power Station - Unit No. 2 Single Line Meter &

Relay Diagram 4.16 kV Buses 24A & 248 (A 1 &A2)"

7. Dwg. No. 25203-30005, "Millstone Nuclear Power Station - Unit No. 2 Single Line Meter &

Relay Diagram 4.16 kV Emergency Buses 24C, 240 (A3, A4 )"

8. NEI 99-01 CU2 Page 98 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: UNPLANNED increase in RCS temperature EAL: CU3.1 Unusual Event UNPLANNED rise in RCS temperature to > 200°F Mode Applicability: 5 - Cold Shutdown, 6 - Refueling Definition(s): CONTAINMENT CLOSURE - The actions taken to secure containment (Primary or Secondary) and their associated structures, systems, and components, as a functional barrier to fission product release under shutdown conditions. , Containment Closure is established when all of the following conditions exist:

The equipment door is closed and held in place by a minimum of four bolts or the outage equipment door is installed.
A minimum of one door in each airlock is closed.
Each penetration providing direct access from the containment atmosphere to the outside atmosphere is closed by an isolation valve, blind flange, manual valve, or special device.

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. Basis: In the absence of reliable RCS temperature indication caused by the loss of decay heat removal capability, classification should be based on time to boil data when in Mode 6 or the RCS is not intact in Mode 5 (ref. 1). If the RCS is intact, classification should be based on the RCS pressure rise criteria of CA3.1. RCS time to 200°F is provided on the Shutdown Safety Assessment Sheet (ref. 2). This .JG-EAL addresses an UNPLANNED increase in RCS_temperature above the Technical Specification cold shutdown temperature limit or the inability to determine RCS temperature and level,and represents a potential degradation of the level of safety ofthe plant (ref. 1). If the RCS_is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency DirectorDSEO/ADTS should. also refer to .JG-EAL CA3~. 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 This EAL This EAL 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 Page 99 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 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 at or 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 increase in reactor coolant temperature depending on the time after shutdown (ref. 3). E/\L #2 reflects a condition *.vhere there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitoLkey 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 CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria. Reference(s):

1. Technical Specifications Table 1.1-1

2. AOP 2572, "Loss of Shutdown Cooling"

3. OP 2301 E, "Draining the RCS (ICCE)"

4. NEI 99-01 CU3 Page 100 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: UNPLANNED rise in RCS temperature EAL: CU3.2 Unusual Event Loss of all RCS temperature and RCS water level indication for ~15 min. (Note 1) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Mode Applicability: 5 - Cold Shutdown, 6- Refueling Definition{s): CONTAINMENT CLOSURE - The actions taken to secure containment (Primary or Secondary) and their associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. Containment Closure is established when all of the following conditions exist:

The equipment door is closed and held in place by a minimum of four bolts or the outage equipment door is installed.
A minimum of one door in each airlock is closed.
Each penetration providing direct access from the containment atmosphere to the outside atmosphere is closed by an isolation valve, blind flange, manual valve, or special device.

Basis: This IC EALEAL addresses an UNPLANNED increase in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level, aR1-and 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 DirectorDSEO/ADTS should also refer to .J.G-EAL CA3j_. A momentary UNPLANNED excursion above the Technical Specification cold shutdovvn temperature limit v,hen the heat removal function is available does not warrant a classification. E/\L #1 involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that v:hich can currently be removed, such that reactor coolant temperature cannot be maintained belm.v 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 lm.ver water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at reduced Page 101 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B inventory may result in a rapid increase in reactor coolant temperature depending on the time after shutdown. El\L #2This El\L This EAL 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. RCS temperature indications include (ref. 1):

RCS loop RTDs
Core inlet and outlet SOC to RCS T351Y & T351X (require SOC flow)
CETs (when operable)
UJTEM8-A/B
UJTEM?-A/8 RCS level indications include (ref. 1):
L-112 RCS mid-loop wide range RCS level transmitter
L-122 No. 2 hot leg narrow range level transmitter
Ll-112 No. 1 hot leg RCS mid-loop level indicator (CCTV)
ICC Reactor Vessel Level Monitoring System (RVLMS)

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication. Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria. Reference(s):

1. AOP 2572, "Loss of Shutdown Cooling"

2. NEI 99-01 CU3 Page 102 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: Inability to maintain plant in cold shutdown EAL: CA3.1 Alert UNPLANNED rise in RCS temperature to > 200°F for> Table C-4 duration (Notes 1, 13). OR UNPLANNED RCS pressure rise > 10 psig Note 1: The DSEO/ADTS should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded. Note 13: If an RCS heat removal system is in operation within the applicable Table C-4 heat-up duration and RCS temperature is being reduced, the EAL is not applicable. Table C-4 RCS Heat-up Duration Thresholds CONTAINMENT RCS Status Heat-up Duration CLOSURE Status Intact AND not 60 min. reduced inventory Not intact OR Established 20 min. reduced inventory Not established 0 min. Mode Applicability: 5 - Cold Shutdown, 6 - Refueling Definition(s): CONTAINMENT CLOSURE - The actions taken to secure containment (Primary or Secondary) and their associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

Containment Closure is established when all of the following conditions exist:
The equipment door is closed and held in place by a minimum of four bolts or the outage equipment door is installed.
A minimum of one door in each airlock is closed.
Each penetration providing direct access from the containment atmosphere to the outside atmosphere is closed by an isolation valve, blind flange, manual valve, or special device.

Page 103 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B 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. Basis: In the absence of reliable RCS temperature indication caused by the loss of decay heat removal capability, classification should be based on the RCS pressure rise criteria when the RCS is intact in Mode 5 or based on time to boil data when in Mode 6 or the RCS is not intact in Mode 5 (ref. 2, 3). RCS time to 200°F is provided on the Shutdown Safety Assessment Sheet (ref. 2). The RCS is considered to be at reduced inventory when RCS level is less than 43 in. above RCS hot leg centerline (greater than 3 ft. below the reactor vessel flange) (ref. 3). This .J.G-EAL 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 an increase in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact, or RCS inventory is reduced (e.g., mid-loop operation in PWRs). The 20-minute criterion was included to allow time for operator action to address the temperature increase. The RCS Heat-up Duration Thresholds table also addresses an increase 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 increase without a substantial degradation in plant safety. Finally, in the case where there is an increase in RCS temperature, the RCS is not intact or is at reduced inventory [PV1/R], 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.

The RCS pressure rise threshold E/\L #2 provides a pressure-based indication of RCS_heat-up in the absence of RCS temperature monitoring capability. RCS pressure indicators Pl-103 and Pl-103-1 are capable of reading a 10 psi RCS pressure rise. Escalation of the emergency classification level would be via IC CS 1 or AS4RS 1. Reference{s): 1 Technical Specifications Table 1.1-1

2. AOP 2572, "Loss of Shutdown Cooling"

3. OP 2301 E, "Draining the RCS (ICCE)"

4. NEI 99-01 CA3 Page 104 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 r Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 4 - Loss of Vital DC Power Initiating Condition: Loss of vital DC power for 15 minutes or longer EAL: CU4.1 Unusual Event Indicated voltage is < 105 voe on required vital 125 voe buses 201 A OR 201 B for ~15 min. (Note 1) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Mode Applicability: 5 - Cold Shutdown, 6 - Refueling Definition(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 (as defined in 10CFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. Basis ( The vital (Class 1E) 125 V DC power system consists of two physically and electrically separated redundant buses - Bus 201A and Bus 2018. Each bus has a 60 cell battery bank with an eight-hour rating of 2300 amp-hours. with an operating range of 105 Volts to 140 Volts. In the event that either battery system is out of service, it is possible through interlocked circuit breakers to feed both battery buses from one battery. Each of the vital batteries supplies control logic, field flashing and breaker control for one diesel generator. They also supply power to a backup DC motor driven starting air compressor for each diesel generator, emergency lighting, turbine driven auxiliary feedwater pump (Terry Turbine) controls (bus 201 B). and 125 VDC/120 VAC inverters for vital instrumentation. The four vital 120 VAC instrumentation panels power reactor protection, engineered safety features and vital instrumentation which is normally supplied by four physically isolated and electrically independent inverters, two of which are supplied by each of the two redundant batteries 201A and 201 B (ref. 1). Each of the four vital instrumentation panels has an alternate power supply via a "zero break" static transfer switch. Vital 120 VAC instrumentation channels 1 and 2 can be fed from separate DC/AC inverters whose power source is the turbine battery (i.e. 201 D). Vital 120 VAC instrumentation channels 3 and 4 can be fed from one of the two regulated AC instrument power panels. Page 105 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 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-servjce (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 CA 1 or CA3, or an IC in Recognition Category AR. This cold condition EAL is equivalent to the hot condition EAL MS2.1. Reference(s):

1. UFSAR Section 8.5, "Battery System"

2. NEI 99-01 CU4

            \                    \,

Page 106 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 5 - Loss of Communications Initiating Condition: Loss of all onsite or offsite communications capabilities EAL: CU5.1 Unusual Event Loss of all Table C-5 onsite communication methods OR Loss of all Table C-5 State and local agency communication methods OR Loss of all Table C-5 NRC communication methods Table C-5 Communication Methods State/ System Onsite NRC Local ENRS/ARCOS X Station Radio System X X Plant Phone System X X Public Address System X Gaitronics / Maintenance Jacks X Federal Telephone System (ENS) X Commercial Telephone System X X Satellite Phones X X Dedicated Hotlines X Mode Applicability: 5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s): None Page 107 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Basis: This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to OROs State and local agencies 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.). The first EAL condition EAL #1 addresses a total loss of the communications methods used in support of routine plant operations. The second EAL condition EAL #2 addresses a total loss of the communications methods used to notify all OROs State and local agencies of an emergency declaration. The OROs State and local agencies referred to here are (see Developer Notes)the State of Connecticut and affected local communities. The third EAL condition EAL #3 addresses a total loss of the communications methods used to notify the NRC of an emergency declaration. This cold condition EAL is equivalent to the hot condition EAL MU? .1. Reference(s):

1. MPS Emergency Plan Sectio~ 7.9, "Communication Systems"

2. MP-26-EPI-FAPO?, "Notifications and Communications"

3. NEI 99-01 CUS Page 108 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 6 - Hazardous Event Affecting Safety Systems Initiating Condition: Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode EAL: CA6.1 Alert The occurrence of any Table C-6 hazardous event AND Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode AND EITHER:

Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode
Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 9, 10)

Note 9: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted. Note 1O: 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. Table C-6 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 DSEO/ADTS Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Page 109 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Definition(s): 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 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 fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed. FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area. 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 (as defined in 10CFRS0.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. 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. Basis: This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS needed 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 indications of degraded performance; 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 addresses damage to a SAFETY SYSTEM train that is in service/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. Page 110 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B VISIBLE DAMAGE addresses damage to a SAFETY SYSTEM train that is not in service/operation and that potentially could cause performance issues. Operators will make this determination 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. This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, needed for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. EAL 1.b.1 addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it 'Nill 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. EAL 1.b.2 addresses damage to a SAFETY SYSTEM component that is not in service/operation or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM_components. Operators will make this determination 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. An event affecting equipment common to two or more trains of a safety system (i.e., there are indications of degraded performance and/or VISIBLE DAMAGE affecting the common equipment) should be classified as an Alert under this EAL, as appropriate to the plant mode. By affecting the functionality of multiple trains of a safety system, the loss of the common equipment effectively meets the two-train impact criteria that underlie the EALs and bases. An event affecting a single-train safety system (i.e., there are indications of degraded performance and/or VISIBLE DAMAGE affecting the one train) would not be classified under this EAL because the two-train impact criteria that underlie the EALs and bases would not be met. If an event affects a single-train safety system, then the emergency classification should be made based on plant parameters/symptoms meeting the EALs for another IC. Depending upon the circumstances, classification may also occur based on Shift Manager/DSEO/ADTS judgement. An event that affects two trains of a safety system (e.g., one train has indications of degraded performance and the other VISIBLE DAMAGE) that also has one or more additional trains should be classified as an Alert under this EAL as appropriate to the plant mode. This approach maintains consistency with the two-train impact criteria that underlie the EALs and bases, and is warranted because the event was severe enough to affect the functionality of two trains of a safety system despite plant design criteria associated with system and system train separation and protection. Such an event may have caused other plant impacts that are not immediately apparent. Escalation of the emergency classification level would be via IC CS1 or AS-1-RS1. This cold condition EAL is equivalent to the hot condition EAL MA8.1. Reference(s): Page 111 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B

1. AOP 2560, "Storms, High Winds and High Tides"

2. AOP 2562, "Earthquake"

3. EP FAQ 2016-002

4. NEI 99-01 GA6 Page 112 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category E - Independent Spent Fuel Storage Installation (ISFSI) EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.) An independent spent fuel storage installation (ISFSI) is a complex_that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. A significant amount of the radioactive material contained within a canister must escape its packaging and enter the biosphere for there to be a significant environmental effect resulting from an accident inv,olving the dry storage of spent nuclear fuel. A Notification of Unusual Event is declared on the basis of the occurrence of an event of sufficient magnitude that a loaded cask CONFINEMENT BOUNDARY is damaged or violated. The MPS ISFSI is located wholly within the MPS plant PROTECTED AREA. Therefore any security event related to the ISFSI is classified under Category H1 security event related EALs. Page 113 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: ISFSI Subcategory: Confinement Boundary Initiating Condition: Damage to a loaded cask CONFINEMENT BOUNDARY EAL: EU1.1 Unusual Event Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading on the surface of a loaded spent fuel cask (HSM) > any of the following:

1,700 mrem/hr on the HSM front bird screen
400 mrem/hr on the outside HSM door
12 mrem/hr on the HSM end shield wall Mode Applicability:

All Definition(s): CONFINEMENT BOUNDARY- The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. Confinement Boundary is defined as the NUHOMS Dry Shielded Canister (DSC). 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. Basis: 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 issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage. The existence of "damage" is determined by radiological survey. The specified EAL threshold values correspond to 2 times the NUHOMS Horizontal Storage Module (HSM) technical specification external surface dose rate limits (ref. 2). The technical specification multiple of "2 times", which is also used in Recognition CategoryA-.B_IC Ald4RU1, 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 (ref. 1, 2.3). Security-related events for ISFSls are covered under Category H ICs HU1 and HA1. Page 114 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Reference(s):

1. NUH-003, "UFSAR for the Horizontal Modular Storage System for Irradiated Fuel"

2. MPS2 ETE-NAF-2010-0004; "MPS Unit 2 ISFSI 10 CFR72.212 Evaluation Report -

Attachment 1 Section 5.4 HSM or HSM-H Dose Rate Evaluation Program"

3. RPM 2.5.9, "Dry Shielded Canisters (DSC) Surveys (ISFSI)"

4. NEI 99-01 E-HU1 Page 115 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category F - Fission Product Barrier Degradation EAL Group: Hot Conditions (RCS temperature > 200°F); EALs in this category are applicable only in one or more hot operating modes. EALs in this category represent threats to the defense in depth design concept that precludes the release of highly 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 fission product barriers are: A. Fuel Clad Barrier (FC): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets. B. Reactor Coolant System Barrier (RCS): The RCS Barrier includes the _RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves. C. Containment Barrier (CTMT): The Containment Barrier includes the containment building and connections up to' and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the containment building up to and including the outermost secondary side isolation valve. Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency. The EALs in this category require evaluation of the loss and potential loss thresholds listed in the fission product barrier matrix of Table F-1. "Loss" and "Potential Loss" signify the relative damage and threat of damage to the barrier. "Loss" means the barrier no longer assures containment of radioactive materials. "Potential Loss" means integrity of the barrier is threatened and could be lost if conditions continue to degrade. The number of barriers that are lost or potentially lost and the following criteria determine the appropriate emergency classification level: ' Alert: Any loss or any potential Joss of either Fuel Clad or RCS Barrier Site Area Emergency: Loss or potential Joss of any two barriers General Emergency: Loss of any two barriers and loss or potential Joss of third barrier The logic used for emergency classification based on fission product barrier monitoring should reflect the fo!lowing considerations:

The Fuel Clad Barrier and the RCS Barrier are weighted more heavily than the Containment Barrier.
Unusual Event ICs associated with RCS and Fuel Clad Barriers are addressed under System Malfunction ICs.

Page 116 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28

For accident conditions involving a radiological release, evaluation of the fission product barrier thresholds will need to be performed in conjunction with dose assessments to ensure correct and timely escalation of the emergency classification. For .example, an evaluation of the fission product barrier thresholds may result in a Site Area Emergency classification while a dose assessment may indicate that an EAL for General Emergency IC AG4-RG1 has been exceeded.
The fission product barrier thresholds specified within a scheme reflect plant-specific MPS2 design and operating characteristics.
As used in this category, the term RCS leakage encompasses not just those types defined in Technical Specifications but also includes the loss of RCS mass to any location- inside the containment, an interfacing system, or outside of the containment.

The release of liquid or steam mass from the RCS due to the as-designed/expected operation of a relief valve is not considered to be RCS leakage.

At the Site Area Emergency level, EAL users should maintain cognizance of how far present conditions are from meeting a threshold that would require a General Emergency declaration. For example, if the Fuel Clad and RCS fission product barriers were both lost, then there should be frequent assessments of containment radioactive inventory and integrity. Alternatively, if both the Fuel Clad and RCS fission product barriers were potentially lost, the Emergency DirectorDSEO/ADTS would have more
assurance that there was no immediate need to escalate to a General Emergency.

Page 117 of 259

Millstone Power Station. Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Te~hnical Bases Enclosure 3; Attachment 2B Category: Fission Product Barrier Degradation Subcategory: NIA Initiating Condition: Any loss or any potential loss of either Fuel Clad or RCS EAL: FA1.1 Alert Any loss or any potential loss of EITHER Fuel Clad or RCS barrier (Table F-1) Mode Applicability: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition{s): None Basis: Fuel Clad, RCS and Containment comprise the fission product barriers. Table F-1 lists the fission product barrier thresholds, bases and references. At the Alert classification level, Fuel Clad and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Clad 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 Clad or RCS barrier results in declaration of a Site Area Emergency under EAL FS1 .1 Reference{s):

1. NEI 99-01 FA1 Page 118 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Loss.or potential loss of any two barriers EAL: FS1.1 Site Area Emergency Loss or potential loss of any two barriers (Table F-1) Mode Applicability: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s): IMMINENT - The trajectory of events or conditions js such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions. Basis: Fuel Clad, RCS and Containment comprise the fission product barriers. Table F-1 lists the fission product barrier thresholds, bases and references. At the Site Area Emergency classification level, each barrier is weighted equally. A Site Area Emergency is therefore appropriate for any combination of the following conditions:

One barrier loss and a second barrier loss (i.e., loss - loss)
One barrier loss and a second barrier potential loss (i.e., loss - potential loss)
One barrier potential loss and a second barrier potential loss (i.e., potential loss -

potential loss)

At the Site Area Emergency classification level, the ability to dynamically assess the proximity of present conditions with respect to the threshold for a General Emergency is important. For example, the existence of Fuel Clad and RCS Barrier loss thresholds in addition to offsite dose assessments would require continual assessments of radioactive inventory and Containment integrity in anticipation of reaching a General Emergency classification. Alternatively, if both Fuel Clad and RCS potential loss thresholds existed, they would have greater assurance that escalation to a General Emergency is less IMMINENT.

Reference(s):

1. NEI 99-01 FS1 Page 119 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Loss of any two barriers and loss or potential loss of the third barrier EAL: FG1.1 General Emergency Loss of any two barriers AND Loss or potential loss of the third barrier (Table F-1) Mode Applicability: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s): None Basis: Fuel Clad, RCS and Containment comprise the fission product barriers. Table F-1 lists the fission product barrier thresholds, bases and references. At the General Emergency classification level each barrier is weighted equally. A General Emergency is therefore appropriate for any combination of the following conditions:

Loss of Fuel Clad, RCS and Containment Barriers
Loss of Fuel Clad and RCS Barriers with potential loss of Containment Barrier
Loss of RCS and Containment Barriers with potential loss of Fuel Clad Barrier
Loss of Fuel Clad and Containment Barriers with potential loss of RCS Barrier Reference(s):

1. NEI 99-01 FG1 Page 120 of 259

Millstone Power Station Unit 2 , Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Table F-1 Fission Product Barrier Threshold Matrix & Bases Table F-1 lists the threshold conditions that define the Loss and Potential Loss of the three fission product barriers (Fuel Clad, Reactor Coolant System, and Co_ntainment). The table is structured so that each of the three barriers occupies adjacent columns. Each fission product barrier column is further divided into two columns; one for Loss thresholds and one for Potential Loss thresholds. The first column of the table (to the left of the Fuel Clad Loss column) lists the categories (types) of fission product barrier thresholds. The fission product barrier categories are: A. RCS or SG Tube Leakage B. Inadequate Heat removal C. CTMT Radiation / RCS Activity D. CTMT Integrity or Bypass E. DSEO/ADTS Judgment Each category occupies a row in Table F-1 thus forming a matrix defined by the categories. The intersection of each row with each Loss/Potential Loss column forms a cell in which one or more fission product barrier thresholds appear. If NEI 99-01 does not define a threshold for a barrier Loss/Potential Loss, the word "None" is entered in the cell. Thresholds are assigned sequential numbers within each barrier column beginning with number one. If a cell in Table F-1 contains more than one numbered threshold, each ofthe numbered thresholds, if exceeded, signifies a Loss or Potential Loss of the barrier. It is not necessary to exceed all of the thresholds in a category before declaring a barrier Loss/Potential Loss. Subdivision of Table F-1 by category facilitates association of plant conditions to the applicable fission product barrier Loss and Potential Loss thresholds. This structure promotes a systematic approach to assessing the classification status of the fission product barriers. When equipped with knowledge of plant conditions related to the fission product barriers, the EAL-user first scans down the category column of Table F-1, locates the likely category and then reads across the fission product barrier Loss and Potential Loss thresholds in that category to determine if a threshold has been exceeded. If a threshold has not been exceeded, the EAL-user proceeds to the next likely category and continues review of the thresholds in the_ new category If the EAL-user determines that any threshold has been exceeded, by definition, the barrier is lost or potentially lost - even if multiple thresholds in the same barrier column are exceeded, only that one barrier is lost or potentially lost. The EAL-user must examine each of the three fission product barriers to determine if other barrier thresholds in the category are lost or potentially lost. For example, if containment radiation is sufficiently high, a Loss of the Fuel Clad and RCS Barriers and a Potential Loss of the Containment Barrier can occur. Barrier Losses and Potential Losses are then applied to the algorithms given in EALs FG1 .1, FS1 .1, and FA 1.1 to determine the appropriate emergency classification. Page 121 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Table F-1 Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FC) Reactor Coolant System Barrier (RCS) Containment Barrier (CTMT) Category Loss Potential Loss Loss Potential Loss Loss Potential Loss

1. RVLMS reading 0% (#8) 1. An automatic or manual SIAS 1. UNISOLABLE RCS or SG tube 1. A leaking or RUPTURED SG is (Note 12) actuation required by EITHER: leakage > 50 gpm excluding FAULTED outside of CTMT normal reductions In RCS

UNISOLABLE RCS leakage A inventory (e.g. letdown, RCP seal leakage)

RCS orSG None

SG tube RUPTURE None Tube 2. Uncontrolled RCS cooldown Leakage > 1OO'F/hr and RCS pressure and temperature are to the left of the 200°F Subcooling (PTS)

Curve (EOP Figure 1)

1. CETs > 1200°F 2. CETs > 700°F 3. Applicable RCS and Core Heat 1. CETs > 1200°F Removal (HR) Safety Function B 3. Applicable RCS and Core Heat Status Check acceptance criteria AND Removal (HR) Safety Function None not met 'None Inadequate Status Check acceptance criteria Restoration procedures not Heat Removal not met effective within 15 min.

(Note 1)

2. CTMT high range radiation 2. CTMT high range radiation 2. CTMT high range radiation monitor RE-8240/8241 monitor RE-8240/8241 reading monitor RE-8240/8241 reading reading> Table F-2 column > Table F-2 column RCS Loss > Table F-2 column CTMT

                . Fuel Clad Loss                                                                                                                                                                                Potential Loss

3. Coolant activity> 300 µCi/gm -

C dose equivalent 1-131 CTMT 4. Dose rate at 1 ft. from an None None None Radiation/ unpressurized RCS sample RCS ;aTable F-3 Activity

5. Sample line dose rate ;,,Table F-4

6. Core damage estimate

                  > 5% clad damage

2. CTMT isolation is required 3. CTMT pressure > 54 psig AND EITHER:

                                                                                                                                                                           . CTMT integrity has been lost

4. CTMT hydrogen concentration

>4%

D based on DSEO/ADTS judgment 5. CTMT pressure > 10 psig with CTMT Integrity or Bypass None None None None

                                                                                                                                                                           . UNISOLABLE pathway from CTMT atmosphere to the
                                                                                                                                                                                                                < one full train of containment heat removal systems (Note 11) operating per design for 2'15 min.

environment exists (Note 1)

3. Indications of RCS leakage outside of CTMT

4. Any condition in the opinion of E 7. Any condition in the opinion of the DSEO/ADTS that indicates

3. Any condition in the opinion of the 4. Any condition in the opinion of the 4. Any condition in the opinion of the 6. Any condition in the opinion of the the DSEO/ADTS that indicates DSEO/ADTS that indicates loss of DSEO/ADTS that indicates potential DSEO/ADTS that indicates loss of DSEO/ADTS that indicates potential DSEO/ADTS potential loss of the fuel clad loss of the fuel clad barrier the RCS barrier loss of the RCS barrier the CTMT barrier loss of the CTMT barrier Judgment barrier Page 122 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Fuel Clad Category: A. RCS or SG Tube Leakage Degradation Threat: Loss Threshold: I None Page 123 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 , Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Fuel Clad Category: A. RCS or SG Tube Leakage Degradation Threat: Potential Loss Threshold: j 1 . RVLMS reading 0% (#8) (Note 12) Note 12: This EAL is only applicable if a RVLMS channel #8 string is operable. Definition(s): None Basis: This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of / heat-induced cladding damage. Millstone 2 includes in its Inadequate Core Cooling instrumentation a reactor vessel level monitoring system (RVLMS) that is displayed to the operators and can measure discrete reactor vessel water levels from the top of the reactor vessel head fo the top of the core plate (string #8 - approximately 10 inches above the top of the active fuel). The bottom of this instrument's span in the reactor vessel plenum is the lowest available reactor vessel level indicator and is used in this EAL to represent approximately the top of active fuel (ref. 1). Reference(s):

1. Millstone 2 UFSAR Section 7.5.4.4, "In-Core Instrumentation"

2. NEI 99-01 RCS or SG Tube Leakage Potential Loss 1.A Page 124 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Fuel Clad Category: B. Inadequate Heat Removal Degradation Threat: Loss Threshold:

11. CETs > 1200°F Definition(s):

None Basis: This reading indicates temperatures within the core are sufficient to cause significant superheating of reactor coolant. The SAMGs use a CET temperature of 1200 °F as an entry condition and the temperature indicative of a badly damaged core (ref. 1, 2). Reference(s):

1. SAMG 4211, "Phase 1 Initial Diagnosis" 2 MP-26-EPI-FAP11-001, "Core Damage Assessment: Core Exit Temperatures"

3. NEI 99-01 Inadequate Heat Removal Loss 2.A Page 125 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Barrier: Fuel Clad Category: B. Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

12. CETs > 700"F Definition(s):

None Basis: This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage. The potential loss threshold is based on not meeting the acceptance criteria for Core Exit Thermocouple readings less than 700 °F for ECCS Heat Removal. 700 °F is the threshold for the threshold indicating a loss of subcooling and further temperature increase will potentially damage fuel cladding (ref. 1, 2, 3). Reference(s):

1. EOP 2540, "Functional Recovery"

2. EOP 2540D, "Functional Recovery of Heat Removal"

3. MP-26-EPI-FAP11-001, "Core Damage Assessment: Core Exit Temperatures"

4. NEI 99-01 Inadequate Heat Removal Loss 2.A Page 126 of 259

Millstone Power Station Unit 2

Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Fuel Clad Category: 8. Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

3. Applicable RCS and Core Heat Removal (HR) Safety Function Status Check acceptance criteria not met Definition(s):

None Basis: There are three defined and potentially applicable RCS and Core Heat Removal (HR) Safety Function Status Check acceptance criteria conditions (ref. 1, 2):

HR-1 -.SG Heat Sink With No SI Operating
HR SG Heat Sink With SI Operating
HR Once-Through-Cooling Failure to meet the applicable HR acceptance criteria This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat.sink). This condition represents a potential loss of the Fuel Clad Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using threshold 'is not warranted.
Meeting this threshold results in a Site Area Emergency because this threshold is identical to I RCS Barrier Potential Loss threshold 2-AB.3; both will be met This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and increase RCS pressure to the point where mass will be lost from the system. *
Reference(s):

1. EOP 2540, "Functional Recovery"

2. EOP 25400, "Functional Recovery of Heat Removal"

.)

3. NEI 99-01 Inadequate Heat Removal Fuel Clad Potential Loss 2.B Page 127 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Barrier: Fuel Clad Category: C. CTMT Radiation / RCS Activity Degradation Threat:, Loss Threshold:

2. CTMT high range radiation monitor RE-8240/8241 reading > Table F-2 column Fuel Clad Loss Table F-2 CTMT High Range Radiation Monitor Barrier Thresholds RE-8240/8241 Time > Shutdown Fuel Clad Loss RCS Loss CTMT Potential Loss (hrs) (R/hr) (R/hr) (R/hr)

               ~2                    65                     5                   260
            >2-    ~                 45                     5                   180
            >4- ~8                   25                     5                   100
           > 8- ~14                  10                     5                   40
              >14                     6                     5                   24 Definition(s):

None Basis: Containment radiation monitor readings greater than the Table F-2 Fuel Clad Loss column threshold indicate the release of reactor coolant, with elevated activity indicative of fuel damage, into the containment. The reading is derived assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with a concentration of 5% clad failure into the containment atmosphere (readings have been rounded for readability). Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations (including iodine spiking) allowed within Technical Specifications and are therefore indicative of fuel damage (approximately 5 % clad failure depending on core inventory and RCS volume)The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals 300 µCi/gm dose equivalent I 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 lo~s of the Fuel Clad Barrier(ref. 1, 2). Time after shutdown values are provided to account for radioactive decay. The values specified in Table F-2 were developed using a method to minimize error(+/-) for the threshold value within each defined time period. Time periods were chosen to fit monitor Page 128 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 response (fast changes in response early following reactor shutdown are broken up into smaller time periods to better approximate expected change). Values were chosen within each time period to minimize error (<50%) to the highest and lowest response within the range. The radiation monitor reading in this threshold is higher than that specified for RCS Barrier Loss threshold C.4-2._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 ECL to a Site Area Emergency. There is no Potential Loss threshold associated with RCS Activity / Containment Radiation. Reference(s):

1. Damage Computer Program

2. Calculation RA-0074," Millstone Unit 2 Expected Containment High Range Radiation Monitor Respons~ to a LOCA Based on Fuel Gap Fractions Defined in NUREG 1228"

3. NEI 99-01 CTMT Radiation / RCS Activity FC Loss 3.A Page 129 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Fuel Clad Category: C. CTMT Radiation / RCS Activity Degradation Threat: Loss Threshold:

3. Coolant activity> 300 µCi/gm dose equivalent 1-131 Definition(s):

None 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/ Containment Radiation. Reference(s):

1. NEI 99-01 CTMT Radiation / RCS Activity FC Loss 3.8 Page 130 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Fuel Clad Category: C. CTMT Radiation / RCS Activity Degradation Threat: Loss Threshold:

4. Dose rate at 1 ft. from an unpressurized RCS sample > Table F-3 Table F-3 FC Loss Coolant Activity Dose Rates Time > Shutdown (hrs) mR/hr/ml

2 15

                            >2- ~8                             8
                               >8                              3 Definition(s):

None 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. This EAL provides the ability to take a dose rate off of an RCS sample to determine fuel clad barrier loss, without the need to analyze the sample before making this determination. This EAL saves significant time by allowing evaluation of contained radioactivity within the RCS by a direct dose rate measurement. Per Engineering Calculation RA-0059, dose rate is assumed to result from radioactive iodines (1-131 thru 1-135) in RCS in concentrations corresponding to the loss of 5% of gap radioactivity of the core. For 5% loss of gap radioactivity (-300 µCi/gm dose equivalent 1-131 ), 2% of the core inventory of radioactive iodines are assumed to be contained in the gap. The values contained in Table F-3 (FC Loss Coolant Activity Dose Rates) represent expected one foot dose rates per ml of sample based on time since reactor shutdown to the time when the sample is taken. Time after shutdown values are provided to account for radioactive decay. The expected dose rate is a near linear relationship with the volume of the sample, so any volume collected can be determined by dividing the measured dose rate by the sample volume and comparing to the threshold value from Table F-3 for the applicable time frame. These dose rates assume no ECCS injection so there is no dilution credited which would vary coolant volume. Values in the table have been rounded for ease of use. The > 8 hour threshold is Page 131 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 conservative up to 24 hours following reactor shutdown. After 24 hours, the expected response from radioactive iodine levels off. Therefore, the value shown for > 8 hours applies for all samples taken 8 hours or more since reactor shutdown (ref. 1, 2). The values specified in Table F-3 were developed using a method to minimize error(+/-) for the threshold value within each defined time period. Values were chosen to minimize error from the highest to lowest dose rate within each range. There is no Potential Loss threshold associated with RCS Activity / Containment Radiation. Reference(s):

1. MP-26-EPI-FAP11, "Core Damage Assessment"

2. RA-0059, "Detector Response to an RCS Sample for EAL Classification of Fuel Clad Degradation and Barrier Loss"

3. NEI 99-01 CTMT Radiation / RCS Activity FC Loss 3.8 Page 132 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Fuel Clad Category: C. CTMT Radiation / RCS Activity

Degradation Threat: Loss Threshold: j s. Sample line dose rate ~Table F-4 Table F-4 FC Loss RCS Sample Line Dose Rates Time > Shutdown (hrs) R/hr

2 4

                             > 2-     ::;;s                      2
                                >8                               1 Definition(s):

None Basis: This threshold indicates that RCS radioactivity concentration is greater th 9n 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. Per Engineering Calculation RA-0079, dose rate is assumed to result from radioactive iodines in the RCS in concentrations corresponding to the loss of 5% of gap radioactivity of the core. The va*lues contained in Table F-4 (FC Loss RCS Sample Line Dose Rates) represent fuel clad failure thresholds when measured approximately 2" from the outside of the RCS hot leg sample line. RCS sample line locations have been predetermined for use with this EAL. Other RCS lines could be used if analyzed on a case-by-case basis. Values in the table have been rounded for ease of use. The sample line dose rates have been calculated for various time ranges after shutdown to account for radioactive decay (ref. 1). The values specified in Table F-4 were developed using a method to minimize error(+/-) for the threshold value within each defined time period. Values were chosen to minimize error from the highest to lowest dose rate within each range. 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. Tt,ere is no Potential Loss threshold associated with RCS Activity / Containment Radiation. Reference(s):

1. Engineering Calculation RA-0079 Page 133 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B

2. NEI 99-01 CTMT Radiation / RCS Activity FC Loss 3.8.

Page 134 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Barrier: Fuel Clad Category: C. CTMT Radiation / RCS Activity Degradation Threat: Loss Threshold:

6. Core damage estimate > 5% clad damage Definition(s):

None Basis: This threshold indicates that RCS radioactivity concentration is greater than 300 µCi/gm dose equivalent I 131 can be determined through use of various plant parameters that indicate 5% or greater fuel clad damage. 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. ' Technical support personnel can use MP-26-PI-FAP11 "Core Damage Assessment" to estimate clad damage (ref. 1). Provisions are provided to estimate fuel clad damage for MPS2 using core damage assessments in the event that RCS sampling options are not available due to design limitations with the RCS sample cooling system. It is recognized that sample collection and analysis of reactor coolant 1.vith highly elevated activity levels could require several hours to complete. Nonetheless, a sample related threshold is included as a backup to other indications. I There is no Potential Loss threshold associated with RCS Activity/ Containment Radiation. Reference(s):

1. MP-26-EPI-FAP11, "Core Damage Assessment"

2. NEI 99-01 CTMT Radiation / RCS Activity FC Loss 3.8 Page 135 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Barrier: Fuel Clad Category: C. CTMT Radiation / RCS Activity Degradation Threat: Potential Loss Threshold: None Page 136 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Fuel Clad Category: D. CTMT Integrity or Bypass Degradation Threat: Loss Threshold: I None Page 137 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Barrier: Fuel Clad Category: D. CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold: INone

Page 138 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bas'es Enclosure 3; Attachment 2B Barrier: Fuel Clad Category: E. DSEO/ADTS Judgment Degradation Threat: Loss Threshold:

7. Any condition in the opinion of the DSEO/ADTS that indicates loss of the Fuel Clad barrier Definition(s):

None Basis: This threshold addresses any other factors that are to be used by the Emergency DirectorDSEO/ADTS in determining whether the Fuel Clad barrier is lost. Reference(s):

1. NEI 99-01 Emergency Director Judgment Fuel Clad Loss 6.A Page 139 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Barrier: Fuel Clad Category: F. DSEO/ADTS Judgment Degradation Threat: Potential Loss Threshold:

4. Any condition in the opinion of the DSEO/ADTS that indicates potential loss of the Fuel Clad barrier Definition(s):

None Basis: This threshold addresses any other factors that are to be used by the Emergency DirectorDSEO/ADTS in determining whether the Fuel Clad barrier is potentially lost. The Emergency DirectorDSEO/ADTS should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored. Reference(s):

1. NEI 99-01 Emergency Director Judgment Potential Fuel Clad Loss 6.A Page 140 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Barrier: Reactor Coolant System Category: A. RCS or S/G Tube Leakage Degradation Threat: Loss Threshold:

1. An automatic or manual SIAS actuation required by EITHER:

c

UNISOLABLE RCS leakage
SG tube RUPTURE Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally. RUPTURE - The condition of a steam generator in which primary-to-secondary leaRage is of sufficient magnitude to require a safety injection. Basis: This threshold is based on an UNISOLABLE RCS leak of sufficient size to require an automatic or manual actuation of the Emergency Core Cooling System (ECCS). This condition clearly represents a loss of the RCS Barrier. A SIAS actuation resulting from a non-RCS leak event (ex.: FAULTED SG) does not meet the intent of this threshold. This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment. A steam generator with primary-to-secondary leakage of sufficient magnitude to require a safety injection is considered to be RUPTURED. If a RUPTURED steam generator is also FAUL TED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold 4-AA.1 will also be met. If EOPs direct operators to open the Pressurizer pressure relief valves to implement a core cooling strategy (i.e., a "feed and bleed" cooldown), then there will exist a reactor coolant flow path from the RCS, past the "pressurizer safety and relief valves" and into the containment that operators cannot isolate without compromising the effectiveness of the strategy (i.e., for the strategy to be effective, the valves must be kept in the open position); therefore, the flow through the pressure relief line is UNISOLABLE. In this case, the ability of the RCS pressure boundary to serve as an effective barrier to a release of fission products has been eliminated and thus this condition constitutes a loss of the RCS barrier. Page 141 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Reference(s):

1. EOP 2532; "Loss of Coolant Accident"

2. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Loss 1.A Page 142 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 'Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Reactor Coolant System Category: A. RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

1. UNISOLABLE RCS or SG tube leakage > 50 gpm excluding normal reductions in RCS inventory (e.g. letdown, RCP seal leakage)

Definition{s): UNISOLABLE -An open or breached system line that cannot be isolated, remotely or locally. Basis: This threshold is based on an UNISOLABLE RCS leak that results in the inability to maintain pressurizer level within specified limits by operation of a normally used charging (makeup) pump, but aR EGGS (Sl)SIAS actuation has not occurred. The threshold is met when aR operating procedure, or operating crmiv supervision, directs that a standby charging (makeup) pump be placed in service to restore and maintain pressurizer levelRCS leakage, excluding normal reductions in RCS inventory (e.g. letdown, RCP seal leakage), exceeds 50 gpm (ref. 1,

~-

When assessing RCS leaks, the classification should be based on actual leakage vice the impact of normal plant response to Operator directed actions. Example: A rapid down power may have the impact of increasing charging flow. The increase in charging should not be considered increased leakage. This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicaple to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location - inside containment, to the secondary-side

(i.e., steam generator tube leakage) or outside of containment.

If a-the leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold 4-AA.1 will also be met. Reference{s):

1. AOP 2568, "Reactor Coolant System Leak"

2. AOP 2569, "Steam Generator Tube Leak"

3. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.A Page 143 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-:47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Barrier: Reactor Coolant System Category: A. RCS or SIG Tube Leakage Degradation Threat: Potential Loss Threshold:

2. Uncontrolled RCS cooldown > 100°F/hr and RCS pressure and temperature are to the left of the 200°F Subcooling {PTS) Curve (EOP Figure 1)

Definition(s): None Basis: This condition indicates an extreme challenge to the integrity of the RCS pressure boundary due to pressurized thermal shock - a transient that causes rapid RCS cooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized). The maximum allowed RCS cooldown rate per Technical Specifications is 100°F/hr with cold leg temperature > 220°F (ref. 1). A RCS cooldown greater than 100°F/hr below 500°F is the temperature that requires implementation of Pressurized Thermal Shock (PTS) guidance (ref. 2, 3, 4). The 200°F maximum subcooling limit ensures PTS and brittle fracture of the reactor vessel will not occur following an RCS overcooling transient (defined as an uncontrolled cooldown to less than 500°F) (ref. 3). Reference(s):

1. Technical Specifications Section 3/4.4.9, "Pressure/Temperature Limits"

2. EOP 2536, "Excess Steam Demand Event"

3. Cale. S-01228-S2 MPS2, "EOP Setpoint Documentation RCS Pressure - Temperature Limits T.06 Figure T.0~-1"

4. EOP 2541 Appendix 2 Figures, "Figure 1 - RCS PIT Curve"

5. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.B Page 144 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Reactor Coolant System Category: B. Inadequate Heat Removal Degradation Threat: ,Loss Threshold: INone Page 145 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Reactor Coolant System Category: B. Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

3. Applicable RCS and Core Heat Removal (HR) Safety Function Status Check acceptance criteria not met Definition(s):

None Basis: There are three defined and potentially applicable RCS and Core Heat Removal (HR) Safety Function Status Check acceptance criteria conditions (ref. 1, 2):

HR SG Heat Sink With No SI Operating
HR SG Heat Sink With SI Operating
HR Once-Through-Cooling Failure to meet the applicable HR acceptance criteriaThis condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted.

Meeting this threshold results in a Site Area Emergency because this threshold is identical to Fuel Clad Barrier Potential Loss threshold BB.3; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and increase RCS pressure to the point where mass will be lost from the system. Reference(s):

1. EOP 2540, "Functional Recovery"

2. EOP 2540D, "Functional Recovery of Heat Removal"

3. NEI 99-01 Inadequate Heat Removal RCS Loss 2.8 Page 146 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Reactor Coolant System Category: C. CTMT Radiation/ RCS Activity Degradation Threat: Loss Threshold:

2. CTMT high range radiation monitor RE-8240/8241 reading > Table F-2 column RCS Loss Table F-2 CTMT High Range ~adiation Monitor Barrier Thresholds RE-8240/8241 Time > Shutdown Fuel Clad Loss RCS Loss CTMT Potential Loss (hrs) (R/hr) (R/hr) (R/hr)

               ~2                   56                     5                   224
             >2-4                   35                     5                   140
             >4-8                   16                     5                    65
            > 8-12                  10                     5                   40
              >12                    7                     5                   20 Definition(s):

None Basis: A reading > 5 R/hr (minimum practical reading) on RM-8240 or 8241 is indicative of a breach in the RCS barrier (ref. 1, 2). The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad barrier loss threshold 3-AC.2 since it indicates a loss of the RCS Barrier only. Because of the very high fuel clad integrity, only small amounts of noble gases would be dissolved in the primary coolant. Conservative estimates indicated that the readings from release of the normal RCS inventory would be below normal readings on the monitor while the station was operating. Therefore, a value 5 times the normal containment radiation monitor (RE-8240/8241) reading of - 1 R/hr is used. The reading is less than that specified for fuel cladding barrier loss because no damage to the fuel cladding is assumed. Only leakage from the RCS is assumed for this barrier loss threshold. The value is high enough to preclude erroneous classification of barrier loss due to normal plant operations and is set at the mid-point of the lowest decade of monitor indication (ref. 2). There is no Potential Loss threshold associated with RCS Activity/ Containment Radiation. Page 147 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Reference(s):

1. Damage Computer Program

2. Calculation RA-0074, "Millstone Unit 2 Expected Containment High Range Radiation Monitor Response to a LOCA Based on Fuel Gap Fractions Defined in NUREG 1228"

3. NEI 99-01 CMT Radiation / RCS Activity RCS Loss 3.A Page 148 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Reactor Coolant System Category: C. CTMT Radiation/ RCS Activity Degradation Threat: Potential Loss Threshold: I None Page 149 of 259

Millstone Power Station Unit 2 . Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Barrier: Reactor Coolant System Category: D. CTMT Integrity or Bypass Degradation Threat: Loss Threshold: INone Page 150 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Reactor Coolant System Category: D. CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold: I None Page 151 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Barrier: Reactor Coolant System Category: E. DSEO/ADTS Judgment Degradation Threat: Loss Threshold:

3. Any condition in the opinion of the DSEO/ADTS that indicates loss of the RCS barrier Definition(s):

None Basis: This threshold addresses any other factors that may be used by the Emergency DirectorDSEO/ADTS in determining whether the RCS barrier is lost. Reference(s):

1. NEI 99-01 Emergency Director Judgment RCS Loss 6.A Page 152 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Reactor Coolant System Category: E. DSEO/ADTS Judgment Degradation Threat: Potential Loss Threshold:

4. Any condition in the opinion of the DSEO/ADTS that indicates potential loss of the RCS barrier Definition(s):

None Basis: This. threshold addresses any other factors that may be used by the Emergency DirectorDSEO/ADTS in determining whether the RCS barrier is potentially lost. The Emergency DirectorDSEO/ADTS should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Reference(s):

1. NEI 99-01 Emergency Director Judgment RCS Potential Loss 6.A Page 153 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Containment Category: A. RCS or SG Tube Leakage Degradation Threat: Loss Threshold:

1. A leaking or RUPTURED SG is FAULTED outside of CTMT Definition(s):

FAUL TED - The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized. RUPTURED - The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection. Basis: This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAUL TED outside of containment. The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the threshqlds for RCS Barrier Potential Loss 4-A-A.1 and Loss 4-c-AA.1, respectively. This condition represents a bypass of the containment barrier. FAULTED is a defined term within the NEI 99-01 methodology; this determination is not necessarily dependent upon entry into, or diagnostic steps within, an EOP. For example, if the pressure in a steam generator is decreasing uncontrollably !fpart of the FAULTED definition.}} and the FAULTED steam generator isolation procedure is not entered because EOP user rules are dictating implementation of another procedure to address a higher priority condition, the steam generator is still considered FAUL TED for emergency classification purposes. Th1;3 FAULTED criterion establishes an appropriate lower bound on the size of a steam release that may require an emergency classification. Steam releases of this size are readily observable with normal Control Room indications. The lower bound for this aspect of the containment barrier is analogous to the lower bound criteria specified in IC -SY4-MU4 for the fuel clad barrier (i.e., RCS activity values) and IC SYa-MU5 for the RCS barrier (i.e., RCS leak rate values). This threshold also applies to prolonged steam releases necessitated by operational considerations such as the forced steaming of a leaking or RUPTURED steam generator directly to atmosphere to cooldown the plant, or to drive an auxiliary (emergency) feed water pump. These types of conditions will result in a significant and sustained release of radioactive steam to the environment (and are thus similar to a FAULTED condition). The inability to isolate the steam flow without an adverse effect on plant cooldown meets the intent of a loss of containment. Steam releases associated with the expected operation of a SG power operated relief valve or safety relief valve do not meet the intent of this threshold. Such releases may occur Page 154 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B intermittently for a short period of time following a reactor trip as operators process through emergency operating procedures to bring the plant to a stable condition and prepare to initiate a plant cooldown. Steam releases associated with the unexpected operation of a valve (e.g., a stuck-open safety valve) do meet this threshold. Following an SG tube leak or rupture, there may be minor radiological releases through a secondary-side system component (e.g., air ejectors, gland seal exhausters, valve packing, etc.). These types of releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A-.R_ICs.

The emergency classification levels resulting from primary-to-secondary leakage, with or without a steam release from the FAULTED SG, are summarized below.

Affected SG is FAULTED Outside of Containment? P-to-S Leak Rate Yes No Less than or equal to 25 gpm No classification No classification Unusual Event per Unusual Event per Greater than 25 gpm SY4MU5.1 SY4MU5.1 . Greater than 50 gpmRequires operation of a standby charging Site Area Emergency per Alert per FA1.J. (makeup) pump (RCS_Barrier FS1J. Potential Loss) Requires an automatic or manual Site Area Emergency per ECCS (SIAS) actuation (RCS Alert per FA1J. FS1J. Barrier Loss) There is no Potential Loss threshold associated with RCS or SG Tube Leakage. Reference(s):

1. NEI 99-01 RCS or SG Tube Leakage Containment Loss 1.A i

Page 155 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Containment Category: A. RCS or SG Tube Leakage Degradation Threat: Potential Loss Threshold: INone Page 156 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Containment Category: B. Inadequate Heat Removal Degradation Threat: Loss I None Page 157 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Barrier: Containment Category: B. Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

1. CETs > 1200°F AND .

Restoration procedures not effective within 15 min. (Note 1) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or. will likely be exceeded. Definition(s): 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. Basis: The SAMGs use a CET temperature of 1200°F as an entry condition and the temperature indicative of a badly damaged core. This condition represents an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure. For this condition to occur there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. If implementation of a procedure(s) to restore adequate core cooling is not effective (successful) within 15 minutes, it is assumed that the event trajectory will likely lead to core melting and a subsequent challenge of the Containment Barrier. The restoration procedure is considered "effective" if core exit thermocouple readings are decreasing and/or if reactor vessel level is increasing. Whether or not the procedure(s) will be effective should be apparent within 15 minutes. The Emergency DirectorDSEO/ADTS should escalate the emergency classification level to a General Emergency as soon as it is determined that the procedure(s) will not be effective. Severe accident analyses (e.g., NUREG-1150) have concluded that functional restoration procedures can arrest core degradation in a significant fraction of core damage scenarios, and that the likelihood of containment failure is very small in these events. Given this, it is appropriate to provide 15 minutes beyond the required entry point to determine if procedural actions can reverse the core melt sequence. Reference(s):

1. SAMG 4211, "Phase 1 Initial Diagnosis" 2 MP-26-EPI-FAP11-001, "Core Damage Assessment: Core Exit Temperatures"

3. NEI 99-01 Inadequate Heat Removal Containment Potential Loss 2.A Page 158 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Containment Category: C. CTMT Radiation/RCS Activity Degradation Threat: Loss Threshold: I None Page 159 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Barrier: Containment Category: C. CTMT Radiation/RCS Activity Degradation Threat: Potential Loss Threshold:

2. CTMT high range radiation monitor RE-8240/8241 reading> Table F-2 column CTMT Potential Loss Table F-2 CTMT High Range Radiation Monitor Barrier Thresholds RE-8240/8241 Time > Shutdown Fuel Clad Loss RCS Loss CTMT Potential Loss (hrs) (R/hr) (R/hr) (R/hr)

2 56 5 224

              >2-4                   35                     5                     140
              >4-8                   16                     5                     65
             > 8 :_ 12               10                     5                     40
               >12                    7                     5                     20 Definition(s):

None Basis: The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that 20% of the fuel cladding has failed (readings have been rounded for readability). This level of fuel clad failure is well above that used to determine the analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds (ref. 1, 2). Time after shutdown values are*provided to account for radioactive decay. 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. The values specified in Table F-2 were developed using a method to minimize error(+/-) for the threshold value within each defined time period. Time periods were chosen to fit monitor response (fast changes in response early following reactor shutdown are broken up into smaller time periods to better approximate expected change). Values were chosen within each time period to minimize error (<50%) to the highest and lowest response within the range. Page 160 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Reference(s):

1. Damage Computer Program

2. Calculation RA-0074, "Millstone Unit 2 Expected Containment High Range Radiation Monitor Response to a LOCA Based on Fuel Gap Fractions Defined_ in NUREG 1228"

3. NEI 99-01 CMT Radiation / RCS Activity Containment Potential Loss 3.A Page 161 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Containment Category: D. CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

2. CTMT isolation is required AND EITHER:

CTMT integrity has been lost based on DSEO/ADTS judgment
UNISOLABLE pathway from CTMT atmosphere to the environment exists Definition(s):

UNISOLABLE -An open or breached system line that cannot be isolated, remotely or locally. Basis: The status of the containment barrier during an event involving steam generator tube leakage is assessed using Loss Threshold 4-:AA.1. Therefore this threshold is not applicable to steam generator tube leakage. These thresholds address a situation where containment isolation is required and one of two conditions exists as discussed below. Users are reminded that there may be accident and release conditions that simultaneously meet both bulleted thresholds 4.l\.1 and 4 .l\.2. 4:A:4First Threshold - Containment integrity has been lost, i.e., the actual containment atmospheric leak rate likely exceeds that associated with allowable leakage (or sometimes referred to as design leakage). Following the release of RCS mass into containment, containment pressure will fluctuate based on a variety of factors; a loss of containment integrity condition may (or may not) be accompanied by a noticeable drop in containment pressure. Recognizing the inherent difficulties in determining a containment leak rate during accident conditions, it is expected that the Emergency DirectorDSEOADTS will assess this threshold using judgment, and with due consideration given to current plant conditions, and available operational and radiological data (e.g., containment pressure, readings on radiation monitors outside containment, operating status of containment pressure control equipment, etc.). Refer to the middle piping run of Figure g._µ1. Two simplified examples are provided. One is leakage from a penetration and the other is leakage from an in-service system valve. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure. Another example would be a loss or potential loss of the RCS barrier, and the simultaneous occurrence of two FAULTED locations on a steam generator where one fault is located inside containment (e.g., on a steam or feedwater line) and the other outside of containment. In this , case, the associated steam line provides a pathway for the containment atmosphere to escape to an area outside the containment. Page 162 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A ICs. 4-:A+/-Second Threshold - Conditions are such that there is an UNISOLABLE pathway for the migration of radioactive material from the containment atmosphere to the environn:tent. As used here, the term "environment" includes the atmosphere of a room or area, outside the containment, that may, in turn, communicate with the outside-the-plant atmosphere (e.g., through discharge of a ventilation system or atmospheric leakage). Depending upon a variety of factors, this condition may or may not be accompanied by a noticeable drop in containment pressure. Refer to the top piping run of Figure 94'.-41. In this simplified example, the inboard and outboara isolation valves remained open after a containment isolation was required (i.e., containment isolation was not successful). There is now an UNISOLABLE pathway from the containment to the environment. The existence of a filter is not considered in the threshold assessment. Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine' and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream. Leakage between two interfacing liquid systems, by itself, does not meet this threshold. Refer to the bottom piping run of Figure 94-41. In this simplified example, leakage in an RCP seal cooler is allowing radioactive material to enter the Auxiliary Building. The radioactivity would be detected by the Process Monitor. If there is no leakage from the closed water cooling system to the Auxiliary Building, then no threshold has been met. If the pump developed a leak that allowed steam/water to enter the Auxiliary Building, then the second threshold-4.-B would be met. Depending upon radiation monitor locations and sensitivities, this leakage could be detected by any of the four monitors depicted in the figure and cause the first threshold 4 .A.1 to be met as well. Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable containment leakage through various penetrations or system components. Minor releases may also occur if a containment isolation valve(s) fails to close but the containment atmosphere escapes to an enclosed system. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A-B._ICs. Reference(s):

1. NEI 99-01 CMT Integrity or Bypass Containment Loss 4.A Page 163 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Containment Category: D. CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

3. Indications of RCS leakage outside of CTMT Definition(s):

None Basis: To ensure proper esc~lation of the emergency classification, the RCS leakage outside of containment must be related to the mass loss that is causing the RCS Loss and/or Potential Loss threshold 4-cAA.1 to be met. The status of the containment barrier during an event involving steam generator tube leakage is assessed using Containment Loss Threshold A.1. Therefore this threshold is not applicable to steam generator tube leakage. Containment sump, temperature, pressure and/or radiation levels will increase if reactor coolant mass is leaking into the containment. If these parameters have not increased, then the reactor coolant mass may be leaking outside of containment (i.e., a containment bypass sequence). Increases in sump, temperature, pressure, flow and/or radiation level readings outside of the containment may indicate that the RCS mass is being lost outside of containment. Unexpected elevated readings and alarms on radiation monitors with detectors outside containment should be corr9borated with other available indications to confirm that the source is a loss of RCS mass outside of containment. If the fuel clad barrier has not been lost, radiation monitor readings outside of containment may not increase significantly; however, other unexpected changes in sump levels, area temperatures or pressures, flow rates, etc. should be sufficient to determine if RCS mass is being lost outside of the containment. Refer to the middle piping run of Figure 94'.--41. In this simplified example, a leak has occurred at a reducer on a pipe c;:arrying reactor coolant in the Auxiliary Building. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause loss threshold CNB4 D.2 to be met as well. Reference(s):

1. NEI 99-01 GMT Integrity or Bypass Containment Loss 4.8 Page 164 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Figure 1: Containment Integrity or Bypass Examples 0 Inside CTMT Auxiliary Building Damper Closed Cooling RCP Seal Cooling Page 165 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Containment Category: D. CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

13. CTMT pressure > 54 psig Definition(s):

None Basis: If containment pressure exceeds the design pressure of 54 psig (ref. 1), there exists a potential . to lose the containment barrier. To reach this level, there must be an inadequate core cooling condition for an extended period of time; therefore, the RCS and Fuel Clad barriers would already be lost. Thus, this threshold is a discriminator between a Site Area Emergency and General Emergency since there is now a potential to lose the third barrier. Reference(s):

1. Unit 2 UFSAR Section 5.2.2.1.3, "Loss-of-Coolant Accident Loads"

2. NEI 99-01 CMT Integrity or Bypass Containment Potential Loss 4.A Page 166 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Containment Category: D. CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold: , 4. CTMT hydrogen concentration> 4% Definition(s): None Basis: 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 therefor~ represents a potential loss of the containment barrier. A containment hydrogen concentration of 4% conservatively represents the lowest threshold for flammability in the presence of oxygen (ref. 1). Reference(s):

1. SAMG 4215 Attachment 1, "Calculation Aids, C'alculational Aid #7 Containment Challenge Due to Hydrogen Combustion"

2. NEI 99-01 CMT Integrity or Bypass Containment Potential Loss 4.B Page 167 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Barrier: Containment Category: D. CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

5. CTMT pressure > 10 psig with < one full train of CTMT heat removal systems (Note 11) operating per design for ~15 min. (Note 1)

Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 11: One full train of containment heat removal systems consist of one Containment Spray pump and two containment air recirculation units in the Containment Air Recirculation and Cooling System. Definition(s): None Basis: This threshold describes a condition where containment pressure is greater than the setpoint (9.48 psig rounded to 10 psig for readability) at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design (ref. 1, 2). The 15-minute criterion is included to allow operators time to manually start equipment that n;iay not have automatically started, if possible. This threshold represents a potential loss of containment in that containment heat removal/depressurization systems (e.g., containment sprays, ice condenser fans, etc., but not including containment venting strategies) are either lost or performing in a degraded manner. One full train of containment heat removal systems consist of one Containment Spray pump and two containment air recirculation units. The combination of required equipment can be obtained from using equipment on either emergency bus in order to meet the "one full train" requirement (ref. 3). Reference(s):

1. UFSAR Section 6.4, "Containment Spray System"

2. UFSAR Section 7.3, "Engineered Safety Features Actuation System"

3. UFSAR Section 6.5, "Containment Air Recirculation and Cooling System"

4. NEI 99-01 CMT Integrity or Bypass Containment Potential Loss 4.C Page 168 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Barrier: Containment Category: E. DSEO/ADTS Judgment Degradation Threat: Loss Threshold: 4, Any condition in the opinion of the DSEO/ADTS that indicates loss of the CTMT barrier Definition(s): None Basis: This threshold addresses any other factors that may be used by the Emergency DirectorDSEO/ADTS in determining whether the containment barrier is lost. Reference(s):

1. NEI 99-01 Emergency Director Judgment Containment Loss 6.A Page 169 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Barrier: Containment Category: E. DSEO/ADTS Judgment Degradation Threat: Potential Loss Threshold:

6. Any condition in the opinion of the DSEO/ADTS that indicates potential loss of the CTMT barrier Definition(s):

None Basis: This threshold addresses any other factors that may be used by the Emergency DirectorDSEO/ADTS in determining whether the containment barrier is potentially lost. The Emergency DirectorDSEO/ADTS should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored. Reference(s):

1. NEI 99-01 Emergency Director Judgment Containment Potential Loss 6.A Page 170 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category H - Hazards and Other Conditions Affecting Plant Safety EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.) Hazards are non-plant, system-related events that can directly or indirectly affect plant operation, reactor plant safety or personnel safety.

1. Security.

Unauthorized entry attempts into the PROTECTED AREA, bomb threats, sabotage attempts, and actual security compromises threatening loss of physical control of the plant.

2. Seismic Event Natural events such as earthquakes have potential to cause plant structure or equipment damage of sufficient magnitude to threaten personnel or plant safety.

3. Natural or Technological Hazard Other natural and non-naturally occurring events that can cause damage to plant facilities include tornados, FLOODING, hazardous material releases and events restricting site access warranting classification.

4. Fire FIRES can pose significant hazards to personnel and reactor safety. Appropriate for classification are FIRES within the plant PROTECTED AREA or which may affect operability of equipment needed for safe shutdown

5. Hazardous Gas Toxic, corrosive, asphyxiant or flammable gas leaks can affect normal plant operations or preclude access to plant areas required to safely shutdown the plant.

6. Control Room Evacuation Events that are indicative of loss of Control Room habitability. If the Control Room must be evacuated, additional support for monitoring and controlling plant functions is necessary through the emergency response facilities.

7. DSEO/ADTS Judgment The EALs defined in other categories specify the predetermined symptoms or events that are indicative of emergency or potential emergency conditions and thus warrant classification. While these EALs have been developed to address the full spectrum of possible emergency conditions which may warrant classification and subsequent implementation of the Emergency Plan, a provision for classification of emergencies based on operator/management experience and judgment is still necessary. The EALs of this category provide the DSEO/ADTS the latitude to classify emergency conditions consistent with the established classification criteria based upon DSEO/ADTS judgment.

Page 171 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level _Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 1 - Security Initiating Condition: Confirmed SECURITY CONDITION or threat EAL: HU1.1 Unusual Event A SECURITY CONDITION that does not involve-a HOSTILE ACTION as reported by MPS Security Shift Supervision OR Notification of a credible security threat directed at the site OR A validated notification from the NRC providing information of an aircraft threat Mode Applicability: All Definition(s): 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 MPS 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 MPS. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between

individuals in the OWNER CONTROLU~D AREA).

OWNER CONTROLLED AREA (OCA) - The area within the SITE BOUNDARY including the PROTECTED AREA. PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety. PROTECTED AREA - The area within the Millstone Power Station security 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 (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; Page 172 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B (3) The capability to prevent or mitigate the consequences: of accidents which could result in potential offsite exposures. SEGUR/TY 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. Basis: 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, and HS1 and HG1. Guidance on assessing Security Conditions is included in the Security Contingency Plan Implementing Procedures (SCIP). The SCIPs are implementing procedures for the Station Safeguards Contingency Plan. 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. 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]. The first threshold EAL #1 references the Security Shift Supervision (site specific security shift supervision)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. The second threshold EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with the Millstone, North Anna and Surry Power Stations' Security Plan, Training and Qualification Plan, Safeguards Contingency Plan .and Independent Spent Fuel Storage Installation Security Program(site specific procedure) (ref. 1). The third threshold EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with OP-AA-900 Authentication (ref. 2)(site specific procedure). Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for MPS (ref. 1). Escalation of the emergency classification level would be via IC HA 1. Page 173 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Reference(s):

1. Millstone, North Anna and Surry Power Stations' Security Plan, Training and Qualification Plan, Safeguards Contingency Plan and Independent Spent Fuel Storage Installation Security Program

2. OP-AA-900, "Authentication"

3. NEI 99-01 HU1 Page 174 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 1 - Security Initiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes EAL: HA1.1 Alert A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by MPS Security Shift Supervision OR A validated notification from NRC of an aircraft attack threat within 30 min. of the site Mode Applicability: All Definition(s): HOSTAGE -A person(s) held as leverage qgainst the station to ensure that demands will be met by the station. HOSTILE ACTION - An act toward MPS 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 MPS. 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 - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction. OWNER CONTROLLED AREA - The area within the SITE BOUNDARY including the PROTECTED AREA. PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety. PROTECTED AREA - The area within the Millstone Power Station security fence. Basis: 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. Page 175 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 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 State and local agenciesOffsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions. This ~EAL 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. The first threshold El\L #1 is 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 /\RE/\. The second threshold El\L #2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and State and local agenciesOROs are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with OP-AA-900 Authentication fsi-te-specific procedure)(ref. 2). 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. Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for MPS (ref. 1). Escalation of the emergency classification level would be via IC HS1. Page 176 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Reference(s):

1. Millstone, North Anna and Surry Power Stations' Security Plan, Training and Qualification Plan, Safeguards Contingency Plan and Independent Spent Fuel Storage Installation Security Program

2. OP-AA-900, "Authentication"

3. NEI 99-01 HA 1 Page 177 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 1 - Security Initiating Condition: HOSTILE ACTION within the PROTECTED AREA EAL: HS1.1 Site Area Emergency A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by MPS Security Shift Supervision Mode Applicability: All Definition(s): 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 MPS 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 MPS. 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 - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction. OWNER CONTROLLED AREA - The area within the SITE BOUNDARY including the PROTECTED AREA. PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety. PROTECTED AREA - The area within the Millstone Power Station security fence. Basis: 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 (ref. 1). 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}. Page 178 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B 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 State and local agencyGRG 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 .f.G-EAL does not apply to- a HOSTILE ACTION directed at an ISFSI Protected Area located outside the PROTECTED /\RE/\; such an attacl< should be assessed using IC H/\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. Emergency plans and implementing procedures are public document~; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for MPS (ref. 1). Escalation of the emergency classification level would be via IC HG1. Reference(s):

1. Millstone, North Anna and Surry Power Stations' Security Plan, Training and Qualification Plan, Safeguards Contingency Plan and Independent Spent Fuel Storage Installation Security Program '

2. NEI 99-01 HS1 Page 179 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level "[echnical Bases Enclosure 3; Attachment 28 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 2 - Seismic Event Initiating Condition: Seismic event greater than OBE levels EAL: HU2.1 Unusual Event Notification by the MPS3 Control Room that a seismic event > OBE has occurred Mode Applicability: All Definition(s): None Basis: This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (OBE). An earthquake greater than an QBE but less than a Safe Shutdown Earthquake (SSE) 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 (e.g., lateral accelerations in excess of 0.00§09g). The Shift Manager or Emergency DirectorDSEO/ADTS may seek external verification if deemed appropriate (e.g., a call to the U.S. Geological Survey (USGS}, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration. For both MPS2 and MPS3, the QBE ground acceleration thresholds are > 0.09g horizontal or

> 0.06g vertical. The MPS3 Control Room has real time OBE exceedance alarm indications (ref. 1, 2, 3). Therefore classification shall be based upon the receipt of the MPS3 OBE alarm light on MPS3 Panel 3ERS-PNLSM1 C (ref. 2). The MPS3 Control Room will notify MPS2 if the seismic event exceeded the OBE threshold.

Additionally, the Unit 2 seismic instrumentation provides a trigger alarm (C06 DA-22) at 0.01 g ground acceleration (ref. 4 ). Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA6 or SABMA9.

                                         - Page 180 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Reference(s):

1. AOP 2562, "Earthquake"

2. MPS3 AOP 3570, "Earthquake"

3. UFSAR 2.1.1, "Site Location and Description"

4. ARP 2590E-119, "SEISMIC INST TRIGGERED"

5. NEI 99-01 HU2 Page 181 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL: HU3.1 Unusual Event A tornado strike within the PROTECTED AREA Mode Applicability: All Definition(s): PROTECTED AREA - The area within the Millstone Power Station security fence. Basis: This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant. This EAL EAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA. EAL #2 addresses flooding of a building room or area that results in operators isolating pm.ver to a SAFETY SYSTEM component due to water level or other wetting concerns. Classification is also required if the 1.vater 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 vJarrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode. EAL #3 addresses a hazardous, materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel 1Nithin the PROTECTED AREA. EAL #4 addresses a hazardous event that causes an on site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of such an event include site flooding caused by a hurricane, heavy rains, up river vvater releases, dam failure, etc., or an on site train derailment blocking the access fea4-This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane /\ndrmv 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. E/\L #5 addresses (site specific description). Escalation of the emergency classification level would be based on ICs in Recognition Categories AR, F, S-M_or C. If damage is confirmed visually or by other in-plant indications, the event may be escalated to an Alert under IC CA6 or MA9. Page 182 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 A tornado striking (touching down) within the PROTECTED AREA warrants declaration of an Unusual Event regardless of the measured wind speed at the meteorological tower. A tornado is defined as a violently rotating column of air in contact with the ground and extending from the base of a thunderstorm. Reference(s):

1. AOP 2560, "Storms, High Winds and High Tides"

2. NEI 99-01 HU3 I

Page 183 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL: HU3.2 Unusual Event 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 Mode Applicability: All Definition(s): FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area. 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 (as defined in 10CFR50.2): Those structures, systems and components* that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant. EAL #1 addresses a tornado striking (touching down) within the PROTECTED /\RE/\. This EAL 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 (ref. 1, 2). EAL #3 addresses a haza~dous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED ARE/\. EAL #4 addresses a hazardous event that causes an on site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of s~ch an event include site flooding caused by a hurricane, heavy rains, Page 184 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 up river water releases, dam failure, etc., or an on site train derailment blocking the access ma4 This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehicle breakdovms or accidents, but rather to more significant conditions such as the Hurricane Andrevv strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011. EAL #5 addresses (site specific description). Escalation of the emergency classification level would be based on ICs in Recognition Categories AR, F, S--M_or C. Refer to EAL CA6.1 or MA9.1 for internal flooding affecting more than one SAFETY SYSTEM train. Reference(s):

1. AOP 2560, "Storms, High Winds and High Tides"

2. SP 2615, "Flood Level Determination"

3. NEI 99-01 HU3 Page 185 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL: HU3.3 Unusual Event Movement of personnel within the PROTECTED AREA is IMPEDED due to an event external to the PROTECTED AREA involving hazardous materials (e.g., an offsite chemical spill or toxic gas release) Mode Applicability: All Definition(s): IMPEDE(D) - Personnel access to a room or area is hindered to an extent that 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). PROTECTED AREA - The area within the Millstone Power Station security fence. Basis: This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant. This EAL EAL #1 addresses a tornado striking (touching down) within the PROTECTED /\RE/\. This EAL addresses flooding of a building room or area that results in operators isolating pov,er to a SAFETY SYSTEM component due to water level or other \Netting concerns. Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its pmver source (e.g., a breaker or relay trip). To warrant classification, operabilit of the affected component must be required by Technical Specifications for the current operating mode. EAL #3 addresses a hazardous materials event originating at aR offsite location outside the PROTECTED AREA and of sufficient magnitude to IMPEDE the movement of personnel within the PROTECTED AREA. EAL #4 addresses a hazardous event that causes an on site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of such an event include site flooding caused by a hurricane, heavy rains, up river v.1ater releases, dam failure, etc., or an on site train derailment blocking the access ma4 This EAL is not intended 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. Page 186 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 E/\L #5 addresses (site specific description). Escalation of the emergency classification level would be based on ICs in Recognition Categories AR, F, S--M_or C. Reference( s):

1. NEI 99-01 HU3 Page 187 of 259

Millstone Power Station Unit 2 Serial-No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL: HU3.4 Unusual Event A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles (Note 7) Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents. Mode Applicability: All Definition(s): FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area. Basis: This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant._E/\L #1 addresses a tornado striking (touching dov,m) within the PROTECTED AREA. This E/\L addresses flooding of a building room or area that results in operators isolating pmNer to a SAFETY SYSTEM component due to water level or other wetting concerns. Classification is also required if the water level or related 1.e.ietting causes an automatic isolation of a SAFETY SYSTEM component from its pmver source (e.g., a breaker or relay trip). To \Narrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode. E/\L #3 addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA. This EAL EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of such an event include site FLOODING caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road. This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the FLOODING around the Cooper Station during the Midwest floods of 1993, or the FLOODING around Ft. Calhoun Station in 2011. EAL #5 addresses (site specific description). Escalation of the emergency classification level would be based on ICs in Recognition Categories AR, F, S--.M_or C. Page 188 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Reference(s):

1. NEI 99-01 HU3 *

Page 189 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Categpry: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL: HU4.1 Unusual Event A FIRE is not extinguished within 15 min. of any of the following fire detection indications (Note 1): *

Report from the field (i.e., visual observation)
Receipt of multiple (more than 1) fire alarms or indications
Field verification of a single fire alarm AND The FIRE is located within any Table H-1 area Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Table H-1 MPS2 Fire Areas

Containment Building
Control Room
Auxiliary Building Areas:

o Penetration Areas o RBCCW Pump Rooms o Diesel Generator Rooms o Diesel Generator Day Tank Rooms o Charging Pump Cubicles o SI Pump Rooms o DC Equipment and Battery Rooms o East 480 VAC Switchgear Room

Intake Structure
Turbine Building Areas:

o Cable Vaults o West 480 VAC Switchgear Room o 4.16 KV Switchgear Rooms o Steam Driven Aux Feedwater Room o Motor Driven Aux Feedwater Room

Yard Areas:

o RWST o CST o Unit 3 SBO DG Mode Applicability: All Definition{s): Page 190 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B 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. VALID-An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. Basis: 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 The 15 minute requirement begins with a credible notification that a FIRE is occurring, or receipt of multiple VALID fire detection system alarms or field validation of a single fire alarm. The alarm is to be validated using available Control Room indications or alarms to prove that it is not spurious, or by reports from the field. Table H-1 Fire Areas are those areas that contain equipment necessary for safe operation and shutdown of the plant (ref. 1, 2). 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 alarm, indication or report._EAL #2 This EAL addresses receipt of a single fire alarm, and the existence of a fl RE 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 1.vas received, and not the time that a subsequent verification action was performed. A single fire alarm, absent other indication(s) of a flRE, may be indicative of equipment failure or a spurious activation, and not an actual flRE. 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 fl RE exists; hm.vever, after that time, and absent information to the contrary, it is assumed that an actual flRE is in progress. If an actual fl RE is verified by a report from the field, then EAL #1 is immediately appl,icable, and the emergency must be declared if the fl RE 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 i.varranted. Page 191 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 E/\L #3 In addition to a FIRE addressed by E/\L #1 or E/\L #2, a FIRE 1.vithin the plant PROTECTED /\REA not extinguished within 60 minutes may also potentially degrade the level of plant safety. This basis extends to a FIRE occurring within the PROTECTED /\RE/\ of an ISFSI located outside the plant PROTECTED /\RE/\. [Sentence for plants with an ISFSI outside the plant Protected /\rea] E/\L #4 If a FIRE \Vithin the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area] PROTECTED /\RE/\ is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish. Declaration is not necessary if the agency resources are placed on stand by, or supporting post extinguishment recovery or investigation actions. Basis Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part: Criterion 3 of Appendix/\ 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." VVhen 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 so impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents. 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). /\s used in E/\L #2, the 30 minutes to verify a single alarm is \VOii within this vv1orst 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 CA6 or-SA9-MA9. Reference(s):

1. AOP 2559, "Fire"

2. MP2 Appendix R Compliance Report

3. NEI 99-01 HU4 Page 192 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL: HU4.2 Unusual Event Receipt of a single fire alarm (i.e., no other indications of a FIRE) AND The fire alarm is indicating a FIRE within any Table H-1 area (excluding Cont~inment Building) AND The existence of a FIRE is not verified within 30 min. of alarm receipt (Notes 1, 14) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 14: A Containment Building fire alarm is considered VALID upon receipt of multiple (more than one) fire zone alarms. Table H-1 MPS2 Fire Areas

Containment Building
Control Room
Auxiliary Building Areas:

a Penetration Areas o RBCCW Pump Rooms a Diesel Generator Rooms a Diesel Generator Day Tank Rooms a Charging Pump Cubicles a SI Pump Rooms , a DC Equipment and Battery Rooms a East 480 VAC Switchgear Room

Intake Structure
Turbine Building Areas:

a Cable Vaults a West 480 VAC Switchgear Room a 4.16 KV Switchgear Rooms a Steam Driven Aux Feedwater Room a Motor Driven Aux Feedwater Room

Yard Areas:

o RWST o CST o Unit 3 SBO DG Mode Applicability: All Page 193 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Definition(s): 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. VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. Basis: 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. E/\L #1 The intent of the 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE 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 E/\L assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report 'Nas received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report. E/\L #2 The 30 minute requirement begins upon receipt of a single VALID fire detection system alarm. The. alarm is to be validated using available Control Room indications or alarms to prove that it is not spurious, or by reports from the field. Actual field reports must be made within the 30 minute time limit or a classification must be made. If a fire is verified to be occurring by field report, classification shall be made based on EAL HU4.1, with the 15 minute requirement beginning with the verification of the fire by field report. Table H-1 Fire Areas are those.areas that contain equipment necessary for safe operation and

 -shutdown of the plant (ref. 1, 2).

This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a , subsequent verification action was performed. With regard to Containment Building fire alarms, there is constant air movement in the enclosed containment due to the operation of the containment ventilation system. The operating cooling units are drawing air to the units past the smoke detectors. It can be reasonably expected that a fire that burns for 15 minutes would produce sufficient products of combustion to cause fire detectors in multiple zones to alarm. Therefore, a single Containment Building fire alarm is not considered VALID. Page 194 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For,this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress. If an actual FIRE is verified by a report from the field, then HU4.1 EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted. EAL #3 In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE \Vithin the plant PROTECTED AREA not extinguished within 60 minutes may also potentially degrade the level of plant safety. This basis extends to a F!RE occurring within the PROTECTED AREA of an !S.c=.s! located outside the pl-ant PROTECTED AREA. [Sentence forp.'-ants with an !SFS! outside the plant Protected Area] EAL#4 Basis-Related Requirements from Appendix R (justification for the use of 30 minute criteria) Appendix R to 10 CFR 50 Appendix R, states in part: Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions." When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off. Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire

       .conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

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 HU4.2EAL #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 CA6 or SA9MA9. Reference(s):

1. AOP, "2559 Fire"

2. MP2 Appendix R Compliance Report

3. NEI 99-01 HU4 Page 195 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL: HU4.3 Unusual Event A FIRE within the PROTECTED AREA not extinguished within 60 min. of the initial report, alarm or indication (Note 1) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Mode Applicability: All Definition(s): 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 encompassed by physical barriers (i.e., the security fence) and to which access is controlled. Basis: 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 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 ,.vas received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, iridication or report. EAL #2 This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30 minutes of the alarm. Upon receipt, operators will take \ prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30 minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed. A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allmved to Page 196 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 verify the validity of the alarm. The 30 minute period is a reasonable amount of time to determine if an actual FIRE exists; hov;ever, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress. If an actual FIRE is verified by a report from the field, then E/\L #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 1JVithin 30 minutes of the receipt of the alarm, then this E/\L is not applicable and no emergency declaration is vvarranted. E/\L #3 In addition to a FIRE addressed by EAL HU4.1 #4-or HU4.2EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety. This basis extends to a FIRE occurring 1.vithin the PROTECTED /\REA of an ISFSI located outside the plant PROTECTED AREA. [Sentence for pl-ants with an lSFSl outside tho pl-ant Protected /1.roa]EAL #4 If a FIRE 1.vithin the plant or !SFS! [for plants with an !SFS! outside tho plant Protected Area] PROTECTED /\RE/\ is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish. Declaration is not necessary if the agency resources are placed on stand by, or supporting post extinguishment recovery or investigation actions. Basis Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part: Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."

         \fl/hen considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume ma:jor 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 shutdovm 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 so impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdovvn 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 E/\L #2, the 30 minutes to verify a single alarm is well 1.vithin this v.mrst 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 CA6 or SA9MA9. Page 197 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Reference(s):

1. AOP 2559, "Fire"

2. NEI 99-01 HU4 Page 198 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4- Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL: HU4.4 Unusual Event A FIRE within the PROTECTED AREA that requires an offsite fire department to assist with extinguishment 0 Mode Applicability: All Definition(s): 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 encompassed by physical barriers (i.e., the security fence) and to which access is controlled. Basis: This IC addresses the magnitude and extent of FIRES that may be indicative of a potential de_gradation of the level of safety of the plant. EAL #1 The intent of the 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering 'Nasta 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 'Nill take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For E/\L assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report. E/\L #2 \ This E/\L 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 \Viii 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 'Nas received, and not the time that a subsequent verification action v,as performed. /\ 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 allovved to verify the validity of the alarm. The 30 minute period is a reasonable amount of time to Page 199 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress. If an actual FIRE is verified by a report from the field, then E/\L #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished 1.vithin 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 E/\L is not applicable and no emergency declaration is warranted. E/\L #3 In addition to a FIRE addressed by E/\L #1 or E/\L #2, a FIRE within the plant PROTECTED /\RE/\ not extinguished within 60 minutes may also potentially degrade the level of plant safety. Thjs basjs extends to a FIRE occurring withjn the PROTECTED AREA of an JSFSJ located outsjde the plant PROTECTED AREA. [Sentence for plants with an !SFSJ outsjde the plant Protected Area] E/\L #4 If a FIRE within the plant or ISFSI [for plants with an !SFS! outside the plant Protected Area] 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. The Shift Fire Brigade Advisor or Shift Fire Brigade Leader will assess whether the fire conditions warrant outside assistance (ref. 1). Basis Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part: Criterion 3 of Appendix/\ 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 vvith 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 so impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents. 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 Page 200 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B redundant train (G.2.c). As used in EAL #2, the 30 minutes to verify a single alarm is well within this vvorst 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 CA6 or SA9MA9. Reference(s):

1. AOP 2559, "Fire"

2. NEI 99-01 HU4 Page 201 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 5 - Hazardous Gases Initiating Condition: Gaseous release IMPEDING access to equipment necessary for normal plant operations, cooldown or shutdown EAL: HAS.1 Alert Release of a toxic, corrosive, asphyxiant or flammable gas into any Table H-2 room or area AND Entry into the room or area is prohibited or IMPEDED (Note 5) Note 5: 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. Table H-2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux. Building El -5'6" West Area Aux. Building El -5'6" East Near SFP Cooling Aux. Building El 14'6" B51 & B61 Enclosures 3 Aux. Building El 14'6" Boric Acid Batching Tank Aux. Building El -25'6" RB HxArea Enc. Building El -5'6" East Pipe Penetration Aux. Building El 14'6" By B61 Enc. Building El -45'6" "A" & "B ESF Rooms 3,4 Aux. Building El -45'6" General Area Enc. Building El -5'6" West Pipe Penetration 3,5 Aux. Building El 14'6" SE Across From MCC B51 4 Aux. Building El -5'6" VCT Block Wall Area 5 Enc. Building El -45'6" "A" ESF Room Mode Applicability: 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown Definition(s): JMPEDE(D) - Personnel access to a room or area is hindered to an extent that 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).

                                                   ~ Page 202 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Basis: This IC addresses an event involving a release of a hazardous gas that precludes or IMPEDES access to equipment necessary to maintain normal plant operation, or required for a normal plant cooldown and shutdown. This condition represents an actual or potential substantial degradation of the level of safety of the plant. An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release. Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency DirectorDSEO/ADTS'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.
If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact beyond that already allowed by Technical Specifications at the time of the event.

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death. This EAL does not apply to firefighting activities that generate smoke and that automatically or manually activate a fire suppression system in an area , or to intentional inerting of containment (BVVR only). Escalation of the emergency classification level would be via Recognition Category AR, M, C or F ICs. Page 203 of 259

MiUstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Reference(s):

1. Attachment 2, "Safe Operation & Shutdown Areas Tables A-3 & H-2 Bases"

2. NEI 99-01 HA5 Page 204 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 6 - Control Room Evacuation Initiating Condition: Control Room evacuation resulting in transfer of plant control to alternate locations EAL: HA6.1 Alert An event has resulted in plant control being transferred from the Control Room to the Hot Shutdown Panel (C-21) or Fire Shutdown Panel (C-10) Mode Applicability: All Definition(s): None 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. Transfer of plant control begins when the last licensed operator leaves the Control Room. Control will be established at Hot Shutdown Panel C-21 if the Control Room was evacuated for reasons other than a fire or smoke. Control will be established at Fire Shutdown Panel C-10 if the Control Room was evacuated due to a fire or smoke (ref. 1, 2). Escalation of the emergency classification level would be via IC HS6. Reference(s):

1. AOP 2551, "Shutdown from Outside the Control Room"

2. AOP 2579A, "Fire Procedure for Hot Standby Appendix R Fire Area R-1"

3. NEI 99-01 HA6 Page 205 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 6 - Control Room Evacuation Initiating Condition: Inability to control a key safety function from outside the Control Room EAL: HS6.1 Site Area Emergency An event has resulted in plant control being transferred from the Control Room to the Hot Shutdown Panel (C-21) or Fire Shutdown Panel (C-10) AND Control of any of the following key safety functions is not re-established within 15 min. of the last licensed operator leaving the Control Room (Note 1):

Reactivity (modes 1,* 2 and 3 only)
Core cooling
RCS heat removal Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Mode Applicability: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling Definition(s): None Basis: This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to.-gain control of a key safety function following a transfer of plant control to alternate locations is a precursor to a challenge to one or more fission product barriers within a relatively short period of time. The determination of whether or not "control" is established at the remote safe shutdown location(s) is based on Emergency DirectorDSEO/ADTS judgment. The Emergency DirectorDSEO/ADTS is expected to make a reasonable, informed judgment within 15 (the site specific time for transfer) minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s). Transfer of plant control and the time period to establish control begins when the last licensed operator leaves the Control Room. Control will be established at Hot Shutdown Panel C-21 if the Control Room was evacuated for reasons other than a fire or smoke. Control will be established at Fire Shutdown Panel C-10 if the Control Room was evacuated due to a fire or smoke (ref. 1, 2). Page 206 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Establishment of the reactivity safety function is only applicable in Modes 1. 2 and 3. Sufficient shutdown margin has already been established once in modes 4, 5 and 6 (ref. 3). Escalation of the emergency classification level would be via IC FG1 or CG1 Reference(s):

1. AOP 2551, "Shutdown from Outside the Control Room"

2. AOP 2579A, "Fire Procedure for Hot Standby Appendix R Fire Area R-1"

3. NRC EP FAQ 2015-014

4. NEI 99-01 HS6 Page 207 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - DSEO/ADTS Judgment Initiating Condition: Other conditions existing that in the judgment of the DSEO warrant declaration of an Unusual Event EAL: HU7.1 Unusual Event Other conditions exist which, in the judgment of the DSEO, 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. Mode Applicability: All Definition(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 (as defined in 10CFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. 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 DirectorDSEO to fall under the emergency classification level description for an Unusual EventNOUE. Reference(s):

1. NEI 99-01 HU7 Page 208 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - DSEO/ADTS Judgment Initiating Condition: Other conditions exist that in the judgment of the DSEO/ADTS warrant declaration of an Alert EAL: HA7.1 Alert Other. conditions exist which, in the judgment of the DSEO/ADTS, 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. Mode Applicability: All Definition(s): 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 MPS 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 MPS. 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). OWNER CONTROLLED AREA - The area within the SITE BOUNDARY including the PROTECTED AREA. PROJECTILE -An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety. PROTECTED AREA - The area within the Millstone Power Station security fence. 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 DirectorDSEO/ADTS to fall under the emergency classification level description for an Alert. Reference(s):

1. NEI 99-01 HA?

Page 209 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - DSEO/ADTS Judgment Initiating Condition: Other conditions existing that in the judgment of the DSEO/ADTS warrant declaration of a Site Area Emergency EAL: HS7 .1 Site Area Emergency

Other conditions exist which in the judgment of the DSEO/ADTS 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 Mode Applicability: All Definition(s): 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 MPS 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 MPS. 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). OWNER CONTROLLED AREA - The area within the SITE BOUNDARY including the PROTECTED AREA. PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for it~ continued operability, reliability, or personnel safety. SITE BOUNDARY - That line beyond which the land is not owned, leased or otherwise controlled by MPS. Also see OWNER CONTROLLED AREA. 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 DirectorDSEO/ADTS to fall under the emergency classification level description for a SITE AREA EMERGENCY. Reference(s):

1. NEI 99-01 HS7 Page 210 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - DSEO/ADTS Judgment Initiating Condition: Other conditions exist that in the judgment of the DSEO/ADTS warrant declaration of a General Emergency EAL: HG7 .1 General Emergency Other conditions exist which in the judgment of the DSEO/ADTS 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. Mode Applicability: All Definiti'on(s): HOSTAGE -A person(s) held as leverage against the station to ensure that demands will be met by the station. , 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 MPS 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 MPS. 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). OWNER CONTROLLED AREA - The area within the SITE BOUNDARY including the PROTECTED AREA. PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety. PROTECTED AREA - The area within the Millstone Power Station security fence. 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 DirectorDSEO/ADTS to fall under the emergency classification level description_ for a GENERAL EMERGENCY. Page 211 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Reference{s):

1. NEI 99-01 HG7 Page 212 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category M - System Malfunction EAL Group: Hot Conditions (RCS temperature > 200°F); EALs in this category are applicable only in one or more hot operating modes. Numerous system-related equipment failure events that warrant emergency classification have been identified in this category. They may pose actual or potential threats to plant safety. The events of this category pertain to the following subcategories:

1. Loss of Emergency AC Power Loss of emergency plant electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite power sources for 4.16 KV emergency buses.

2. Loss of Vital DC Power Loss of emergency plant electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of power to or degraded voltage on the 125V DC vital buses.

3. Loss of Control Room Indications Certain events that degrade plant operator ability to effectively assess plant conditions within the plant warrant emergency classification. Losses of indicators are in this subcategory.

4. RCS Activity During normal operation, reactor coolant fission product activity is very low. Small concentrations of fission products in the coolant are primarily from the fission of tramp uranium in the fuel clad or minor perforations in the clad itself. Any significant rise from these base-line levels (2% - 5% clad failures) is indicative of fuel failures and is covered under the Fission Product Barrier Degradation category. However, lesser amounts of clad damage may result in coolant activity exceeding Technical Specification limits. These fission products will be circulated with the reactor coolant and can be detected by coolant sampling. * *

5. RCS Leakage I

The reactor vessel provides a volume for the coolant that covers the reactor core. The reactor pressure vessel and associated pressure piping (reactor coolant system) together provide a barrier to limit the release of radioactive material should the reactor fuel clad integrity fail. Excessive RCS leakage greater than Technical Specification limits indicates potential pipe cracks that may propagate to an extent threatening fuel clad, RCS and containment integrity. Page 213 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28

6. RPS Failure This subcategory includes events related to failure of the Reactor Protection System (RPS),

to initiate and complete reactor trips. In the plant licensing basis, postulated failures of the RPS to complete a reactor trip comprise a specific set of analyzed events referred to as Anticipated Transient Without Scram (ATWS) events. For EAL classification, however, A TWS is intended to mean any scram failure event that does not achieve reactor shutdown. If RPS actuation fails to properly result in reactor shutdown, positive control of reactivity is at risk and could cause a threat to fuel clad, RCS and containment integrity.

7. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.

8. Containment Failure Failure of containment isolation capability (under conditions in which the containment is not currently challenged) warrants emergency classification. Failure of containment pressure control c;:apability also warrants emergency classification.

9. Hazardous Event Affecting Safety Systems Various natural and technological events that result in degraded plant safety system train performance or significant VISIBLE DAMAGE warrant emergency classification under this subcategory.

Page 214 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: M - System Malfunction Subcategory: 1 - Loss of Emergency AC Power Initiating Condition: Loss of all offsite AC power capability to emergency buses for 15 minutes or longer EAL: MU1.1 Unusual Event Loss of all offsite AC power capability, Table M-1, to 4.16 kV emergency buses 24C and 240 for >15 min. (Note 1) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. SU3.1 Table M-1 AC Power Sources Offsite

Unit 2 Reserve Station Service Transformer (RSST)
Unit 2 Normal Station Service Transformer (NSST)
Unit 3 Normal Station Service Transformer (NSST) via Buses 34A/B to Unit 2 emergency bus 24E (if already aligned)
Unit 3 Reserve Station Service Transformer (RSST) via Buses 34A/B to Unit 2 emergency bus 24E (if already aligned)

Onsite

Diesel Generator 15G-12U
Diesel Generator 15G-13U
SBO Diesel Generator (if already aligned)

Mode Applicability: 1 - Power Operation, 2 -Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s): None Basis: Table M-1 provides a list of offsite AC electrical power sources credited for this EAL. The offsite AC power sources annotated "(if already aligned)" require more than 15 minutes to establish and therefore are only credited if the source was already aligned at the time of AC power loss. 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.

                                              .Page 215 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B 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 SMMA 1. Under normal conditions, four 345 kV lines will be in service to connect the Millstone Station to the main electric system. The emergency buses powering equipment for safe shutdown are 4.16 kV emergency buses 24C (A3), 24D (A4 ), and 24E (AS). 4.16 kV emergency bus 24E (AS) may be fed from either 24C or 24D. The associated 480 V emergency buses are 22E (fed from 24C) and 22F (fed from 24D). MPS2 has the following methods available to provide power to the 4.16 kV emergency buses (ref. 1, 2, 3):

The Normal Station Service Transformer (NSST). During normal power operation, power is supplied to buses 24A (A 1) and 248 (A2). Bus ties connect to 4.16 kV emergency buses 24C (A3) and 24D (A4 ). Additionally, the NSST may be used during shutdown and when maintenance is being performed on the Reserve Station Service Transformer by removing links for the main generator and providing power through the 15G-8T-2 or 15G-9T-2 breakers.
The Unit 2 Reserve Station Service Transformer (RSST). This is the connection to the utility system for the preferred power supply. During other periods, such as startup and shutdown when the NSST is not used, power is supplied from the Unit 2 RSST directly to 4.16 kV emergency buses 24C (A3) and 24D (A4).
Diesel Generator 15G-12U(H7A) supplying 4.16 kV emergency bus 24C(A3).
Diesel Generator 15G-13U(H78) supplying 4.16 kV emergency bus 24D(A4).
Unit 3 supplying power through bus 34A/34B to emergency bus 24E. This is controlled by procedure. However, there are power limitations when using this method to supply MPS2 buses when Millstone 3 bus 34A/34B is being used.

Reference(s):

1. Technical Specifications Section 3.8.1.2, "Electrical Power Systems Shutdown"

2. UFSAR Section 8.2, "4160-Volt and 6900-Volt Systems"

3. UFSAR Section 8.3, "Emergency Generators"

4. AOP 2580, "Degraded Voltage"

5. AOP 2583, "Loss of All AC Power During Shutdown Conditions"

6. Dwg. No. 25203-30004, "Millstone Nuclear Power Station - Unit No. 2 Single Line Meter &

Relay Diagram 4.16 kV Buses 24A & 248 (A 1 &A2)"

7. Dwg. No. 25203-30005, "Millstone Nuclear Power Station - Unit No. 2 Single Line Meter &

Relay Diagram 4.16 kV Emergency Buses 24C, 24D (A3, A4 )"

8. NEI 99-01 SU1 Page 216 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: M - System Malfunction Subcategory: 1 - Loss of Emergency AC Power Initiating Condition: Loss of all but one AC power source to emergency buses_ for 15 minutes or longer EAL: MA1.1 Alert AC power capability, Table M-1, to 4.16 kV emergency buses 24C and 240 reduced to a single power source for >15 min. (Note 1) AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Table M-1 AC Power Sources Offsite

Unit 2 Reserve Station Service Transformer (RSST)
Unit 2 Normal Station Service Transformer (NSST)
Unit 3 Normal Station Service Transformer (NSST) via Buses 34A/B to Unit 2 emergency bus 24E (if already aligned) ,
Unit 3 Reserve Station Service Transformer (RSST) via Buses 34A/B to Unit 2 emergency bus 24E (if already aligned)

Onsite

Diesel Generator 15G-12U
Diesel Generator 15G-13U
SBO Diesel Generator (if already aligned)

Mode Applicability: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s): 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 (as defined in 10CFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: Page 217 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. Basis: Table M-1 provides a list of offsite and onsite AC electrical power sources credited for this EAL. AC power sources annotated "(if already aligned)" require more than 15 minutes to establish and therefore are only credited if the source was already aligned at the time of AC power loss. The SBO Diesel Generator meets the definition for an Alternate AC power source per 10CFR50.2. 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 S-Y-4MU1. An "AC power source" is a source recognized in AOPs 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 generatorUnit 3.
A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being fed or 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 SS4MS1. This hot condition EAL is equivalent to the cold condition EAL CU2.1. Under normal conditions, four 345 kV lines will be in service to connect the Millstone Station to the main electric system. The emergency buses powering equipment for safe shutdown are 4.16 kV emergency buses 24C (A3), 240 (A4), and 24E (A5). 4.16 kV emergency bus 24E (A5) may be fed from either 24C or 240. The associated 480 V emergency buses are 22E (fed friom 24C) and 22F (fed from 240). MPS2 has the following methods available to provide power to the 4.16 kV emergency buses (ref. 1, 2, 3):

The Normal Station Service Transformer (NSST). During normal power operation, power is supplied to buses 24A (A 1) and 248 (A2). Bus ties connect to 4.16 kV emergency buses 24C (A3) and 240 (A4 ). Additionally, the NSST may be used during shutdown and when maintenance is being performed on the Reserve Station Service Transformer by removing links for the main generator and providing power through the 15G-8T-2 or 15G-9T-2 breakers.

Page 218 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28

The Unit 2 Reserve Station Service Transformer (RSST). This is the connection to the utility system for the preferred power supply. During other periods, such as startup and shutdown when the NSST is not used, power is supplied from the Unit 2 RSST directly to 4.16 kV emergency buses 24C (A3) and 240 (A4 ). *
Diesel Generator 15G-12U(H7A) supplying 4.16 kV emergency bus 24C(A3).
Diesel Generator 15G-13U(H78) supplying 4.16 kV emergency bus 24D(A4).
Unit 3 supplying power through bus 34A/34B to emergency bus 24E. This is controlled by procedure. However, there are power limitations when using this method to supply MPS2 buses when Millstone 3 bus 34A/34B is being used.

Reference( s ):

1. Technical Specifications Section 3.8.1.1, "Electrical Power Systems Operating"

2. UFSAR Section 8.2, "4160-Volt and 6900-Volt Systems"

3. UFSAR Section 8.3, "Emergency Generators"

4. AOP 2580, "Degraded Voltage"

5. Dwg. No. 25203-30004, "Millstone Nuclear Power Station - Unit No. 2 Single Line Meter &

Relay Diagram 4.16 kV Buses 24A & 248 (A 1 &A2)"

6. Dwg. No. 25203-30005, "Millstone Nuclear Power Station - Unit No. 2 Single Line Meter &

Relay Diagram 4.16 kV Emergency Buses 24C, 240 (A3, A4 )"

7. NEI 99-01 SA1 Page 219 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: M - System Malfunction Subcategory: 1 - Loss of Emergency AC Power Initiating Condition: Loss of all offsite power and all onsite AC power to emergency buses for 15 minutes or longer EAL: MS1 .1 Site Area Emergency Loss of all offsite and all onsite AC power to 4.16 kV emergency buses 24C and 24D for

>15 min. (Note 1)

Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Mode Applicability: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(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 (as defined in 10CFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. ' Basis: For this EAL credit can be taken for any AC power source that has sufficient capability to operate equipment necessary to maintain a safe shutdown condition, such as the Unit 3 SBO diesel or FLEX generators, provided it can be aligned within the 15 minute classification criteria. The SBO Diesel Generator meets the definition for an Alternate AC power source per 10CFR50.2. 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 AG4RG1, FG1 or SG4MG1. Page 220 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B This hot condition EAL is equivalent to the cold condition EAL CA2.1. Under normal conditions, four 345 kV lines will be in service to connect the Millstone Station to the main electric system. The emergency buses powering equipment for safe shutdown are 4.16 kV emergency buses 24C (A3), 240 (A4 ), and 24E (A5). 4.16 kV emergency bus 24E (A5) may be fed from either 24C or 240. The associated 480 V emergency buses are 22E (fed from 24C) and 22F (fed from 240). MPS2 has the following methods available to provide power to the 4.16 kV emergency buses (ref. 1, 2, 3):

The Normal Station Service Transformer (NSST). During normal power operation, power is supplied to buses 24A (A 1) and 248 (A2). Bus ties connect to 4.16 kV emergency buses 24C (A3) and 240 (A4 ). Additionally, the NSST may be used during shutdown and when maintenance is being performed on the Reserve Station Service Transformer by removing links for the main generator and providing power through the 15G-8T-2 or 15G-9T-2 breakers.
The Unit 2 Reserve Station Service Transformer (RSST). This is the connection to the utility system for the preferred power supply. During other periods, such as startup and shutdown when the NSST is not used, power is supplied from the Unit 2 RSST directly to 4.16 kV emergency buses 24C (A3) and 240 (A4).
Diesel Generator 15G-12U(H7A) supplying 4.16 kV emergency bus 24C(A3).
Diesel Generator 15G-13U(H78) supplying 4.16 kV emergency bus 24D(A4).
Unit 3 supplying power through bus 34A/34B to emergency bus 24E. This is controlled by procedure. However, there are power limitations when using this method to supply MPS2 buses when Millstone 3 bus 34A/34B is being used.

Reference(s):

1. Technical Specifications Section 3.8.1.1, "Electrical Power Systems Operating"

2. UFSAR Section 8.2, "4160-Volt and 6900-Volt Systems"

3. UFSAR Section 8.3, "Emergency Generators"

4. AOP 2580, "Degraded Voltage"

5. Dwg. No. 25203-30004, "Millstone Nuclear Power Station - Unit No. 2 Single Line Meter &

Relay Diagram 4.16 kV Buses 24A & 248 (A 1 &A2)"

6. Dwg. No. 25203-30005, "Millstone Nuclear Power Station - Unit No. 2 Single Line Meter &

Relay Diagram 4.16 kV Emergency Buses 24C, 240 (A3, A4 )"

7. NEI 99-01 SS1 Page 221 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: M -System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Prolonged loss of all offsite and all onsite AC power to emergency buses EAL: MG1 .1 General Emergency Loss of all offsite and all onsite AC power to 4.16 kV emergency buses 24C and 240 AND CETs > 1200°F Mode Applicability: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - 'Hot Shutdown Definition(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 EGGS. These are typically systems classified as safety-related (as defined in 10CFRS0.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. Basis: For this EAL credit can be taken for any AC power source that has sufficient capability to operate equipment necessary to maintain a safe shutdown condition. such as the Unit 3 SBO diesel or FLEX generators (ref. 1. 2. 3. 4). The SBO Diesel Generator meets the definition for an Alternate AC power source per 10CFR50.2. The SAMGs use a GET temperature of 1200 °F as an entry condition and the temperature indicative of a badly damaged core (ref. 5) This IC addresses a prolonged loss of all power sources to AC emergency buses that results in degraded core cooling. 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 eventually lead to a loss of one or more fission product barriers. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. Page 222 of 259

Millstone Power Station Unit 2 Serial No.. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B +Re-For extended loss of emergency bus AC power events that do not result in a breach of the RCS barrier, this 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 /\.rea Emergency will occur if it is pr9:iected that pmver cannot be restored to at least one AG 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 atso-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. Under normal conditions, four 345 kV lines will be in service to connect the Millstone Station to the main electric system. The emergency buses powering equipment for safe shutdown are 4.16 kV emergency buses 24C (A3), 240 (A4 ), and 24E (AS). 4.16 kV emergency bus 24E (AS) may be fed from either 24C or 240. The associated 480 V emergency buses are 22E (fed from 24C) and 22F (fed from 240). MPS2 has the following methods available to provide power to the 4.16 kV emergency buses (ref. 1, 2, 3):

The Normal Station Service Transformer (NSST). During normal power operation, power is supplied to buses 24A (A1) and 24B (A2). Bus ties connect to 4.16 kV emergency buses 24C (A3) and 240 (A4 ). Additionally, the NSST may be used during shutdown and when maintenance is being performed on the Reserve Station Service Transformer by removing links for the main generator and providing power through the 15G-8T-2 or 15G-9T-2 breakers.
The Unit 2 Reserve Station Service Transformer (RSST). This is the connection to the utility system for the preferred power supply. During other periods, such as startup and shutdown when the NSST is not used, power is supplied from the Unit 2 RSST directly to 4.16 kV emergency buses 24C (A3) and 240 (A4).
Diesel Generator 15G-12U(H7A) supplying 4.16 kV emergency bus 24C(A3).
Diesel Generator 15G-13U(H7B) supplying 4.16 kV emergency bus 24D(A4).
Unit 3 supplying power through bus 34A/34B to emergency bus 24E. This is controlled by procedure. However, there are power limitations when using this method to supply MPS2 buses when Millstone 3 bus 34A/34B is being used.

Reference(s):

1. Technical Specifications Section 3.8.1.1, "Electrical Power Systems Operating"

2. UFSAR Section 8.2, "4160-Volt and 6900-Volt Systems"

3. UFSAR Section 8.3, "Emergency Generators"

4. EOP 2530, "Station Blackout" Page 223 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28

5. SAMG 4211, "Phase 1 Initial Diagnosis"

6. Dwg. No. 25203-30004, "Millstone Nuclear Power Station - Unit No. 2 Single Line Meter &

Relay Diagram 4.16 kV Buses 24A & 248 (A 1 &A2)"

7. Dwg. No. 25203-30005, "Millstone Nuclear Power Station - Unit No. 2 Single Line Meter &

Relay Diagram 4.16 kV Emergency Buses 24C, 240 (A3, A4 )"

8. NEI 99-01 SG1 Page 224 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: M - System Malfunction Subcategory: 2 - Loss of Vital DC Power Initiating Condition: Loss of all vital DC power for 15 minutes or longer EAL: MS2.1 Site Area Emergency Indicated voltage is< 105 voe on both vital 125 voe buses 201AAND 2018 for >15 min. (Note 1) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Mode Applicability: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(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 (as defined in 10CFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. Basis: The Vital (Class 1E) 125 V DC power system consists of two physically and electrically separated redundant buses - Bus 201 A and Bus 201 B. Each bus has a 60 cell battery bank with an eight-hour rating of 2300 amp-hours, with an operating range of 105 Volts to 140 Volts. In the event that either battery system is out of service, it is possible through interlocked circuit breakers to feed both battery buses from one battery. Each of the vital batteries supplies control logic, field flashing and breaker control for one diesel generator. They also supply power to a backup DC motor driven starting air compressor for each diesel generator, emergency lighting, turbine driven auxiliary feedwater pump (Terry Turbine) controls (bus 2018), and 125 VDC/120 VAC inverters for vital instrumentation. The four vital 120 VAC instrumentation panels power reactor protection, engineered safety features and vital instrumentation which is normally supplied by four physically isolated and electrically independent inverters, two of which are supplied by each of the two redundant batteries 201A and 201 B (ref. 1). Each.of the four vital instrumentation panels has an alternate power supply via a "zero break" static transfer switch. Vital 120 VAC instrumentation channels 1 and 2 can be fed from separate DC/AC inverters whose power source is the turbine battery (i.e. 201 D). Vital 120 VAC instrumentation channels 3 and 4 can be fed from one of the two regulated AC instrument power panels. Page 225 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B 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 AG4-RG1, FG1 or MG1-SGg.. This hot condition EAL equivalent of the cold condition EAL CU4.1 *. Reference(s):

1. UFSAR Section 8.5, "Battery System"

2. NEI 99-01 SS8

( Page 226 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: M -System Malfunction Subcategory:

2 - Loss of Vital DC Power Initiating Condition: Loss of all emergency AC and vital DC power sources for 15 minutes or longer EAL:

MG2.1 General Emergency Loss of all offsite and all onsite AC power to 4.16 kV emergency buses 24C and 240 for

~15 min. (Note 1)

AND Indicated voltage is < 105 VDC on both vital 125 VDC buses 201 A AND 201 B for

~15 min. (Note 1)

Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely ~e exceeded. Mode Applicability: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(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 (as defined in 10CFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. Basis: This IC addresses a concurrent and prolonged loss of both emergency AC and vital DC power. A loss of all emergency 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 emergency AC and vital DC power will lead to multiple challenges to fission product barriers. For this EAL credit can be taken for any AC power source that has sufficient capability to operate equipment necessary to maintain a safe shutdown condition. such .as the Unit 3 SBO diesel or FLEX generators. provided it can be aligned within the 15 minute classification criteria {ref. 1. 2. 3. 4). Page 227 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 The SBO Diesel Generator meets the definition for an Alternate AC power source per 10CFR50.2. The Vital (Class 1 E) 125 V DC power system consists of two physically and electrically separated redundant buses - Bus 201A and Bus 2018. Each bus has a 60 cell battery bank with an eight-hour rating of 2300 amp-hours, with an operating range of 105 Volts to 140 Volts. In the event that either battery system is out of service, it is possible through interlocked circuit breakers to feed both battery buses from one battery. Each of the vital batteries supplies control logic, field flashing and breaker control for one diesel generator. They also supply power to a backup DC motor driven starting a'ir compressor for each diesel generator, emergency lighting, turbine driven auxiliary feedwater pump (Terry Turbine) controls (bus 201 B), and 125 VDC/120 VAC inverters for vital instrumentation. The four vital 120 VAC instrumentation panels power reactor protection, engineered.safety features and vital instrumentation which is normally supplied by four physically isolated and electrically independent inverters, two of which are supplied by eacti of the two redundant batteries 201 A and 201 B (ref. 5). Each of the four vital instrumentation panels has an alternate power supply via a "zero break" static transfer switch. Vital 120 VAC instrumentation channels 1 and 2 can be fed from separate DC/AC inverters whose power source is the turbine battery (i.e. 2010). Vital 120 VAC instrumentation channels 3 and 4 can be fed from one of the two regulated AC instrument power panels. 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 both EAL thresholds are met. Under normal conditions, four 345 kV lines will be in service to connect the Millstone Station to the main electric system. The emergency buses powering equipment for safe shutdown are 4.16 kV emergency buses 24C (A3), 240 (A4 ), and 24E (AS). 4.16 kV emergency bus 24E (AS) may be fed from either 24C or 240. The associated 480 V emergency buses are 22E (fed from 24C) and 22F (fed from 240). MPS2 has the following methods available to provide power to the 4.16 kV emergency buses (ref. 1, 2, 3):

The Normal Station Service Transformer (NSST). During normal power operation, power is supplied to buses 24A (A 1) and 248 (A2). Bus ties connect to 4.16 kV emergency buses 24C (A3) and 240 (A4). Additionally, the NSST may be used during shutdown and when maintenance is being performed on the Reserve Station Service Transformer by removing links for the main generator and providing power through the 15G-8T-2 or 15G-9T-2 breakers.
The Unit 2 Reserve Station Service Transformer (RSST). This is the connection to the utility system for the preferred power supply. During other periods, such as startup and shutdown when the NSST is not used, power is supplied from the Unit 2 RSST directly to 4.16 kV emergency buses 24C (A3) and 240 (A4 ).
Diesel Generator 15G-12U(H7A) supplying 4.16 kV emergency bus 24C(A3).
Diesel Generator 15G-13U(H7B) supplying 4.16 kV emergency bus 24D(A4 ).
Unit 3 supplying power through bus 34A/34B to emergency bus 24E. This is controlled by procedure. However, there are power limitations when using this method to supply MPS2 buses when Millstone 3 bus 34A/34B is being used.

Page 228 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Reference(s):

1. Technical Specifications Section 3.8.1.1, "Electrical Power Systems Operating"

2. UFSAR Section 8.2, "4160-Volt and 6900-Volt Systems"

3. UFSAR Section 8.,3 "Emergency Generators"

4. EOP 2530, "Station Blackout"

5. UFSAR Section 8.5, "Battery System"

6. Dwg. No. 25203-30004, "Millstone Nuclear Power Station - Unit No. 2 Single Line Meter &

Relay Diagram 4.16 kV Buses 24A & 24B (A 1 &A2)"

7. Dwg. No. 25203-30005, "Millstone Nuclear Power Station - Unit No. 2 Single Line Meter &

Relay Diagram 4.16 kV Emergency Buses 24C, 240 (A3, A4)"

8. NEI 99-01 SGS Page 229 of 259

Millstone Power Station Unit 2

Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: M - System Malfunction Subcategory: 3 - Loss of Control Room Indications Initiating Condition: UNPLANNED loss of Control Room indications for 15 minutes or longer EAL:

MU3.1 Unusual Event An UNPLANNED event results in the inability to monitor one or more Table M-2 parameters from within the Control Room for >15 min. (Note 1) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded .

                             . 1  Table M-2 Safety System Parameters

Reactor power
RCS level
RCS pressure
CET temperature
Level in at least one SG
Auxiliary feedwater flow to at least oneSG Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(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 (as defined in 10CFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result

      . in potential offsite exposures.

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. Page 230 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Basis: Applicable safety system parameters are listed in Table M-2. The Plant Process Computer System and Safety Parameter Display System (SPDS) serve as redundant indicators which may be utilized as compensatory measures in lieu of the Control Room indicators associated with safety functions (ref. 1. 2). 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 one or more 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.

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 [PV'IR] I RPV level [BV1/R] and RCS heat removal. The loss of the ability to determine one or more 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 one or more 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 [PVVR] / RPVRCS water level [BVVR] 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 MA~. Reference(s):

1. UFSAR Section 7.5, "Instrumentation System"

2. AOP 2518, "Loss of Plant Process Computer

3. NEI 99-01 SU2 Page 231 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: M - System Malfunction Subcategory: 3 - Loss of Control Room Indications Initiating Condition: UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress EAL: MA3.1 Alert An UNPLANNED event results in the inability to monitor one or more Table M-2 parameters from within the Control Room for ~15 min. (Note 1) AND Any significant transient is in progress, Table M-3 Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Table M-2 Safety System Parameters

Reactor power
RCS level
RCS pressure
CET temperature
Level in at least one SG
Auxiliary feedwater flow to at least oneSG Table M-3 Significant Transients
Electrical load rejection > 25% full electrical load
Reactor Trip
SIAS actuation Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(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 (as defined in 10CFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: Page 232 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47. Emergency Action Level Technical Bases Enclosure 3; Attachment 28 (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. 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. Basis: Applicable safety system parameters are listed in Table M-2. Significant transients are listed in Table M-3. The Plant Process Computer System and Safety Parameter Display System (SPDS) serve as redundant indicators which may be utilized as compensatory measures in lieu of the Control Room indicators associated with safety functions (ref. 1, 2). 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 one or more 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. 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 decisi?n-making. This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling [Pv1/R] I RPV level [BV'IR] and RCS heat removal. The loss of the ability to determine one or more 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 one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SY$TEM parameters may be impacted as well. For example, if the value for reactor vessel level [PV'/R] / RPVRCS water level [BV'IR] 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. Page 233 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B 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 AS1 RS1 Reference(s):

1. UFSAR Section 7.5, "Instrumentation System"

2. AOP 2518, "Loss of Plant Process Computer"

3. NEI 99-01 SA2 Page 234 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: M - System Malfunction Subcategory: 4 - RCS Activity Initiating Condition: RCS activity greater than'Technical Specification allowable limits EAL: MU4.1 Unusual Event Dose rate at 1 ft. from an unpressurized RCS sample ~Table M-4 Table M-4 Tech. Spec. Coolant Activity Dose Rates Time > Shutdown (hrs) mR/hr/ml

2 0.7

                          >2- ::;8                           0.5
                              >8                             0.3 Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s): None 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. Per Engineering Calculation RA-0059, dose rate is assumed to result from radioactive iodines {1-131 thru 1-135) in RCS in concentrations corresponding to 60 µCi/gm DEl-131. This value corresponds to the Technical Specification coolant activity limit for iodine spike at full power operations. The values contained in Table M-4 (Tech. Spec. Coolant Activity Dore Rates) represent expected one foot dose rates per ml of sample based on time since reactor shutdown to the time when the sample is taken. Time after shutdown values are provided to account for radioactive decay. The expected dose rate is a near linear relationship with the volume of the sample. so any volume collected can be determined by dividing the measured dose rate by the sample volume and comparing to the threshold value from Table M-4 for the applicable time frame. These dose rates assume no emergency core cooling system (ECCS) injection so there is no dilution credited which would vary coolant volume. Values in the table have been rounded for ease of use. The > 8 hour threshold is conservative up to 24 hours following reactor shutdown. After 24 hours, the expected response from radioactive iodine levels off. Therefore. the value shown for > 8 hours applies for all samples taken 8 hours or more since reactor shutdown. The values specified in Table M-4 were developed using a method to minimize error(+/-) for the threshold value within each defined time period. Values were chosen to minimize error from the highest to lowest dose rate within each range. Page 235 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47

Emergency Action Level Technical Bases Enclosure 3; Attachment 2B It should be noted that this EALs is primarily directed toward mechanical damage to the clad not involving inadequate core cooling (ICC) sequences. Clad damage due to ICC sequences is addressed by the fuel clad and CTMT fission product barrier thresholds (Category F).

Escalation of the emergency classification level would be via ICs FA1 or the Reeognition Category A-R ICs. Reference(s):

1. RA-0059, "Detector Response to an RCS Sample for EAL Classification of Fuel Clad Degradation and Barrier Loss"

2. Technical Specification Section 3.4.8, "RCS Specific Activity"

3. AOP 2511, "High Activity in RCS"

4. NEI 99-01 SU3 Page 236 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: M - System Malfunction Subcategory: 4- RCS Activity Initiating Condition: Reactor coolant activity greater than Technical Specification allowable limits

EAL:

MU4.2 Unusual Event Sample analysis indicates that a reactor coolant activity value is > an allowable limit specified in Technical Specification 3.4.8 Mode Applicability: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown D.efinition(s): None 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. Escalation of the emergency classification level would be via ICs FA 1 or the Recognition Category A-B._ICs. Reference(s):

1. Technical Specification Section 3.4.8, "RCS Specific Activity"

2. AOP 2511, "High Activity in RCS"

3. NEI 99-01 SU3 Page 237 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: M - System Malfunction Subcategory: 5 - RCS Leakage Initiating Condition: RCS leakage for 15 minutes or longer EAL: MU5.1 Unusual Event RCS unidentified or pressure boundary leakage > 10 gpm for ~15 min. OR RCS identified leakage > 25 gpm for ~15 min. OR Leakage from the RCS to a location outside containment > 25 gpm for >15 min. (Note 1) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Mode Applicability: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s): UN/SOLABLE - An open or breached system line that cannot be isolated, remotely or locally. Basis: The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible. Once the RCS leak rate has been quantified to be greater than the specified value, failure to isolate the leak within 15 minutes, or if known that the leak cannot be isolated within 15 minutes, from the time of leak rate quantification, requires immediate classification. 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. The first and second EAL conditions EAL #1 and EAL #2 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). The third condition Ab

a-addresses an RCS mass loss caused by an UNISOLABLE leak through an interfacing system. These conditions EALs thus apply to leakage into the containment, a secondary-side system (e.g., steam generator tube leakage in a P'NR) or a location outside of containment.

The leak rate values for each condition Ab-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). The first condition EAL #1 uses a lower value that reflects the greater significance of unidentified or pressure boundary leakage. Page 238 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 The release of mass from the RCS due to the as-designed/expected operation of a relief valve does not warrant an emergency classification. For PVI/Rs, aAn emergency classification would be required if a mass loss is caused by a relief valve that is not functioning as designed/expected (e.g., a relief valve sticks open and the line flow cannot be isolated). -F-ef BVVRs, 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. Escalation of the emergency classification level would be via ICs of Recognition Category A-R or F. Reference(s):

1. Technical Specification Section 1.1, "Definitions"

2. Technical Specification Section 3.4.6, "RCS Operational Leakage"

3. AOP 2568, "Reactor Coolant Leakage'.'

4. NEI 99-01 SU4 Page 239 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: M - System Malfunction Subcategory: 6 - RPS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor EAL: MU6.1 Unusual Event An automatic trip did not shut down the reactor as indicated by reactivity control Safety Function Status Check acceptance criteria not met after any RPS setpoint is exceeded AND , A subsequent automatic trip or EITHER manual trip (RX TRIP TCBS BUTTONS OR MG Set Output Breakers (80505 and 80608)) are successful in shutting down the reactor as indicated by reactivity control Safety Function Status Check acceptance criteria met (Note 8) Note 8: A manual trip 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. Mode Applicability: 1 - Power Operation, 2 - Startup Definition(s): 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. Basis: This G--EAL addresses a failure of the RPS to initiate or complete an automatic or manual reactor (trip [Pl/1/R] I scram [Bl/1/R])that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic {trip [PL 11/R] I scram [Bll'/R]) (i.e., any subsequent RPS setpoint trip) 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. This EAL is applicable in Mode 2 as well as Mode 1 since the power level specified in the reactivity control Safety Function Status Check acceptance criteria is below the Mode 2 to Mode 1 transition power of 5% (ref. 1). Following the failure on an automatic reactor {trip[Pll'/R] I scram [BWR]), operators will promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor {trip[Pll'/R] I scram [Bll'/R]) by either pushing the RX TRIP TCBS buttons or tripping the MG Set Output Breakers (80505 AND 80608)). If either of 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. If an initial manual reactor (trip [PL 11/R] I scram [Bll'/R])is unsuccessful, operators \Viii promptly take manual action at another location(s) on the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor (trip[Pll'/R] I scram [BL11/R])) using a different switch). Depending upon several factors, the initial or subsequent effort to manually (trip [PL11/R] / scram Page 240 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 [BV'IR]) the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor (trip [PV'IR] I scram [BV1/R]) signal. If a subsequent manual or automatic (trip [PV1/R] I scram [BV'IR]) 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 consoles console (Panel C04) 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 {trip by either pushing the RX TRIP TCBS buttons or tripping the MG Set Output Breakers (B0505 AND B0608) [PV'IR] I scram [BV1/R])). This action does not include opening the reactor trip feeder breakers locally, 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 consoles". Taking the Reactor Mode Switch to SHUTDOVVN is considered to be a manual scram action. [BV'IR] The plant response to the failure of an automatic or manual reactor (trip[PVVR] / scram [BVVR]) 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 consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC SMMA6. Depending upon the plant response, escalation is also possible via IC FA 1. Absent the plant conditions needed to meet either IC Me-MA6 or FA1, an Unusual Event declaration is appropriate for this event. A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria (ref. 3, 4 ). Should a reactor {trip [PVVR] I scram [BVVR])signal be generated as a result of plant work (e.g., RPS setpoint testing), the following classification guidance should be applied.

If the signal causes a plant transient that should have included an automatic reactor {trip

[PVVR] / scram [BVVR])and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.

If the signal does not cause a plant transient and the {trip [PWR] / scram [BVVR])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.

In the event that the operator identifies a reactor trip is IMMINENT and initiates a successful manual reactor trip before the automatic RPS trip setpoint is reached, no declaration is required. The successful manual trip of the reactor before it reaches its automatic trip setpoint or reactor trip signals caused by instrumentation channel failures do not lead to a potential fission product barrier loss. However, if subsequent manual reactor trip actions* fail to shutdown the reactor, the event escalates to the Alert under EAL MA6.1. Reference(s):

1. Technical Specification Table 1.1, "Operational Modes"

2. Technical Specification Table 3.3-1, "Reactor Protective Instrumentation"

3. EOP 2525, "Standard Post Trip Actions" Page 241 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28

4. EOP 2526, "Reactor Trip Recovery"

5. NEI 99-01 SU5 Page 242 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: M - System Malfunction Subcategory: 6 - RPS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor. EAL: MU6.2 Unusual Event A manual trip (RX TRIP TCBS BUTTONS OR MG Set Output Breakers (B0505 and B0608)) did not shut down the reactor as indicated by reactivity control Safety Function Status Check acceptance criteria not met AND A subsequent manual trip OR automatic trip is successful in shutting down the reactor as indicated by reactivity control Safety Function Status Check acceptance criteria met (Note 8) Note 8: A manual trip 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. Mode Applicability: 1 - Power Operation, 2 - Startup Definition(s): None Basis: This G-EAL addresses a failure of the RPS to initiate or complete an automatic OF§ manual reactor ftrip [Pl/1/R] / scram [8111/R]) that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic ftrip[Pl/1/R] / scram [8111/R]) 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. Follov:ing the failure on an automatic reactor (trip[Pl/1/R] / scram [8111/R]), operators will promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor (trip[Pl/1/R] / scram [8111/R])). 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. This EAL is applicable in Mode 2 as well as Mode 1 since the power level specified in the reactivity control Safety Function Status Check acceptance criteria is below the Mode 2 to Mode 1 transition power of 5% (ref. 1). If an initial manual reactor ftrip[Pl/1/R] / scram [8111/R]) is unsuccessful, operators will promptly take manual action§ at another other location(s) eR-away from the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor ftrip[Pl/1/R] / scram [8111/R])) using a different svvitch!;!y opening the reactor trip feeder breakers locally) (ref. 3). However, those actions are not credited as a successful manual reactor trip for this EAL. Page 243 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Depending upon several factors, the initial or subsequent effort to manually {trip [PV'IR] I scram [BV'/R])the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor {trip [PV'IR] I scram [BV'/R])signal. If a subsequent manual or automatic {trip [PVIR] I scram [BV'/R])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 consoles (Panel C04) 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 {trip by pushing the RX TRIP TCBS buttons or tripping the MG Set Output Breakers (80505 AND 80608) [PV'IR] l scram [BV'/R])). This action does not include opening the reactor trip feeder breakers locally, 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 consoles". Taking the Reactor Mode Switch to SHUTDOVVN is considered to be a manual scram action. [BV'IR] The plant response to the failure of an automatic or manual reactor {trip [PWR] / scram [BVVR]) 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 consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC S/\5. Depending upon the plant response, escalation is also possible via IC FA 1. Absent the plant conditions needed to meet either IC SAa--MA6 or FA1, an Unusual Event declaration is appropriate for this event. A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria (ref. 3, 4 ). Should a reactor {trip [PVVR] / scram [BVVR]) signal be generated as a result of plant work (e.g., RPS setpoint testing), the following classification guidance should be applied.

If the signal causes a plant transient that should have included an automatic reactor {trip

[PVVR] / scram [BVVR]) and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.

If the signal does not cause a plant transient and the {trip [PVVR] / scram [BVVR]) 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.

Reference(s):

1. Technical Specification Table 1.1, "Operational Modes"

2. Technical Specification Table 3.3-1, "Reactor Protective Instrumentation"

3. EOP 2525, "Standc;!rd Post Trip Actions"

4. EOP 2526, "Reactor Trip Recovery"

5. NEI 99-01 SU5 Page 244 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: M - System Malfunction Subcategory: 2 - RPS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor EAL: MA6.1 Alert An automatic or manual trip (RX TRIP TCBS BUTTONS OR MG Set Output Breakers (B0505 and B0608)) did not shut down the reactor as indicated by reactivity control Safety Function Status Check acceptance criteria not met AND Subsequent automatic or manual trip actions (RX TRIP TCBS buttons AND MG Set Output Breakers (B0505 and B0608)) are not successful in shutting down the reactor as indicated by reactivity control Safety Function Status Check acceptance criteria not met (Note 8) Note 8: A manual trip 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. Mode Applicability: 1 - Power Operation, 2 - Startup Definition(s): None Basis: This .J.G-.EAL addresses a failure of the RPS to initiate or complete an automatic reactor trip or failure of a manual reactor {trip [PV1/R]./ scram [BV1/R]) that results in a reactor shutdown, and subsequent operator manual actions taken at the reactor control consoles 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 consoles since this event entails a significant failure of the RPS. This EAL is applicable in Mode 2 as well as Mode 1 since the power level specified in the reactivity control Safety Function Status Check acceptance criteria is below the Mode 2 to Mode 1 transition power of 5% (ref. 1). A manual action at the reactor control console (Panel C04) 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 {trip[PV1/R] / scram [BV1/R]) by pushing the RX TRIP TCBS buttons or tripping the MG Set Output Breakers (B0505 AND B0608)). This action does not include opening the reactor trip feeder breakers locally, 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 consoles (opening the Page 245 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 reactor trip feeder breakers locallye.g., locally opening breakers). Actions taken at back panels eF-other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the reactor control consoles". Taking the Reactor Mode S1.vitch to SHUTDOVVN is considered to be a manual scram action. [BvVR] The plant response to the failure of a~ automatic or manual reactor ftrip [PLAIR] l scram [BWR]) 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 shut_down the reactor is prolonged enough to cause a challenge to the core cooling [P'NR] / RPV water level [BVVR]or RCS heat removal safety functions, the emergency classification level will escalate to a Site Area Emergency via IC SMS§.a. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC SMS§.a 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. A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria (ref. 3, 4 ). Reference(s):

1. Technical Specification Table 1.1, "Operational Modes"

2. Technical Specification Table 3.3-1, "Reactor Protective Instrumentation"

3. EOP 2525, "Standard Post Trip Actions"

4. EOP 2526, "Reactor Trip Recovery"

5. NEI 99-01 SA5 Page 246 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: M - System Malfunction Subcategory: 2 - RPS Failure Initiating Condition: Inability to shut down the reactor causing a challenge to core cooling or RCS heat removal EAL: MS6.1 Site Area Emergency An automatic or manual trip. did not shut down the reactor as indicated by reactivity control Safety Function Status' Check acceptance criteria not met AND All actions taken to shut down the reactor are not successful as indicated by reactivity control Safety Function Status Check acceptance criteria not met AND EITHER:

CETs >1200°F
Applicable RCS and Core Heat Removal (HR) Safety Function Status Check acceptance criteria not met Mode Applicability:

1 - Power Operation, 2 - Startup Definition(s): None B~sis: This .J.G..EAL addresses a failure of the RPS to initiate or complete an automatic reactor trip or failure of a manual reactor ftrip [Pv'IR] l scram [Bl/1/R]) that results in a reactor shutdown, all subsequent operator actions to manually shutdown the reactor 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. This EAL is applicable in Mode 2 as well as Mode 1 since the power level specified in the reactivity control Safety Function Status Check acceptance criteria is below the Mode 2 to Mode 1 transition power of 5% (ref. 1). Reactor shutdown achieved by use of other actions such as opening supply breakers, emergency boration, or manually driving control rods are also credited for achieving a successful shutdown provided reactivity control Safety Function Status Check acceptance criteria are met before indications of an extreme challenge to either core cooling or heat removal exist. 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 Page 247 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B ICs/EALs do not address the additiona.1 threat posed by a failure to shut_down the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shut_down the reactor. A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria (ref. 3, 4). The SAMGs use a CET temperature of 1200 °F as an entry condition and the temperature indicative of a badly damaged core (ref. 7, 8). This reading indicates temperatures within the core are sufficient to cause significant superheating of reactor coolant. Failure to meet the applicable HR acceptance criteria indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e .. loss of an effective secondary-side heat sink). There are three defined and potentially applicable RCS and Core Heat Removal (HR) Safety Function Status Check acceptance criteria conditions (ref. 5. 6):

HR SG Heat Sink With No SI Operating
HR SG Heat Sink With SI Operating
HR Once-Through-Cooling Escalation of the emergency classification level would be via IC AG4-RG1 or FG1.

Reference( s):

1. Technical Specification Table 1.1, "Operational Modes"

2. Technical Specification Table 3.3-1, "Reactor Protective Instrumentation".

3. EOP 2525, "Standard Post Trip Actions"

4. EOP 2526, "Reactor Trip Recovery"

5. EOP 2540, "Functional Recovery"

6. EOP 25400, "Functional Recovery of Heat Removal"

7. SAMG 4211, "Phase 1 Initial Diagnosis"

8. MP-26-EPI-FAP11-001, "Core Damage Assessment: Core Exit Temperatures"

9. NEI 99-01 SS5 Page 248 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: M - System Malfunction Subcategory: 7 - Loss of Communications Initiating Condition: Loss of all onsite or offsite communications capabilities EAL: MU7.1 Unusual Event Loss of all Table M-5 onsite communication methods OR Loss of all Table M-5 State and local agency communication methods OR Loss of all Table M-5 NRC communication methods Table M-5 Communication Methods State/ System Onsite NRC Local ENRS/ARCOS X Station Radio System X X Plant Phone System X X Public Address System X .... Gaitronics / Maintenance Jacks X Federal Telephone System (ENS) X Commercial Telephone System X X Satellite Phones X X Dedicated Hotlines X Mode Applicability: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s): None Page 249 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Basis: This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to OROs State and local agencies 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.). The first EAL condition E/\L #1 addresses a total loss of the communications methods used in support of routine plant operations. The second EAL condition E/\L #2 addresses a total loss of the communications methods used to notify all OROs State and local agencies of an emergency declaration. The OROs State and local agencies referred to here are the State of Connecticut and local communities. (see Developer Notes) The third EAL EAL #3 addresses a total loss of the communications methods used to notify the NRG of an emergency declaration. This hot condition EAL is equivalent to the cold condition EAL CU5.1. Reference{s):

1. MPS Emergency Plan Section 7.9, "Communication Systems"

2. MP-26-EPI-FAPO?, "Notifications and Communications"

3. NEI 99-01 SU6 Page 250 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Emergency Action Level Technical Bases Enclosure 3; Attachment 2B Category: M - System Malfunction Subcategory: 8 - Containment Failure Initiating Condition: Failure to isolate containment or loss of containment pressure control EAL: I MU8.1 Unusual Event Any penetration is not closed within 15 min. of a VALID CIAS actuation signal OR CTMT pressure > 10 psig with < one full train of CTMT heat removal systems (Note 11) operating per design for ~15 min. (Note 1) Note 1: The DSEO/ADTS should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. Note 11: One full train of containment heat removal systems consist of one Containment Spray pump and two containment air recirculation units in the Containment Air Recirculation and Cooling System.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s): VALID -An indication, report, or condition, is considered to be valid wheri it is verified_ by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. Basis: This -IG-EAL addresses a failure of one or more containment penetrations to automatically isolate (close) when required by an actuation signal. It also addresses an event that results in high containment pressure with a concurrent failure of containment pressure control systems. Absent challenges to another fission product barrier, either condition represents potential degradation of the level of safety of the plant. For EAL #1the first condition, the containment isolation signal (CIAS) must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); a failure resulting from testing or maintenance does not warrant classification. The determination of containment and penetration status - isolated or not isolated - should be made in accordance with the appropriate criteria contained in the plant AOPs and EOPs. The 15-minute criterion is included to allow operators time to manually isolate the required penetrations, if possible. EAL #2The second condition addresses a condition where containment pressure is greater than the setpoint (9.48 psig rounded to 10 psig for readability) at which containment energy . (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design (ref. 1. 2). One full train of containment heat Page 251 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 removal systems consist of one Containment Spray pump and two containment air recirculation units. The combination of required equipment can be obtained from using equipment on either emergency bus in order to meet the "one full train" requirement (ref. 3). The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. The inability to start the required equipment indicates that containment heat removal/depressurization systems (e.g., containment sprays et= ice condenser fans) are either lost or performing in a degraded manner. This event would escalate to a Site Area Emergency in accordance with IC FS1 if there were a concurrent loss or potential loss of either the Fuel Clad or RCS fission product barriers. Reference{s):

1. UFSAR Section 6.4, "Containment Spray System"

2. UFSAR Section 7.3, "Engineered Safety Features Actuation System"

3. UFSAR Section 6.5, "Containment Air Recirculation and Cooling System"

4. NEI 99-01 SU?

Page 252 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 Category: M - System Malfunction Subcategory: 9 - Hazardous Event Affecting Safety Systems Initiating Condition: Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode EAL: MA9.1 Alert The occurrence of any Table M-6 hazardous event AND Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode AND EITHER:

Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode
Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 9, 10)

Note 9: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted. Note 10: 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.

Table M-6 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 DSEO/ADTS Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s): 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, Page 253 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 arcing, etc.) should not automatically be considered an explosion. Such events 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 fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed. FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area. 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 (as defined in 10CFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could re~ult in potential offsite exposures. 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. Basis: This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS needed 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 indications of degraded performance; 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 addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significantenough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train. VISIBLE DAMAGE addresses damage to a SAFETY SYSTEM train that is not in service/operation and that potentially could cause performance issues. Operators will make this determination 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 Page 254 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 1 Emergency Action Level Technical Bases Enclosure 3; Attachment 28 damage. This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train. This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, needed for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. E/\L 1.b.1 addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it 1.vill 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. E/\L 1.b.2 addresses damage to a SAFETY SYSTEM component that is not in service/operation or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components. Operators will make this determination 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. An event affecting equipment common to two or more trains of a safety system (i.e., there are indications of degraded performance and/or VISIBLE DAMAGE affecting the common equipment) should be classified as an Alert under this EAL, as appropriate to the plant mode. By affecting the functionality of multiple trains of a safety system, the loss of the common equipment effectively meets the two-train impact criteria that underlie the EALs and bases. An event affecting a single-train safety system (i.e., there are indications of degraded performance and/or VISIBLE DAMAGE affecting the one train) would not be classified under this EAL because the two-train impact criteria that underlie the EALs and bases would not be met. If an event affects a single-train safety system, then the emergency classification should be made based on plant parameters/symptoms meeting the EALs for another IC. Depending upon the circumstances, classification may also occur based on Shift Manager/DSEO/ADTS ,judgement. An event that affects two trains of a safety system (e.g., one train has indications of degraded performance and the other VISIBLE DAMAGE) that also has one or more additional trains should be classified as an Alert under this EAL. as appropriate to the plant mode. This approach maintains consistency with the two-train impact criteria that underlie the EALs and bases, and is warranted because the event was severe enough to affect the functionality of. two trains of a safety system despite plant design criteria associated with system and system train separation and protection. Such an event may have caused other plant impacts that are not immediately apparent. Escalation of the emergency classification level would be via IC FS1 or AS4RS1. This hot condition EAL is equivalent of the cold condition EAL CA6.1. Reference(s):

1. AOP 2560, "Storms, High Winds and High Tides"

2. AOP 2562, "Earthquake"

3. EP FAQ 2016-002 Page 255 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-4 7 Emergency Action Level Technical Bases Enclosure 3; Attachment 28

4. NEI 99-01 SA9 Page 256 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Safe Operation & Shutdown Rooms/Areas Tables R-2 & H-2 Bases Encl. 3: Att. 2B

Background

NEI 99-01 Revision 6 ICs M3 and HA5 prescribe declaration of an Alert based on IMPEDED access to rooms or areas (due to either area radiation levels or hazardous gas concentrations) where equipment necessary for normal plant operations, cooldown or shutdown is located. These areas are intended to be plant operating mode dependent. Specifically the Developers Notes for M3 and HA5 states: The "site-specific list of plant rooms or areas with entry-related mode applicability identified" should specify those rooms or areas that contain equipment which require a manual/local

action as specified in operating procedures used for normal plant operation, coo/down and shutdown. Do not include rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations). In addition, the list should specify the plant mode(s) during which entry would be required for each room or area.

The list should 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). Further, as specified in IC HA5: The list need not include the Control Room if adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas. Such features may include, but are not limited to, capability to draw air from multiple air intakes at different and separate locations, inner and outer atmospheric boundaries, or the capability to acquire and maintain positive pressure within the Control Room envelope. Page 257 of 259

Millstone Power Station Unit 2 - Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Attachment 2 Safe Operation & Shutdown Rooms/Areas Tables R-2 & H-2 Bases Encl. 3: Att. 2B MPS2 Table R-2 and H-2 Bases A review of station operating procedures identified the following mode dependent in-plant actions and associated areas that are required for normal plant operation, cooldown or shutdown: In-Plant Actions (MPS2) Safe Shutdown Area Modes AB El 14'6" BA Batching Tank Perform "Boration During Cooldown" AB El -5'6" West Area 3 AB El -45'6" General Area Commence SOC Preps: Align RB to SOC Reduce Non-Essential RB Loads Place In-Service RB Hx in "Summer Control Perform Line-up 2310-001 AB El -45'6" General Area Place Sl-306 in RC EB El -45'6" "A"&"B" ESF Rooms Open Sl-400 AB El -5'6" East Near SFP Cooling 3 Obtain SOC Boron AB El -25'6" RB Hx Area Commence Warmup & Pressurization EB El -5'6" East & West Piping Rooms Throttle LPSI Min Flow for Press. Control AB El 14'6" Near B61 Throttle RB for SOC Verify LPSI Suction Pressure Realign to RWST (if necessary) Close Sl-709 Install ClosinQ Coils for All SIT Isolation Valves AB El 14'6" B51 & B61 Enclosures 3 Pressure< 1400 psia, Place 2"0 letdown EB El -5'6" West Pipe Penetration Room 3 FCV/PCV Close 2-Sl-651 Disconnect AB El 14'6" SE Across From MCC B51 4 Initiate SOC: EB El -45'6" "A" ESF Room Close LRR-39 Vent EB El -45'6" "A"& "B" ESF Rooms Throttle Sl-444 or 432 EB El -45'6" "A"& "B" ESF Rooms Close Sl-444 or 432 4 EB El -45'6" "B" ESF Room Throttle LPSI Min. Flow AB El 14'6" Near B61 Close Sl-400 AB El -45'6" General Area Adjust Temp. EB El -5'6" West Pipe Penetration Room Establish Excess Letdown EB El -45'6" "A" ESF Room SW 5 AB El -5'6" VCT Block Wall Area Remove Gagging Device from 2-SI 468 EB El -5'6" West Area 5 Control Room ventilation systems have adequate engineered safety/design features in place to

preclude a Control Room evacuation due to the external release of a hazardous gas (UFSAR S~ction 9.9.11 ). Therefore, the Control Room is not included in this assessment or in Table H-2.

Ref:* OP 2201, "Plant Heatup" OP 2204, "Load Changes" OP 2206, "Redactor Shutdown" OP 2207, "Plant Cooldown" Page 258 of 259

Millstone Power Station Unit 2 Serial No. 18-364 Emergency Action Level Technical Bases Document Docket Nos. 50-336; 72-47 Safe Operation & Shutdown Rooms/Areas Tables R-2 & H-2 Bases Encl. 3: Att. 28 Table R-2 & H-2 Results Table R-2/H-2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux. Building El -5'6" West Area Aux. Building El -5'6" East Near SFP Cooling Aux. Building El 14'6" B51 & B61 Enclosures 3 Aux. Building El 14'6" Boric Acid Batching Tank Aux. Building El -25'6" RB HxArea

              . Enc. Building El -5'6"    East Pipe Penetration

Aux. Building El 14'6" By B61 Enc. Building El -45'6" "A" & "B" ESF Rooms 3,4 Aux. Building El -45'6" General Area Enc. Building El -5'6" West Pipe Penetration 3,5 Aux. Building El 14'6" SE Across From MCC B51 4 Aux. Building El -5'6" VCT Block Wall Area 5

Enc. Buildin_g El -45'6" "A" ESF Room Page 259 of 259}}

ML19011A171

Text

SUMMARY

SUMMARY

1.0 INTRODUCTION

4.0 REFERENCES

1.0 INTRODUCTION

4.0 REFERENCES

1.0 INTRODUCTION

4.0 REFERENCES

1.0 INTRODUCTION

4.0 REFERENCES

Background

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