ML19051A139

Attachment 3: Mark-ups of Callaway EAL Technical Bases Document Affected Pages

ML19051A139
Person / Time
Site:	Callaway
Issue date:	02/20/2019
From:	Ameren Missouri, Union Electric Co
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML19051A135	List: ML19051A137 ML19051A139 ML19051A140 ML19051A141 ULNRC-06488, Supplement and Response to Request for Additional Information Regarding License Amendment Request for Emergency Action Level (EAL) Changes
References
ULNRC-06488
Download: ML19051A139 (20)

Text

Attachment 3 to ULNRC-06488 Mark-ups of Callaway EAL Technical Bases Document Affected Pages (19 pages)

EIP-ZZ-00101 ADDENDUM 2 Rev.015 EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT 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 process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or hostile actions that result 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.

High Winds - Winds in excess of 40 mph (18 mis) sustained, or 58 mph (26 mis) gusting.

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 Callaway 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 destrnctive 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 Callaway. Non-terro1ism-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 - The trajectory of events or conditions is such that an EAL will be met within a relatively short pe1iod 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) - 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 - 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.

Page 20 of 241 INFORMATION USE

EIP-ZZ-00 lOl ADDENDUM 2 Rev.015 EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT Site Area Emergency - Events are in process or have occun-ed which involve actual or likely major failures of plant functions needed for protection of the public or hostile actions that result in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or* l2) 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 Guidelines expo ure levels beyond the site boundary.

Site Boundary - Exclusion Area Boundary is a synonymous term for Site Boundary. The Exclusion Area is defined as the area that encompasses the land surrounding the Plant to a radius of 1.200 meters (3 937 feet) from the midpoint of the Unit l Reactor Building and the canceled Unit 2 Reactor Building. Control of access to this is by virtue of ownership and in accordance with 10CFRlOO (ref. 4.1.12.

Unisolable - An open or breached system line that cannot be isolated, remotely or locally.

Unplanned - A parameter change or an event that is not l) 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 process 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 exi tence, or lhe report's accuracy is removed. Implicit in thi definition is the need for timely asse sment.

[Insert #2 here]

Page 22 of 241 INFORMATION USE

EfP-ZZ-00101 ADDENDUM 2 Rev. 015 EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT 6.0 CALLAWAY-TO-NEI 99-01 REV. 6 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of a Callaway EAL within the NE! 99-0 l IC/EAL identification scheme. Further information regarding the development of the Callaway EALs based on the NET guidance can be found in the EAL Comparison Matiix.

Callaway NEI 99-01 Rev. 6 Callaway NEI 99-01 Rev. 6 Caflaway NEl 99-01 Rev. 6 EAL JC Example EAL IC Example EAL IC Example EAL EAL EAL RU1.1 AU1 1, 2 CU5.1 CU5 1, 2, 3 HA5.1 HAS 1

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CG1.2 CG1 2

SU4.1 SU3 2

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SUB.1 SU7 1, 2 RG1.1 AG1 1

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Page 25 of 241 INFORMATION USE

.EIP-ZZ-00101 ADDENDUM 2 Rev. 015 EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT - Emergency Action Level Technical Bases The existence of "damage" i determined by radiological survey. The technical spedfication multiple of 2 times, which is also used in Recognition Category RIC RUl, 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 f

s r e t

• st n from Lhe cask.

I.

2. NEJ 99-01, E-HUl Page 69 of 241 INFORMATION USE

EJP-ZZ-OOJ O I ADDENDUM 2 Rev. 015 EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT - Emergency Action Level Technical Bases Category:

C - Cold Shutdown/ Refueling System Malfunction Subcategory:

6 - Hazardous Event Affecli.ng Safety Systems Initiating Condition:

Hazardous event affecting a SAFETY SYSTEM needed for the current operating MODE AND EITHER:

cture needed for the current operating MODE.

MODE Applicability:

Table C-6 Hazardous Events EXPLOSION FIRE HIGH WINDS or tornado strike Internal or external FLOODING event Seismic event (earthquake)

Other events wi1h similar hazard characteristics as determined by the Emergency Coordinator 5 - Cold Shutdown, 6 - Refueling Definition(s):

EXPLOSION - A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or over pressurization. A release of sleam (from high energy lines or components) or an electrical component failure cau ed by sbort 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 electrkal equipment do not constitute fires. Observation of flame is prefen-ed but is NOT required if large quantities of smoke and beat are observed.

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a iise of water level within the room or area.

HIGH WINDS - Winds in excess of 40 mph ( 18 mis) sustained, or 58 mph (26 mis) gusting.

Page 111 of 241 INFORMATION USE

EIP-ZZ-00101 ADDENDUM 2 Rev. 015 EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT - Emergency Action Level Technical Bases 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 safely-related as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional duting and following design basis events to assure:

I.

The integrity of the reaclor 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

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Annunciator 980 OBE will illuminate if the seismic instrument detects ground motion in excess of the OBE threshold. OTO-SG-00001, Seismic Event provides the guidance for determining if an OBE eartbqualce threshold is exceeded and any required response actions (ref. 1 ).

Internal FLOODING may be caused by events such as component failures, equipment misalignment, or outage activity mishaps (ref. 2).

External flooding may be due to high rainfall. Callaway plant grade elevation is 840.0 ft. MSL.

(ref. 3).

Seismic Category I structures are analyzed to withstand a sustained, design wind velocity of at least 100 mph. (ref. 4).

Areas containing functions and systems required for afe shutdown of the plant are identified by fire area (ref. 5).

The second conditional addresses damage component that is not in service/operation or readily apparent through indica

• alone, or to a structure contarn*1 SAFETY SYSTEM components.

Operators will maJce this d nation based on the totality of available even d damage report information. Thi i

• ended to be a brief assessment not requiring lengthy analysis uantification of the damage.

ation of the emergency classification level would be via IC CS I or RS 1.

[I nsert #6 here]

EIP-ZZ-00101 ADDENDUM 2 Rev. 015 EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT - Emergency Action Level Technical Bases Callaway Basis Reference(s):

1.

OTO-SG-00001, Seismic Event

2.

IPE Section 3.4.2.3 Results of the Vulnerability Screening

3.

FSAR, Section 3.4 Water Level (Flood) Design Table 3.4-1 PMF, Groundwater, Reference, and Actual Plant Elevations

4.

FSAR, Section 3.3.1.1 Design Wind Loadings

5.

FSAR, Section 9.5.1 Fire Protection System

6.

NEI 99-01, CA6 Page 113 of 241 INFORMATION USE

EIP-ZZ-00101 ADDENDUM 2 Rev. 015 EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT Category: - Emergency Action Level Technical Bases H - Hazards Subcategory:

I - Secmity Initiating Condition:

Confinned SECURITY CONDITION or threat EAL:

HUl.1 Unusual Event A SECURITY CONDITION that does not in olve a HOSTILE ACTION as reported by the Security Shrft Supervisor.

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

OR A validated notification from the NRC providing information of an aircraft tfaeat.

MODE Applicability:

All Definition(s):

SECURJ1Y CONDITION - Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk ro site personnel, or a potential degradation to the level of safety of the plant. A security condition does not involve a hostile action.

HOSTILE ACTION -An act toward Callaway or its personnel that include 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 Callaway.

Non-te1TOrism-based EALs should be used to address such activities (i.e. this may include violeot acts between individuals jn the owner controlled area).

Basis:

The secmity hift supervi ion is defined as the Security Shift Supervisor.

This EAL is based on the Callaway Plant Secmity Plan and DBT ref, 1 ).

Timely and accurate communications between Secmity r

p v 10 a 1

n ro oom 1s es ential for proper classification of a security-related event lref. 2, 3, 4. Classification of these event will initiate appropriate threat-related notifications to plant personnel and Offsite Response Organizations.

Page 115 of 241 INFORMATION USE

EIP-ZZ-00101 ADDENDUM 2 Rev. 015 EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT - Emergency Action Level Technical Bases As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures e.g., evacuation. dispersal or sheltering). The Site Area Emergency declaration will mobilize Offsite Response Organization (ORO) resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing muJtipJe safety functions.

This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from bunters, phy ical disputes between employees, etc. Repo1ting of these types of events is adequately addressed by other EAL or the requirements of 10 CFR 73.71 or 10 CFR 50.72.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive infonnation. This includes infomrnlion that may be advantageous to a potential adversaiy, such as the particulars concerning a specific threat or threat location. Secmity-sensitive information should b contained in non-public documents such as the Callaway Plant Security Plan and DBT

1.

Callaway Plant Security Plan and DBT (Safeguards)

2.

EIP-ZZ-SKOO l, Response to Security Threat

3.

SDP-CP-00003, Security Contingeucy Events

4.

OTO-SK-00001, Plant Security Event - Hostile Intrusion

5.

OTO-SK-00002 Plant Security Event - Aircraft Threat

6.

NEI 99-01 HS I Page 120 of 241 INFORMATION USE

EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT - Emergency Action Level Technical Bases H-Hazards I - Secutity HOSTILE ACTION resulting in Joss of physical control of the f EAL:

HGl.1 eneral Emergency A HOSTILE ACTION. occurring or has occu1Ted within the PROTEC the Security Shift Superv1

r.

AND EITHER of the folio

• g has occun-ed:

Any of the following s Reactivity control.

Core cooling.

RCS heat removal.

OR Damage to spent fuel has occmTed MODE Applicability:

All Defini tion(s):

HOSTILE ACTION - An act toward Calla ay or its personnel tha i11cludes the use of violent force to destroy equipment, take hostages, and/or intim.i ate the licensee to achieve end. This includes attack by air, land, or water using guns, explosives, proje iles vehicles, or other devices 1sed to deliver destructive force.

Other acts that satisfy the overall in nt may be included. Hostile action should not be construed to include acts of civiJ disobedience or felo *ous acts that are not part of a concerted. ttack on Callaway.

Non-tenmism-based EALs sho d be used to addres such activities i.e.. th may include violent acts between individuals in the o er controlled area).

IMMINENT-The trajecto of events or conditions is su h that an EAL will be t within a relatively short period of time regardles of mitigation or corrective actions.

PROTECTED ARE. - An area encompassed by physical baniers and to which access 1 controlled. The Protected Area rei *s to the designated security area around the process building and is picted in Drawing 8600-X-88 l 00 P, operty-Site Layout, Owner Controlled Area and Sun-ounding Area.

Page 121 of 241 INFORMATION USE

EIP-ZZ-00101 ADDENDUM EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT - Emergency Action Level Technical Bases ift supervision is defined as the Security Shift Supervisor.

This IC addresse an event in which a HOSTILE FORCE has taken phy ical control of the 5

extent that Lhe plan staff can no longer operate equipment necessary to maintain key sai functions. It also addresses a HOSTIL ACTION leading to a loss of physical control that results in actl I or IMMINENT damage to spent fuel d to 1) damage to a spent fuel pool cooling system (e.g., pum s, heat exchangers, controls, etc.) or, 2) loss spent fuel pool integrity such that sufficient water level annot be maintained.

Timely and accurate commu

• cations between Security Shjft Supervision and t Control Room is essential for proper classification of a se urity-related event (ref. 2, 3).

Security plans and terminology ar based on the guidance provided by Plan, Training and Qualification Pia, Safeguards Contingency Plan an Installation Security Program.

~ 03-12, Template for the Security ndependent Spent Fuel Storage Emergency plans and implementing proc ures are public docume ts; therefore, EALs should not incorporate Security-sensitive infmmation.

his includes infor

• tion that may be advantageous to a potential adversary, such as the particulars co1 eming a speci *c threat or tlu*eat location. Security-sensitive information should be contained in non-public cuments s h as the Callaway Plant Security Plan & DBT (ref.I).

Callaway Basis Reference(s):

1.

Callaway Plant Security Plan and DBT (Safe

2.

EIP-ZZ-SKOOl, Response to Secmity Thr t

3.

SDP-CP-00003, Security Contingency

4.

OTO-SK-00001, Plant Security Eve - Hostile Intrusion

5.

OTO-SK-00002, Plant Security

6.

NEI 99-01, HG I Page I 22 of 241

EIP-ZZ-00101 ADDENDUM 2 Rev. 015 EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT - Emergency Action Level TechnicaJ Bases Category:

Subcategory:

Initiating Condition:

AND EITHER:

MODE Applicability:

S - System Malfunction 9 - Hazardous Event Affecting Safety Systems Hazardous event affecting a SAFETY SYSTEM needed for the current operating MODE Table S-5 Hazardous Events EXPLOSION FIRE HIGH WINDS or tornado strike Internal or external FLOODING event Seismic event (earthquake)

Other events with similar hazard characteristics as determined by the Emergency Coordinator I - 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 over pressurization. A release of steam (from high energy lines or components) or an electiical 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 beat and light. Sources of smoke such as slipping drive belts or overheated elecuical equipment do not constitute fires. Observ~1tion of flame i preferred but is NOT required if large quantities of smoke and beat are observed.

FLOODING-A condition where water is enter.ing a room or area faster than installed equipment is capable of removal, resulting in a tise of water level within the room or area.

HIGH WINDS - Winds in excess of 40 mph ( 18 mis sustained, or 58 mph (26 mis gusting.

Page 188 of 241 INFORMATION USE

EIP-ZZ-00101 ADDENDUM 2 Rev. 015 EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT - Emergency Action Level Technical Bases SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in Lhe Cold Shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in IOCFRS0.2):

Those sbuctures, systems and components that are relied upon to remain functional during and following design basis events to assure:

1.

The integrity of Lhe reactor coolant pressure boundary;

2.

The capability to shut down the reactor and maintain it in a safe shutdown condition;

3.

The capabi1Hy to prevent or mitigate the consequences of accidents which could result in potential CJ' to a component or structure that is readily observab easoremenfs.

The visual irn act of se concern regarding the operability Basis:

1'1-------1![lnsert #9 here]

Annunciator 980 OBE will illuminate if the seismic instrument detects ground motion in excess of the OBE threshold. OTO-SG-00001, Seismic Event provides the guidance for determining if an OBE earthquake d1seshold is exceeded and any required response actions (ref. 1 ).

Internal FLOODING may be caused by events such as component failures, equipment misalignment, or outage activity mishaps (ref. 2).

External flooding may be due to high lake level. Callaway plant grade elevation is 840.0 ft. MSL.

(ref. 3).

Seismic Category I struct11res are analyzed to withstand a sustained, design wind velocity of at least 100 mph. ref. 4).

Areas containing functions and systems required for safe shutdown of the plant are identified by fire area (ref. 5).

An explosion that degrades the performance of a SAFETY SYSTEM train or visibly damages a SAFETY SYSTEM component or strncture would be classified under this EAL.

A single FAULTED steam generator would NOT require declaration per th.is EAL. Technical Specification Ba es 3.7.4 explains that two intact Stearn Generators are required for cooldown of the RCS and a Lhfrd Stearn Generator is assumed to be RUPTURED. If more than one Steam Generator is FAULTED, then this l

Page 189 of 241 INFORMATION USE

EIP-ZZ-00101 ADDENDUM 2 Rev. 015 EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT Callaway Basis Reference(s):

1.

OTO-SG-00001 Seismic Event

2.

IPE Section 3.4.2.3 Results of the Vulnerability Screening

3.

FSAR, Section 3.4 Water Level (Flood) Design Table 3.4-1 PMF, Groundwater, Reference, and Actual Plant Elevations

4.

FSAR. Section 3.3.1.1 Design Wind Loadings

5.

FSAR, Section 9.5.l Fire Protection System

6.

NEI 99-0 I, SA9 Page 190 of 241 INFORMATION USE

b)

A required system redundant to the suppo1t system for the sup systems (a) and (b) above is also INOPERABLE.

Insert #2 Visible Damage - Damage to a SAFETY SYSTEM train that is readily observable without measurements, testing, or analysis. The visual impact oftbe damage is sufficient to cause concern regarding the operability or reliability of the affected SAFETY SYSTEM train.

Insert #3 CA6.1 AJert The occurrence of any Table C-6 hazardous event AND Event damage has caused indication of degraded performance on one train of a SAFffi SYSTEM needed for the current operating MODE AND EITHER:

Event damage bas caused indications of degraded performance in a second train of a SAFETY SYSTEM needed for the cmTent operating MODE.

Event damage has resulted in VISIBLE DAMAGE to a second train of a SAFETY SYSTEM needed for the current operating MODE.

(Notes JI, f l)

Note 11: lf the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then this emergency classification is not warranted.

Note 12: Jfthe hazardous event only results in VISIBLE DAMAGE, with no indication of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

a) b)

A required system re ant to the system in turn supported by the system is als PERABLE; OR quired system redundant to the support system for the supported systems (a) and is also INOPERABLE.

Insert #5 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.

Insert #6 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.

Operators will make a determination of VISIBLE DAMAGE based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage. This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

An event affecting equipment common to two or more safety systems or safety system trains (i.e.,

there are indications of degraded performance and/or VISIBLE DAMAGE affecting common equipment) should be classified as an Alert. By affecting the operability or reliability of multiple system trains, the loss of the common equipment effectively meets the two-train impact criteria that underlie the EALs and Bases. (For example, this guidance would apply to a unit with a tank that is the water source for multiple safety injection systems or trains, such as a Refueling Water Storage Tank.)

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. 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 operability or reliability 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. (For example, this guidance would apply to a unit that has an Auxiliary/Emergency Feedwater system with three trains.)

Escalation of the emergency classification level would be via ICs CSl or RSl.

Insert #7 SA9.1 AJert The occurrence of any Table S-5 hazardous event AND Event damage has caused indication 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 petformance in a second train of a SAFETY SYSTEM needed for the cmrent operating MODE.

Event damage has resulted in VISIBLE DAMAGE to a second train of a SAFETY SYSTEM needed for the cu1rnnt operating MODE.

(Nores 11, I 2)

Note 1 J: If the affected system train was already inoperable or out of service before the hazardous evelll occurred, then this emergency classification is not wan*anted.

No1e 12; If the hazardous event only results in VISIBLE DAMAGE, with no indication of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

function assumed In the accident a sis cannot be performed.

Determination Program, a LOSF may exist w a) b)

A required system undant to the system in turn supported by the IN system is OPERABLE; OR ulred system redundant to the support system for the supported systems (a) and (b) is also INOPERABLE.

Insert #9 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.

Insert #10 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.

Operators will make a determination of VISIBLE DAMAGE based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage. This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

An event affecting equipment common to two or more safety systems or safety system trains (i.e.,

there are indications of degraded performance and/or VISIBLE DAMAGE affecting common equipment) should be classified as an Alert. By affecting the operability or reliability of multiple system trains, the loss of the common equipment effectively meets the two-train impact criteria that underlie the EALs and Bases. (For example, this guidance would apply to a unit with a tank that is the water source for multiple safety injection systems or trains, such as a Refueling Water Storage Tank.)

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. 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 operability or reliability 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. (For example, this guidance would apply to a unit that has an Auxiliary/Emergency Feedwater system with three trains.)

Escalation of the emergency classification level would be via I Cs FSl or RSl.