NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 7 of 8

Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 7 of 8

ML16071A188
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	03/03/2016
From:	Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML16071A108	List: ML16071A110 ML16071A126 ML16071A132 ML16071A136 ML16071A137 ML16071A140 ML16071A144 ML16071A146 ML16071A147 ML16071A149 ML16071A150 ML16071A152 ML16071A153 ML16071A158 ML16071A160 ML16071A166 ML16071A170 ML16071A174 ML16071A176 ML16071A180 ML16071A181 ML16071A184 ML16071A185 ML16071A187 ML16071A188 ML16071A193 ML16071A195 ML16071A198 NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 1 of 4 NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 2 of 4 NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 3 of 4 NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 4 of 4 NL-15-1898, Enclosure 3: Hatch EAL Calculations - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 3 NL-15-1898, Enclosure 3: Hatch EAL Calculations - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 2 of 3 NL-15-1898, Enclosure 3: Hatch EAL Calculations - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 3 of 3 NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 6 NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 2 of 6 NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 3 of 6 NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 4 of 6 NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 5 of 6 NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 6 of 6 NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 8 NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 2 of 8 NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 3 of 8 NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 4 of 8 NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 5 of 8 NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 6 of 8 NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 7 of 8 NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 8 of 8 NL-15-1898, Enclosure 5: Vogtle Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 4 ... further results
References
NL-15-1898
Download: ML16071A188 (50)

Text

E-HU1 ECL: Notification of Unusual Event Initiating Condition:

Damage to a loaded cask CONFINEMENT BOUNDARY.Operating Mode Applicability:

All Emergency Action Levels: (I) Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 ti!mes the site speeifie ac-,:k epecifie technical epeelt+icati

.... ~lloal r.adi.tion le....l) on ,th .....e af th.. sent. f... l + a, c ANY valtuc listed on 7U .l i:0 i: V~atlw' of Dose Rzte ll~-1J~ 25$id b b __________________________

WI IJI4TAII AttwHL-$TQRMI~11 V 0 30 I Basis: C()NtINNllIN I 1301 Nl)ARY: I hc barnrers) arca~s containinag radioacti,,e suhsianccs anld thc II if)lroncnft.

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes whieh-tlhat could cause challenges in removing the cask or fuel from storage.81 The existence of "damage" is determined by radiological survey. The radiation reading values listed in the table represent 2 times the sitepcSlCiei cask-specific technical specification allowvable radiation level on the designated surthecc of the spent ftci cask. The technical specification multiple of"2 times", -hich ic alce u.ced inz Peecagn'itiz Categcr:'

R IC R.UI, is used here to distinguish between non-emergency and emergency conditions.

The emphasis for this classification is the degradation in the level of safety of the spent fuel cask, and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the-fact hatdcterntining if the "on-contact" dose rate limit is exceeded may be detem1ifned-based on measurement of a dose rate at some distance from the cask.Security-related events for ISFSIs are covered under ICs HU1I and HAlI.in the Cer"tificate of Cemplianee the related NRPC Evaluati.en RPai.cp identi:fy the 1BOU N.TDIARY.

Thia; E2AL l dreaace~s damage that ceuld r..... fre ran..... t identified natural or man made ........ e.g ....adee ir, tip.. d zvv.......

E. PLOSI.. ..F.......EARTUQUKE

.t......, ECL ,^aai:.7nment Attributed:

3.l.I.B 82 06 FISSION PRODUCT BARRIER ICS/EALS ae-9-FA----1.Recognition Category "'F" Initiating Condition Matrix LOSPLODNAL LOSS POCNA LOS 555t*__ GENERAL EMERGENCY Loss of any two barriers and Loss or Potential Loss of the third barrier.FGI Op. Modes; Power Operation, Hot Standby.Startup, Hot Shutdown__ SITE AREA EMERGENCY Loss or Potential Loss of any two barriers.FI Op. Modes: Power Operation, Hot Standby, IStartup, Hot Shutdown-- -,o5 END ~LOSS i __ ......LOSS I, A ALERT Any Loss or any Potential Loss of either the Fuel Clad or RCS barrier.FAI Op. Modes: Power Operation, Hot Standby, Startup, Hot Shutdown LOSS LOSS~LOSS LOSS S-z TaIkI9 FI "fA- 1}1WR E- Lt D.........

.. :..... ...... fl: ' j .....y^ is fo tyji ......Th ' ...... .I t% .'t~~i1 83

1. Tha ta~ia nani fer thana iritiating ditnna raflaatz tha fctIa~.'~r.g aan~idaraticna:

Tha Fant Clad Baanar a..d tha RCF Bani.. .....~,htJ ..... h..... I, th.... thaCantanniant Ban~an.In.. .1/'. C..A..4.LC,~..A..

~ p~,...;.;.....r,...

C........ p, ..........

v ...........

1. cmlt r' t.c~.ati.n methodi fer tinc RP."nngnitin Catagar'y F IC. and fi=:.dnn pmadnact bari'jar thre~hzti=

ara aaaaptabla an j*.Iud; ti,;ch zi an!zzd cznc.teme naaha.:.n:

in thB\RarP.rPWR pm=dnathn.-..a"mt hL. The NRC ata..ff annaida.a tha^ .....t"t n abrtRed af -ha .. aagaactzan the "am, -*ncna....................

t a..... d ........ .mamj.aataahTan.-

ta, S aetat~dta.p but ...... i~a................

..........

.,,a..--,aaa.......mat an i te a .......... r...... ........jna.e~den tha lana~ af RCS mann t. any tneaticr Jni-de aim-.ni'a~~t,., na .

ny."tan (ia., PWP. ntn--l gau.a~tor tabe !c.daaga).

an'a rmiinfv;'a;e

.. .et c..eid..'.d tn ha .C$ !tadaae..ascatata to a Gananrat Emaaganay.

"7..... Tbhe alninty In aeaalate ta a. high:am ...........

... ...........

cann.....n-^*ma*^

!r t dagm'-ading annidtiena aha.ld ha maintainad.

F.ar c...anip, a 84 Fission Product Barrier Table Thresholds for LOSS or POTENTIAL LOSS of Barriers FGI GENERAL EMERGENCY Loss of any two barriers and Loss or Potential Loss of the third harrier.FSI SITE AREA EMERGENCY FAI ALERT Loss or Potential Loss of any two barriers.

FueAny Lossca Oor anyRCPotentialbri.

Loss of either the Fu.......

a... .... .. .RE B rre ...... ...... Ba se LOSS POTENTIALLS LOSS POTENTIAL LOSS LOSS POTENTIAL LS 1. RCS Activity 1. Primary Containment Pressure I. Primary Containment Conditions A. ,+Si......

l., Not Applicable A. Primary Not Applicable A. UNPLANNED A Primary,

containment rapid drop in containment

=:rc:!- pressure greater primary pressure greater5 containment than *~.th4Onjs iLgi/s.: speeic. due pressure following seii to RCS leakage, primary vo 4-34-+/- \cji ut? containment OR B. Primary containment pressure response not consistent with mPtue exists LOCA conditions, inside primary containment OR C. HCTL exceeded.2. RPV Water Level 2. RPV Water Level 2. RPV Water Level SA. A. RPV water level A. RPV water level Not Applicable Not Applicable

]A. iuy eflet cannot be cannot be restored 4edi j restored and and maintained fIodg eequi-eedAG maintained above above $5ialr _____________

etie-AG 85 I~i~-~cqu*~41Ji Vtstt .tO~m5m~s4f441rV7RWL~wt~t~The6y LOSS POTENTIAL LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSSet" l or cannot be fse~ or cannot be determined.

determined.

3. Not Applicable

3. RCS Leak Rate 3. Primary Containment Isolation Failure Not Applicable Not Applicable A. UNISOLABLE A. UNISOLABLE A. UNISOLABLE Not Applicable break in Maii primary system direct downstream St'llIn K Il( leakage that pathway to the I dxae results in environment existsT oK it(l exceeding after primary AYe4eEITHER of the containmentfollowing:

isolation signal spe......

s..... I. ~~~ii OR..... O ..........

B. intentional primary* .,, .. ....w: ....containmentventing per EOPs OR2. ...... O B. Emergency RPV C.USOAL Depressurization.

primary system Level.leakage that results in exceeding EITHER of the following:

OR 2.twS[V Ii~~iit~47~s Vt25 yCoab.R$k~ptso I 86 ii 87 Basis Information For BWR-DEAL Fission Prdc *are lIl* Tse-9-,., F4 BW-R-FUEL CLAD BARRIER THRESHOLDS:

The fuel clad barrier consists of the zircalloy or stainless steel fuel bundle tubes that contain the fuel pellets.1. RCS Activity Loss l.A This threshold indicates that RCS radioactivity concentration is greater than 300 PaCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5-%- percent fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the fuel clad barrier.It is recognized thit sample co!lection and anaI\ysis of reactor coolant x~ilh highis elevated aictix it) tc,,cls could require se, eral hours to complete.

Nonetheless, a sample related threshold is included as a backup to other itndications.

There is no potential loss threshold associated with RCS Activity.

...... site ....s+ pecific capabilities, this; threshald may, have a amaple analys'is ccmpcnnt and/gcr a radiatien mnitar rdingec.........

Ad t his p..r.gr..ph (ar. sim;iar...

arding, ta+ the Basis: if te +1-h e.hoeld includesao an...i e"o mp......., "It is recognized tat. sample collection and analysis:

afreac~tar Ncnethceless a sample related thres~hald is in':.ludred as a backup ta other indieations." 2. RPV Water Level Loss 2.A++++° + ... ...... .. ++ +' + + + + ++ a + + ++ + ++ + + :i +88 Potential Loss 2.A This water level corresponds to the top of the active fuel and is used in the EOPs to indicate a challenge to core cooling.The RPV water level threshold is the same as RCS barrier Loss threshold 2.A. Tgh**-,This threshold indicates a potential loss of the fuel clad barrier and a loss of the RCS barrier that appropriately escalates the emergency classification level to a Site Area Emergency.

This threshold is considered fe-be-exceeded when, as specified in the site-specific EOPs, RPV water cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization.

EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this fuel clad barrier potential loss is met only after either: 1) the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory.

The term "cannot be restored and maintained above" means the value of RPV water level is not able to be brought above the specified limit (top of active fuel). The detenmination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation below the The threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained.In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level to the top of active fuel in order to reduce reactor power. RPV water level is then controlled between the top of active fuel and the Minimum Steam Cooling RPV Water Level (MSCRWL).

Although such action is a challenge to core cooling and the fuel clad barrier, the immediate need to reduce reactor power is the higher priority.

For such events, ICs SA5 or SS5 will dictate the need for emergency classification.

Since the loss of ability to determine if adequate core cooling is being provided presents a significant challenge to the fuel clad barrier, a potential loss of the fuel clad barrier is specified.

lDeve~pe~-oer et 89

3. Not Applicable (included for numbering consistency between barrier tables)4. Primary Containment Radiation Loss 4.A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals 300 pCi/gm dose equivalent I-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5%4- percent fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the fuel clad barrier.The radiation monitor reading in this threshold is higher than that specified for RCS Barrier loss threshold 4.A since it indicates a loss of both the fuel clad barrier and the RCS Barrier. Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.

There is no potential loss threshold associated with primary containment radiation.

The reading 5hould be dete:rminked the releaa.e and diupermal ef ,he..... to 300 pa dc .. ui..l. n :"' I 13' inte the primary ....tain....t atmeephera.

5. Other Indications L~os> 5A Readinos hrom Om['las pre- and post-treatment monitors that indicate OtV~cale t ligh are used to detect the effluent of the Otfgas s) stem anmd therefore iudicate fission products escaping the clad, Calculated readings Ibr 300) p'igigm are 4.82 \ el8 cps and the instruments to of scale is I c-i 6 cps, lhese instruments going high otiseale pros idc an indication that there isclad damage to aid in elassifticat ion of an event. Sam pie results are still needed to establish that the 300 pCi."ign threshold is being esceeded.I here is no potential loss threshold associated ,a ith ()ther Indications.

90 This ~u~thresho addresses ancther fa~ pcitors hrhd~ thatse may the emrgnI tcy idirctr in c determning whehe fthe fuel CLad barrier bisc znplost.ifcd~g Pote ntialLos 6cz.tAlL&5.

This thpreshold addresssny ifother fclactor thdat may be use tbylt the mrec dietoru inth deemnaying whether the Fupael)h gCla Briert is oenti'ally loni. Te riemserecy irecto barrier-ac ihl alhso consider winthir orunot todcarez thfrbarrienfr ptenial lothin the event mayhat ua oguatarlt~

barrierrsatuhcanot e1mnitred 6. EmerenpcyDrctorJugmn 91 B-WR-RCS BARRIER THRESHOLDS:

The RCS Barrier is the reactor coolant system pressure boundary and includes the RPV and all reactor coolant system piping up to and including the isolation valves.1. Primary Containment Pressure Loss 1.A The ..r........primary containment pressure is the -I drywell high pressure setpoint which indicates a LOCA by automatically initiating the ECCS or equivalent makeup system.There is no potential loss threshold associated with primary containment pressure.2. RPV Water Level Loss 2.A This water level corresponds to the top of active fuel and is used in the EOPs to indicate challenge to core cooling.The RPV water level threshold is the same as fuel clad barrier potential loss threshold 2.A. This threshold indicates a loss of the RCS barrier and potential loss of the fuel clad barrier, and that appropriately escalates the emergency classification level to a Site Area Emergency.

This threshold is considered leobe-exceeded when, as specified in the site-specific EOPs, RPV water cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization.

EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify' depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this RCS barrier loss is met only after either: 1)the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory.

The term, "cannot be restored and maintained above," means the value of RPV water level is not able to be brought above the specified limit (top of active fuel). The determination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not 92 require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation beyond the limit,-. The threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained.In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level to the top of active fuel in order to reduce reactor power. RPV water level is then controlled between the top of active fuel and the Minimum Steam Cooling RPV Water Level (MSCRWL).

Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority.

For such events, ICs SA5 or SS5 will dictate the need for emergency classification.

There is no RCS potential loss threshold associated with RPV water level.3. RCS Leak Rate Loss Threshold 3.A Large high-energy lines that rupture outside primary containment can discharge significant amounts of inventory and jeopardize the pressure-retaining capability of the RCS until they are isolated.

If it is determined that the ruptured line cannot be promptly isolated from the control room, the RCS barrier loss threshold is met.Loss Threshold 3.B Emergency RPV Depressurization in accordance with the EOPs is indicative of a loss of the RCS barrier. If emergency RPV depressurization is performed, the plant operators are directed to open safety relief valves, (SRlVs '- : J,, Even though the RCS is 1:1 0I FQ 2W500 ti l }uc being vented into the suppression pool, a loss of the RCS barrier exists due to the diminished effectiveness of the RCS to retain fission products within its boundary.Potential Loss Threshold 3.A Potential loss of RCS based on primary system leakage outside the primary containment is determined from EOP temperature or radiation Max Normal Operating values in areas such as main steam line tunnel, RCIC, HPCI, etc., which indicate a direct path from the RCS to areas outside primary containment.

A Max Normal Operating value is the highest value of the identified parameter expected to occur during normal plant operating conditions with all directly associated support and control systems functioning properly.The indicators reaching the threshold barriers and confirmed to be caused by RCS leakage from a primary system warrant an Alert classification.

A primary system is defined to be the pipes, valves, and other equipment whaieh-that connect directly to the RPV such that a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system.An UNISOLABLE leak which is indicated by Max Normal Operating values escalates to a Site Area Emergency when combined with containment barrier loss threshold 3.A (after 93 a containment isolation) and a General Emergency when the fuel clad barrier criteria is also exceeded.t.Primally olataned nt Radtiation fteLaDtcincyt.

Thjeraition monCitor redating RctorresptndsCloanu insantCeus, releaseon Candenctr (C crRlantr Cars intolthepimr Conaling menC)tht, asun thSOat Leatorclnt actignity eant Iclaeare ostrsod4Asnei niae os of the RCS barrier oly 4. r P n otnills trsodasoitdwt rimary Containment Radiation.

ac!'b tTechnical Specificatio loabl Th.isralu ,eisn: loeh!an th:at- speifie for fUel Thre reading hudi berdenti-er

-"mindac th."x a:'ed ..nati.anin u .-r elca.e aend d'.i.p---

a o f th...........e

.... gace.......t.b.di.ti..u.ce fr.......

radiatian emanating frm piping .ampnena eataiing levted eacar ealat aciviy. I c refr t theDevlope

5. Other Indications I oss 5A A Drx well I ission Pr oducts Monitor reading 5.0 x 1 05 cpm indicates a breach of thc RCS as an effluent.

The monitor ,,aluc calculated in Calculation SM N H-I13-021.

Rex I. xxas 1.008 x I 0' cpm: hoxxcvcr, rhe top of thc scale for the monitor is I \ 10" cpm. Therefore.

94 the IAL, threshold value has been established at one half decade belo'v top ol scale to aid the operator in distinguishina betx~een a loss of RCS cx ent and an insiruiment failure resulting in the monitor readina high off" scale. No~( radiation monitors capable ol indticatina a po~tential loss of the R,(S barrier xscre identified.

I here is no Potential I oss Threshold associated xs ith Other Indications.

Losa an4'r Pztzntinl 5.A This zubzatzgzr.' ether zite specific thrczhc.ld:

that may be inzludsd tc indicate D-e~lopcr:;

m hcukl deter'mine if ether reliable i.ndicators te evaluate the zfthb.fie,,in" ..

ba.rrier (e.g, r..i..a. id.t..............d i th i.. .... .... Fina.... ... Saet indicatiaen that will pramote timely and accu-rate acceccrnent of barrier etatuc.: 6. Emergency Director Judgment Loss 6.A This threshold addresses any other factors ~hthat erete-be-used by the emergency director in determining whether the RCS barrier is lost.Potential Loss 6.A This threshold addresses any other factors 4ha, i--my.b-bused by the emergency director in determining whether the RCS Barrier is potentially lost. The emergency director se4 xx ill also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

95 B-WR-CONTAINMENT BARRIER THRESHOLDS:

The primary containment barrier includes the drywell, the wetwell, their respective interconnecting paths, and other connections up to and including the outermost containment isolation valves. Containment barrier thresholds are used as criteria for escalation of the ECL from Alert to a Site Area Emergency or a General Emergency.

1. Primary Containment Conditions Loss l.A and I.B Rapid UNPLANNED loss of primary containment pressure (i.e., not attributable to drywell spray or condensation effects) following an initial pressure increase indicates a loss of primary containment integrity.

Primary containment pressure should increase as a result of mass and energy release into the primary containment from a LOCA.:lu Primary containment pressure not increasing under these conditions indicates a loss of primary containment integrity.

These thresholds rely on operator recognition of an unexpected response for the condition and therefore a specific value is not assigned.

The unexpected (UNPLANNED) response is important because it is the indicator for a containment bypass condition.

Potential Loss l.A The threshold pressure is the primary containment internal design pressure.

Structural acceptance testing demonstrates the capability of the primary containment to resist pressures greater than the internal design pressure.

A pressure of this magnitude is greater than those expected to result from any design basis accident and.hi represents a potential loss of the containment barrier.Potential Loss I .B If hydrogen concentration reaches or exceeds the lower flammability limit, as defined in plant EOPs, in an oxygen rich environment, a potentially explosive mixture exists. If the combustible mixture ignites inside the primary containment, loss of the containment barrier could occur.Potential Loss I.C The heat capacity temperature limit (HCTL) is the highest suppression pool temperature from which emergency RPV depressurization will not raise: Suppression chamber temperature above the maximum temperature capability of the suppression chamber and equipment within the suppression chamber which may be required to operate when the RPV is pressurized, OR Suppression chamber pressure above Primary Containment Pressure Limit A, while the rate of energy transfer from the RPV to the containment is greater than the capacity of the containment vent.96 The HCTL is a function of RPV pressure, suppression pool temperature and suppression pooi water level. It is to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant and therefore, the inability to maintain plant parameters below the limit constitutes a potential loss of containment.

BW' erPr a'SAue s" Tpeiial dhefhine thelimit as::~ sa'citdih pliv mixture"isyoyo s in!k h EPG/SAG "'deflagraticn limits".Since the HCTL is defirned assumilng a rane, cC f uppression po w.t.r.....l............

Patential Loas thresalod ba.cd an the inabilty ta maintain suppressian p.al water lavel decay heat. remove!~ if it willt simplify the assessezz.net eaf the suppression poo!2. RPV Water Level There is no loss threshold associated with RPV water level.Potential Loss 2.A The potential loss threshold is identical to the Fuel Clad Loss RPV W 9 A The nntpntiml IAQQ rpnuiirpment fnr ~mr "i~r"n 'irh c~uum.ntad( ~core cooling.PRA studies indicate that the condition of this potential loss threshold a core melt sequence if not corrected, could lead to RPV failure and increased potential for primary containment failure. In conjunction with the RPV water level loss thresholds in the fuel clad and RCS barrier columns, this threshold results in the declaration of a General Emergency.

97

~Doeve~i-Nete**

3. Primary Containment Isolation Failure These thresholds address incomplete containment isolation (autonmatic or manual) that allows an UNISOLABLE direct release to the environment.

Ax Loss 3.A The use of the modifier "direct" in defining the release path discriminates against release paths through interfacing liquid systems or minor release pathways, such as instrument lines, not protected by the Primary Containment Isolation System (PCIS).The existence of a filter is not considered in the threshold assessment.

Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.Following the leakage of RCS mass into primary containment and a rise in primary containment pressure, there may be minor radiological releases associated with allowable primary containment leakage through various penetrations or system components.

Minor releases may also occur if a primary containment isolation valve(s) fails to close but the primary containment atmosphere escapes to an enclosed system. These releases do not constitute a loss or potential loss of primary containment but should be evaluated using the Recognition Category R ICs.Loss 3.B EOPs may direct primary containment isolation valve logic(s) to be intentionally bypassed, even if offsite radioactivity release rate limits will be exceeded.

Under these conditions with a valid primary containment isolation signal, the containment ehetil-l also be considered lost if primary containment venting is actually performed.

Intentional venting of primary containment for primary containment pressure or combustible gas control to the secondary containment and/or the environment is a loss of the containment.

Venting for primary containment pressure control when not in an accident situation (e.g., to control pressure below the dryweUl high pressure scram setpoint) does not meet the threshold condition.

Loss 3.C The Max Safe Operating Temperature and the Max Safe Operating Radiation Level are each the highest value of these parameters at which neither: (.) equipment necessary for 98 the safe shutdown of the plant will fail, nor 4+2) personnel access necessary for the safe shutdown of the plant will be precluded.

EOPs **ilk-e-use these temperatures and radiation levels to establish conditions under which RPV depressurization is required.The temperatures and radiation levels 5teodd-wil!

be confirmed to be caused by RCS leakage from a primary system. A primary system is defined to be the pipes, valves, and other equipment whiehthat connect directly to the RPV suieh-ha~insuring a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system.In combination with RCS potential loss 3.A this threshold would result in a Site Area Emergency.

There is no potential loss threshold associated with Primary Containment Isolation Failure...............

ma b ....... tc ....t n thz. ..... fl p ... rccedural ztzp ..............

Prim .ry....imz.t..........

..... .. th..t.........................

vctn zfthc Cznt.,.inn

...regardless radicaeti'ity; relaa~c rate.4. Primary Containment Radiation There is no loss threshold associated with primary containment radiation.

Potential Loss 4.A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that 2 0%.-percent of the fuel cladding has failed. This level of fuel clad failure is well above that used to determine the analogous fuel clad barrier loss and RCS barrier loss thresholds.

NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately percent in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist, there must already have been a loss of the RCS barrier and the fuel clad barrier. It is therefore prudent to treat this condition as a potential loss of containment ,whieh-hat would then escalate the emergency classification level to a General Emergency.+:./++ ... .p n;+*. .. -NoteOA4,1 1,+4+ s:1.. .. 99

5. Other Indications Not Applicable (included numbering consistencx barrier tables)Lc.ee ana~'cr Po.tential Lasz 5.A Th~yie ..... ..g ,, as -dr-eeee*a eTher gtea epci thr that mn y be inc-luded' t inficat ine dreptermnting wheter the containment barrier isee lost. n eeiiede Le d/rPotential Loss 6.A Thvisthes hould ddrtesses ify other rflactor thdaterasb used tby~lut the eterenc drtof hin nyddedemnn thretherd theul conpainent bapprier isptentaly thoerlastiTe ehrgenay toiteto may beuced-w tlo gaugier the rther o~r nthreto delaevtelbrirptnily oti hvn Thsthabariesholdaddrssesanynothbermfatorse htaetde.sdb hmegnydrco 100 J,07HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS GENERAL SITE AREA EMRENY EMRENYALERT UNUSUAL EVENT HGI HOSTILE HlS1 HOSTILE HAl HOSTILE HU1 Confirmed ACTION resulting in ACTION within the ACTION within the SECURITY loss of physical PROTECTED AREA. OWNER CONDITION or control of the facility.

Op. Modes: All CONTROLLED threat.Op. Modes:" All AREA or airborne Op. Modes: All attack threat within 30 minutes.Op. Modes:" All HU2 Seismic event greater than OBE levels.Op. Modes: All HU3 Hazardous event.Op. Modes: All HU4 FIRE potentially degrading the level of safety of the plant.Op. Modes: All HA5 Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.Op. Modes:" All 11S6 Inability to 11A6 Control Room control a key safety evacuation resulting in function from outside transfer of plant the Control Room. control to alternate Op. Modes: All locations.

Op. Modes: All 101 GENERAL SITE AREA EMRENY EMRENYALERT UNUSUAL EVENT 11G7 Other HS57 Other HA7 Other HU7 Other conditions exist which conditions exist which conditions exist which conditions exist in the judgment of the in the judgment of the in the judgment of the which in the emergency director emergency director emergency director judgment of the warrant declaration of warrant declaration of warrant declaration of emergency director a General Emergency.

a Site Area an Alert. warrant declaration of Op. Modes:" All Emergency.

Op. Modes:" All a (NO)UE.________Op.

Modes: All _ _______Op.

Modes: All 102 HG1 ECL: General Emergency Initiating Condition:

HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:

All Emergency Action Levels: (I) a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA (PA) as reported by the Security Shift Captain or dcsigncc(-si~te-speei-ie AND b. EITHlER of the following has occurred: I. ANY of the following safety functions cannot be controlled or maintained.

• Reactivity control* RPV water level-f.W-

• RCS heat removal OR 2. Damage to spent fuel has occurred or is IMMINENT.Basis: II I()S [ll I ACI It()N: An ac t toss atd a nuclecar poss cr plant (N PP) or its persomncel that i ncl udes~tihe use oF violenit tbrcc to detoyeuipment, take I I( )S IlAG![S, and/or intirnidate thc l icclnsce to atchics c an end. Ibhis inc ludcs attack b\ air, laud. or ssatcr using guns. cxptosix cs.PR()F H 'TIIt Is. '.ehicles, or other de ices uscd to delis cr dcstructisc liwcc. ()ther actts tha.t satist\ thc overall intent mas hc includ,.d.

I 1OSTIII!: should not con*strued to inclIude acts ot ci il d isobed ience or l; Ion ions acts that arc not part otfa conccrtcd attack on the NPP. Non-terrorism-hascd

[Al .s should be used to address such activitics (ice.. this max include ,s iolcnt acts be<tssctie individuals in the osxncr controlled arca tOC(A)).I \MM1NLN I : lhc tiajcctory of ce cuts or conditions is such that an [Al ss itt hc nict within a rclatiycl\

short period of timtc regardless of mitigation or corrective actions.PR( )ltt{i 114 ARIA I(PA): l'hc arca that cncontpasscs alt controlced arcas ss ithin thc security protcctcd arca lt.-ncc.This IC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions.

It also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to I) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls,-.el.)

or; 2) loss of spent fuel pool integrity stieh-so that sufficient water level cannot be maintained.

103 Timely and accurate communications between Security shift supervision and the control room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Thoe (site

...urity shf ..... ... i... ) ..... h..... t...f.th....n...hi...in

......ual r,-pon.ibl....r E.me~rgencypan ari n.'d implem.enting pr 'dure&ar publi docum.. nt..:.....................h.uld adanag...

us t.... a ..t..ti.l advesa...., such so thc particuhors concerning a specific threat+ or such as the Plan.With due cn..i..eration++--

gi:e .... abOVe developer note, EAL ay ... ntai.. al.ha numb.. t....... secte e..n. descri..bed in Security Ptan and .....oci.ate implem..nting

...ample,+ an EAL m...' be ..rd.d .+as. ,,ct .... nt...... #5' or ^ #9 is reported by. the (site ...e.ifico ECL+ A.ssi.enmentAtibutes:

..,.- .atJ 104 HG7 ECL: General Emergency Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of a General Emergency.

Operating Mode Applicability:

All Emergency Action Levels: (I) Other conditions exist which in the judgment of the emergency director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.Basis: I!I()Sl I~tl AC 1I( IN: An act tos\,ard a nuclear posser plant (N P1) or its personnel that includes the usc of x olen~t lbrce to dcstroy cquiptnent, takc I lOS'I AGILS. and/or intimidatc the licensee to achice e an end. [his includes attack h) air, land, or usinag guns. cxplusivcs.

I'ROJLC Ill I/:s. 'vehicles.

or other devices used to deliver destructive toree. Other acts thait sat is! thc o\ecral I intent ni a be in~cludedI t( )S IlliA; A( 1 ION should not he construed to include acts ol civil disobedienee or kilonious acts that are not part ol' a concerted attack on thle N PP.

[!Al s should he used to address such a~ctis ities (ice.. this ma\ incltudc v iolcut acts indis iduals in thc owner controlled area (O(A)).I ,I lINI/N I: I he I ratjctors olfecents or conditions is such that an LA AI he nict within a relativcl\

shot~r period of time regardless ol' mitigation or corrective actions.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist wieb-that are believed by the emergency director to fall under the emergency classification level description for a General Emergency.

105 HS1 ECL: Site Area Emergency Initiating Condition:

HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:

All Emergency Action Levels: (I) A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREAas reported by the Seccurity Shift Captain or h!ft Basis: IIO S I II Ii AC I 1O)N: A n act tot'. ard a nutc cl ox' pmcr plant (NPP'l) or it s personnel that i ncl udes thc usc of violcnt tbrcc to dcstroy e quiptmnt.

takc I IO S I AL I S. and byju in iidaic the licenscc to achievec an cnd. Ihi s inicludes attack hy air. land. or w\atcr using guns. explosives.

PRO)Jl[IL(IIIs, vchictcs, or other dcv iccs uscd to delivcr destructive Ibrce. ()ther acts that sat isf3 ilk o\ intcnt may hc cinchdcd., I( ttSll ,II AC I'I )N should not hc constmced to inclIudc acts ot civil d isohedicncc or ti. tonions acts that! arc not part o F a conccrtcd attack on thc N'PI. Non-tcrrorismn-hascd

[Al .5 sthould bc uscd to addrcss such actit itics i~c., this nmav includc violcnt acts hctxxccn imdix idual, in the ow'.ncr controllcd arca t(O ).,\).PR() I [CU IFl) AREA (PA): ['hc arca that cncomnpasscs alt controtlled areas xvtthin thc sccuritx protectcd arca tizncc.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA.This event will require rapid response and assistance due to the possibility for damage to plant equipment.

Timely and accurate communications between Security shift supervision and the control room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualifi cation Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal.

or sheltering).

The Site Area Emergency declaration will mobilize ORO resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.

This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA; such an attack should be assessed using IC HAl.It also does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, or physical disputes between employees,--ete.

Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.106 Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level ...........

us IC HGI.super.':sien G~f the an shift security, feree.Em.r..n. pl.... an.... implement'ng procedures are public documcnts; therefcrc

[ALtsheu...d such as; the Security Plan.With,.. due consideratien gi-ven ta the a.bc'c...

dcvleoper note, EA.s ....- centain lpha .sr numbered re.fernc to L~etd events described, in the Sceurity' Plan ~danss.ceciate.d implementing security, shift super-visien)." a eheme 'lefniticn fr~r th~e PROTECTED AREA.ECL Ass:gnmcnt Attributes:

J. 1.3 .D 107 HS6 ECL: Site Area Emergency Initiating Condition:

Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:

All Emergency Action Levels: SNote: The emergency director sho*d ill. declare the Site Area Emergency promptly upon determining that (site speeific number cl 15 minutes-)

has been exceeded, or will likely be exceeded.(1) a. An event has resulted in plant control being transferred from the control room to remote shititdo>

n pancI;(site speitc!. remote ihu.,cw .a...... and n tc..AND b. Control of ANY of the following key safety functions is not reestablished within (oitc:' ............

1t 5 minutes).* Reactivity control* RPV water level-fWR* RCS heat removal Basis: This IC addresses an evacuation of the control room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plant control to alternate locations is a precursor to a challenge to one or more fission product barriers within a relatively short period of time.The determination of whether or not "control" is established at the remote safe shutdown location(s) is based on emergency director judgment.

The emergency director is expected to make a reasonable, informed judgment within "(thz.. It.. zpc..... for..,.

I5 minutes a> 10 whether ef--te-the operating staff has control of key safety functions from the remote safe shutdown locationfs-).

Escalation of the emergency classification level wel'o! -be vie~use IC FG1I or CG 1.The "!e o pe e.fNo# ... s n"+:"- ...

..Th 'it pcifzrzct hudcv~pnzz n lza znrc taiz~'a~ hcpn~~108zntc pcricd may b~ u~ad with apprapriata b~L/Iuiiflcatizn.

EUL Aalanmzrfl Attnbutcs:

3.1.3.B 109 HS7 ECL: Site Area Emergency Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of a Site Area Emergency.

Operating Mode Applicability:

All Emergency Action Levels: (1) Other conditions exist which in the judgment of the emergency director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, *1) toward site personnel or equipment that could lead to the likely failure of or, that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Basis: I1lOS [I'I!F A(XI IO N: An act toward a nuclear power plant (NPP) or its personnel that includes the ose of violent force to destroy equipment.

take ttOS !A(IBS, and/or intimidate the licensee to achieve an end. T'his in~cludes attack by air, land. or water using guns. cxplosix es, PRO.IECTII.l-ys vehicles, or other devices used to (lelivcr destructive force. Other acts that satisfy, the overall intent max he: included.

IIOSTILIi; ACITION should not be construed to include acts of civil disobedience or le!onious acts that ate not part ot a concerted attack on the NPP. Non-terrorism-based EAI~s shottld be used to address such activities (i.e.. this may include violent acts betweecn individuals in the oxx~ner controlle~d area (O(iA)).This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist ,hieha-thai are believed by the emergency director to fall under the emergency classification level description for a Site Area Emergency.

110 HA1 ECL: Alert Initiating Condition:

HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.Operating Mode Applicability:

All Emergency Action Levels: (I or 2)(I) A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA l(OA) as reported by the Securit) Shift (Captain or dcsiignce(aite Tpec'fic security (2) A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.Basis: I IO 5It-1 ,\( I'ION: An act toxxad a nuclear poxxcr plant (N PPI 01 its personnel that include>the use ofx iolent force to destroxy cqoipmnent, take IIlOS IA( iLS. and/or intimidate thc licensee to achieve an end. I his includes attack hx air. land, or water using cutsc explosives.

PR()J 1(1 I' s. xehiclcs.

or other dex ices used to dclix cr destructix.e iwrc., t ither acts that sat is t\ the oxerall intent oays he incl1uded.

II tO( III. AC I IO( N should not he construed to include acts of cix ii d isohed ience or flIon ious acts that are not part ot a conceited attack on the NPP. Non-terrorisnt-based I Al s shoutld he used t'o address sutch actixities (ice.. this max includeoletnt acts hetxxcen individuals in the owsner controlled area O(OCA)).O)V NI H ( UN I R( l1I,1-1) ARIA t(d'At: ] he site property ost ned by or o~therxx i~c under thc control 01 I INP Security This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA (PA), or the need to prepare the plant and staff for a potential aircraft impact.Timely and accurate communications between Security shift supervision and the control room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualifi cation Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal.

or sheltering).

The Alert declaration will also heighten the awareness of offsite response organizations, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, or physical disputes between employees,-ete.

111 Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL # 1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA.EAL #2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness.

This EAL is met when the threat-related information has been validated in accordance with stai ion " -o* u" .... if,, pr.... re.....The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate federal agency to the site would clarify this point.In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a federal agency.Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level weuild-be-v4au-scs IC HS I.Emergency, pane and i:mplementing pr....d.....

e ..ub.i ..d...m.n....th.....r.......

..h.... net ........at S"nEAuriy zeeiie ..... a tien. Thcuity in-luen #2, #5 or , th, t may:te be'a adatgcue .t. peenia a...er.... , .. h a- th ,D~nticureeneen ao gu eitane athreat thea lepin.Seurt cnetieine~tinehul b unoi~e n enpul112cmet FCL Mzi~nmcr.t Attribut~z:

3.I.2.D 113 HA5 ECL: Alert Initiating Condition:

Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

All Emergency Action Levels: SNote: If the equipment in the listed room or area was already inoperable or out-of-service before the event occurred, then no emergency classification is warranted.

(1) a. Release of a toxic, corrosive, asphyxiant or flammable gas into any 4h re4wi~ abic tIll plant rooms or areas: '[able Ill Btuilding Rooms. Applicable Modes I )icscl ucn~cratr building AlI A\lI tUnit 1P2 130 All R, ector building t nit 1/2 ~Sl! lDin 'nals (RI IR) All tUnit 1/2 NP Diagonals (RI IR) All (~ic pecfi lit f plat! as~ ....... ith ..... rclatcd mode AND b. Entry into the room or area is prohibited or impeded.Basis: This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to maintain normal plant operation, or required for a normal plant cooldown and shutdown.

This condition represents an actual or potential substantial degradation of the level of phint safety o ....e-plei.'.An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the emergency director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert. or operating experience with the same or similar hazards.Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

114 An emergency declaration is not warranted if any of the following conditions apply.* The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release).

For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.* The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).* The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

• The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels.Most commonly, asphyxiants work by Imefey-displacing air in an enclosed environment.

This reduces the concentration of oxygen below the normal level of around which can lead to breathing difficulties, unconsciousness.

or even death.This EAL does not apply to firefighting activities that automatically or manually activate a fire suppression system in an area, or to intentional inerting of containment ,tWR-eD ._, Escalation of the emergency classification level ...... ,-, k u ., Reogiio.atgryR.Co F ICs.The ..... .... sp :ecific list ..f pla.t-"' .. rooms or areac with entry related mode applicability identified"'specify rooms or ar-eas that' contain quimen ....h requir....

a ........ /'eal action as specifi.ed in .p.rtin pr... dur.. us.....d" for normal operation, co^ld.....

en shtown.. ...plan m.d.... during'; which entry. ...uld be .required for each room or area.f.......y.icluebut..

o....... limited.......

to, .apailit to draw..air....om multpe air intak2es a~t acquire and maint:ain.=.

po.ti. pressur.......

within- te Control Roo en.elop... Ifthek. equipen i the.listed room..or...ea..w..al..

ady inoperable o.... out ofi ..r.ic.....ore.the e.ent oc.urred, the noI e.. rgen. y should.. be.I declared ince4.;-.

the evn will. + ,,1 n .. ad.....iLUL Ass...nment

... l"1.2U 115 HA6 ECL: Alert Initiating Condition:

Control Room evacuation resulting in transfer of plant control to alternate locations.

Operating Mode Applicability:

All Emergency Action Levels: (1) An event has resulted in plant control being transferred from the control room to rem1ote shutito , puIanclis,,it

.... fi rzm.... hu............n.l.......

.............

)Basis: This IC addresses an evacuation of the control room that results in transfer of plant control to alternate locations outside the control room. The loss of the ability to control the plant from the control room is considered to be a potential substantial degradation in the level of plant safety.Following a control room evacuation, control of the plant will be transferred to alternate shutdown locations.

The necessity to control a plant shutdown from outside the control room, in addition to responding to the event that required the evacuation of the control room, will present challenges to plant operators and other on-shift personnel.

Activation of the ERO and emergency response facilities will assist in responding to these challenges.

Escalation of the emergency classification level we*.:.d-be-:'auscs IC HS6.cta-tion; rzfercnczd in plant przccdure;

'us'ed tc cccldc-:, and thc plaznt f'rcm a....ic(~ :, uti.... , the, Control Room.116 HA7 ECL: Alert Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of an Alert.Operating Mode Applicability:

All Emergency Action Levels: (I) Other conditions exist which, in the judgment of the emergency director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Basis: I!(t)S Illt1£ A CI ION: An act towvard a inc lear powecr plant (N Pl) or its personnel that includes the use of~ jolent Iorcc to destroy cquipment.

take I t )OSI AGE[S. and."or intimidate the licensee to achieve an cnd. Tlhis includes a:ttack b5 air. land, or using explosives.

~R()JE(7 HI' ,Es. vehicles, or other devices used to deliver destructive to~rce. Other acts thatthe overatl intent may he included.

I t lOS IIlEI A( lIOI.N should not he consmtred to include acts ofci' ii disobedience or telonious acts that are not part of a concerted attack on the NPP. Non-tcrrorism-bascd EAt~s should bc used to addrcss such acti, ities tie.e, this ia,, includc violcnt acts hctw~een indiv idual:, in the oo ncr controtlled area (OtCA I).This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist whieh-that are believed by the emergency director to fall under the emergency classification level description for an Alert.117 HUl ECL: Notification of Unusual Event Initiating Condition:

Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:

All Emergency Action Levels: (I or 2 or 3)(1) A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift (aptain or designee(it

.... ~~rty~il ue.'sa (2) Notification of a credible security threat directed at th-se IN P.(3) A validated notification from the NRC providing information of an aircraft threat.Basis: SI 2 CUiRIl 'Y CNI)I IlION: Anx Security I-vent as listed in the approved security contingencx plan that constitutes a threaticonprornise to site sccurit), threat/risk to sits personnel, or a potentatl degradation to the level of' saftely of' the pltnt. A SI (t RI ItY C'ONI)I IION does not inv olve a I I()S1II ,E AC I ION.1I10Sf 1Ilt AC'IVION:

An act to\\ ard a nuclear powecr platnt (N PP)1 or its personnel that includes the usc of j olent lbrcc Ito destroy cquipentct take I I( )S tAGI S. andjor intitnidate the licensee to achtics, an cnd. Ibhis includes attack by air, land, or \\ater using guns. explosi, es.PR()JI{(i I Ill-s vehicles, or other ices used to dtclixe.r destrueti~e force. Other acts that satist"y the oxeralt intent ina3 be included, lOS tIllF A( IIt()N should not he construed to inclIude acts o1' civil disobedicece or te ton iou' acts that are not pa1rt of'a concerted attack on thc NPP. Non-tcerrorisiu-based I Al s should bc used to address such activities (i~e., this ma,, include Siolcnt acts Ihetween indix iduals in the or, ner controlled area (OY\A t).This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety. Security events whieh-that do not meet one of these EALs are adequately addressed by the requirements of 1 0 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, HSI and HG1.Timely and accurate communications between Security shift supervision and the control room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 references the Security Shift' Captain or designec~site

ecurit:,'

because these are the individuals trained to confirm that a security event is occurring or has occurred.

Training on security event confirmation and classification is controlled due to the nature of safeguards and 10 CFR § 2.39 information.

118 EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with station procdist

.."")EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with station procedures (ci~te ....i : pr..d.. e. ..Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level "weuld-be-v*,auscs IC HAl.s'cuprih ,a f the SeuiyPan.citccriyfre pWenlth ddte nidrmtinea giecurity threa aic; Eandt valiay rceit af airhacraf th~reat euchuritythe, Scuerit lcan." o&L,'~ecIgnrnenI~'xETr1r.utce: .e.i.z..'~

119 HU2 ECL: Notification of Unusual Event Initiating Condition:

Seismic event greater than OBE levels, Ope rating Mode Applicability:

All Emergency Action Levels: I) Seismic event greater than Operating Basis Earthquake (OBE) as indicated by+ ~ N'~ ol ihc Ibliow in* Unit O~e Ismi PA~4 Shock Re W 0 17 657-06k) larat* Lltiit Tw Seisng ra ittti9n T -, (657-04~1 alarm* A 12,7 Hzan~berl

' itv~1~ N/ ~E/W~luma~npancl IHIJ-P701* A 121Hz r d li2ht ilium redinthe2N/SQR FIWcnhimn~mnan~l IHtI4~7~t'"',..t ....

-,iatn that a sei~mie e'e~nt met or exceeeded OBE limits)Basis: This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake An earthquake greater than an OBE but less than a Safe Shutdown Earthquake (SSE)8 should have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections).

Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety-44hte pha.plant snltny.Event verification with external sources should not be necessary during or following an OBE.Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g). The Shift Manager or emergency director may seek external verification if deemed appropriate (e.g., a call to the USGS;- or check internet news sources,-et.);

however, the verification action must not preclude a timely emergency declaration.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level Itd-b 4tuscs IC CA6 or SA9.Dea..epe +a ... t .e s +. -a!b+t.... + .... v: tra.. y g~...*I..., dI fc+ v+hl zh th-- z atu~. z+ ... kl .c.,I ... .,+mt. ...a o z rt..i+An.................

..........

..... r...........

..... ...... t+ ...... .........

... )... .............. .. ... e tz r~.~i ...n;- i"- na^120

b. iczta d a Thaoc urnce ilf a scsabla O-D itin thamc Ccn;r.cl aprcc ram, b dc~ lcpra couHu~c hc cl~cingaltrnat EA (crcimlar crdng)(1, aC.l Ca ntr::,al pcccnnhcl " an,*,: actua, or,.,- ant abmic c'.ront.'

z:a~Tha EAL I vbc ta tmc m ont torincludc

'to~ cnaur tat! a detectanicr.n dcc E nt rcult fa-ltcfo LUL Acclgnmant Attritutas

3.1.1 A 121 HU3 ECL: Notification of Unusual Event Initiating Condition:

Hazardous event.Operating Mode Applicability:

All Emergency Action Levels: (1 or 2 or 3 or 4 or 5)Note: EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

(1) A tornado strike within the PROTECTED AREA (PA).(2) Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode.(3) Movement of personnel within the PROTECTED AREA (PA) is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).(4) A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site ,,4a-in personal vehicles.(5) Sustained hurricane Ibree w~inds greater thtan 74 mph Forecast to he at the plant sire in the next Fotur hours. (Site .pzifei.c af ...ur.. or t......hn..,gic, hazr ...a..n..)Basis: PR()l~ HI f( ) ARE!A (PA): the area which encompasses all control led areas w\ithin the sccturitx protected area f'ence.SAIL 1V SYSTEMI: A system required For plant operation, cooling dowvn the plant and/or placin,2 it in the cold condition, including thc IIt'S. I'hese arc typically s~stcms classihied as salkty-related.

This IC addresses hazardous events that are considered to represent a potential degradation of the level of plant EAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA (PA).EAL #2 addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.

Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.EAL #3 addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA (PA).122 EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, an on-site train derailment blocking the access road.This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.EAL #5 addresses (cit .......e dc"e.. "r ... p........v....,he phenomena of the hurricane based on the severe t' eather mitigation procedure,:

Escalation of the emergency classification level ,,**ld-bis based on ICs in Recognition Categories A, F, S or C.may b., a pr............m.r.

cignitcateen

.........

eandit, +andta nr, ...p.....a..

ta ..h.. cite<-location and eharaeterictiec.

daag and th r...u.. ing ..... q........

can be dxeterminedau it iny sarlatianl ochartimed framae, Intaccrance.

a.*.t daemagc accecament cat~n' bn padcmdition, ater the'-rne efent, and the event tl.ill be abl.e tbe idniy. tn.a.r...

mat apln ytm adercuec hnwl...A.+ ..." rmpdfiionndinlm taticn af om natry reretv mauc ih 123 HU4 ECL: Notification of Unusual Event Initiating Condition:

FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:

All Emergency Action Levels: (I or 2 or 3 or 4)Note: The emergency director she*4d-will declare the Unusual Event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.(1) a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:

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

• Receipt of multiple (more than I) fire alarms or indications

• Field verification of a single fire alarm AND b. The FIRE is located within ANY n~fth. fcll;wing pla.ntI'd ble 112 rooms or areas-(2) a. Receipt of a single fire alarm (i.e., no other indications of a FIRE), AND b. The FIRE is located within ANY l4!2irooms or areas-AND c. The existence of a FIRE is not verified within 30-minutes of alarm receipt.(3) A FIRE within the plant PR.01)It( ll) A RIA (P'A) or ISFSI Var" p',a;-ta ...t.. , o...... "hc pl ant P,'oc:c~d .rea] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.

(4) A FIRE within the plant P R()TI II-L) AREA (PA) or p..... ,,t an.:l th,:.4 plant ~ t ... '... 4,.1r]

AREA that requires firefighting support by an offsite fire response agency to extinguish.

124 Basis: I-t1t(,: (ornhustion characterized by. heat and light. Sources oft sioke such as' slipping drive helts or overheated elcctrical equipment do not constitute H Rt-S. Obhservation of flame is prcfkncd hut is N()I requited if large quantities of smoke and heat are observecd.

PR( OHlC01HII)

A RI ,A (PA): [he area that encompasses all control led areas within the securi t\protected area lhnee, This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of plant safety-af the-p1at.EAL # 1 The intent of the 1 5-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure;-

or automatic activation of a suppression system.--te.

Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was perfortned.

Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication, or report.EAL #2 This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30- minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.

EAL #3 125 In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA (PA) not extinguished within 60- minutes may also potentially degrade the level of plant safety. This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA (PA.r ......[Sn~c fc ....t wi....:th.

an rc ...... :uti.EAL #4 If a FIRE within the plant PRIJ I-(I AR[.A (PA) or ISFSI,,l" or-.-" ...... n .:s z .... i .tk !SF .i.wsi tiw pl-" Prc~Ax~drcJ Ae] PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., lzcal t.awn: Fire Deparme.nt), then the level of plant safety is potentially degraded.

The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support fire fighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish.

Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Apptendix R Appendix R to 10 CFR 50, states in part: Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions." When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

I4, R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30- minutes to verify a single alarm is well within this worst-case I-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergency classification level ;weuld-be IC CA6 or SA9.lNcdeoper Th. ... :, ....... It cf pl.nt .........r .az" .hould zpeoify thc~e or :.z-z that ..ni....: SA.FETY SYSTEMd cquiprneA.

126 ECL A~ziTnrnent Att'rib !uteo: 3.1.!.A 127 HU7 ECL: Notification of Unusual Event Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of a or t Jnusual Evecnt (NOt I).Operating Mode Applicability:

All Emergency Action Levels: (1) Other conditions exist which in the judgment of the emergency director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the emergency director to fall under the emergency classification level description for a NOUE.128 IItSSYSTEM MALFUNCTION ICS/EALS.............

b ........ C ..... ."3 ...............................

GENERAL SITE AREA EMREC EEGNYALERT UNUSUAL EVENT SG1 Prolonged loss of SS1 Loss of all offsite SAl Loss of all but one SUI Loss of all offsite all offsite and all onsite and all onsite AC power AC power source to AC power capability to AC power to to emefger.icesscntiai eicefgenycssentiaI buses emefgeeccsscntial buses esentil buses for 15 minutes or for 15 minutes or longer, for 15 minutes or longer.buses. longer. Op. Modes: Power Op. Modes: Power Op. Modes: Power Op. Modes: Power Operation, Startup, Hot Operation, Startup, Hot Operation, Startup, Hot Operation, Startup, Hot Standby, Hot Shutdown Standby, Hot Shutdown Standby, Hot Shutdown Standby, Hot Shutdown SA2 UNPLANNED SU2 UNPLANNED loss of Control Room loss of Control Room indications for 15 indications for 15 minutes or longer with a minutes or longer.significant transient in Op. Modes: Power progress.

Operation, Startup, Hot Op. Modes: Power Standby, Hot Shutdown Operation, Startup, Hot Standby, Hot Shutdown SU3 Reactor coolant activity greater than Technical Specification allowable limits.Op. Modes: Power Operation, Startup, Hot Standby, Hot Shutdown SU4 RCS leakage for 15 minutes or longer.Op. Modes: Power Operation, Startup, Hot_________________Standby, Hot Shutdown 5S5 Inability to SA5 Automatic or SUS Automatic or shutdown the reactor manual scram fails to manual scram fails to causing a challenge to shutdown the reactor, and shutdown the reactor.RPV water level or RCS subsequent manual Op. Modes: Power heat removal, actions taken at the Operation Op. Modes: Power reactor control consoles Operation are not successful in shutting down the reactor.Op. Modes: Power__________________

__________________Operation

____________

129 GENERAL SITE AREAALRUNSLEVT EMERGENCY EMERGENCYALRUNSLEVT SU6 Loss of all onsite or offsite communications capabilities.

Op. Modes: Power Operation, Startup, Hot Standby, Hot Shutdown SG8 Loss of all AC SS8 Loss of all vital and vital DC power DC power for 15 minutes sources for 15 minutes or or longer.longer. Op. Modes: Power Op. Modes: Power Operation, Startup, Hot Operation, Startup, Hot Standby, Hot Shutdown Standby, Hot Shutdown SA9 Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.Op. Modes: Power Operation, Startup, Hot Standby, Hot Shutdown 130 E-HU1 ECL: Notification of Unusual Event Initiating Condition:

Damage to a loaded cask CONFINEMENT BOUNDARY.Operating Mode Applicability:

All Emergency Action Levels: (I) Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 ti!mes the site speeifie ac-,:k epecifie technical epeelt+icati

.... ~lloal r.adi.tion le....l) on ,th .....e af th.. sent. f... l + a, c ANY valtuc listed on 7U .l i:0 i: V~atlw' of Dose Rzte ll~-1J~ 25$id b b __________________________

WI IJI4TAII AttwHL-$TQRMI~11 V 0 30 I Basis: C()NtINNllIN I 1301 Nl)ARY: I hc barnrers) arca~s containinag radioacti,,e suhsianccs anld thc II if)lroncnft.

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes whieh-tlhat could cause challenges in removing the cask or fuel from storage.81 The existence of "damage" is determined by radiological survey. The radiation reading values listed in the table represent 2 times the sitepcSlCiei cask-specific technical specification allowvable radiation level on the designated surthecc of the spent ftci cask. The technical specification multiple of"2 times", -hich ic alce u.ced inz Peecagn'itiz Categcr:'

R IC R.UI, is used here to distinguish between non-emergency and emergency conditions.

The emphasis for this classification is the degradation in the level of safety of the spent fuel cask, and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the-fact hatdcterntining if the "on-contact" dose rate limit is exceeded may be detem1ifned-based on measurement of a dose rate at some distance from the cask.Security-related events for ISFSIs are covered under ICs HU1I and HAlI.in the Cer"tificate of Cemplianee the related NRPC Evaluati.en RPai.cp identi:fy the 1BOU N.TDIARY.

Thia; E2AL l dreaace~s damage that ceuld r..... fre ran..... t identified natural or man made ........ e.g ....adee ir, tip.. d zvv.......

E. PLOSI.. ..F.......EARTUQUKE

.t......, ECL ,^aai:.7nment Attributed:

3.l.I.B 82 06 FISSION PRODUCT BARRIER ICS/EALS ae-9-FA----1.Recognition Category "'F" Initiating Condition Matrix LOSPLODNAL LOSS POCNA LOS 555t*__ GENERAL EMERGENCY Loss of any two barriers and Loss or Potential Loss of the third barrier.FGI Op. Modes; Power Operation, Hot Standby.Startup, Hot Shutdown__ SITE AREA EMERGENCY Loss or Potential Loss of any two barriers.FI Op. Modes: Power Operation, Hot Standby, IStartup, Hot Shutdown-- -,o5 END ~LOSS i __ ......LOSS I, A ALERT Any Loss or any Potential Loss of either the Fuel Clad or RCS barrier.FAI Op. Modes: Power Operation, Hot Standby, Startup, Hot Shutdown LOSS LOSS~LOSS LOSS S-z TaIkI9 FI "fA- 1}1WR E- Lt D.........

.. :..... ...... fl: ' j .....y^ is fo tyji ......Th ' ...... .I t% .'t~~i1 83

1. Tha ta~ia nani fer thana iritiating ditnna raflaatz tha fctIa~.'~r.g aan~idaraticna:

Tha Fant Clad Baanar a..d tha RCF Bani.. .....~,htJ ..... h..... I, th.... thaCantanniant Ban~an.In.. .1/'. C..A..4.LC,~..A..

~ p~,...;.;.....r,...

C........ p, ..........

v ...........

1. cmlt r' t.c~.ati.n methodi fer tinc RP."nngnitin Catagar'y F IC. and fi=:.dnn pmadnact bari'jar thre~hzti=

ara aaaaptabla an j*.Iud; ti,;ch zi an!zzd cznc.teme naaha.:.n:

in thB\RarP.rPWR pm=dnathn.-..a"mt hL. The NRC ata..ff annaida.a tha^ .....t"t n abrtRed af -ha .. aagaactzan the "am, -*ncna....................

t a..... d ........ .mamj.aataahTan.-

ta, S aetat~dta.p but ...... i~a................

..........

.,,a..--,aaa.......mat an i te a .......... r...... ........jna.e~den tha lana~ af RCS mann t. any tneaticr Jni-de aim-.ni'a~~t,., na .

ny."tan (ia., PWP. ntn--l gau.a~tor tabe !c.daaga).

an'a rmiinfv;'a;e

.. .et c..eid..'.d tn ha .C$ !tadaae..ascatata to a Gananrat Emaaganay.

"7..... Tbhe alninty In aeaalate ta a. high:am ...........

... ...........

cann.....n-^*ma*^

!r t dagm'-ading annidtiena aha.ld ha maintainad.

F.ar c...anip, a 84 Fission Product Barrier Table Thresholds for LOSS or POTENTIAL LOSS of Barriers FGI GENERAL EMERGENCY Loss of any two barriers and Loss or Potential Loss of the third harrier.FSI SITE AREA EMERGENCY FAI ALERT Loss or Potential Loss of any two barriers.

FueAny Lossca Oor anyRCPotentialbri.

Loss of either the Fu.......

a... .... .. .RE B rre ...... ...... Ba se LOSS POTENTIALLS LOSS POTENTIAL LOSS LOSS POTENTIAL LS 1. RCS Activity 1. Primary Containment Pressure I. Primary Containment Conditions A. ,+Si......

l., Not Applicable A. Primary Not Applicable A. UNPLANNED A Primary,

containment rapid drop in containment

=:rc:!- pressure greater primary pressure greater5 containment than *~.th4Onjs iLgi/s.: speeic. due pressure following seii to RCS leakage, primary vo 4-34-+/- \cji ut? containment OR B. Primary containment pressure response not consistent with mPtue exists LOCA conditions, inside primary containment OR C. HCTL exceeded.2. RPV Water Level 2. RPV Water Level 2. RPV Water Level SA. A. RPV water level A. RPV water level Not Applicable Not Applicable

]A. iuy eflet cannot be cannot be restored 4edi j restored and and maintained fIodg eequi-eedAG maintained above above $5ialr _____________

etie-AG 85 I~i~-~cqu*~41Ji Vtstt .tO~m5m~s4f441rV7RWL~wt~t~The6y LOSS POTENTIAL LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSSet" l or cannot be fse~ or cannot be determined.

determined.

3. Not Applicable

3. RCS Leak Rate 3. Primary Containment Isolation Failure Not Applicable Not Applicable A. UNISOLABLE A. UNISOLABLE A. UNISOLABLE Not Applicable break in Maii primary system direct downstream St'llIn K Il( leakage that pathway to the I dxae results in environment existsT oK it(l exceeding after primary AYe4eEITHER of the containmentfollowing:

isolation signal spe......

s..... I. ~~~ii OR..... O ..........

B. intentional primary* .,, .. ....w: ....containmentventing per EOPs OR2. ...... O B. Emergency RPV C.USOAL Depressurization.

primary system Level.leakage that results in exceeding EITHER of the following:

OR 2.twS[V Ii~~iit~47~s Vt25 yCoab.R$k~ptso I 86 ii 87 Basis Information For BWR-DEAL Fission Prdc *are lIl* Tse-9-,., F4 BW-R-FUEL CLAD BARRIER THRESHOLDS:

The fuel clad barrier consists of the zircalloy or stainless steel fuel bundle tubes that contain the fuel pellets.1. RCS Activity Loss l.A This threshold indicates that RCS radioactivity concentration is greater than 300 PaCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5-%- percent fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the fuel clad barrier.It is recognized thit sample co!lection and anaI\ysis of reactor coolant x~ilh highis elevated aictix it) tc,,cls could require se, eral hours to complete.

Nonetheless, a sample related threshold is included as a backup to other itndications.

There is no potential loss threshold associated with RCS Activity.

...... site ....s+ pecific capabilities, this; threshald may, have a amaple analys'is ccmpcnnt and/gcr a radiatien mnitar rdingec.........

Ad t his p..r.gr..ph (ar. sim;iar...

arding, ta+ the Basis: if te +1-h e.hoeld includesao an...i e"o mp......., "It is recognized tat. sample collection and analysis:

afreac~tar Ncnethceless a sample related thres~hald is in':.ludred as a backup ta other indieations." 2. RPV Water Level Loss 2.A++++° + ... ...... .. ++ +' + + + + ++ a + + ++ + ++ + + :i +88 Potential Loss 2.A This water level corresponds to the top of the active fuel and is used in the EOPs to indicate a challenge to core cooling.The RPV water level threshold is the same as RCS barrier Loss threshold 2.A. Tgh**-,This threshold indicates a potential loss of the fuel clad barrier and a loss of the RCS barrier that appropriately escalates the emergency classification level to a Site Area Emergency.

This threshold is considered fe-be-exceeded when, as specified in the site-specific EOPs, RPV water cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization.

EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this fuel clad barrier potential loss is met only after either: 1) the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory.

The term "cannot be restored and maintained above" means the value of RPV water level is not able to be brought above the specified limit (top of active fuel). The detenmination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation below the The threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained.In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level to the top of active fuel in order to reduce reactor power. RPV water level is then controlled between the top of active fuel and the Minimum Steam Cooling RPV Water Level (MSCRWL).

Although such action is a challenge to core cooling and the fuel clad barrier, the immediate need to reduce reactor power is the higher priority.

For such events, ICs SA5 or SS5 will dictate the need for emergency classification.

Since the loss of ability to determine if adequate core cooling is being provided presents a significant challenge to the fuel clad barrier, a potential loss of the fuel clad barrier is specified.

lDeve~pe~-oer et 89

3. Not Applicable (included for numbering consistency between barrier tables)4. Primary Containment Radiation Loss 4.A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals 300 pCi/gm dose equivalent I-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5%4- percent fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the fuel clad barrier.The radiation monitor reading in this threshold is higher than that specified for RCS Barrier loss threshold 4.A since it indicates a loss of both the fuel clad barrier and the RCS Barrier. Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.

There is no potential loss threshold associated with primary containment radiation.

The reading 5hould be dete:rminked the releaa.e and diupermal ef ,he..... to 300 pa dc .. ui..l. n :"' I 13' inte the primary ....tain....t atmeephera.

5. Other Indications L~os> 5A Readinos hrom Om['las pre- and post-treatment monitors that indicate OtV~cale t ligh are used to detect the effluent of the Otfgas s) stem anmd therefore iudicate fission products escaping the clad, Calculated readings Ibr 300) p'igigm are 4.82 \ el8 cps and the instruments to of scale is I c-i 6 cps, lhese instruments going high otiseale pros idc an indication that there isclad damage to aid in elassifticat ion of an event. Sam pie results are still needed to establish that the 300 pCi."ign threshold is being esceeded.I here is no potential loss threshold associated ,a ith ()ther Indications.

90 This ~u~thresho addresses ancther fa~ pcitors hrhd~ thatse may the emrgnI tcy idirctr in c determning whehe fthe fuel CLad barrier bisc znplost.ifcd~g Pote ntialLos 6cz.tAlL&5.

This thpreshold addresssny ifother fclactor thdat may be use tbylt the mrec dietoru inth deemnaying whether the Fupael)h gCla Briert is oenti'ally loni. Te riemserecy irecto barrier-ac ihl alhso consider winthir orunot todcarez thfrbarrienfr ptenial lothin the event mayhat ua oguatarlt~

barrierrsatuhcanot e1mnitred 6. EmerenpcyDrctorJugmn 91 B-WR-RCS BARRIER THRESHOLDS:

The RCS Barrier is the reactor coolant system pressure boundary and includes the RPV and all reactor coolant system piping up to and including the isolation valves.1. Primary Containment Pressure Loss 1.A The ..r........primary containment pressure is the -I drywell high pressure setpoint which indicates a LOCA by automatically initiating the ECCS or equivalent makeup system.There is no potential loss threshold associated with primary containment pressure.2. RPV Water Level Loss 2.A This water level corresponds to the top of active fuel and is used in the EOPs to indicate challenge to core cooling.The RPV water level threshold is the same as fuel clad barrier potential loss threshold 2.A. This threshold indicates a loss of the RCS barrier and potential loss of the fuel clad barrier, and that appropriately escalates the emergency classification level to a Site Area Emergency.

This threshold is considered leobe-exceeded when, as specified in the site-specific EOPs, RPV water cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization.

EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify' depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this RCS barrier loss is met only after either: 1)the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory.

The term, "cannot be restored and maintained above," means the value of RPV water level is not able to be brought above the specified limit (top of active fuel). The determination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not 92 require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation beyond the limit,-. The threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained.In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level to the top of active fuel in order to reduce reactor power. RPV water level is then controlled between the top of active fuel and the Minimum Steam Cooling RPV Water Level (MSCRWL).

Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority.

For such events, ICs SA5 or SS5 will dictate the need for emergency classification.

There is no RCS potential loss threshold associated with RPV water level.3. RCS Leak Rate Loss Threshold 3.A Large high-energy lines that rupture outside primary containment can discharge significant amounts of inventory and jeopardize the pressure-retaining capability of the RCS until they are isolated.

If it is determined that the ruptured line cannot be promptly isolated from the control room, the RCS barrier loss threshold is met.Loss Threshold 3.B Emergency RPV Depressurization in accordance with the EOPs is indicative of a loss of the RCS barrier. If emergency RPV depressurization is performed, the plant operators are directed to open safety relief valves, (SRlVs '- : J,, Even though the RCS is 1:1 0I FQ 2W500 ti l }uc being vented into the suppression pool, a loss of the RCS barrier exists due to the diminished effectiveness of the RCS to retain fission products within its boundary.Potential Loss Threshold 3.A Potential loss of RCS based on primary system leakage outside the primary containment is determined from EOP temperature or radiation Max Normal Operating values in areas such as main steam line tunnel, RCIC, HPCI, etc., which indicate a direct path from the RCS to areas outside primary containment.

A Max Normal Operating value is the highest value of the identified parameter expected to occur during normal plant operating conditions with all directly associated support and control systems functioning properly.The indicators reaching the threshold barriers and confirmed to be caused by RCS leakage from a primary system warrant an Alert classification.

A primary system is defined to be the pipes, valves, and other equipment whaieh-that connect directly to the RPV such that a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system.An UNISOLABLE leak which is indicated by Max Normal Operating values escalates to a Site Area Emergency when combined with containment barrier loss threshold 3.A (after 93 a containment isolation) and a General Emergency when the fuel clad barrier criteria is also exceeded.t.Primally olataned nt Radtiation fteLaDtcincyt.

Thjeraition monCitor redating RctorresptndsCloanu insantCeus, releaseon Candenctr (C crRlantr Cars intolthepimr Conaling menC)tht, asun thSOat Leatorclnt actignity eant Iclaeare ostrsod4Asnei niae os of the RCS barrier oly 4. r P n otnills trsodasoitdwt rimary Containment Radiation.

ac!'b tTechnical Specificatio loabl Th.isralu ,eisn: loeh!an th:at- speifie for fUel Thre reading hudi berdenti-er

-"mindac th."x a:'ed ..nati.anin u .-r elca.e aend d'.i.p---

a o f th...........e

.... gace.......t.b.di.ti..u.ce fr.......

radiatian emanating frm piping .ampnena eataiing levted eacar ealat aciviy. I c refr t theDevlope

5. Other Indications I oss 5A A Drx well I ission Pr oducts Monitor reading 5.0 x 1 05 cpm indicates a breach of thc RCS as an effluent.

The monitor ,,aluc calculated in Calculation SM N H-I13-021.

Rex I. xxas 1.008 x I 0' cpm: hoxxcvcr, rhe top of thc scale for the monitor is I \ 10" cpm. Therefore.

94 the IAL, threshold value has been established at one half decade belo'v top ol scale to aid the operator in distinguishina betx~een a loss of RCS cx ent and an insiruiment failure resulting in the monitor readina high off" scale. No~( radiation monitors capable ol indticatina a po~tential loss of the R,(S barrier xscre identified.

I here is no Potential I oss Threshold associated xs ith Other Indications.

Losa an4'r Pztzntinl 5.A This zubzatzgzr.' ether zite specific thrczhc.ld:

that may be inzludsd tc indicate D-e~lopcr:;

m hcukl deter'mine if ether reliable i.ndicators te evaluate the zfthb.fie,,in" ..

ba.rrier (e.g, r..i..a. id.t..............d i th i.. .... .... Fina.... ... Saet indicatiaen that will pramote timely and accu-rate acceccrnent of barrier etatuc.: 6. Emergency Director Judgment Loss 6.A This threshold addresses any other factors ~hthat erete-be-used by the emergency director in determining whether the RCS barrier is lost.Potential Loss 6.A This threshold addresses any other factors 4ha, i--my.b-bused by the emergency director in determining whether the RCS Barrier is potentially lost. The emergency director se4 xx ill also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

95 B-WR-CONTAINMENT BARRIER THRESHOLDS:

The primary containment barrier includes the drywell, the wetwell, their respective interconnecting paths, and other connections up to and including the outermost containment isolation valves. Containment barrier thresholds are used as criteria for escalation of the ECL from Alert to a Site Area Emergency or a General Emergency.

1. Primary Containment Conditions Loss l.A and I.B Rapid UNPLANNED loss of primary containment pressure (i.e., not attributable to drywell spray or condensation effects) following an initial pressure increase indicates a loss of primary containment integrity.

Primary containment pressure should increase as a result of mass and energy release into the primary containment from a LOCA.:lu Primary containment pressure not increasing under these conditions indicates a loss of primary containment integrity.

These thresholds rely on operator recognition of an unexpected response for the condition and therefore a specific value is not assigned.

The unexpected (UNPLANNED) response is important because it is the indicator for a containment bypass condition.

Potential Loss l.A The threshold pressure is the primary containment internal design pressure.

Structural acceptance testing demonstrates the capability of the primary containment to resist pressures greater than the internal design pressure.

A pressure of this magnitude is greater than those expected to result from any design basis accident and.hi represents a potential loss of the containment barrier.Potential Loss I .B If hydrogen concentration reaches or exceeds the lower flammability limit, as defined in plant EOPs, in an oxygen rich environment, a potentially explosive mixture exists. If the combustible mixture ignites inside the primary containment, loss of the containment barrier could occur.Potential Loss I.C The heat capacity temperature limit (HCTL) is the highest suppression pool temperature from which emergency RPV depressurization will not raise: Suppression chamber temperature above the maximum temperature capability of the suppression chamber and equipment within the suppression chamber which may be required to operate when the RPV is pressurized, OR Suppression chamber pressure above Primary Containment Pressure Limit A, while the rate of energy transfer from the RPV to the containment is greater than the capacity of the containment vent.96 The HCTL is a function of RPV pressure, suppression pool temperature and suppression pooi water level. It is to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant and therefore, the inability to maintain plant parameters below the limit constitutes a potential loss of containment.

BW' erPr a'SAue s" Tpeiial dhefhine thelimit as::~ sa'citdih pliv mixture"isyoyo s in!k h EPG/SAG "'deflagraticn limits".Since the HCTL is defirned assumilng a rane, cC f uppression po w.t.r.....l............

Patential Loas thresalod ba.cd an the inabilty ta maintain suppressian p.al water lavel decay heat. remove!~ if it willt simplify the assessezz.net eaf the suppression poo!2. RPV Water Level There is no loss threshold associated with RPV water level.Potential Loss 2.A The potential loss threshold is identical to the Fuel Clad Loss RPV W 9 A The nntpntiml IAQQ rpnuiirpment fnr ~mr "i~r"n 'irh c~uum.ntad( ~core cooling.PRA studies indicate that the condition of this potential loss threshold a core melt sequence if not corrected, could lead to RPV failure and increased potential for primary containment failure. In conjunction with the RPV water level loss thresholds in the fuel clad and RCS barrier columns, this threshold results in the declaration of a General Emergency.

97

~Doeve~i-Nete**

3. Primary Containment Isolation Failure These thresholds address incomplete containment isolation (autonmatic or manual) that allows an UNISOLABLE direct release to the environment.

Ax Loss 3.A The use of the modifier "direct" in defining the release path discriminates against release paths through interfacing liquid systems or minor release pathways, such as instrument lines, not protected by the Primary Containment Isolation System (PCIS).The existence of a filter is not considered in the threshold assessment.

Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.Following the leakage of RCS mass into primary containment and a rise in primary containment pressure, there may be minor radiological releases associated with allowable primary containment leakage through various penetrations or system components.

Minor releases may also occur if a primary containment isolation valve(s) fails to close but the primary containment atmosphere escapes to an enclosed system. These releases do not constitute a loss or potential loss of primary containment but should be evaluated using the Recognition Category R ICs.Loss 3.B EOPs may direct primary containment isolation valve logic(s) to be intentionally bypassed, even if offsite radioactivity release rate limits will be exceeded.

Under these conditions with a valid primary containment isolation signal, the containment ehetil-l also be considered lost if primary containment venting is actually performed.

Intentional venting of primary containment for primary containment pressure or combustible gas control to the secondary containment and/or the environment is a loss of the containment.

Venting for primary containment pressure control when not in an accident situation (e.g., to control pressure below the dryweUl high pressure scram setpoint) does not meet the threshold condition.

Loss 3.C The Max Safe Operating Temperature and the Max Safe Operating Radiation Level are each the highest value of these parameters at which neither: (.) equipment necessary for 98 the safe shutdown of the plant will fail, nor 4+2) personnel access necessary for the safe shutdown of the plant will be precluded.

EOPs **ilk-e-use these temperatures and radiation levels to establish conditions under which RPV depressurization is required.The temperatures and radiation levels 5teodd-wil!

be confirmed to be caused by RCS leakage from a primary system. A primary system is defined to be the pipes, valves, and other equipment whiehthat connect directly to the RPV suieh-ha~insuring a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system.In combination with RCS potential loss 3.A this threshold would result in a Site Area Emergency.

There is no potential loss threshold associated with Primary Containment Isolation Failure...............

ma b ....... tc ....t n thz. ..... fl p ... rccedural ztzp ..............

Prim .ry....imz.t..........

..... .. th..t.........................

vctn zfthc Cznt.,.inn

...regardless radicaeti'ity; relaa~c rate.4. Primary Containment Radiation There is no loss threshold associated with primary containment radiation.

Potential Loss 4.A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that 2 0%.-percent of the fuel cladding has failed. This level of fuel clad failure is well above that used to determine the analogous fuel clad barrier loss and RCS barrier loss thresholds.

NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately percent in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist, there must already have been a loss of the RCS barrier and the fuel clad barrier. It is therefore prudent to treat this condition as a potential loss of containment ,whieh-hat would then escalate the emergency classification level to a General Emergency.+:./++ ... .p n;+*. .. -NoteOA4,1 1,+4+ s:1.. .. 99

5. Other Indications Not Applicable (included numbering consistencx barrier tables)Lc.ee ana~'cr Po.tential Lasz 5.A Th~yie ..... ..g ,, as -dr-eeee*a eTher gtea epci thr that mn y be inc-luded' t inficat ine dreptermnting wheter the containment barrier isee lost. n eeiiede Le d/rPotential Loss 6.A Thvisthes hould ddrtesses ify other rflactor thdaterasb used tby~lut the eterenc drtof hin nyddedemnn thretherd theul conpainent bapprier isptentaly thoerlastiTe ehrgenay toiteto may beuced-w tlo gaugier the rther o~r nthreto delaevtelbrirptnily oti hvn Thsthabariesholdaddrssesanynothbermfatorse htaetde.sdb hmegnydrco 100 J,07HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS GENERAL SITE AREA EMRENY EMRENYALERT UNUSUAL EVENT HGI HOSTILE HlS1 HOSTILE HAl HOSTILE HU1 Confirmed ACTION resulting in ACTION within the ACTION within the SECURITY loss of physical PROTECTED AREA. OWNER CONDITION or control of the facility.

Op. Modes: All CONTROLLED threat.Op. Modes:" All AREA or airborne Op. Modes: All attack threat within 30 minutes.Op. Modes:" All HU2 Seismic event greater than OBE levels.Op. Modes: All HU3 Hazardous event.Op. Modes: All HU4 FIRE potentially degrading the level of safety of the plant.Op. Modes: All HA5 Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.Op. Modes:" All 11S6 Inability to 11A6 Control Room control a key safety evacuation resulting in function from outside transfer of plant the Control Room. control to alternate Op. Modes: All locations.

Op. Modes: All 101 GENERAL SITE AREA EMRENY EMRENYALERT UNUSUAL EVENT 11G7 Other HS57 Other HA7 Other HU7 Other conditions exist which conditions exist which conditions exist which conditions exist in the judgment of the in the judgment of the in the judgment of the which in the emergency director emergency director emergency director judgment of the warrant declaration of warrant declaration of warrant declaration of emergency director a General Emergency.

a Site Area an Alert. warrant declaration of Op. Modes:" All Emergency.

Op. Modes:" All a (NO)UE.________Op.

Modes: All _ _______Op.

Modes: All 102 HG1 ECL: General Emergency Initiating Condition:

HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:

All Emergency Action Levels: (I) a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA (PA) as reported by the Security Shift Captain or dcsigncc(-si~te-speei-ie AND b. EITHlER of the following has occurred: I. ANY of the following safety functions cannot be controlled or maintained.

• Reactivity control* RPV water level-f.W-

• RCS heat removal OR 2. Damage to spent fuel has occurred or is IMMINENT.Basis: II I()S [ll I ACI It()N: An ac t toss atd a nuclecar poss cr plant (N PP) or its persomncel that i ncl udes~tihe use oF violenit tbrcc to detoyeuipment, take I I( )S IlAG![S, and/or intirnidate thc l icclnsce to atchics c an end. Ibhis inc ludcs attack b\ air, laud. or ssatcr using guns. cxptosix cs.PR()F H 'TIIt Is. '.ehicles, or other de ices uscd to delis cr dcstructisc liwcc. ()ther actts tha.t satist\ thc overall intent mas hc includ,.d.

I 1OSTIII!: should not con*strued to inclIude acts ot ci il d isobed ience or l; Ion ions acts that arc not part otfa conccrtcd attack on the NPP. Non-terrorism-hascd

[Al .s should be used to address such activitics (ice.. this max include ,s iolcnt acts be<tssctie individuals in the osxncr controlled arca tOC(A)).I \MM1NLN I : lhc tiajcctory of ce cuts or conditions is such that an [Al ss itt hc nict within a rclatiycl\

short period of timtc regardless of mitigation or corrective actions.PR( )ltt{i 114 ARIA I(PA): l'hc arca that cncontpasscs alt controlced arcas ss ithin thc security protcctcd arca lt.-ncc.This IC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions.

It also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to I) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls,-.el.)

or; 2) loss of spent fuel pool integrity stieh-so that sufficient water level cannot be maintained.

103 Timely and accurate communications between Security shift supervision and the control room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Thoe (site

...urity shf ..... ... i... ) ..... h..... t...f.th....n...hi...in

......ual r,-pon.ibl....r E.me~rgencypan ari n.'d implem.enting pr 'dure&ar publi docum.. nt..:.....................h.uld adanag...

us t.... a ..t..ti.l advesa...., such so thc particuhors concerning a specific threat+ or such as the Plan.With due cn..i..eration++--

gi:e .... abOVe developer note, EAL ay ... ntai.. al.ha numb.. t....... secte e..n. descri..bed in Security Ptan and .....oci.ate implem..nting

...ample,+ an EAL m...' be ..rd.d .+as. ,,ct .... nt...... #5' or ^ #9 is reported by. the (site ...e.ifico ECL+ A.ssi.enmentAtibutes:

..,.- .atJ 104 HG7 ECL: General Emergency Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of a General Emergency.

Operating Mode Applicability:

All Emergency Action Levels: (I) Other conditions exist which in the judgment of the emergency director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.Basis: I!I()Sl I~tl AC 1I( IN: An act tos\,ard a nuclear posser plant (N P1) or its personnel that includes the usc of x olen~t lbrce to dcstroy cquiptnent, takc I lOS'I AGILS. and/or intimidatc the licensee to achice e an end. [his includes attack h) air, land, or usinag guns. cxplusivcs.

I'ROJLC Ill I/:s. 'vehicles.

or other devices used to deliver destructive toree. Other acts thait sat is! thc o\ecral I intent ni a be in~cludedI t( )S IlliA; A( 1 ION should not he construed to include acts ol civil disobedienee or kilonious acts that are not part ol' a concerted attack on thle N PP.

[!Al s should he used to address such a~ctis ities (ice.. this ma\ incltudc v iolcut acts indis iduals in thc owner controlled area (O(A)).I ,I lINI/N I: I he I ratjctors olfecents or conditions is such that an LA AI he nict within a relativcl\

shot~r period of time regardless ol' mitigation or corrective actions.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist wieb-that are believed by the emergency director to fall under the emergency classification level description for a General Emergency.

105 HS1 ECL: Site Area Emergency Initiating Condition:

HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:

All Emergency Action Levels: (I) A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREAas reported by the Seccurity Shift Captain or h!ft Basis: IIO S I II Ii AC I 1O)N: A n act tot'. ard a nutc cl ox' pmcr plant (NPP'l) or it s personnel that i ncl udes thc usc of violcnt tbrcc to dcstroy e quiptmnt.

takc I IO S I AL I S. and byju in iidaic the licenscc to achievec an cnd. Ihi s inicludes attack hy air. land. or w\atcr using guns. explosives.

PRO)Jl[IL(IIIs, vchictcs, or other dcv iccs uscd to delivcr destructive Ibrce. ()ther acts that sat isf3 ilk o\ intcnt may hc cinchdcd., I( ttSll ,II AC I'I )N should not hc constmced to inclIudc acts ot civil d isohedicncc or ti. tonions acts that! arc not part o F a conccrtcd attack on thc N'PI. Non-tcrrorismn-hascd

[Al .5 sthould bc uscd to addrcss such actit itics i~c., this nmav includc violcnt acts hctxxccn imdix idual, in the ow'.ncr controllcd arca t(O ).,\).PR() I [CU IFl) AREA (PA): ['hc arca that cncomnpasscs alt controtlled areas xvtthin thc sccuritx protectcd arca tizncc.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA.This event will require rapid response and assistance due to the possibility for damage to plant equipment.

Timely and accurate communications between Security shift supervision and the control room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualifi cation Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal.

or sheltering).

The Site Area Emergency declaration will mobilize ORO resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.

This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA; such an attack should be assessed using IC HAl.It also does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, or physical disputes between employees,--ete.

Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.106 Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level ...........

us IC HGI.super.':sien G~f the an shift security, feree.Em.r..n. pl.... an.... implement'ng procedures are public documcnts; therefcrc

[ALtsheu...d such as; the Security Plan.With,.. due consideratien gi-ven ta the a.bc'c...

dcvleoper note, EA.s ....- centain lpha .sr numbered re.fernc to L~etd events described, in the Sceurity' Plan ~danss.ceciate.d implementing security, shift super-visien)." a eheme 'lefniticn fr~r th~e PROTECTED AREA.ECL Ass:gnmcnt Attributes:

J. 1.3 .D 107 HS6 ECL: Site Area Emergency Initiating Condition:

Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:

All Emergency Action Levels: SNote: The emergency director sho*d ill. declare the Site Area Emergency promptly upon determining that (site speeific number cl 15 minutes-)

has been exceeded, or will likely be exceeded.(1) a. An event has resulted in plant control being transferred from the control room to remote shititdo>

n pancI;(site speitc!. remote ihu.,cw .a...... and n tc..AND b. Control of ANY of the following key safety functions is not reestablished within (oitc:' ............

1t 5 minutes).* Reactivity control* RPV water level-fWR* RCS heat removal Basis: This IC addresses an evacuation of the control room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plant control to alternate locations is a precursor to a challenge to one or more fission product barriers within a relatively short period of time.The determination of whether or not "control" is established at the remote safe shutdown location(s) is based on emergency director judgment.

The emergency director is expected to make a reasonable, informed judgment within "(thz.. It.. zpc..... for..,.

I5 minutes a> 10 whether ef--te-the operating staff has control of key safety functions from the remote safe shutdown locationfs-).

Escalation of the emergency classification level wel'o! -be vie~use IC FG1I or CG 1.The "!e o pe e.fNo# ... s n"+:"- ...

..Th 'it pcifzrzct hudcv~pnzz n lza znrc taiz~'a~ hcpn~~108zntc pcricd may b~ u~ad with apprapriata b~L/Iuiiflcatizn.

EUL Aalanmzrfl Attnbutcs:

3.1.3.B 109 HS7 ECL: Site Area Emergency Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of a Site Area Emergency.

Operating Mode Applicability:

All Emergency Action Levels: (1) Other conditions exist which in the judgment of the emergency director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, *1) toward site personnel or equipment that could lead to the likely failure of or, that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Basis: I1lOS [I'I!F A(XI IO N: An act toward a nuclear power plant (NPP) or its personnel that includes the ose of violent force to destroy equipment.

take ttOS !A(IBS, and/or intimidate the licensee to achieve an end. T'his in~cludes attack by air, land. or water using guns. cxplosix es, PRO.IECTII.l-ys vehicles, or other devices used to (lelivcr destructive force. Other acts that satisfy, the overall intent max he: included.

IIOSTILIi; ACITION should not be construed to include acts of civil disobedience or le!onious acts that ate not part ot a concerted attack on the NPP. Non-terrorism-based EAI~s shottld be used to address such activities (i.e.. this may include violent acts betweecn individuals in the oxx~ner controlle~d area (O(iA)).This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist ,hieha-thai are believed by the emergency director to fall under the emergency classification level description for a Site Area Emergency.

110 HA1 ECL: Alert Initiating Condition:

HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.Operating Mode Applicability:

All Emergency Action Levels: (I or 2)(I) A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA l(OA) as reported by the Securit) Shift (Captain or dcsiignce(aite Tpec'fic security (2) A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.Basis: I IO 5It-1 ,\( I'ION: An act toxxad a nuclear poxxcr plant (N PPI 01 its personnel that include>the use ofx iolent force to destroxy cqoipmnent, take IIlOS IA( iLS. and/or intimidate thc licensee to achieve an end. I his includes attack hx air. land, or water using cutsc explosives.

PR()J 1(1 I' s. xehiclcs.

or other dex ices used to dclix cr destructix.e iwrc., t ither acts that sat is t\ the oxerall intent oays he incl1uded.

II tO( III. AC I IO( N should not he construed to include acts of cix ii d isohed ience or flIon ious acts that are not part ot a conceited attack on the NPP. Non-terrorisnt-based I Al s shoutld he used t'o address sutch actixities (ice.. this max includeoletnt acts hetxxcen individuals in the owsner controlled area O(OCA)).O)V NI H ( UN I R( l1I,1-1) ARIA t(d'At: ] he site property ost ned by or o~therxx i~c under thc control 01 I INP Security This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA (PA), or the need to prepare the plant and staff for a potential aircraft impact.Timely and accurate communications between Security shift supervision and the control room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualifi cation Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal.

or sheltering).

The Alert declaration will also heighten the awareness of offsite response organizations, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, or physical disputes between employees,-ete.

111 Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL # 1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA.EAL #2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness.

This EAL is met when the threat-related information has been validated in accordance with stai ion " -o* u" .... if,, pr.... re.....The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate federal agency to the site would clarify this point.In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a federal agency.Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level weuild-be-v4au-scs IC HS I.Emergency, pane and i:mplementing pr....d.....

e ..ub.i ..d...m.n....th.....r.......

..h.... net ........at S"nEAuriy zeeiie ..... a tien. Thcuity in-luen #2, #5 or , th, t may:te be'a adatgcue .t. peenia a...er.... , .. h a- th ,D~nticureeneen ao gu eitane athreat thea lepin.Seurt cnetieine~tinehul b unoi~e n enpul112cmet FCL Mzi~nmcr.t Attribut~z:

3.I.2.D 113 HA5 ECL: Alert Initiating Condition:

Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

All Emergency Action Levels: SNote: If the equipment in the listed room or area was already inoperable or out-of-service before the event occurred, then no emergency classification is warranted.

(1) a. Release of a toxic, corrosive, asphyxiant or flammable gas into any 4h re4wi~ abic tIll plant rooms or areas: '[able Ill Btuilding Rooms. Applicable Modes I )icscl ucn~cratr building AlI A\lI tUnit 1P2 130 All R, ector building t nit 1/2 ~Sl! lDin 'nals (RI IR) All tUnit 1/2 NP Diagonals (RI IR) All (~ic pecfi lit f plat! as~ ....... ith ..... rclatcd mode AND b. Entry into the room or area is prohibited or impeded.Basis: This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to maintain normal plant operation, or required for a normal plant cooldown and shutdown.

This condition represents an actual or potential substantial degradation of the level of phint safety o ....e-plei.'.An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the emergency director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert. or operating experience with the same or similar hazards.Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

114 An emergency declaration is not warranted if any of the following conditions apply.* The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release).

For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.* The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).* The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

• The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels.Most commonly, asphyxiants work by Imefey-displacing air in an enclosed environment.

This reduces the concentration of oxygen below the normal level of around which can lead to breathing difficulties, unconsciousness.

or even death.This EAL does not apply to firefighting activities that automatically or manually activate a fire suppression system in an area, or to intentional inerting of containment ,tWR-eD ._, Escalation of the emergency classification level ...... ,-, k u ., Reogiio.atgryR.Co F ICs.The ..... .... sp :ecific list ..f pla.t-"' .. rooms or areac with entry related mode applicability identified"'specify rooms or ar-eas that' contain quimen ....h requir....

a ........ /'eal action as specifi.ed in .p.rtin pr... dur.. us.....d" for normal operation, co^ld.....

en shtown.. ...plan m.d.... during'; which entry. ...uld be .required for each room or area.f.......y.icluebut..

o....... limited.......

to, .apailit to draw..air....om multpe air intak2es a~t acquire and maint:ain.=.

po.ti. pressur.......

within- te Control Roo en.elop... Ifthek. equipen i the.listed room..or...ea..w..al..

ady inoperable o.... out ofi ..r.ic.....ore.the e.ent oc.urred, the noI e.. rgen. y should.. be.I declared ince4.;-.

the evn will. + ,,1 n .. ad.....iLUL Ass...nment

... l"1.2U 115 HA6 ECL: Alert Initiating Condition:

Control Room evacuation resulting in transfer of plant control to alternate locations.

Operating Mode Applicability:

All Emergency Action Levels: (1) An event has resulted in plant control being transferred from the control room to rem1ote shutito , puIanclis,,it

.... fi rzm.... hu............n.l.......

.............

)Basis: This IC addresses an evacuation of the control room that results in transfer of plant control to alternate locations outside the control room. The loss of the ability to control the plant from the control room is considered to be a potential substantial degradation in the level of plant safety.Following a control room evacuation, control of the plant will be transferred to alternate shutdown locations.

The necessity to control a plant shutdown from outside the control room, in addition to responding to the event that required the evacuation of the control room, will present challenges to plant operators and other on-shift personnel.

Activation of the ERO and emergency response facilities will assist in responding to these challenges.

Escalation of the emergency classification level we*.:.d-be-:'auscs IC HS6.cta-tion; rzfercnczd in plant przccdure;

'us'ed tc cccldc-:, and thc plaznt f'rcm a....ic(~ :, uti.... , the, Control Room.116 HA7 ECL: Alert Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of an Alert.Operating Mode Applicability:

All Emergency Action Levels: (I) Other conditions exist which, in the judgment of the emergency director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Basis: I!(t)S Illt1£ A CI ION: An act towvard a inc lear powecr plant (N Pl) or its personnel that includes the use of~ jolent Iorcc to destroy cquipment.

take I t )OSI AGE[S. and."or intimidate the licensee to achieve an cnd. Tlhis includes a:ttack b5 air. land, or using explosives.

~R()JE(7 HI' ,Es. vehicles, or other devices used to deliver destructive to~rce. Other acts thatthe overatl intent may he included.

I t lOS IIlEI A( lIOI.N should not he consmtred to include acts ofci' ii disobedience or telonious acts that are not part of a concerted attack on the NPP. Non-tcrrorism-bascd EAt~s should bc used to addrcss such acti, ities tie.e, this ia,, includc violcnt acts hctw~een indiv idual:, in the oo ncr controtlled area (OtCA I).This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist whieh-that are believed by the emergency director to fall under the emergency classification level description for an Alert.117 HUl ECL: Notification of Unusual Event Initiating Condition:

Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:

All Emergency Action Levels: (I or 2 or 3)(1) A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift (aptain or designee(it

.... ~~rty~il ue.'sa (2) Notification of a credible security threat directed at th-se IN P.(3) A validated notification from the NRC providing information of an aircraft threat.Basis: SI 2 CUiRIl 'Y CNI)I IlION: Anx Security I-vent as listed in the approved security contingencx plan that constitutes a threaticonprornise to site sccurit), threat/risk to sits personnel, or a potentatl degradation to the level of' saftely of' the pltnt. A SI (t RI ItY C'ONI)I IION does not inv olve a I I()S1II ,E AC I ION.1I10Sf 1Ilt AC'IVION:

An act to\\ ard a nuclear powecr platnt (N PP)1 or its personnel that includes the usc of j olent lbrcc Ito destroy cquipentct take I I( )S tAGI S. andjor intitnidate the licensee to achtics, an cnd. Ibhis includes attack by air, land, or \\ater using guns. explosi, es.PR()JI{(i I Ill-s vehicles, or other ices used to dtclixe.r destrueti~e force. Other acts that satist"y the oxeralt intent ina3 be included, lOS tIllF A( IIt()N should not he construed to inclIude acts o1' civil disobedicece or te ton iou' acts that are not pa1rt of'a concerted attack on thc NPP. Non-tcerrorisiu-based I Al s should bc used to address such activities (i~e., this ma,, include Siolcnt acts Ihetween indix iduals in the or, ner controlled area (OY\A t).This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety. Security events whieh-that do not meet one of these EALs are adequately addressed by the requirements of 1 0 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, HSI and HG1.Timely and accurate communications between Security shift supervision and the control room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 references the Security Shift' Captain or designec~site

ecurit:,'

because these are the individuals trained to confirm that a security event is occurring or has occurred.

Training on security event confirmation and classification is controlled due to the nature of safeguards and 10 CFR § 2.39 information.

118 EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with station procdist

.."")EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with station procedures (ci~te ....i : pr..d.. e. ..Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level "weuld-be-v*,auscs IC HAl.s'cuprih ,a f the SeuiyPan.citccriyfre pWenlth ddte nidrmtinea giecurity threa aic; Eandt valiay rceit af airhacraf th~reat euchuritythe, Scuerit lcan." o&L,'~ecIgnrnenI~'xETr1r.utce: .e.i.z..'~

119 HU2 ECL: Notification of Unusual Event Initiating Condition:

Seismic event greater than OBE levels, Ope rating Mode Applicability:

All Emergency Action Levels: I) Seismic event greater than Operating Basis Earthquake (OBE) as indicated by+ ~ N'~ ol ihc Ibliow in* Unit O~e Ismi PA~4 Shock Re W 0 17 657-06k) larat* Lltiit Tw Seisng ra ittti9n T -, (657-04~1 alarm* A 12,7 Hzan~berl

' itv~1~ N/ ~E/W~luma~npancl IHIJ-P701* A 121Hz r d li2ht ilium redinthe2N/SQR FIWcnhimn~mnan~l IHtI4~7~t'"',..t ....

-,iatn that a sei~mie e'e~nt met or exceeeded OBE limits)Basis: This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake An earthquake greater than an OBE but less than a Safe Shutdown Earthquake (SSE)8 should have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections).

Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety-44hte pha.plant snltny.Event verification with external sources should not be necessary during or following an OBE.Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g). The Shift Manager or emergency director may seek external verification if deemed appropriate (e.g., a call to the USGS;- or check internet news sources,-et.);

however, the verification action must not preclude a timely emergency declaration.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level Itd-b 4tuscs IC CA6 or SA9.Dea..epe +a ... t .e s +. -a!b+t.... + .... v: tra.. y g~...*I..., dI fc+ v+hl zh th-- z atu~. z+ ... kl .c.,I ... .,+mt. ...a o z rt..i+An.................

..........

..... r...........

..... ...... t+ ...... .........

... )... .............. .. ... e tz r~.~i ...n;- i"- na^120

b. iczta d a Thaoc urnce ilf a scsabla O-D itin thamc Ccn;r.cl aprcc ram, b dc~ lcpra couHu~c hc cl~cingaltrnat EA (crcimlar crdng)(1, aC.l Ca ntr::,al pcccnnhcl " an,*,: actua, or,.,- ant abmic c'.ront.'

z:a~Tha EAL I vbc ta tmc m ont torincludc

'to~ cnaur tat! a detectanicr.n dcc E nt rcult fa-ltcfo LUL Acclgnmant Attritutas

3.1.1 A 121 HU3 ECL: Notification of Unusual Event Initiating Condition:

Hazardous event.Operating Mode Applicability:

All Emergency Action Levels: (1 or 2 or 3 or 4 or 5)Note: EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

(1) A tornado strike within the PROTECTED AREA (PA).(2) Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode.(3) Movement of personnel within the PROTECTED AREA (PA) is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).(4) A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site ,,4a-in personal vehicles.(5) Sustained hurricane Ibree w~inds greater thtan 74 mph Forecast to he at the plant sire in the next Fotur hours. (Site .pzifei.c af ...ur.. or t......hn..,gic, hazr ...a..n..)Basis: PR()l~ HI f( ) ARE!A (PA): the area which encompasses all control led areas w\ithin the sccturitx protected area f'ence.SAIL 1V SYSTEMI: A system required For plant operation, cooling dowvn the plant and/or placin,2 it in the cold condition, including thc IIt'S. I'hese arc typically s~stcms classihied as salkty-related.

This IC addresses hazardous events that are considered to represent a potential degradation of the level of plant EAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA (PA).EAL #2 addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.

Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.EAL #3 addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA (PA).122 EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, an on-site train derailment blocking the access road.This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.EAL #5 addresses (cit .......e dc"e.. "r ... p........v....,he phenomena of the hurricane based on the severe t' eather mitigation procedure,:

Escalation of the emergency classification level ,,**ld-bis based on ICs in Recognition Categories A, F, S or C.may b., a pr............m.r.

cignitcateen

.........

eandit, +andta nr, ...p.....a..

ta ..h.. cite<-location and eharaeterictiec.

daag and th r...u.. ing ..... q........

can be dxeterminedau it iny sarlatianl ochartimed framae, Intaccrance.

a.*.t daemagc accecament cat~n' bn padcmdition, ater the'-rne efent, and the event tl.ill be abl.e tbe idniy. tn.a.r...

mat apln ytm adercuec hnwl...A.+ ..." rmpdfiionndinlm taticn af om natry reretv mauc ih 123 HU4 ECL: Notification of Unusual Event Initiating Condition:

FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:

All Emergency Action Levels: (I or 2 or 3 or 4)Note: The emergency director she*4d-will declare the Unusual Event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.(1) a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:

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

• Receipt of multiple (more than I) fire alarms or indications

• Field verification of a single fire alarm AND b. The FIRE is located within ANY n~fth. fcll;wing pla.ntI'd ble 112 rooms or areas-(2) a. Receipt of a single fire alarm (i.e., no other indications of a FIRE), AND b. The FIRE is located within ANY l4!2irooms or areas-AND c. The existence of a FIRE is not verified within 30-minutes of alarm receipt.(3) A FIRE within the plant PR.01)It( ll) A RIA (P'A) or ISFSI Var" p',a;-ta ...t.. , o...... "hc pl ant P,'oc:c~d .rea] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.

(4) A FIRE within the plant P R()TI II-L) AREA (PA) or p..... ,,t an.:l th,:.4 plant ~ t ... '... 4,.1r]

AREA that requires firefighting support by an offsite fire response agency to extinguish.

124 Basis: I-t1t(,: (ornhustion characterized by. heat and light. Sources oft sioke such as' slipping drive helts or overheated elcctrical equipment do not constitute H Rt-S. Obhservation of flame is prcfkncd hut is N()I requited if large quantities of smoke and heat are observecd.

PR( OHlC01HII)

A RI ,A (PA): [he area that encompasses all control led areas within the securi t\protected area lhnee, This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of plant safety-af the-p1at.EAL # 1 The intent of the 1 5-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure;-

or automatic activation of a suppression system.--te.

Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was perfortned.

Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication, or report.EAL #2 This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30- minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.

EAL #3 125 In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA (PA) not extinguished within 60- minutes may also potentially degrade the level of plant safety. This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA (PA.r ......[Sn~c fc ....t wi....:th.

an rc ...... :uti.EAL #4 If a FIRE within the plant PRIJ I-(I AR[.A (PA) or ISFSI,,l" or-.-" ...... n .:s z .... i .tk !SF .i.wsi tiw pl-" Prc~Ax~drcJ Ae] PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., lzcal t.awn: Fire Deparme.nt), then the level of plant safety is potentially degraded.

The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support fire fighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish.

Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Apptendix R Appendix R to 10 CFR 50, states in part: Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions." When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

I4, R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30- minutes to verify a single alarm is well within this worst-case I-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergency classification level ;weuld-be IC CA6 or SA9.lNcdeoper Th. ... :, ....... It cf pl.nt .........r .az" .hould zpeoify thc~e or :.z-z that ..ni....: SA.FETY SYSTEMd cquiprneA.

126 ECL A~ziTnrnent Att'rib !uteo: 3.1.!.A 127 HU7 ECL: Notification of Unusual Event Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of a or t Jnusual Evecnt (NOt I).Operating Mode Applicability:

All Emergency Action Levels: (1) Other conditions exist which in the judgment of the emergency director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the emergency director to fall under the emergency classification level description for a NOUE.128 IItSSYSTEM MALFUNCTION ICS/EALS.............

b ........ C ..... ."3 ...............................

GENERAL SITE AREA EMREC EEGNYALERT UNUSUAL EVENT SG1 Prolonged loss of SS1 Loss of all offsite SAl Loss of all but one SUI Loss of all offsite all offsite and all onsite and all onsite AC power AC power source to AC power capability to AC power to to emefger.icesscntiai eicefgenycssentiaI buses emefgeeccsscntial buses esentil buses for 15 minutes or for 15 minutes or longer, for 15 minutes or longer.buses. longer. Op. Modes: Power Op. Modes: Power Op. Modes: Power Op. Modes: Power Operation, Startup, Hot Operation, Startup, Hot Operation, Startup, Hot Operation, Startup, Hot Standby, Hot Shutdown Standby, Hot Shutdown Standby, Hot Shutdown Standby, Hot Shutdown SA2 UNPLANNED SU2 UNPLANNED loss of Control Room loss of Control Room indications for 15 indications for 15 minutes or longer with a minutes or longer.significant transient in Op. Modes: Power progress.

Operation, Startup, Hot Op. Modes: Power Standby, Hot Shutdown Operation, Startup, Hot Standby, Hot Shutdown SU3 Reactor coolant activity greater than Technical Specification allowable limits.Op. Modes: Power Operation, Startup, Hot Standby, Hot Shutdown SU4 RCS leakage for 15 minutes or longer.Op. Modes: Power Operation, Startup, Hot_________________Standby, Hot Shutdown 5S5 Inability to SA5 Automatic or SUS Automatic or shutdown the reactor manual scram fails to manual scram fails to causing a challenge to shutdown the reactor, and shutdown the reactor.RPV water level or RCS subsequent manual Op. Modes: Power heat removal, actions taken at the Operation Op. Modes: Power reactor control consoles Operation are not successful in shutting down the reactor.Op. Modes: Power__________________

__________________Operation

____________

129 GENERAL SITE AREAALRUNSLEVT EMERGENCY EMERGENCYALRUNSLEVT SU6 Loss of all onsite or offsite communications capabilities.

Op. Modes: Power Operation, Startup, Hot Standby, Hot Shutdown SG8 Loss of all AC SS8 Loss of all vital and vital DC power DC power for 15 minutes sources for 15 minutes or or longer.longer. Op. Modes: Power Op. Modes: Power Operation, Startup, Hot Operation, Startup, Hot Standby, Hot Shutdown Standby, Hot Shutdown SA9 Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.Op. Modes: Power Operation, Startup, Hot Standby, Hot Shutdown 130