ML20215M600

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Requests Review of Encl Emergency Action Levels to Identify Deficiencies to Provide Technical Assistance for NRC Emergency Preparedness Program.Response Requested within 45 Days of Ltr Date
ML20215M600
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 10/27/1986
From: Shafer W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Essig T
Battelle Memorial Institute, PACIFIC NORTHWEST NATION
References
NUDOCS 8611030051
Download: ML20215M600 (18)
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Text

{{#Wiki_filter:- OCT 271986 Docket No. '50-295; 50-304 MEMORANDUM FOR: Thomas Essig, Section Manager, Health Physics Technology Section, Radiological Science Department, Battelle Pacific Northwest Labs THRU: David Matthews, Chief, Emergency Preparedness Branch, Division of Emergency Preparedness and Engineering Response, 0IE FROM: W. D. Shafer, Chief, Emergency Preparedness and Radiological Safety Branch, Region III

SUBJECT:

REQUEST FOR TECHNICAL ASSISTANCE - NRC EMERGENCY PREPAREDNESS PROGRAM l PLANT NAME: Zion Station LICENSEE / APPLICANT: Commonwealth Edison EP REVIEWER: Tom Ploski Please take action as indicated. If you have any questions regarding the information, activity, or schedule, contact the reviewer whose name is shown above. This request has been cleared thru the NRC Headquarters program management office. I. Area of Review: 1. () Emergency Plan 2. () Dose calculation methodology 3. () Evacuation Time Estimates 4. (X) Emergency Action Levels 5. () Other: II. Information Supplied: 1. () Radiological Emergency Plan Revision No. , Dated 2. (X) Submittal from the Licensee 3. () Evacuation Time Estimates 4. () Other: g 8611030051 861027 PDR ADOCK 05000295 F PDR

OCT 271986 Thomas'Essig 2 III. Scope of_ Activities: 1. (X) Conduct. review'for deficiencies and submit questions for clarification. 2. () Conduct review and submit evaluation for preparation of input to SER. a 3. () Other: IV. Schedule: 1. () Urgent: Contact EP Reviewer upon receipt. 2. (X) Provide requested information/ response by 45 days after the date of this memorandum. 3. () Initiate meeting to discuss findings (10 working days prior to response date). 4. () Other: V. Supplement information or instructions: 1. A copy of the current Zion Station EALs is included for reference. 2. To expedite the review process, necessary in view of FFE scenario development activities, the Region requests that one of the following contractors perform the review, based on their familiarity with the licensee's EP program and the Station's EALs in particular: F. McManus; D. Schultz; K. Loposer; G. Bethke. " Original signed by "J.D. Shafer" ~ W. D. Shafer, Chief Emergency Preparedness and Radiological Safety Branch

Enclosure:

As stated cc w/ enclosure: D. Matthews, EPB, 0IE R. Meck, EPB, OIE EP Reviewer -RIII(# M \\ RIII RIi l' d5 Ploski/mj Snell

U 1: 33 S 1 Rev. 2 JUL*1 H3 Index for Zion Emegency c.ction t.evels Page 1. Aircraf t Crash or Missiles from *stever S.3urce 5 2. Control Room Evacuation 5 3. Earthquake 6 4 L41arv.ed Explosion 6 5. Fire 6 6. Flooo or Lcw Water Le.el 7 7. Mcurity Toreat 7 8. Tornc,o Or Se vere 'a'.ms Seing Es perienced 8 r.ic Gus 8 3. c

10. t oss of AC Pc *er 8

i

11. Loss of DC P0aer 9
12. F'. ant $ hut o:wn F.JXti ans 9
13. Gt'. r Concitions or Systems seguired by Te@ Specs 10 t

14 bsteal 7,el Tecaerature 10

15. ana: mal C.ol snt

.:e -:ature 10

16. Elesatec *.rea Pac %3nitor Reacings 10 17.. s s o f.; ir ary ::F. 2nt 10 d. E, s u G e e: S tar Tu.a Rupture 11
19.._rss of Asactor Cociant Flow 11
20. scIs of Se c.c ary Coclant 11
21. v+1n 3*eam tir.e 3:eak 11 i
22. Lcss of Fission ?:ococt cirrier 12 i
23. Fediation elescs f::s the Plant 13 r

2c. Fuel kanclicq '.ccicent 13

25. Feedwater %furetion 14
26. Turbine-Generator *.ccident in nhir. vissiles are ';er.e:ated Ic CL29E 3

0006A

E?IP 330-1 Rev. 2 JUL 21 '393 Index for Zion Emerjency Action Levels (cont') Page

27. Uncontrolled FCC Withdrcwal from Suberitical 14
28. Uncontrolleo ACC Withdrawal at Pcwer 14
29. CVCS Halfunction Erroneous Eoron Oilutions 15
30. Rupture of Control Rod Drive Mechanism 15
31. Personnel Injury 15
32. Hazardous Materials 16
33. Any Other Conditions of Equivalent Pagnitude to the Criteria Used to Define the Accident Category as DeteImined by Station Director 16 0029E 4

0006A L

tPlP 330-1 Rev. 2 - TABLE lA 5-1 ZION EMERENCY ACTION LEVELS C6NDlII6NS UNUSUAL EVENI ALERI SITE EMERGENCY & NEMAL EMERENCY Class Descriptton Events in progress or Events _1n progress Events in progress or Events in progress have occurred which or have occurre*o nave occurred which or have occurred indicate a potential which involve an involve actual or which involve actual degradat ion o f t he actual or potential likely major failures or inuinent sustar.tial level of safety of sonstant irii degrad-of plant functions core aegradation or the plant. allon of the level needed for protection melting with potential of safety of the of tr.e public. for loss of contalieneret p lant. integrity. 1i Aircraf t crash or Inpacted un-site. inpacted on-site and A's inpacted onsite and missiles from has degraded equip-has degracea equipment whatever source. eent described in the descrined in the Technical Specifica-Technical Specifications tions such that a beyond the limiting limiting condition condition for operation for operation re-that require a shutdown;. quires a shutdown. _ or

8) has exceeded a rechaical Specification safety' limit.
2) Control Room when llEFR2O exposure Due to exceeding 10CFR2O Fv acuation limits are expected exposure limits, evacua-to be exceeded, tion is required and control is not esta-blished from Local Control Stations or from Remote Shutdown Panel within 15 mins.

t f>2'/E S FKk%E

p sum s V EPiP ' 3Y Rev. 2 TA8i.E lA 5-1 (CONT) WL 21 sir 3 UNb5UTCTVEfn IEERI 51it EMERGENCY GthERAL EENGt-NCY CONDITIOM i

3) Earthquake has Equipment ' damage may Ea r thquake. has A) Earthquake has occurred or is or may not have degraded equipment degradeo equipment being occurred as italicated described in tras described in the experienced by visual inspection.

Technical Specifica-Technical Specifications-t ions sucn tnat. a beyon_d the limiting limiting condition conditions for operation for operation requires that require a shutdown; a shutdown. or

8) has exceeoed a Technical Specification safety limit.
4) Unplanned Onsite not not affecting Explosion onsite has A) Explosion onsite has Explosion plant operations.

degraded equipment degradeo equipment described in the descritard in the j Technical Specifica-Technical Specifications tions such that a neyond the limiting condition conaltion for operation for operation re-that requires a shutdown; quires a shutdown. or B) has exceeded a Technical Specification safety limit. ^ ')) F ire (ongoing as ATFire requires E.UC fire requires offsite A) Fire requires offsite described by notificalion if not essistance and has assistance and has observation or identified within' lu degraded equipment degraded equipment i a larm, and minutes; described in the described in the verifled by the or Technical Specifica-Technical Specifications fire brigade). B) Fire requiring offsite tinos such that a_ beyond the limiting assistance but on!. affect-lin.iting condition condition for operation t Ing plant operation, for operation that requires a shutdown; i " requires a shutdown, or B) has exceeded a Technical Specification j safety limit. s l LYJ2VE 6 Ou;6E 4

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d EPIP 3Y " nev. 4 I TABLE /A S-1 (CONT) (LNOi T 1ONS UNUSUAL E VLNi hHI S1iti EKRGENCY GENERAL EMLxt. thcy

8) 10rnado or A) Toroado near A) Tornado str1kes Susta2nec wirds > 90 mph severe winds Facility facility or and either unit not being experienced.
1. Control room B) Sustained winds in cold shutdown.

(Wind speed as informed by > 75 mph indicated in control load dispatcher room is used to or c lassi fy condit lon. )

2. Station personnel have mace visua1 sighting; or
8) Sustained winas

> 60 mph

9) foxic Gs thcontrolled release Entry of toxic gas Entry of toxic gas of toxic gas at life into the security into vital areas threatening levels a rea.

affecting the safe near or onsite, shutdown of the pit.nt. '1T7; toss orliC Loss of AC power has ffTor,s oIAC power Engineered salely Power degraded equipe nt has dei} raced equipment feature buses are described on tiie described in the deenergized for > fechnical Specification <, Teciviicai Specifica-15 minutes, such that a 1imitlog tions peyond the limiting condit ion for operation condition for operation requires a shutdown. that requires a shutdown; or

8) has exceeded a lechmcal Specification Safety Limit.

OO29E 6 tiA4E

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"g - EPIP 3X4+- Rev. 2.-- TABLE Z S-1 (CONI) CUNUli10NS UNUSUAL EVENI ALLH4 blit EMtHt1NCY GEttRALEMERGENCh

18) Steam Cenerator lhe FSAR accident Tube Rupture consists of a double
  • coded rupture of a single steam generator
tube,
19) Loss of Reactor Should loss of reactor Shouli) instantaneous Coolant flow coolant flow occur due seizure of a reactor to electrical or coolant pump rotor mechanical failure occur using extremely several separate circuits conservative assumptions, will trip the reactor the integrity of the promptly.

primary coolant system is not endangered and under the worse case less than llK of the fuel rods exhibit a DNO rat 10 of less than 1.3.

20) Loss of Less than 6An psi I n' Non-Isolable steam Norwisolable steam Loss of feedwater and Secondary any operatlonal 91onm line break with line break with aux. feedwater for 3/4 Coolant generator.

> 10 gpm primary to > 50 gpm prTmary to hours. secondary leakage. secondary leakage and indication of fuel damage >.1%.

21) Main Steam With zero or small FS/W ANALYSIS:

And 50 gpm primary to Line Break primary to secomlary With 1 gpm primary to secondary leakage leakage and/or small secondary leakage and fod significant fuel percentage of failed with 1% failed fuel, camage. fuel, the accident results in an integrated would properly be dose of 11.5 mrem. categorlied as an unusual event. OO29E 11 lUK ' ~ ^'-

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_~ I -~ EPIP 3X % Rev.'2 : N' TMLE IA 5-1 (CONT) CONulIluh5_ UNU5UAL E,vENI. ALEn i_ 51TE EMcRGENCY GEhtRAL EMERGENCY

29) CVCS Malfurction Should erroneous boron dilu-I Erroneous Boron t lon occur numerous alarms Dilutions and Indications are available te !n# !?:: cperater tu ine 1

condition to take corrective action before excessive shutdown margin is lost. ihe GM acciderd pre-I Jid Rupture of Cont rol Rod Drive clicl e, a 7% 1rw'reaw. in Mechanism failed fuel as.a result I (rod ejection of this accident, which accident) places it in the Alert category based on NUREG IM54. Hwever, the integrated dose is 100 1 mrem over 2 hours, which would place it in the Site Emergency category ac-cording to GSEP 5.0-4, 3 item 17. I

31) a3rsonnel Injury Iranspor tat.lon 01 radioactivity con-4 i

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'EPIP 33 Q - . Rey, 3'[ e. JUL 2 I h. TA0i.E ZA 5-l (CONT) CONDlIIvN5 UNU5UAL EVENT ALEHI SIIt. EMLHGENCY f ENERAL EERGENCY

32) Inzardous As a direct result of Materials hazardous materials a person is killed or hospitalized or esti-mated property damage exceeds $50, LAX >.
33) Any other condi- ~ Warran'ts increased

'rlarrants activation

1) warrants Imminent Core Melt.

t ions of equiva-awareness on the part of Technical Support activation of tent magnitude to of the state and/or Center Nearsite EOF the criteria used local offsite to define the o f ficials

2) Warrants accident category activation of as determined environmental Station Director.'

monitoring teams "Coswillions that may or may not warrant classification under GSEP loclude: a. Incident reporting per IOCFR50.72. b. Incident reportJng per lifFR20.403 or Illinois Rules and Regulations, Part D.403. c. Discharges of oil on.iazardous substances into waterways per 33CFR153. d. Security contingency events per the Station Security Plan. The Station Director may, at his discretion, categorl/e the above situations as GSEP emergencies, depending upon the seriousness of the situation. (Refer to Section 9.3 of the generic plant for additional information.) (D29E 16 Of1>6E Q

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u f. 2 .2 m-m A } Commonwealth Edison 72 West Adams Street. Chicago, lilinois Address Reply to: Fost Office Box 767 Chicago, Illinois 60690 0767 October 23, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 l

Subject:

Zion Station Units 1 and 2 GSEP Annex EAL Revision NRC Docket Nos. 50-295 and 50-304

Dear Mr. Keppler:

Enclosed for your review and approval is a revision to the Emergency Action Levels of the Zion County Station Generating Station Emergency Plan Annex. This revision to Emergency Action Levels (EALs) is being proposed in order to standardize the EAL j format for Zion, Byron and Braidwood Stations. The table of Emergency Action Levels (EALS) is consistent with the concerns of the general class descriptions and the examples provided in Appendix 1 of NUREG 0654. Where possible, these emergency action levels have been related to plant instrumentation readings. In some instances, it was inappropriate to adopt initiating conditions exactly equivalent to those examples specified in NUREG 0654. Site specific annexes should categorize postulated accidents contained in the Stations Final Safety Analysis Report provided the event produced a concern consistent with the class description in NUREG 0654. The changes to the Annex are consistent with the requirements of 10 CFR 50 App. E, and do not decrease the effectiveness of the plan. Since this is a major change to the format of the EAL's, this change will not be implemented prior to NRC review and approval. l t rr / r/ - ./1-mm-pp, 4 ocT 2 uses

r-g 9 A copy of this letter along with two copies of the proposed revision are being sent to the Document control Desk. Commonwealth Edison is notifying the State of Illinois of our request for this revision by transmitting a copy of this letter and enclosure to the designated state official. Sincerely, I. M. Johnson Nuclear Licensing Administrator encl. cc: NRC Document Control Desk Mike Parker - State of Ill. J. Norris - NRR /klj 2311K .i

ATTACHMENT I Zion Station Emergency Action Levels (EALs) l

T 4 PWR EMERGENCY ACTION LEVELS CONDITION 1. RADIDACTIVE EFFLUENT RELEASES TO THE ENVIRONMENT UNUSUAL SITE GENERAL EVENT ALERT EMERGENCY EMERGENCY One of the following: One of the following: One of the following: One of the following: GASECUS RELEASE Average of ten (10) highest core thennocouples less than 13000F, contairunent radiation level less than 200 R/hr, no core uncovery, M less than 1 R/hr on Fuel Handling ARMS. Release rates are on a per Station basis. A. Instantaneous noble gas G. Instantaneous noble gas M. Noble gas release S. Instantaneous noble release rate is greater release rate is greater rate averaged for gas release rate than or equal to than or equal to 2 minutes is greater is greater than or 8.32 E +4 uCl/sec. 1.63 E + 5 uCi/sec, than or equal to equal to 2.3 E + 6 uCi/sec. 4.50 E + 6 uC1/sec. OR OR Instantaneous noble Instantaneous noble gas release rate is gas release rate is greater than or equal greater than or equal to 60,000 uC1/sec as to 600,000 uCi/sec as indicated by the noble indicated by the noble gas detectors which gas detectors which monitor the release monitor the release paths stated in paths stated in Technical Specification Technical Specification Table 4.12-1 and/or Table 4.12-1 and/or noble gas monitor noble gas monitor ORE 0014. ORE 0014. B. Instantaneous Iodine N. Noble gas release release rate is greater rate averaged for than or equal to 30 minutes is greater 2.0 uCl/sec. than or equal to (as indicated by 2.30 E + 5 uti/sec. Grab Sanple) alF A-MODEL IS AVAILA8LE, CLASSIFICATION WILL BE MADE IN ACCORDANCE WITH A-MODEL OUTPUT. Emergency Action Levels (EALS) C, H, 7, P, & T for Gaseous releases appear on next page. Condition I continued next page. 6915E/2

5 l + Ptm EMERGENCY ACTION LEVELS CONDITION 1. RADIOACTIVE EFFLUENT RELEASES TO THE ENVIRONMENT UNUSUAL SITE GENERAL EVENT ALERT EMERGENCY EMERGENCY One of the following: One of the following: One of the following: One of the following: GASECUS RELEASE 0 Average of ten (10) highest core thermocouples greater than or equal to 1300 F, contalrunent radiation level greater than or aqual to 200 R/hr, E core partially E totally uncovered, OR, greater than or equal to 1 R/hr on Fuel Handling ARMS Release rates are on a per Station basis. C. Instantaneous noble H. Instantaneous noble

0. Noble gas release rate T. Instantaneous noble gas release rate is gas release rate is averaged for 2 minutes gas release rate is greater than OR equal greater than or equal is greater than or greater than or equal to 2.22 E + 4 uCi/sec.

to 4.44 E + 4 uCi/sec. ' equal to to 2.82 E + 6 uCi/sec. 1.40 E + 6 uCi/sec. P. Noble gas release rate averaged for 30 minutes is greater than or equal to 1.40 E + 5 uCi/sec.

  • 1F A-MODEL IS AVAILABLE, CLASSIFICATION WILL BE MADE IN ACCORDANCE WITH A-MODEL OUTPUT.

Emergency Action Levels (EALS) D, E, F, I, J, K, L, Q, R, U & V for Liquid releases appear on next page. Condition 1 continued next page. 6915E/3 4

(_ Ptst EERGENCY ACTION LEVELS' CONDITION 1. RADI0 ACTIVE EFFLUENT RElIASES TO THE ENVIRONMENT (continued) SITE GENERAL UNUSUAL EVENT ALERT EERGENCY EERGENCY One of the following: One of the following: One of the following: One of the following: L10U10 RELEASE D. Liquid release

1. Liquid release Q. Liquid release U. Liquid release greater than g equal greater than g equal greater than g equal greater than g equal to 1 x 10-7uC1/m1 to 1 x 104 uci/mi to 2 x 10 Ci but to 2x104 Ci total 3

4 but less than as measured by monitors less than 2x10 Cl in 24 hours. I x 104 uC1/ml as M counting equipment. total in 24 hours. sampled g measured by counting equipment. R. Trititan release V. Tritium release greater than OR equal greater than OR to2x10CibuEless equalto2x10ki 4 E. Estimated liquid J. Estimated liquid 5 release greater than release greater than than 2x10 C) total total in 24 hours, g equal to 4 Cl but g equal to 40 Cl but in 24 hours. less than 40 Cl total less than 2000 Cl total in 24 hours. in 24 hours. F. Trittism release K. Tritium release greater greater than OR than OR equal to D cl/mi 3x10-El/m1as equal to 3x10 u but less than measured by monitors 3 x 10-2 uCl/mi g counting equipment. as sangles and measured by counting equipment. L. Tritium release greater than OR equal to 5x1@Cibutless 4 than 2 x 10 Cl total in 24 hours. 1692A/3/wjm l

PWt EMERGENCY ACTION LEVELS e CONDITION 2. LOSS OF FISSION PRODUCT BARRIERS tpluSUAL SITE GENERAL EVENT ALERT EMERGENCY EMERGENCY ) One of the One of the One of the One of the i following: following: following: following: / A. Coolant I. Loss of gne Fission

0. Loss of M Fission S. Loss of M Fission activity Product Barrler as Product Barriers as Product Barriers sample greater indicated by any of indicated by any of with probable loss than E equal to the following:

the following: of the third Fission 30 uC1/mi of equiva-Product Barriers as lent Iodine 131. indicated by any of the following: a) Cladding l Grab sample activity equivalent to 300 uti/ml of I-131, 62 uCi/ml of CS-137 E 41 uCi/ml of Xe-133. b) Reactor Coolant System RCS pressure less than or equal to 1815 PSIG H ' Containment pressure greater than or equal to 4.5 PSIG c) Primary Containment. 1. Contaltunent pressure greater than or equal to 47 PSIG E 2. Containment temperature greater than or equal to 271 0F E 3. Unisolable breech of the contairunent. l 8. Primary Contaltunent J. Primary Containment P. Primary Containment T. Primary Containment radiation level is radiation level is radiation level is radiation level is l greater than or equal greater than or equal greater than or equal greater than or equal l to 1 x 102 R/hr to 2 x 102 R/hr to 4 x 102 R/hr. to 2 x 103 R/hr. but less than but less than M probable loss of 2 x 102 R/hr 4 x 102 R/hr. Primary Containment. C. Average of ten (10) K. Average of ten (10) Q. Average of ten (10) U. Total core uncovery highest incore highest incore highest incore has occurred or is thennocouple readings thennocouple readings thennocouple readings projectedtooccur is greater than or is greater than or is greater than or within 6 hours 3 equal to 7500F but equal to 13000. but equal to 16500F. the average of the F less than 13000F less than 16500F. (Using YO606) ten (10) highest (Using YO606) (Using YO606) incore thennocouple readings is greater D. Failed fuel monitor L. Failed fuel monitor than or equal to indicates greater indicates greater 16500F, (Using YO606) than or equal to than or equal to OR Containment Hydrogen 100 R/hr increase 1000 R/hr increase concentration is in 30 minutes. in 30 minutes. greater than or equal to 6%. Emergency Action level (EALS) E, F, G, H, M, N, R and V appear on next page. Condition 2 continued on next page. 6915E/5

Plst EMERGENCY ACTION LEVELS CONDITION 2. LDSS OF FISSION PRODUCT BARRIERS (cont'd) UNUSUAL SITE GENERAL EVENT ALERT EMERGENCY EMERGENCY One of the One of the One of the One of the following: following: following: following: E. Total reactor coolant M. A 50 gpm leakage V. Events are in progress leakage rate to rate increase in g have occurred Primary Containment a 4 hour period which involve actual is greater than Tech-as indicated by E laminent substan-nical Specifications either leak rate tial core degradation Limiting Condition calculations, E melting with for operation. (See charging pump flow probable loss of also EALA4A.) E VCT level containment. changes. N. Primary system R. Primary systen leakage is beyond leakage is beyond makeup capabilities makeup capabilities of available of available ECCS or charging peps. ECCS falls to actuate. F. Primary Containment integrity is degraded such that a Technical Specification Limiting condition for operation requires a Shutdown M Reactor power is or has been reduced to less than or equal to 50Y. as indicated by power range instrumentation. G. ECCS initiation signal M resultant injectiontothe vessel. (Not Supurious) H. Failure of a primary system safety valve to close, g failure of a primary PORV to close, M its block l valve will not isolate. 1692A/S/wjm i l

PWI EMERGENCY ACTION LEVELS CONDITION 3. SYSTEM MALFUNCTIONS UNUSUAL SITE GENERAL EVENT ALERT EMERGENCY EMERGENCY One of the following: One of the following: One of the following: One of the following: A. Equipment described E. Equipment is degraded I. Equipment is degraded M. Events are in progress in the Technical such that a Mode 5 such that a condition E have occured Specifications is condition (Cold Shut-with the reactor which involve actual degraded such that down) can not be subcritical M with E inninent a Limiting Condition achieved or maintained reactor pressure substantial core for Operation by any means. less than (lowest degradation E melting requires a Shutdown pressurizer PORV with probable loss of and Reactor power is F. Technical Specifica-setpoint) cannot be containment integrity. or has been reduced tions Safety Limit has achieved or maintained to less than or equal been or will be by any means. to 50% as indicated exceeded. by power range instrumentation.

8. Loss of Instrimen-G. Failure of the Reactor J. Loss of all 12SV DC N. Total core uncovery tation such that Protection System in-power to a unit.

has occurred or is accident classifica-strisnentation to projectedtooccur tion E offsite dose initiate g couplete within 6 hours g assessment can a reactor trip which the average of the not be made. brings the reactor sub-ten (10) highest critical once a limit-in core thennocouple ing safety system . readings is greater setting, as specified than or equal to in the Technical Speci-16500, (Using Y0606) F fications has been E Containment Hydrogen exceeded. (ATWS Event) concentration is greater than or i l C. Loss of power to the H. Unplanned loss of most K. Loss of power to the ' equal to 6%. Unit Auxiliary Trans-or all annunciators Unit Auxiliary Trans-fonner g the associa-on ECCS Panel, Reactor fonners g the Station ted Station Auxiliary Control Panel M Auxiliary Transfonners Transfonner with the Electrical Panel, associated with a Unit Unit not in Mode 5 or 6. MlD_ D. Loss of all Olesel Generators associated Loss of all Diesel with the Unit not in Generators associated P % or 6, with that Unit. L. Loss of all Feedwater

0. Loss of all Feedwater M all Auxiliary Feed-E all Auxiliary water g the Residual Feedwater M the Heat Removal System is Residual Heat Removal not in operation.

System is not in operation for greater than 45 minutes.

PWL EMERGENCY ACTION LEVELS CONDITION 4. SECONDARY SYSTEM MALFUNCTIONS UNUSUAL SITE GENERAL EVENT ALERT EMERGENCY EMERGENCY One of the One of the One of the One of the following: following: following: following: A. Main Ste mline or D. Main Ste mline Break F. Main Ste mline Break

1. Events are in progress Feedline break that or Feedline Break or Feedline Break E have occurred results in rapid with 10 gpm primary with greater than or which involve depressurization of to secondary leakage.

equal to ten (10) gpm actual 3 the secondary system. primary to secondary inminent substantial leakage M average core degradation M of ten (10) highest melting with probable incore thennocouple loss of containment readings is greater integrity, than or equal to 7500F B. Exceeding primary to E. Rupture of Stem G. Rupture of Ste m secondary leakage Generator tube (s) is Generator tube (s) is rates as specified beyond the capability beyond the capability .in Technical Speci-of available charging of available ECCS or cations. (See also ptmps. ECCS falls to actuate. EALf2E.) C. Any Main Feedwater malfunc-H. Loss of all Feedwater J. Loss of all Feedwater tion resulting in a M all auxiliary M0_ all Auxiliary sustained Feedwater Feeduater, g the Feedwater g the Inlet Tenperature Residual Heat Removal Residual Heal Removal to the stem generators System is not in. System is not in of less than 700F. operation. operation for greater than AS minutes. l l ? 6915E/8

PWR EMERGENCY ACTION LEVELS CONDITION 5. FUEL HANDLING ACCIDENT. UNUSUAL SITE GENERAL EVENT ALERT EMERGENCY EMERGENCY One of the following: One of the following: A. Radiation levels in C. Radiation levels in the Fuel Handling Building Fuel Handling Building are greater than OR are greater than E equal to 1 R/hr as equal to 1 R/hr as indicated by ORT AR03 indicated by ORT AR03 g Fuel Handling Bldg. A!!D_ Fuel Handling Bldg. Exhaust has been Exhaust charcoal filters diverted through the are depleted M inop-charcoal filters, erable.

8. Fuel Pool level D. Fuel Pool level decreases below the decreases below the Technical Specifica-top of irradiated tion limit.

fuel. 1692A/8/wjm c,

MR ENERGENCY ACTION LEVELS CONDITION 6. NATURAL AND DESTRUCTIVE PHENOMENA (EARTHQUAKE, EXPLOSION, FIRE, FLOOD, TORNADO, SUSTAINED WINDS, AIRCRAFT CRASH E MISSILES FROM WATEVER SOURCES) UNUSUAL SITE GENERAL EVENT ALERT EMERGENCY EMERGENCY One of the following: One of the following: One of the following: One of the following: A. Equipment described H. Equipment is degraded R. Equipment is degraded Y. Events are in progress in the Technical such that a Mode 5 such that a condition E have occurred which Specifications is condition cannot be with the reactor involve actual E degraded such that achieved OR maintained subcritical AND with inninent substantial a Limiting Condition by any means. reactor pressure core degradation gR. for Operation less than (lowest melting with probable requires a Shutdown pressurizer PORV loss of containment AND reactor power is setpoint) cannot be integrity. achieved or maintained or has been reduced to less than or equal by any means. to 50% as indicated by power range instru-mentation. B. Damage is such that

1. As the result of a Z. Total core uncovery off-site assistance natural or destructive has occurred E is is required to prevent phenonema a Safety projected to occur further degradation of System is affected within 6 hours the level of safety such that it may not M the average of of the facility.

perfonn its required the ten (10) highest function. incore thennocouple readings is greater than or equal to 16500F (Using YO606) M Containment Hydrogen concentration is greater than or equal to 6%. C. Not Applicable J. Control Room evacua-S. Control Room evacuation at Zion Station. tion is anticipated is required M control j E required with is not established from control established local station. I from local stations. K. Sustained winds of T. Sustained winds of of greater than or of greater than or equal to 75 mph. equal to 90 mph, with a Unit not in Cold Shutdown. or Refuel. D. Lake level L. Lake level U. Lake level is greater projectedtorise greater than g equal than gR. equal to 592' above 584'. to 584'. with a unit not in Cold Shutdown OR_ Refuel. E. Lake level M. Lake level V. Lake level is less projectedtodrop less than @ equal to than @, equal to 552'. below 566'. 566'. Emergency Action levels (EALS) F, G. N, 0, P, Q, W and X appear on the next page. Condition 6 continued on next page.

PWR EMERGENCY ACTION LEVELS CONDITION 6. NATURAL AND DESTRUCTIVE PHENOMENA (EARTHQUAKE, EXPLOSION, FIRE, FLOOD, TORNADO, SUSTAINED WINDS, AIRCRAFT CRASH E MISSILES FROM 65tATEVER SOURCES - cont'd) UNUSUAL SITE GENERAL EVENT ALERT EMERGENCY EMERGENCY One of the following: One of the following: One of the following: F. Aircraft N. Aircraft W. Aircraft lapacted ing: acted within ispected within onsite. the protected the protected area but not area g is affecting affecting vital areas. vital areas. G. Earthquake at a level

0. Earthquake X. Earthquake greater than g at a level experienced at equal to.02g greater a level greater (Alann Setpoint) is than B equal than B equal confinned, to.08g(OBE) to.16g (SSE)

(Not Spurious) is confinned. is confinned with a unit not in Cold Shutdown E Refuel. P. Technical Speci-fication Safety limit has been E will be exceeded. Q. Turbine failure causing casing penetration. 1692A/10/wjm l l

c PWt EMERGENCY ACTION LEVELS CONDITION 7. HAZARDOUS, T0XIC OR FLAMA8LE MATERIALS UNUSUAL SITE GENERAL EVENT ALERT EMERGENCY EMERGENCY One of the One of the One of the following: following: following: ) A. Uncontrolled C. Uncontrolled G. Uncontrolled release of release of release of toxic gR. flan-toxic OR. flam-toxic gR_ flan-mable gas at mable gas at mable gas at life threat-Ilfe threat-life threat-ening levels ening levels ening levels is detected AND is detected AND is detected AND confinied on-site. confirmed within the confinned within protected vital areas area.

8. Release of large E. Control Room H. Control Room quantitles of evacuation is evacuation is flannable, anticipated 9R required g g control explosivegR required with is not estabilshed toxic material control established from local stations such that from local stations, plant operation may be affected.

C. As a direct result F. Not appilcable for I. Not Appilcable for of hazardous material Zion Station. Zion Station, a person is killed 9R. hospitalized AN0/0R estimated property damageexceeds$50,000. 1 l 1692A/11/wjm

Met EMERGENCY ACTION LEVELS CONDITION 8. SECURITY THREAT INIU5UAL SITE GENERAL EVENT ALERT EM RGDICY EERGENCY One of the One of the One of the One of the following: following: following: following: A. Obvious attempt to G. Security threat of J. Inninent loss of L. Loss of physical sabatoge safety related increasing severity physical control of control of the equipment, that persists for the facility. facility. acre than 60 minutes. B. Internal disturbance (a disturbance that is H. Security threat that K. Security threat that M. Loss of physical not short lived g is generates an unusual results in loss of control of the not a harmless outburst Event under control of any vital Control Room due to involving one g more another condition. area. (For control a security threat. Individuals within Example: Scub explo-Room, refer to j the protected area.) slon results in loss General Emergency.) l of plant systems C. ecub device discovered sufficient to classify inside the protected as an Unusual Event. area. D. Hostage situation

1. Armed g forced vital which disrupts area intrusion.

normal operation. E. Civil disturbance l (spontaneous) l collective group gathering which disrupts normal operations.) F. Armed g forced protected area intrusion. l l l i 1692A/12/wjm i i I n - .--------.,,,-,n...,,n,nc...,... ,--,n -~ n,,------..

PWL EMERGENCY ACTION LEVELS CON 01T10N 9. ANY OTHER CONDITIONS OF Equ1 VALENT MAGNITUDE TO THE CRITERIA USED TO DEFINE THE ACCIDENT CATEGORY AS DETERMINED BY THE STATION DIRECTOR UNUSUAL SITE GENERAL EVENT ALERT EMERGENCY EMERGENCY one of the following: One of the following: One of the following: i A. A condition that D. A condition that H. A condition that K. Events are in progress warrants increased warrants precautionary warrants activation E have occurred which awareness on the part activation of Techni-of the Emergency involve actual E of State AN0/0R local cal Support Center g Operations Facility inninent substantial offsite officials, placing Emergency M monitoring teams core degradation OR, Facility 3 Corporate E a precautionary of melting with probable Connand Center on notification of the loss of containment standby. public near the site. integrity. 1 1 S. Inadvertent dilution E. ARM reading (s) M L. Total core uncovery such that: survey results OR_ has occurred E survey results alone isprojectedto

1) Technical Specifi-confim an increase in occur within cation shutdown Plant radiation levels 6 hours M the margin requirements by a factor of 1000.

ten (10) highest are violated. incore themocouple readings is greater gR_ than or equal to F. Fuel Pool level de-

1. Fuel Pool level 16500F (Using YO606)
2) The control bank creases below the decreases below g Contaltunent Hydrogen l

low low insertion Technical Specifica-the top of irra-concentration is limit is reached. tions Limit. diated fuel. greater than or . equal to 6%. C. Uncontrolled rod G. Not Applicable for J. Not Applicable withdrawal from Zion Station. for Zion Station. subcritically gR. power operation. 6915E/14 ..- ~

Plet EERGENCY ACT*0N LEVELS CONDITION 10. PERSONAL INJURY UNUSUAL SITE GENERAL EVENT ALERT EMERGENCY EMERGENCY A. Transportation of a radioactively containatedinjured person (s) to an offsite medical facility for treatment. i 1692A/14/w)n

'I P6ft EMERGENCY ACTION LEVELS CONDITION 11. TRANSPORTATION AOC10ENT A. A vehicle transporting radioactive materials OR non-radioactive Hazardous materials from'a Commonwealth Edison generating station is involved in a situation in which: 1. Fire, breakage or suspected radioactive contamination occurs involving a shipment of radioactive material OR; 2. As a direct result of Hazardous Materials, (a) A person is killed; OR (b) Apersonreceivesinjuriesrequiringhospitalization;OR (c) Estimated carrier OR other property damage exceeds $50,000. 8. Any other condition involving Hazardous material transportation ANO equivalent to the criteria in Item A. I 6915E/16

ZION STATION PWREhERGENCYACTIONLEVEL(EAL) PHILOSOPHY 1711A/wjm 1

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 1. Radioactive Effluent Release calculation of reportable gaseous release rates and projected downwind dose (ren) will be performed using both SPINGs. All release rates stated in Condition 1 and explained in the basis are for the purpose of ) classification. Unless otherwise stated, dose rates are 1 gamma whole body. BALSIA Noble Gas Release Rate This emergency action level action addresses the concern of Example #2 under Unusual Event in NUREG 0654. Example #2 reads as follows:

  1. 2 Radiological effluent Technical Specification limits exceeded.

Classification release rate is calculated in such a way that release of a normal operation noble gas mix will not exceed the Tech Spec dose rate limit of 500 ares /yr at the site boundary. the classification release rate is calculated in the " worst" direction (469m, North) for vent release mode, using annual average (ODCM) meteorology. This release rate was reduced by a factor of 5 to, avoid situation when EALs based on annual average meteorology (conditions 1A, B, C, G, H) result in higher release rates than RALs based on a worst case meteorology (conditions 1M, N, 0, P, S, T). Normal operation noble gas six used 4 as a basis of this EAL (and other "no core damage" conditions) represents Zion Station annual average (1977-1984) effluent mix as given in station's effluent reports at the time of this writing. This release rate is determined based on a SPING monitor low range detector i reading. I l The release rate for the second condition listed is the current Technical Specification release rate limit, conservatively calculated to ensure that the limits in 10CFR20 Appendix B for unrestricted areas are not exceeded. Basis is further defined in T.S. 3.12. 2 i t i ~

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 1. Radioactive Effluent Release EAL#1B Iodine / Particulate Release Rate This emergency action level action addresses the concern of Example #2 under Unusual Event in NUREG 0654. Example #2 reads as follows:

  1. 2 Radiological effluent Technical Specification limits exceeded.

The release rate level is the current Technical Specification release rate limit, conservatively calculated to limit the concentration of halogens and particulates with half-lives greater than eight days to 1/~100 of the limits of 10CFR20, Appendix B, for unrestricted areas. EAL#1C Noble Gas Release Rate This emergency action level action addresses the concern of Example #2 under Unusual Event in NUREG 0654. Example #2 reads as follows:

  1. 2 Radiological effluent Technical Specification limits exceeded.

Classification release rate calculated ins uch a way that release of any assumed accident noble gas mix at time O to 24 hrs post shutdown will not exceed Tech Spec dose rate limit of 500 mrem /yr at the site boundary. Assumptions for the calculation (meteorology, release mode, etc.) and conservative correction factor are the same as for condition lA.. Given release rate is determined based on the SPING monitor low range detector reading. 4 3

=- PWR EMERGENCY ACTION LEVEL (EAL) PHIlhSOPHY Condition 1. Radioactive Effluent Release s BAL41D Liquid Release This emergency action level is based on Table 5.0-7, Emergency Action Levels for Radioactivity in Liquid Effluents, of the Generating Stations Emergency Plan. EAL#lE Liquid Release This emergency action level is based on Tuble 5.0-7, Emergency Action Levels for Radioactivity in Liquid Bffluents, of the Generating Stations Emergency Plan. EAL#1F Liquid Release This emergency action level is based on Table 5.0-7, Emergency Action Levels for Radioactivity in Liquid Effluents, of the Generating Stations Emergency Plan. EAL#1G Noble Gas Release Rate This emergency action level action addresses the concern of Example #15 under Alert in NUREG 0654. Example #15 reads as follows: " Radiological effluents greater than 10 times l' Technical Specification instantaneous limits (an instantaneous rate which, if continued over 2 hours, would result in about 1 mr at the site boundary under average meteorological conditions.)" Classification release rate calculated in such a way that release of a normal noble gas mix will not i exceed 10 times Tech Spec. dose rate limits at the site boundary, i.e., 5000 arem/yr. This release rate is established at a level twice (x2) the condition la 4 i release rate. All other assumptions and correction factors are the same as for Condition lA. Given i release rate is based on the SPING monitor low range detector reading. 1 { The second release rate level indicated is a factor of 10 greater than the Unusual Event limit specified in Condition lA. l I 4 l

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 1. Radioactive Effluent Release EAL#1H Noble Gas Release Rate This emergency action level action addresses the concern of Examplo #15 under Alert in NUREG 0654. Example #15 reads as follows: " Radiological effluents greater than 10 times Technical Specification instantaneous limits (an instantaneous rate which, if continued over 2 hours, would result in about 1 mr at the site boundary under average meteorological conditions.)" calculated for the same dose rate limits as condition 10. All other assumptions, correction factors and monitor channel are the same as condition IC. EAL#11 Liquid Release i This emergency action level is based on Table 5.0-7, Emergency Action Levels for Radioactivity in Liquid 2 Effluents, of the Generating Stations Emergency Plan. EAL#1J Liquid Release This emergency a~ction level is based on Table 5.0-7, amergency Action Levels for Radioactivity in Liquid Effluents, of the Generating Stations Emergency Plan. EAL#1K Liquid Release This emergency action level is based on Table 5.0-7, Emergency Action Levels for Radioactivity in Liquid Effluents, of the Generating Stations Emergency Plan. EAL41L Liquid Release This emergency action level is based on Table 5.0-7, Emergency Action Levels for Radioactivity in Liquid Effluents, of the Generating Stations Emergency Plan. I l i i 5

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 1. Radioactive Effluent Release EAL41M Noble Gas Release Rate This emergency action level adresses the concern of Example #13 under Site Emergency in NUREG 0654. Example #13 reads as follows: i a. Effluent monitors detect levels corresponding to greater than 50 mr/hr for 1/2 hour oI, greater than 500 mr/hr W.B. for two minutes (or five times these levels to the thyroid) at the site boundary f_qr adverse meteoroloav. 1 b. These dose rates are projected based on other plant parameters (e.g., radiation level in containment with leak rate appropriate for existing containment pressure) or are measured in the environs. c. EPA Protective Action Guidelines are projected to be exceeded outside the site boundary. Release rate is calculated in such a way that release of normal operation mix averaged for 2 minutes

  • will not exceed dose rate of 500 mrea/hr at 400 meters downwind distance, based on the worst case meteorology (stability class F, wind speed 1 m/sec),

ground level release. Noble gas mix is defined in condition 1A. This release rate is determined based on the SPING monitor mid range channel reading.

  • Based on the best instantaneous monitor reading available.

i J 6

Ptill EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Ccndition 1. Radioactive Effluent Release EAL#1N Noble Gas Release Rate Tais emergency action level adresses the concern of Ecample #13 under Site Emergency in NUREG 0654. E:tample #13 reads as follows: a. Effluent monitors detect levels corresponding to greater than 50 mr/hr for 1/2 hour or greater than 500 mr/hr W.B. for two minutes (or five times these levels to the thyroid) at the site boundary h adverse meteoroloav. b. These dose rates are projected based on other plant parameters (e.g., radiation level in containment with leak rate appropriate for existing containment pressure) or are measured in the environs. c c. EPA Protective Action Guidelines are projected to be exceeded outside the site boundary. The basis for this condition is the same as IM. Exctpt the release rate is average over 30 minutes

  • and dose rate is not to exceed 50 mrem /hr.
  • Based on the best instantaneous monitor reading available.

4 a 7

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 1. Radioactive Effluent Release EAL#10 Noble Gas Release Rate This emergency action level adresses the concern of i Example #13 under Site Emergency in NUREG 0654. Example #13 reads as follows: a. Effluent monitors detect levels corresponding to greater than 50 mr/hr for 1/2 hour o.r_ greater than 500 ar/hr W.B. for r two minutes (or five times these levels to the thyroid) at the site boundary for adverse meteoroloav. b. These dose rates are projected based on other plant parameters (e.g., radiation level in containment with leak rate appropriate for existing containment pressure) or are measured in the environs, c. EPA Protective Action Guidelines ate projected to be exceeded outside the site boundary. Classification release rate is calculated in such a way I that release of any assumed accident noble gas mix at time O to 24 hrs. post shutdown and averaged over period of 2 minutes

  • will not exceed a dose rate of 500 mrem /hr at 400 mete'rs.**

All other assumptions, correcton factors and monitor channel are as in condition IM.

  • Based on the best instantaneous monitor reading available.
    • Release rates for Condition 10 are 10 times those for Condition IP.

l i 8

J l PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 1. Radioactive Effluent Release EAL41P Noble Gas Release Rate This emergency action level adresses the concern of l Example #13 under Site Emergency in NUREG 0654. Example #13 reads as follows: a. Effluent monitors detect levels corresponding to greater than 50 mr/hr for 1/2 hour gr greater than 500 nr/hr W.B. for two minutes (or five times these levels to the thyroid) at the site boundary Lor _ o adverse meteoroloav. b. These dose rates are projected based on other plant parameters (e.g., radiation 'i level in containment with leak rate appropriate for existing containment pressure) or are measured in the environs. c. EPA Protective Action Guidelines are projected to be exceeded outside the site boundary. The release rate is based on the same mix as in condition 10. Other conditions are,as in condition IN. EAL#1Q Liquid Release This emergency action level is based on Table 5.0-7, Emergency Action Levels for Radioactivity in Liquid Effluents, of the Generating Stations Emergency Plan. l EAL#1R Liquid Release This emergency action level is based on Table 5.0-7, Emergency Action Levels for Radioactivity in Liquid Effluents, of the Generating Stations Emergency Plan. i 4 i 9 i _.------,-----,mm,,,7,,y-, .,,,,. _ - -. - ---w--3 -,.-,wy.m-g.w3,,_,mnm_.w 4% ,.,ypq-_r,__p_, --y m m,r,.%--

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 1. Radioactive Effluent Release EAL#1s Noble Gas Release Rate This emergency action level addresses the concern of Example #1 under General Baergency in NUREG 0654. Example #1 reads as follows: a. Effluent monitors detect levels corresponding to 1 ren/hr W.B. or 5 res/hr thryoid at the site boundary under actual meteoroloaical conditions, b. These dose rates are projected based on other plant parameters (e.g., radiation levels in containment with leak rate appropriate for existing containment pressure with some confirmation from effluent monitors) or are measured in the environs. Release rate is calculated in such a way that instantaneous release of normal operation mix will not exceed dose rate of 1 ren/hr at 400 meters downwind distance based on the worst case meteorology 1 (see condition 1M for all assumptions). This worst case meteorology is a conservative susbstitute for an actual meteorological condition specified in NUREG-0654. This rolese rate is based on the SPING monitor high range channel reading. 1. I 10 l

PWR EMERGENCY ACTION LEVEL (EAL) PHI 14 SOPHY Condition 1. Radioactive Effluent Release EAL41T Noble Gas Felease Rate This emergency action level addresses the concern of Example #1 under General Emergency in NUREG 0654. Example #1 reads as follows: a. Effluent monitors detect levels corresponding to 1 rem /hr W.B. or 5 rem /hr thryoid at the site boundary under actual meteorological conditions. b. These dose rates are projected based on other plant parameters (e.g., radiation levels in containment with leak rate appropriate for existing containment pressure with some confirmation from effluent monitors) or are measured in the environs. This emergency action level is based on the same mix as conditions IC, and 10. All other conditions, assumptions, and monitor channel are as in Condition IS. I EAL410 Liquid Release This emergency action level is based on Table 5.0-7, Emergency Action Levels for Radioactivity in Liquid Effluents, of the Generating Stations Emergency Plan. EAL41V Liquid Release This emergency action level is based on Table 5.0-7, Emergency Action Levels for Radioactivity in Liquid Effluents, of the Generating Stations Emergency Plan. -l 11

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 2. Loss of Fission Product Barriers RAL42A Coolant Activity This emergency action level addresses the concern of Example #3b under unusual Event in NUREG 0654. Example

  1. 3b reads as follows:

~ High coolant activity sample (e.g., exceeding coolant technical specifications for iodine spike.) l This EAL is adopted from the Technical Specification limit. EAL42B Primary Containment Radiation Level This emergency action level is gradation of Example #1, #6 and #12 under Alert in NUREG 0654. These examples read as follows:

  1. 1 Severe loss of fuel cladding.
  2. 6 Radiation levels or airborne contamination which indicate a severe degradation in the control of radioactive raterials (e'.g.,

increase of factor of 1000 in direct radiation readings within facility.)

  1. 12 Fuel damage accident with release of l

radioactivity to containment or fuel handling building. This is a gradation of EAL #2I. The lower boundary for containment radiation level will be the alarm setpoint. l EAL #2C Incore Thermocouple Readings This emergency action level addresses the concern of l Example #3 and #4 under Unusual Event in NUREG 0654. These examples read as follows:

  1. 3 Fuel damage indication.
  2. 4 Abnormal coolant temperature and/or pressure or abnormal fuel temperatures outside of technical specification limits.

l This emergency action level uses core exit thermocouple I readings which are indicative of 0 to 50 percent cladding j damage. l l l l 12 I

PWR EMEROENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 2. Loss of Fission Product Barriers (Cont'd) EAL #2D Failed Fuel Monitor This emergency action level addresses the concern of Example #3C under Unusual Event in NUREG 0654. Example

  1. 3C reads as follows:

Failed fuel monitor (PWR) indicates increase greater than 0.1% equivalent fuel failures within 30 minutes. The R/hr increase is equivalent to 0.1% fuel failures. EAL#2E Primary System Leakage This emergency action level addresses the concern of Example #5 under Unusual Event in NUREG 0654. Example #5 reads as follows: Exceeding either primary / secondary leak rate technical specification or primary system leak rate technical specification. This EAL was worded similar to the NUREG example and adopted from Technical Specification. EAL#2F Loss of Primary Containment Integrity This emergency action level addresses the concern of Example #8 under Unusual Event in NUREG 0654. Example #8 reads as follows: Loss of containment integrity requiring shutdown by technical specificiation. l 'his EAL is very similar to the example provided in the l MREG. The words "and reactor power is or has been reduced to less than or equal to 50% as indicated by power range indtrumentation" were added to clearly define when the Unusual Event is to be declared. 50% power allows for repairs to be accomplished during laod drop from 100%. If repairs have not been accomplished by the 50% power mark, an Unusual Event will be declared. For a BWR control rod insertion will have commenced. Since control rod i l insertion can occur at any power level for a PWR, the 50% l power mark was selected. Power reduction to less than or equal to 50% is indicative of a commitment to fully shutdown. Termination should be considered once the Unit j l has been place in a shutdown Condition. j 13 i

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 2. loss of Fission Product Barriers (Cont'd) EAL42G ECCS Initiation This emergency action level addresses the concern of Example #1 under Unusual Event in NUREG 0654. Example #1 reads as follows: Emergency Core Cooling System (ECCS) initiated and discharge to vessel. The wording, although similar to the MUREG, was changed to indicate thai. the signal was " valid" and "not suprious." Site specific examples of non-LOCA conditions that could generate such an initiation may be included as part of the EAL. EAL#2H Safety or Relief Valve Closure This emergency action level addresses the concern of Example #6 under Unusual' Event in NUREG 0654. Example #6 reads as follows: Failure of safety or relief valve in a safety related system to close following reduction of applicable pressure. This EAL is essentially word for word from the NUREG example. 14 _ _. _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _,. _.. _. ~... _ _ _ _ _.

PWR IDGERGIDICY ACTION LEVEL (EAL) PHILOSOPHY Condition 2. Loss of Fission Product Barriers (Cont'd) EAL#21 Loss of Or.e Fission Product Barrier This emergency action level is a gradation of Example #2 under General Emergency in NUREG 0654. Example #2 read as follows: Loss of 2 of 3 fission product barriers with a potential loss of 3rd barrier, (e.g., loss of primary coolant boundary, clad failure, and high potential for loss of contairment.) This EAL provides indications of a LOCA or an undesired release of coolant and/or fission products to the primary containment. a) The indication of cladding failure chosen is high coolant activity. Example #16 under Alert in NUREG 0654, indicates 300 uCi/cc equivalent of I-131. Using NEDO-22215 this correlates to approximately 6.5% fuel cladding failure. 4 Using the 6.5% fuel cladding failure, the Cs-137 and Xe-133 levels of 62 uCi/cc and 41 uCi/c'c respectively, were determined. Actual site specific values for Cs-137 and Xe-133 may be determined using core damage assessment procedures. If determined these values may be substituted in the EALs. Classification under this criteria can only be accomplished after isotopic analysis has been performed. b) The indication of reactor coolant system failure is the emergency core cooling initiation signals. These signals are related by an "and" as a single signal can also be indicative of a loss of containment cooling. c) The indications of primary containment failure are the containment design parameters and the words "unisolable breech of containment." 4 15 l l

O PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 2. Loss of Fission Product Barriers (Cont'd) EAL82J Primary Cantainment Radiation Level This emergency action level addresses the concern of Example #1, #6 and #12 under Alert in NUREG 0654. These examples read as follows:

  1. 1 Severe loss of fuel cladding.
  2. 6 Radiation levels or airborne contamination which indicate a severe degradation in the control of radioactive materials (e.g.,

increase of factor of 1000 in direct radiation readings within facility.)

  1. 12 Fuel damage accident with release of radioactivity to containment or fuel handling building.

EAL#2K Incore Thermocouple Readings This emergency action level addresses the concern of Example #1 under Alert in NUREG 0654. Example #1 reads as follows: Severe loss of fuel cladding. This emergency action level used core exit thermocouple readings that are indicative of 50 to 100 percent cladding damage. HALS2L Failed Fuel Monitor This emergency action level addresses the concern of Example #1C under Alert in NUREG 0654. Example #1C reads as follows: Failed fuel monitor (PWR) indicates increase greater than 1% fuel failures within 30 minutes or 5% total fuel failures. The R/hr increase is equivalent to 1% failed fuel. EAL82M Primary System Leakage This emergency action level addresses the concern of Example #5 under Alert in NUREG 0654. Example #5 reads as follows: 1 Primary coolant leak rate greater than 50 gym. 16 I

e e PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 2. Loss of Fission Product Barriers (Cont'd) RAL#2N Primary System Leakage This emergency action level addresses the concern of Example #2, #3 and #5 under Alert in NUREG 0654. These examples read as follows:

  1. 2 Rapid gross failure of one steam generator tube with loss of offsite power.
  2. 3 Rapid failure of steam generator tubes (e.g., several hundred gym primary to secondary leak rate.)
  3. 5 Primary coolant leak rate greater than 50 9Pa.

l'1

~ PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 2. Loss of Fission Product Barriers (Cont'd) EAL420 Loss of Two Fission Product Barriers This emergency action level is a gradation of Example #2 under General Emergency in NUREG 0654. Example #2 reads as follows: Loss of 2 of 3 fission product barriers with a potential loss of 3rd barrier, (e.g., loss of primary coolant boundary, clad failure, and high potential for loss of containment.) This EAL provides indications of a LOCA or an undesired release of coolant and/or fission products to the primary containment. a) The indication of cladding failure chosen is high coolant activity. Example #16 under Alert in NUREG 0654, indicates 300 uCi/cc equivalent of I-131. Using NEDO-22215 this correlates to approximately 6.5% fuel cladding failure. Using the 6.5% fuel cladding failure, the Cs-137 and Xe-133 levels of 62 uci/cc and 41 uci/cc, respectively, were determined. Actual site specific values for Cs-137 and Xe-133 may be determined using core damage assessment l procedures. If determined these values may be substituted in the EALs. Classification under this i criteria can only be accomplished after isotopic analysis has been performed. b) The indication of reactor coolant system failure is the emergency core cooling initiation signals. These signals are related by an "and" as a single signal can also be indicative of a loss of containment cooling. c) The indications of primary containment failure are the containment design parameters and the words "unisolable breech of containment." l l l 18 1

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 2. Loss of Fission Product Barriers (Cont'd) EAL#2P Primary Containment Radiation Level This emergency action level is a gradation of Example #2 and #10 under site Emergency in NUREG 0654. These examples read as follows:

  1. 2 Degraded core with possible loss of coolable geometry (indicators should include instrumentation to detect inadequate core cooling, coolant activity and/or containment radioactivity levels.)
  2. 10 Major damage to spent fuel in containment or fuel handling building (e.g., large object damages fuel or water loss below fuel level.)

So long as containment failure remains unlikely, there is no primary containment activity which will cause escalation to General Emergency. EAL42Q Incore Thermocouple Readings This emergency action level addresses the concern of Example #2 under Site Emergency and NUREG 0654. Example

  1. 2 reads as follows:

Degraded core with possible loss of coolable geometry (indicators should include instrumentation to detect inadequate core cooling, coolant activity and/or containment radioactivity levels.) EAL#2R Primary System Leakage This emergency action level addresses the concern of Example #1 and #3 under Site Emergency in NUREG 0654. These examples read as follows:

  1. 1 Known loss of coolant accident greater than makeup pump capacity.
  2. 3 Rapid failure of steam generator tubes (several hundred gpm leakage) with loss of offsite power.

This emergency action level uses core exit thermocouple readings indicative of fuel pellet overtemperature and/or fuel melt. 19

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 2. Loss of Fission Product Barriers (Cont'd) EAL#2S Loss of Two Fission Product Barriers With Probable Loss Of The Third This emergency action level addresses the concern of Example #2 under General Emergency in NUREG 0654. Example

  1. 2 reads as follows:

Loss of 2 of 3 fission product barriers with potential loss of 3rd barrier, (e.g., loss of primary coolant boundary, clad failure, and high potential for loss of containment.) This EAL provides indications of a LOCA or an undesired 1 release of coolant and/or fission products to the primary containment. a) The indication of cladding failure chosen is high coolant activity. Example #16 under Alert in NUREG 0654, indicates 300 uci/cc equivalent of I-131. Using NEDO-22215 this correlates to approximately 6.5% fuel cladding failure. Using the 6.5% fuel cladding failure, the CS-137 and Xe-133 levels of 62 uci/cc and 41 uci/cc, respectively, were determined. Actual -site specific values for Cs-137 and Xe-133 may be determined using core damage assessment procedures. If determined these values may be substituted in the EALs. Classification under this criteria can only be accomplished after isotopic analysis has been performed. b) The indication of reactor coolant system failure is the emergency core cooling initiation signals. These signals are related by an "and" as a single signal can also be indicative of a loss of containment cooling or a loss of feedwater. c) The indications of primary containment failure are the containment design parameters and the words "unisolable breech of containment." 20 1

9 PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 2. Loss of Fission Product Barriers (Cont'd) EAL#2T Primary Containment Radiation Level With Probable Loss of Containment Integrity This emergency action level addresses the concern of Example #1b and #2 under General Emergency in NUREG 0654. These examples read as follows:

  1. 1b These dose rates are projected based on other plant parameters (e.g., radiation levels in containment with leak rate appropriate for existing containment pressure with some confirmation from effluent monitors) or are measured in the environs.
  2. 2 Loss of 2 of 3 fission product barriers with a potential loss of 3rd barrier,

) (e.g., loss of primary coolant boundary, clad failure, and high potential for loss of containment) If primary containment activity is greater than or equal 3 to 2x10 R/hr and primary containment integrity is intact and is expected to remain intact, then the classification i remains Site Emergency. 3 If primary containment activity is less than 2x10 R/hr and primary containment integrity is expected to be lost, the classification remains at Site Emergency. It is only when primary containment integrity is greater than or 3 equal to 2x10 R/hr and when loss of containment integrity is probable that a General Emergency would be declared. 21

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 2. Loss of Fission Product Barriers (Cont'd) EAL92U Imminent Core Melt This emergency action level is a gradation of Example #4 and #5 under General Emergency in NUREG 0654. These examples read as follows:

  1. 4 Other plant conditions exist, from whatever source, that make release of large amounts of radioactivity in a short time period possible, e.g., any core melt situation.
  2. 5 Example PWR Sequences (That could lead to eventual core melt and likely failure of the containment.

This emergency action level uses core exit thermocouple readings or percent hydrogen in conjunction with core uncovery to project imminent core melt. The core thermocouple readings and percent hydrogen adopted by this EAL are indicative of fuel pellet overtemperature and fuel melt. The time used for projected

  • core uncovery should be based on the nominal evacuation time for the two mile radius of the Emergency Planning Zone.

BAL#2V General Emergency Class Description l This is general guidance extracted from NUREG 0654. This EAL is written to address Examples #4 and #5 under General i Emergency in NUREG 0654. These examples read as follows:

  1. 4 Other plant conditions exist, from whatever source, that make release of large amounts of radioactivity in a short time period possible, e.g.,

any core melt situation.

  1. 5 Example PWR Sequences (That could lead to eventual core melt and likely failure of the containment.

The term " probable" was substituted for the term " potential" to be consistent with GSEP and with other EALs. 22 l ,.---.--n-.-. .-n,-

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 3. System Malfunctions EAL#3A Technical Specification Requiring Shutdown This emergency action level addresses the concerns of Examples #9, #11 and #15 under Unusual Event of NUREG 0654. These examples read as follows:

  1. 9 Loss of engineered safety feature or fire protection system function requiring shutdown by technical specification (e.g.,

because of malfunction, personnel error or procedural inadequacy.)

  1. 11 Indications or alarms on process or effluent parametes not functional in control room to an extent requiring plant shutdown or other significant loss of assessment or cammunication capability (e.g., plant computer, Safety Parameter Display System, all meteorological instrumentation.)
  2. 15 other plant conditions exist that warrant increased awareness on the part of a plant operating staff or State and/or local offsite authorities or require plant shutdown under technical specification requirements or involve other than normal controlled shutdown (e.g., cooldown rate exceeding technical specification limits, pipe cracking found during operation.)

The EAL is provided to allow for equipment degradations the combinations of which could place a unit in jeopardy. Rather than listing all possible combinations of equipment failures, and thereby establish a " pseudo" technical specification, reference is made to existing Technical Specifications. Operating personnel and Station management are intimately familiar with Technical Specifications. The words "and reactor power is or has been reduced to less than or equal to 50% as indicated by power range indtrumentation" were added to clearly define when the Unusual Event is to be declared. 50% power allows for repairs to be accomplished during laod drop from 100%. If repairs have not been accomplished by the 50% power mark, an Unusual Event will be declared. For a BWR control rod insertion will have coiunenced. Since control rod insertion can occur at any power level for a PWR, the 50% power mark was selected. Power reduction to less than or equal to 50% is indicative of a coamitment to fully shutdown. Termination should be considered once the Unit has been place in a shutdown condition. 23

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 3. System Malfunctions (Cont'd) EALt3B loss of Instrumentation This emergency action level relates to EAL#3A and addresses the concerns of Example #11 under Unusual Event of MUREG 0654. Example #11 reads as follows: Indications or alarms on process or effluent parameters not functional in control room to an extent requiring plant shutdown or other significant loss of assessment or communication capability (e.g., plant computer, Safety Parameter Display System, all meteorological instrumentation.) No attempt to detail the specific instruments that are critical to accident classification or to offsite dose assessment has been made. As an example, so long as manual procedures for offsite dose assessment and the necessary input parameters are available, this event need not be dec?.ared. EAL#3C Loss of Station Auxiliary Transformer and Unit Auxiliary Transformer. This emergency action level addresses the concern of Example #7 under Unusual Event in NUREG 0654. Example #7 reads as follows: Loss of offsite power or loss of onsite AC power capability. Loss of all offsite power refers to the loss of the Station Auxiliary Transformer and the Unit Auxiliary Transformer. For purposes of the emergency action level, credit is not taken for unit tie breakers. Therefore, declaration of an Unusual Event cannot be avoided if the only sourco of offsite power is through the unit tie breakers. The words "with the Unit not in Mode 5 or 6" emphasize the fact that such a loss of power should not constitute a Unusual Even so long as Diesel Generators are available. l 24 i i

PWR EMERGIDICY ACTION LEVEL (EAL) PHILOSOPHY condition 3. System Malfunctions (Cont'd) RAL43D Loss of All Diesel Generators This emergency action level addresses the concern of Example #7 under Unusual Event in NUREG 0654. Example #7 reads as follows: Loss of offsite power or loss of onsite AC power capability. Loss of all Diesel Generators associated with a unit refers to only the normal diesel supplies. The words "with the Unit not in Mode 5 or 6" emphasize the fact that such a loss of power should not constitute a Unusual Even so long as Diesel Generators are available. EAL#3E Loss of Ability To Reach Cold Shutdown This emergency action level addresses the concern of Example #10 under Alert in NUREG 0654. Example #10 reads as follows: Complete loss of any function needed for plant cold shutdown. The wording of this EAL is an attempt to clarify the concern of NUREG 0654. The use of the term "any function" in the NUREG could result in inappropriate G.S.E.P. activation and was therefore avoided. For example, the loss of a single system would generate an Alert declaration despite the fact that numerous methods exist for achieving Cold Shutdown. The use of the words "by any means" allows personnel the opportunity to use available systems to achieve the condition before issuing a declaration. This wording is not intended to delay declaration once it is recognized that the desired condition cannot be achieved or maintained. EAL#3F Technical Specification Safety Limit Although not specifically addressed in NUREG 0654, violaticn of a Technical Specification Safety Limit constitutes a degradation in the level of safety of the plant consistent with the Alert class description provided in the NUREG. 25

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 3. System Matfunctions (Cont'd) EAL#3G ATWS Event This emergency action level is adopted essentially word for word from Example #11 under Alert in NUREG 0654. Example #11 reads as follows: Failure of the reactor protection system to initiate and complete a scram which brings the reactor subcrit.fcal. This EAL contains additional wording with respect to having reached a " Limiting Safety System Setting" as specified in the Technical Specifications. The additional wording clarifies when the SCRAM should have occurred. EAL#3H Loss of Annuciators This emergency action level addresses the concern of Example #14 under Alert in NUREG 0654. Example #14 reads as follows: Most of all alarms (annunciators) lost. The term " unplanned" was added to indicate that there may be planned losses of power to the annunciators. For example, D.C. ground search procedures may result in temporary loss of power to annunciators. The listing of panels specifies certain annunciator panels to be critical. The NRC has indicated that this condition should be an "and" condition. Loss of power to all of the indicated panels is required before declaration is made. 26

4 PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 3. System Malfunctions (Cont'd) RAL43I Loss of Ability to Reach Hot Shutdown This emergency action level addresses the concern of Example #8 under Site Emergency in NUREG 0654. Example #8 reads as follows: Complete loss of any function needed for plant hot shutdown. The wording of this EAL is an attempt to clarify the concern of NUREG 0654. The use of the term "any system" in the NUREG could result in inappropriate G.S.E.P activation and was therefore avoided. For example, the loss of a single system would generate a Site Emergency declaration despite the fact that numerous methods exist for achieving a Hot shutdown condtion. The term " Hot Shutdown" was not used since the Technical Specification definition is not applicable to the concerns of this accident classification. This emergency action level is addressed as a condition in which reactor pressure cannot be maintained below the lowest relief valve setting. This is an indication that pressure is not being controlled by normal means but still allows for manual operation of the Safety Relief Valves if needed to keep pressure below the Safety Limit. Note that the wording chosen for the EAL does not require that "all rods be inserted" or that " shutdown margin be met" but rather that the reactor be "subcritical". Subcriticality is a condition that can be indicated by rod insertion and/or decaying power level. The use of the words "by any means" allows personnel the-opportunity to use available systems to achieve the condition before issuing a declaration. This wording is not intended to delay declaration once it is recognized that the desired condition cannot be achieved or maintained. 27

I' PWR EMERGENCY ACTION LEVEL (EAL) PHIl4 SOPHY condition 3. System Malfunctions (cont'd) RAL#3J Loss of DC Power This emergency action level addressses the concerns of Example #8 under Alert and Example #7 under Site Emergency in NUREG 0654. These examples read as follows:

  1. 8 (Alert) Loss of all onsite DC power
  2. 7 (Site Emergency) Loss of all vital onsite DC power for more than 15 minutes.

The NUREG addresses an Alert condition for a loss of all DC power and upgrades to Site Emergency if loss is for greater than 15 minutes. The 15 minutes is of no consequence. The time to restore power once lost and to complete notification is expected to take more than 15 minutes. The event is of such magnitude that offsite assistance would be required. Therefore, the 15 minute time frame and the Alert EAL has been dropped. This EAL is more conservative than the NUREG without being more l restrictive. Such a massive degradation of power sources would more appropriately justify a Site Emergency declaration without an interim Alert declaration. Stations may chose to list busses by number if so desired. 28 l

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 3. System Malfunctions (cont'd) EAL#3K Loss of All AC Power This emergency action level addresses the concerns of Example #~1 under Alert and Example #6 under Site Emergency of NUREG 0654. These examples read as follows:

  1. 7 (Alert) Loss of offsite power and loss of all onsite AC power.
  2. 8 (Site Emergency) Complete loss of any function needed for plant hot shutdown.

The NUREG addresses an Alert condition for a loss of all AC power and upgrades to Site Emergency if loss is for greater than 15 minutes. The 15 minutes is of no consequence. The time to restore power once lost and to complete notification is expected to take more than 15 minutes. The event is of such magnitude that offsite assistance would be required. Therefore, the 15 minute time frame and the Alert EAL has been dropped. Such a massive degradation of power sources more appropriately justifies a Site Emergency. This EAL is more conservative than the NOREG wthout being more ' restrictive. Credit is not taken for the unit cross ties. This EAL is based on the loss of all Diesel Generators associated with a unit in conjunction with loss of the Station Auxiliary Transformer and of the Unit Auxiliary Transformer. EAL#3L Loss of Feedwater and Auxiliary Feedwater This emergency action level addresses the concern of Example #2 under Site Emergency in NUREG 0654. Example #2 reads as follows: Degraded core with possible loss of coolable geometry (indicators should include 1 instrumentation to detect inadequate core cooling, coolant activity and/or containment radioactivity levels.) This emergency action level is based upon a loss of Feedwater induced loss-of-coolant accident. If this condition exist for greater than 45 minutes declaration of General Emergency is warranted. (Refer to EAL 30.) 29 ( _- ~ _

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 3. System Malfunctions (cont'd) EAL#3M General Emergency Class Description This is general guidance extracted from NUREG 0654. This EAL is written to address Examples #4 and #5 under General Emergency in NUREG 0654. These examples read as follows:

  1. 4 Other plant conditions exist, from whatever source, that make release of large amounts of radioactivity in a short time period possible, e.g.,

any core melt situation.

  1. 5 Example PWR Sequences (That could lead to eventual core melt and likely failure of the containment.

The term " probable" was substituted for the term " potential" to be consistent with GSEP and with other EALs. EAL#3N Imminent Core Melt This emergency action level is a gradation of Example #4 and #5 under General Emergency in NUREG 0654. These examples read as follows:

  1. 4 other plant conditions exist, from whatever source, that make release of large amounts of radioactivity in a short time period possible, e.g.,

any core melt wa s situation. s

  1. 5 Example PWR Sequences (That could lead to l

eventual core melt and likely failure of i the containment. l This emergency action level uses core exit thermocouple readings or percent hydrogen in conjunction with core uncovery to project imminent core melt. The core thermocouple readings and percent I hydrogen adopted by this EAL are indicative of fuel pellet overtemperature and fuel melt. I I l l l 30

PWR EMMtGENCY ACTION LEVEL (HAL) PHILOSOPHY condition 3. System Malfunctions (cont'd) RALS30 Loss of Feedwater and Auxiliary Feedwater This emergency action level addresses the concerns of Example #5b under General Emergency in NUREG 0654. Example #5b reads as follows: Transient initiated by loss of feedwate and condensate systems (principal heat removal system) followed by failure of emergency feedwater system for extended period. Core melting possible in several hours. Ultimate failure of containment likely if core melts. This emergency action level is based upon a loss of Feedwater induced loss-of-coolant accident. i 31 i t

PWR EMERGENCY ACTION LEVELS CONDITION 4. SECONDARY SYSTEM MALFUNCTIONS EAL#4A Main Steamline Break This emergency action level addresses the concern of Example #17 under Unusual Event in NUREG 0654. Example

  1. 17 reads as follows:

Rapid depressurization of PWR secondary side. EAL#4B Primary to Secondary Leakeage This emergency action level addresses the concern of Example #5 under Unusual Event in NUREG 0654. Example #5 reads as follows: Exceeding either primary / secondary leak rate technical specification or primary system leak rate technical specification. EAL#4C Decreased Feedwater Temperature This emergency action level addresses the concerns of Example #4 under Unusual Event in NUREG 0654. Example #4 reads as follows: Abnormal coolant temperature and/or pressure or abnormal fuel temperatures outside of technical specification limits. The temperature chosen for this EAL should be based on technical specifications and available FSAR analysis. Refer to Chapter 14, section 14.1.9, pages 14.1, thru 39 of the Zion FSAR. EAL#4D Main Steamline Break or Feedline Break This emergency action level addresses the concern of Example #4 under Alert in NUREG 0654. Example #4 reads as follows: Steamline break with significant (e.g., greater than 10 gpm) primary to secondary leak rate (PWR) or MSIV malfunction causing leakage (BWR). l 32 ,--,,y ,,-,m-=,m.n -,..-,.v,. f - -,-w.- .,--,ve.-

PWR EMERGENCY ACTION LEVELS CONDITION 4. SECONDARY SYSTEM MALFUNCTIONS (Cont'd) EAL#4B Steam Generator Tube Rupture This emergency action level addresses the concern of Example #3 and #5 under Alert in NUREG 0654. These examples read as follows:

  1. 3 Rapid failure of steam generator tubes (e.g., several hundred gym primary to secondary leak rate.)
  2. 5 Primary coolant leak rate greater than 50 9Pa.

EAL#4F Main Steamline Break or Feedline Break This emergency action level addresses the concern of Example #5 under Site Emergency in NUREG 0654. Example #5 reads as follows: PWR Stearaline break with greater than 50 gym primary to secondary leakage and indication of fuel damage. The primary to secondary leakage rate is consistent with that chosen for EAL 4 C since the degree of fuel damage is not sepcified. The core exit thermocouple reading is indicative of some cladding damage. EAL#4G Steam Generator Tube Rupture This emergency action level addresses the concern of i Example #1 and #3 under Site Emergency in NUREG 0654. These examples read as follows:

  1. 1 Known loss of coolant accident greater than makeup pump capacity.
  2. 3 Rapid failure of steam generator tubes (several hundred gym leakage) with loss of offsite power.

33

PWR EMERGENCY ACTION LEVELS CONDITION 4. SECONDARY SYSTEM MALFUNCTIONS (Cont'd) EAL#4H Loss of Feedwater and Auxiliary Feedwater This emergency action level addresses the concern of Example #2 under Site Emergency in NUREG 0654. Example #2 reads as follows: Degraded core with possible loss of coolable geometry (indicators should include instrumentation to detect inadequate core cooling, coolant activity and/cr containment radioactivity levels.) This emergency action level is based upon a loss of Feedwater induced loss-of-coolant accident. If this condition exist for greater than 45 minutes declaration of General Emergency is warranted. (Refer to EAL 30.) EAL44I General Emergency Class Description This is general guidance extracted from NUREG 0654. This EAL is written to address Examples #4 and #5 under General Emergency in NUREG 0654. These examples read as follows:

  1. 4 other plant conditions exist, from whatever source, that make release of large amounts of radioactivity in a short time period possible, e.g., any core melt situation.
  2. 5 Example PWR Sequences (That could lead to eventual core melt and likely failure of the containment.

The term " probable" was substituted for the term " potential" to be consistent with GSEP and with other EALs. 34

PWR EMERGENCY ACTION LEVELS CONDITION 4. SECONDARY SYSTEM MALFUNCTIONS (Cont'd) EAL#4J Loss of Feedwater and Auxiliary Feedwater This emergency action level addresses the concerns of Example #5b under General Emergency in NUREG 0654. Example #5b reads as follows: Transient initiated by loss of feedwate and condensate systems (principal heat removal system) followed by failure of emergency feedwater system for extended period. Core melting possible in several hours. Ultimate failure of containment likely if core melts. This emergency action level is based upon a loss of Feedwater induced loss-of-coolant accident. 35 l

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 5. Fuel Handling Accident EAL#5A Damage to Irradiated Fuel and Fuel Handling Building Exhaust Diverted This emergency action level addresses the concern of Examples #6 and #12 under Alert in NUREG 0654. These examples read as follows:

  1. 6 Radiation levels or airborne contamination which indicate a severe degradation in the control of radioactive materials (e.g., increase of factor of 1000 in direct radiation readings within facility.)
  2. 12 Fuel damage accident with release of radioactivity to containment or fuel handling building.

Fuel pool exhaust monitors were not chosen to initiate this EAL since their isolation signal is set relatively low and would essentially halt the tracking of higher readings. In addition, the exhaust monitors may not provide a sufficiently high reading in the case of an exposed spent fuel element. The 1 R/hr on the Refuel Floor ARM was chosen based upon Example #6 under Alert in NUREG 0654 and upon the range of the Refuel Floor ARM. EAL#5B Fuel Pool Level This emergency action level ir, a gradation of Example #10 under Site Emergency in NUREG 0654. Example #10 reads as follows: Major damage to spent fuel in containment or fuel handling building (e.g., large object damages fuel or water loss below fuel level.) i 36

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 5. Fuel Handling Accident (Cont'd) RAL#5C Damage to Irradiated Fuel and High Radiation in the Fuel Handling Building This emergency action level addresses the concern of Example #10 under Site Emergency in NUREG 0654. Example

  1. 10 reads as follows:

Major damage to spent fuel in containment or fueld handling building (e.g., large object damages fuel or water loss below fuel level.) Fuel pool exhaust monitors were not chosen to initiate this EAL since their isolation signal is set relatively low and would essentially halt the tracking of higher readings. In addition, the exhaust monitors would not provide a sufficiently high reading in the case of an exposed spent fuel element. The 1 R/hr on the Refuel Floor ARM was chosen based upon Example #6 under Alert in NUREG 0654 and upon the range of the Refuel Floor ARM. EAL45D Fuel Pool Level This emergency action level addresses the concern of Example #10 under Site Emergency in NUREG 0654. Example

  1. 10 reads as follows:

Major damage to spent fuel in containment or fueld handling building (e.g., large object damages fuel or water loss below fuel level.) 1 37

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 6. Natural and Destructive Phenomena EAL46A Technical Specification Requiring Shutdown This emergency action level (EAL) addresses the concerns of Example #9, #11 and #15 under Unusual Event of NUREG 0654. These examples read as follows:

  1. 9 Loss of engineered safety feature or fire protection system function requiring shutdown by technical specification (e.g.,

because of malfunction, personnel error or procedural inadequacy.)

  1. 11 Indications or alarms on process or effluent parametes not functional in control room to an extent requiring plant shutdown or other significant loss of assessment or communication capability (e.g., plant computer, Safety Parameter Display System, all meteorological instrumentation.)
  2. 15 Other plant condit, ions exist that warrant increased awareness on the part of a plant operating staff or State and/or local offsite authorities or require plant shutdown under technical specification requirements or involve other than normal controlled shutdown (e.g., cooldown rate exceeding technical specification limits, pipe cracking found during operation.)

i The EAL is provided to allow for equipment degradations the combinations of which could place a unit in jeopardy. -l Rather than listing all possible combinations of equipment l failures, and thereby establish a " pseudo" technical i specification, reference is made to existing Technical Specifications. Operating personnel and Station management are intimately familiar with Technical Specifications. The words "and reactor power is or has been reduced to less than or equal to 50% as indicated by power range indtrumentation" were added to clearly define when the Unusual Event is to be declared. 50% power allows for l repairs to be accomplished during laod drop from 100%. If repairs have not been accomplished by the 50% power mark, an Unusual Event will be declared. For a BWR control rod l insertion will have commenced. Since control rod insertion can occur at any power level for a PWR, the 50% power mark was selected. Power reduction to less than or l equal to 50% is indicative of a commi'cnent to fully shutdown. Termination should be considered once the Unit has been place in a shutdown condition. 38

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 6. Natural and Destructive Phenomena (Cont'd) EAL#6B Offsite Assistance Although not specifically addressed in NUREG 0654, this emergency action level addresses several examples listed in the NUREG. This EAL provides a symptomatic spproach based on damage to the facility and/or equipm..it. This approach allows other initiating events to be covered by the same EAL, for example, explosion, fire, flood, earthquake, etc. The statement "to prevent further degradation..." was used to segregat'e events which might require off-site assistance for " clean up" measures but which would not constitute an Unusual Event. EAL#6C Not applicable to Zion Station EAL#6D High Lake or River Level ':'his emergency action level addresses the concern of Example #13b under Unusual Event in NUREG 0654. Example I

  1. 13b reads as follows:

50 year floor or low water, tsunami, hurricane surge, seiche. The river level chosen should correspond to the 50 year flood level or to the river level that first endangers vital equipment motors, ie. Service Water Pump Motors, whichever is lower. This EAL relates to a proiection of reaching the level selected. i l l 39

PWR EMERGENCY ACTION LEVEL (EAL) PHIlhSOPHY Condition 6. Natural and Destructive Phenomena (cont'd) EAL#6E Low Lake or River Level This emergency action level addresses the concern of Example #13b under Unusual Event in NUREG 0654. Example

  1. 13b reads as follows:

50 year floor or low water, tsunami, hurricane 4 surge, seiche. The river level chosen should correspond to the point at which cribhouse pumps, ie. Circulating Water Pumps or Service Water Pumps, would start to lose suction. This EAL relates to a proiection of reaching the level selected. EAL#6F Aircraft Crash Onsite This emergency action level addresses the concern of Example #14a under Unusual Event in NUREG 0654. Example 14a reads as follows: Aircraft crash on-site or unusual aircraft activity over facility. The wording selected is consistent with the NUREG. EAL#6G Earthquake This emergency action level addresses the concern of Example #13a under Unusual Event in NUREG 0654. Example

  1. 13a reads as follows:

Any earthquake felt in-plant or detected on station seismic instrumentation. The wording is consistcML with the NUREG. The term "in house" was added ec alley ate the problem of free field monitors which a;e Me*.,ctivated by trains or thunder. l 40 i l l l

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 6. Natural and Destructive Phenomena (cont'd) EAL#6H Loss of Ability To Reach Cold Shutdown This emergency action level addresses the concern of Example #10 under Alert in NUREG 0654. Example #10 reads as follows: Complete loss of any function needed for plant cold shutdown. The wording of this EAL is an attempt to clarify the concern of NUREG 0654. The use of the term "any system" in the NUREG could result in inappropriate G.S.E.P. activation and was therefore avoided. For example, the loss of a single system would generate an Alert declaration despite the fact that numerous methods exist for achieving Cold Shutdown. The use of the words "by any means" allows personnel the opportunity to use available systems to achieve the condition before issuing a declaration. This wording is not intended to delay declaration once it is recognized that the desired condition cannot be achieved or maintained. EAL#6I Safety Systems This emergency action level addresses the concern of Example #13 under Alert in NUREG 0654. Example #13 reads as follows: Fire potentially affecting safety system. Example #13 relates to a " Fire potentially affecting safety systems". 41

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 6. Natural and Destructive Phenomena (cont'd) EAL86I Safety Systems (cont'd) The wording of this EAL requires some indication that the system may not perform its required function. It also applies this criteria to damage caused by explosion, tornado, earthquake, etc. EAL46J Control Room Evacuation This emergency action level has been adopted word for word from Example #20 under Alert in NUREG 0654. Example #20 reads as follows: Evacuation of control room anticipated or required with control of shutdown systems established from local stations. EALS6K Sustained Winds This emergency action level addresses the concern of. Example #17d under Alert in NUREG 0654. Example #17d reads as follows: Hurricane winds near design basis level. The wind speed chosen should be approximately 90% of the design basis wind speed for the containment. EAL46L High Lake or River Level This emergency action level addresses the concern of Example #17b under Alert in NUREG 0654. Example #17b reads as follows: Flood, low water, tsunami, hurricane surge, seiche near design levels The river level chosen should be the same as the level projected in RAL#6D for the Unusual Event. The river level chosen should correspond to the 50 year flood level or to the river level that first endangers vital equipment motors, ie. Service Water Pump Motors, whichever is lower. This EAL is declared when the projection described in RAL#6D has been reached. i 42

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 6. Natural and Destructive Phenomena (cont'd) CAL #6M Low Lake or River Level This emergency action level addresses the concern of Example #1'ib under Alert in NUREG 0654. Example #1'1b reads as follows: Flood, low water, tsunami, hurricane surge, seiche near design levels The river level chosen should be the same as the level projected in EAL#6E for the Unusual Event. The river level chosen should correspond to the point at which cribhouse pumps, ie. Circulating Water Pumps or Service Water Pumps, would start to lose suction. This EAL is declared when the projection described in EAL#6E has bean reached. EAL#6N Aircraft Crash Inside Protected Area This emergency action level addresses the concern of Example #18a under Alert in NUREG 0654. Example 18a reads as follows: Aircraft crash on facility. The wording is consistent with the concerns of the NUREG. 43 'l

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 6. Natural and Destructive Phenomena (cont'd) EAL460 Earthquake This emergency action level addresses the concern of Example #17a under Alert in NUREG 0654. Example #17a reads as follows: Earthquake greater than OBE levels. The level selected is that of the Operating Basis Earthquake. The words "is confirmed" were added for stations which do not have direct readout instrumentation and to avoid declaration due to spurious actuations. EAL#6P Safety Limit Although not specifically addressed in NUREG 0654, violation of a Technical Specification Safety Limit constitutes a degradation in the level of safety of the plant consistent with the Alert class description provided in the NUREG. EAL#6Q Turbine Failure This emergency action level addresses the concern of Example #18e under Alert in NUREG 0654. Example #18e reads as follows: Turbine failure causing casing penetration. This EAL is word for word from the NUREG and, although concerns are covered by other EAL statements, is retained at the request of the NRC. l 44

O PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 6. Natural and Destructive Phenomena (cont'd) EAL#6R Loss of Ability to Reach Hot Shutdown This emergency action level a.ddresses the concern of Example #8 under Site Emergency in NUREG 0654. Example #8 reads as follows: Complete loss of any function needed for plant hot shutdown. i The wording of this (EAL) is an attempt to clarify the concern of MUREG 0654. The use of the term "any system" in the NUREG could result in inappropriate G.S.E.P activation and was therefore avoided. For example, the loss of a single system would generate a Site Emergency declaration despite the fact that numerous methods exist for achieving a Hot Shutdown condition. i This emergency action level is addressed as a condition in which reactor pressure cannot be maintained below the lowest relief valve setting. This is an indication that pressure is not being controlled by normal means but still allows for, manual operation of the Safety Relief Valves if needed to keep pressure below the Safety Limit. Note that the wording chosen for the EAL does not require that "all rods be inserted" or that " shutdown margin be met" but rather that the reactor be "subcritical". Subcriticality is a condition that can be indicated by rod insertion and/or decaying power level. The use of the words "by any means" allows personnel the opportunity to use available systems to achieve the condition before issuing a declaration. This wording is not intended to delay declaration once it is recognized that the desired condition cannot be achieved or maintained. l 1 45 a 3

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 6. Natural and Destructive Phenomena (cont'd) EAL#6S Control Room Evacuation This emergency action level addresses the concern of Example #18 under Site Emergency in NUREG 0654. Example

  1. 18 reads as follows:

Evacuation of control room and control of shutdown systems not established from local stations in 15 minutes. This EAL is adopted word for word except that the 15 minute requirement to establish control has been dropped with concurrence of the NRC. Stations with Remote Shutdown Panels may be able to meet the 15 minute requirement. However, stations with local control modifications may not meet the arbitrary 15 minutes. The need to upgrade from Alert to Site Emergency is in the judgment of the Shift Engineer. EAL#6T Sustained Winds This emergency action level addresses the concern of Example #15c under Site Emergency in NUREG 0654. Example

  1. 15c reads as follows:

Sustained winds or tornadoes in excess of design levels. The wind speed chosen is the design basis wind speed for the containment. The words "with a unit not in Cold Shutdown or Refuel" were added to indicate that if units are in Cold Shutdown or Refuel, a Site Emergency need not be declared. 46 . ~

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 6. Natural and Destructive Phenomena (cont'd) EAL#6U High Lake or River Level This emergency action level addresses the concerns of Example #15b under Site Emergency in NUREG 0654. Example

  1. 15b reads as follows:

Flood, low water, tsunami, hurricane surge, seiche greater than design levels or failure of protection of vital equipment at lower levels. The river level chosen should correspond to the 100 year flood levels. The words "with a unit not in Cold Shutdown or Refuel" were added to indicate that if units are in Cold Shutdown or Refuel, a Site Emergency need not be declared. EAL86V Low Lake or River Level This emergency action level addresses the concern of i Example #15b under Site Emergency in NUREG 0654. Example 15b reads as follows: Flood, low water, tsunami, hurricane surge, seiche greater than design levels or failure of protection of vital equipment at lower levels. The river level chosen should be the level at which containment cooling service water pumps start to lose suction. EAL#6W Aircraft Crash Affecting Vital Areas This emergency action level addresses the concern of Example #16a under Site Emergency in NUREG 0654. Example 16a reads as follows: Aircraft crash affecting vital structures by impact or fire. I This EAL is worded similar to the NUREG example. 47 l

a PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 6. Natural and Destructive Phenomena (cont'd) HAL46X Earthquake This emergency action level addresses the concern of Example #15a under Site Emergency in NUREG 0654. Example

  1. 15a reads as follows:

Earthquake greater than SSR levels. The level chosen should equate to the Safe Shutdown Earthquake. The words "with a unit not in Cold shutdown or Refuel" were added to indicate that if units are in Cold Shutdown or Refuel, a Site Emergency need not be declared. EAL46Y General Emergency Class Description This is general guidance extracted from NUREG 0654. This EAL is written to address Example #4 and #5 under General Emergency in NUREG 0654. These examples read as follows:

  1. 4 other plant conditions exist, from whatever source, that make release of large amounts of radioactivity in a short time period possible, e.g., any core melt situation.
  2. 5 Example PWR Sequences (That could lead to eventual core melt and likely failure of the containment.

The term " probable" was substituted for the term " potential" to be consistent with GSEP and with other EALs. 48 i l

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 6. Natural and Destructive Phenomena (cont'd) EAL46Z Inuainent Core Melt This emergency action level is a gradation of Example #4 and #5 under General Emergency in NUREG 0654. These examples read as follows:

  1. 4 Other plant conditions exist, from whatever source, that make release of large amounts of radioactivity in a short time period possible, e.g.,

any core melt situation.

  1. 5 Example PWR Sequences (That could lead to eventual core melt and likely failure of the containment.

This emergency action level uses core exit thermocouple readings or percent hydrogen in conjunction with core uncovery to project imminent core melt. The core thermocouple readings and percent hydrogen adopted by this EAL are indicative of fuel pellet overtemperature and fuel malt. ) 49 i

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 7. Hazardous, Toxic or Flammable Materials RAL#7A Life Threatening Levels Onsite This emergency action level addresses the concern of Example #14d under Unusual Event in NUREG 0654. Example

  1. 14d reads as follows:

Near or onsite toxic or flammable gas release. The significant wording is " life threatening levels" and " confirmed". Placing specific limits for all the toxic, hazardous and flanunable materials in the table would be difficult. However, to determine if the release of these materials is life threatening may be easier to assess. Unless personnel have been affected and until analysis confirms the release and quantity of such materials, the G.S.E.P. condition need not be declared. EAL#7B Plant Operation Affected This emergency action level addresses the concern of Example #14d under Unusual Event in NUREG 0654. Example

  1. 14d reads as follows:

j Near or onsite toxic or flammable gas release. This partir.ular EAL addresses releases that may occur offsite but which impact plant operation. l EAL#7C Hazardous Material This emergency action level also relates to Example 14d under Unusual Event in NUREG 0654. Example #14d reads as follows: Near or onsite toxic or flammable gas release. This EAL addresses the State of Illinois Public Act 79-1442 Hazardous Materials Regulation. 50

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 7. Hazardous, Toxic or Flammable Materials (Cont'd) RAL#7D Life Threatening Levels Within Protected Area This emergency action level addresses the concerns of Example #18d under Alert in NUREG 0654. Example #18d reads as follows: Entry into facility environs of uncontrolled toxic or flammable gases. The significant wording is " life threatening levels" and " confirmed within the protected area". Placing specific limits for all the toxic, hazardous and flammable materials in the table would be difficult. However, to determine if the release of these materials is life threatening may be easier to assess. Unless personnel have been affected and until analysis confirms the release and quantity of such materials, the G.S.E.P. condition need not be declared. EAL87E Control Room Evacuation This emergency action level has been adopted word for word from Example #20 under Alert in NUREG 0654. Example #20 reads as follows: Evacuation of control room anticipated or required with control or shutdown systems established from local stations. Toxic or flammable material entry into the control Room is foreseen as one possible cause for a Control Room evacuation. 1 51 i t .. _ _ - _ _,.. _ _ _. _ _ _ _ _.. _ _. - ~... r,

4 PWR IMEltGIDICY ACTION LEVEL (EAL) PHILOSOPHY Condition 7. Hazardous, Toxic or Flaimmable Materials (cont'd) BAL47F Not applicable to Zion Station. EAL47G Life Threatening Levels within Vital Areas This emergency action level addresses the concerns of Example #16c under Site Emergency in NUREG 0654. Example

  1. 16c reads as follows:

Entry of uncontrolled flammable gases into vital areas. Entry of uncontrolled toxic gases into vital areas where lack of access to the area constitutes a safety problem. The significant wording is " life threatening levels" and " confirmed within the vital area." Placing specific limits for all the toxic, hazardous and flammable materials in the table would be difficult. However, to determine if the release of these materials is life threatening may be easier to assess. Unless personnel have been affected and until analysis confirms the release and quantity of such materials, the G.S.E.P. condition need not be declared, i 4 52 i i i ._,,-_.,___mr,,, ,,,,,_e_.,m%_--r. ,m,,y.m,m.,. ,,.7_-,_r--y-,_.

_----.,.-s__,----.._.mm.

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 7. Hazardous, Toxic or Flammable Materials (cont'd) EAL#7H Control Rooma Evacuation This emergency action level addresses the concern of Example #18 under Site Emergency in NUREG 0654. Example

  1. 18 reads as follows:

Evacuation of control room and control of shutdown systems not established from local stations in 15 minutes. This EAL is adopted word for word except that the 15 minute requirement to establish control has been dropped with concurrence of the NRC. Stations with Remote Shutdown Panels may be able to meet the 15 minute requirement. However, stations with local control modifications may not meet the arbitrary 15 minutes. The need to upgrade from Alert to Site Emergency is in the judgment of the Shift Engineer. Toxic or flamsable material entry into the Control Room is foreseen as one possible cause for control Room evacuation. EAL#7I Not applicable to Zion Station. 53 i

PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 8. Security Threat EAL#8A Attempt to Sabotage i This emergency action level addresses the concern of Example #12 under Unusual Event in NUREG 0654. Example

  1. 12 reads as follows:

Security threat or attempted entry or attempted sabotage. This is adopted from the list of Security Plan contingencies. EAL#8B Internal Disturbance This emergency action level addresses the concern of Example #12 under Unusual Event in NUREG 0654. Example

  1. 12 reads as follows:

Security threat or attempted entry or attempted sabotage. This is adopted from the list of Security Plan contingencies. EAL#8C Bomb Device Discovered This emergency action level addresses the concern of Example #12 under Unusual Event in NUREG 0654. Example

  1. 12 reads as follows:

Security threat or attempted entry or attempted sabotage. This is adopted from the list of Security Plan contingencies. EALS8D Hostage This emergency action level addresses the concern of Example #12 under Unusual Event in NUREG 0654. Example

  1. 12 reads as follows:

Security threat or attempted entry or attempted sabotage. This is adopted from the list of Security Plan Contingencies. A hostage situation, which does not disrupt normal operations, should not be declared as a GSEP event. 54

1 PWR EMERGIDICY ACTION LEVEL (EAL) PHILOSOPHY condition 8. Security Threat (Cont'd) RAL48E Civil Disturbance This emergency action level addtesses the concern of Example #12 under Unusual Event in NUREG 0654. Example

  1. 12 reads as follows:

Security threat or attempted entry or attempted sabotage. This is adopted from the list of Security Plan Contingencies. BALS8F Armed or Forced Protected Area Intrusion This emergency action level addresses the concern of Example #12 under Unusual Event in NUREG 0654. Example

  1. 12 reads as follows:

Security threat or attempted entry or attempted sabotage. This is adopted from the list of Security Plan j contingencies. I EAL48G Ongoing Security Threat i This emergency action level addresses the concern of Example #16 under Alert in NUREG 0654. Example #16 reads as follows: Ongoing security compromise. l EAL48H Security Threat That Generates An Unusual Event i This particular emergency action level is not required by NUREG 0654. However, some criteria for escalation was needed above and beyond that presented in EAL#7J. l This emergency action level provides guidance for an escalating security event. For example, if a bomb device were to explode, there is no EAL that requires escalation above Unusual Event. However, if as a result of the detonation, equipment degradation meets the criteria for j an Unusual Event, excalation to an Alert would be required by this EAL. 55 i

PWR EMERGENCY ACTION LEVEL (EAL) PHIlhSOPHY condition 8. Security Threat (cont'd) RALS8I Armed or Forced Vital Area Intrusion This emergency action level addresses the concern of Example #16 under Alert in NUREG 0654. Example #16 reads as follows: ongoing security compromise. This is adopted from the list of Security Plan Contingencies RAL48J Imminent Loss of Physical control of Facility This emergency action level addresses the concern of Example #14 under Site Emergency in NUREG 0654. Example

  1. 14 reads as follows:

Imminent loss of physical control of the plant. EALS8K Loss of Cont!rol of Vital Areas This emergency action level addresses the concern of Example #14 under Site Emergency in NUREG 0654. Example

  1. 14 reads as follows:

Imminent loss of physical control of the plant. This is a gradation upward from RAL#81 and is more definitive than #8J. RALS8L Loss of Physical control of Facility This emergency action level addresses the concern of Example #3 under General Emergency in NUREG 0654. Example

  1. 3 reads as follows:

Loss of physical control of the facitity. EAL#8M Loss of the Control Room This emergency action level addresses the concern of Example #3 under General Emergency in NUREG 0654. Example

  1. 3 reads as follows:

Loss of physical control of the facitity, i This is a gradation upward from EAL#8K and is more definitive than 8L. 4 56

l PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 9. Other Conditions of Equivalent Magnitude EAL49A Unusual Event Class Description This is general guidance extracted from Example #15 under Unusual Event in NUREG 0654. Example #15 reads as follows: other plant conditions exist that warrant increased awareness on the part of a plant operating staff or State and/or local offsite authorities or require plant shutdown under technical specification requirements or involve other than normal controlled shutdown (e.g., cooldown rate exceeding technical specificiation limits, pipe cracking found during operation.) EAL#9B Inadvertent Dilution 1 This is an FSAR analyzed transient which meets the general class description for Unusual Event and is not covered by other EALs. EAL#9C Control Rod Withdrawal This is an FSAR analyzed transient which meets the general class description for Unusual Event and is not covered by other EALs. l HAL#9D Alert Class Description This is general guidance extracted from Example #19 under Alert in NUREG 0654. Example #19 reads as follows: Other plant conditions exist that warrant precautionary activtion of technical support center and placing near-site Emergency operations Facility and other key emergency personnel on standby. EAL#9E ARM Readings and Survey Results This emergency action level addresses the concern of Example #6 under Alert in NUREG 0654. Example #6 reads as follows: Radiation levels or airborne contamination which indicate a severe degradation in the control of radioactive materials (e.g., increase of factor of 1000 in direct radiation readings within facility.) l 5'l i e --.,_~.,,,_..--.,__-__y.,.-,,...7,m_,m._,._._ ,y....

PNR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY Condition 9. Other Conditions of Equivalent Magnitude (Cont'd) h EAL49F Fuel Pool Level t This emergency action level is a gradation of Example #10 under Site meergency in NUREG 0654. Exmaple #10 reads as follows: Major damage to spent fuel in containsment or fuel handling building (e.g., large object damages fuel or water loss below fuel level.) RAL#9G Not applicable for Zion Station. EAL#9H Site Baergency Class Description This is general guidance extracted from Example #17 under i j Site meergency in NUREG 0654. Example #17 reads as follows: other plant conditions exist that warrant activation of emergency centers and inonitoring 4 teams or a precautionary notification to the public neir the site. EAL89I Fuel Pool Level This emergency action level addresses the concern of Example #10 under Site Emergency in NUREG 0654. Example 4

  1. 10 reads as follows:

Major damage to spent fuel in containment or fuel handling building (e.g., large object damages fuel or water loss below fuel level.) EAL#9J Not applicable to Zion Station. i i I 58

PWR EMERGIDICY ACTION LEVEL (EAL) PHIlhSOPHY Condition 9. Other Conditions of Equivalent Magnitude (Cont'd) EAL#9K General Baergency Class Description i i This is general guidance extracted from NUREG 0654. l This EAL is written to address Examples #4 and #5 under General Emergency in NUREG 0654. These examples read as follows:

  1. 4 other plant conditions exist, from whatever source, that make release of large amounts of radioactivity in a short time period possible, e.g.,

any core melt situation.

  1. 5 Example PWR Sequences (That could lead to eventual core melt and likely failure of the contairunent.

J The term " probable" was substituted for the term " potential" to be consistent with OSEP and with other EALs. i EAL#9L Imminent Core Melt 1 This emergency action level is a gradation of Example #4 and #5 under General Emergency in NUREG 0654.. These ? examples read as follows:

  1. 4 other plant conditions exist, from whatever source, that make release of large anounts of radioactivity in a short time period possible, e.g.,

any core melt l situation.

  1. 5 Example PWR Sequences (Tha' could lead to eventual core melt and likely failure of the containment, i

This emergency action level uses core exit thermocouple i readings or percent hydrogen in conjunction with core j uncovery to project isminent core melt. The core thermocouple readings and percent hydrogen adopted by this i EAL are indicative of fuel pellet overtemperature and fuel i melt. 59 l.

G = ,~' PWR EMERGENCY ACTION LEVEL (EAL) PHILOSOPHY condition 10. Personal Injurey EAL#10A Transportation of Contaminated Injured Person This emergency action level addresses the concern of Example #16 under Unusual Event in NUREG 0654. Example

  1. 16 reads as follows:

Transportation of contaminated injured individual from site to offsite hospital. ( 0 l 1 60 l ,. - _ _ _ _ ~ -. _ _ _ - - -. _ ,-m ,m ,,_.y-_,,.-_..,,,, _m-,--_ 7

.$ y M EMERGIDICY ACTION LEVEL (EAL) PHILOSOPHY Condition 11. Transportation Accident This condition is derived from GSEP and is related to the laws governing transportation of hazardous materials. l l 61}}

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