Text

Attachment 11 - EP-AA-1009, Revised Radiological Emergency Plan Annex Information for Three Mile Island Station
	ML15072A412
Person / Time
Site:	Three Mile Island
Issue date:	03/02/2015
From:	; Exelon Generation Co
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML15071A122	List: ML15071A119; ML15071A128; ML15071A137; ML15071A172; ML15071A173; ML15072A388; ML15072A389; ML15072A399; ML15072A411; RA-15-019, Attachment 1 - Response to the Request for Additional Information - License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors; RA-15-019, Attachment 11 - EP-AA-1009, Revised Radiological Emergency Plan Annex Information for Three Mile Island Station; RA-15-019, Attachment 3 - EP-AA-1002, Revised Radiological Emergency Plan Annex Information for Byron Station; RA-15-019, Attachment 4 - EP-AA-1003, Revised Radiological Emergency Plan Annex Information for Clinton Power Station; RA-15-019, Attachment 5 - EP-AA-1004, Revised Radiological Emergency Plan Annex Information for Dresden Station; RA-15-019, Attachment 6 - EP-AA-1005, Revised Radiological Emergency Plan Annex Information for LaSalle County Station; RA-15-019, Attachment 7 - EP-AA-1008, Revised Radiological Emergency Plan Annex Information for Limerick Generating Station; RA-15-019, Attachment 9 - EP-AA-1007, Revised Radiological Emergency Plan Annex Information for Peach Bottom Atomic Power Station; RA-15-019, Exelon - Response to Request for Additional Information License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors; RS-15-082, Response to Request for Additional Information License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors; TMI-15-034, Attachment 8 - EP-AA-1010, Revised Radiological Emergency Plan Annex Information for Oyster Creek Nuclear Generating Station;
References
	RA-15-019, RS-15-082, TMI-15-034 EP-AA-1009
	Download: ML15072A412 (331)
	v • d • e

4, ATTACHMENT 11 REVISED RADIOLOGICAL EMERGENCY PLAN ANNEX INFORMATION FOR THREE MILE ISLAND NUCLEAR STATION EP-AA-1 009 Enclosures 0 Enclosure 11 A - Revised EAL Revised Comparison Matrix Document 6 Enclosure 11 B - Revised EAL Red-Line Basis Documents 0 Enclosure 11 C - Revised EAL Basis Documents

NEI 99-01 Rev 6 Proposed EAL ]Justification AG1 RGI Initiating Condition - GENERAL EMERGENCY Initiating Condition: [D No Change M Difference 1 Deviation Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem Release of gaseous radioactivity resulting in offsite dose greater than 1,000 1) Listed site-specific monitors and Threshold values to ensure timely TEDE or 5,000 mrem thyroid CDE. mRem TEDE or 5,000 mRem thyroid CDE. classification.

Operating Mode Applicability: All Operating Mode Applicability:

2) Added "Classification based On effluent monitor readings assumes that a 1,2,3,4,5,6,D release path to the environment is established." To the third bullet in order to Example Emergency Action Levels: (1 or 2 or 3) Emergency Action Levels (EAL): delete the following from the basis section "Classification based on effluent monitor readings assumes that a release path to the environment is established. If Notes: Notes: the effluent flow past an effluent monitor is known to have stopped due to actions

The Emergency Director should declare the General Emergency promptly

The Emergency Director should declare the event promptly upon determining to isolate the release path, then the effluent monitor reading is no longer valid for upon determining that the applicable time has been exceeded, or will likely be that the applicable time has been exceeded, or will likely be exceeded. classification purposes." This allows for more timely classification since all the exceeded. basis information pertaining to Note bullet 3 will be contained in the IC and therefor

If an ongoing release is detected and the release start time is unknown, readily available on the 11x17 procedure matrix used by the SM.

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

assume that the release duration has exceeded 15 minutes.

Classification based on effluent monitor readings assumes that a release path

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

The pre-calculated effluent monitor values presented in EAL #1 should be

The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. assessment using actual meteorology are available.

1. Reading on any of the following radiation monitors greater than the 1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 reading shown for 15 minutes or longer: minutes.

OR (site specific monitor list and threshold values) 2. Dose assessment Using actual meteorology indicates doses at or beyond the site boundary of EITHER:

2. Dose assessment actual meteorology indicates doses greater than 1000 a. >1000 mRem TEDE mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dose OR receptor point)

b. > 5000 mRem CDE Thyroid OR

3. Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point): 3. Field survey results at or beyond the site boundary indicate EITHER:

Closed window dose rates greater than 1000 mR/hr expected to a. Gamma (closed window) dose rates >1000 mR/hr are expected to continue for 60 minutes or longer. continue for > 60 minutes.

Analysis of field survey samples indicate thyroid CDE greater than OR 5000 mrem for one hour of inhalation. b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.

Table R1 Effluent Monitor Thresholds Effluent Monitor I General Emergency RM-G-25 (Cond Offgas) 9.53 E+06 mR/hr RM-A-BGH (Station Vent) 3.09 E+05 cpm RM-G-24 (RB Purge) 5.55 E+05 mR/hr RM-A-14 (ESF Vent) 6.66 E+02 uCi/cc Page 1 of 66

NEI 99-01 Rev 6 j Proposed EAL Justification ASI RS1 Initiating Condition - SITE AREA EMERGENCY Initiating Condition: H No Change W Difference 1: Deviation Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem 1) Listed site-specific monitors and Threshold values to ensure timely TEDE or 500 mrem thyroid CDE. TEDE or 500 mRem thyroid CDE. classification.

Operating Mode Applicability: All Operating Mode Applicability:

1,2,3,4,5,6,D 2) Added "Classification based on effluent monitor readings assumes that a Example Emergency Action Levels: (1 or 2 or 3) Emergency Action Levels (EAL) release path to the environment is established." To the third bullet in order to delete the following from the basis section "Classification based on effluent Notes: Notes: monitor readings assumes that a release path to the environment is established. If The Emergency Director should declare the General Emergency promptly

The Emergency Director should declare the event promptly upon determining the effluent flow past an effluent monitor is known to have stopped due to actions upon determining that the applicable time has been exceeded, or will likely be that the applicable time has been exceeded, or will likely be exceeded. to isolate the release path, then the effluent monitor reading is no longer valid for exceeded. classification purposes." This allows for more timely classification since all the

If an ongoing release is detected and the release start time is unknown, basis information pertaining to Note bullet 3 will be contained in the ICand therefor

Ifan ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes. readily available on the 11x17 procedure matrix used by the SM.

assume that the release duration has exceeded 15 minutes.

Classification based on effluent monitor readings assumes that a release path

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

The pre-calculated effluent monitor values presented in EAL #1 should be

The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. assessment using actual meteorology are available.

1. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 15

1. .Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer: minutes.

OR (site specific monitor list and threshold values) 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:

a. >100 mRem TEDE

2. Dose assessment actual meteorology indicates doses greater than 1000 mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dose OR receptor point)

b. > 500 mRem CDE Thyroid OR

3. Field survey results indicate EITHER of the following at or beyond (site

3. Field survey results at or beyond the site boundary indicate EITHER:

specific dose receptor point):

a. Gamma (closed window) dose rates >100 mR/hr are expected to

Closed window dose rates greater than 100 mR/hr expected to continue for > 60 minutes.

continue for 60 minutes or longer.

OR

Analysis of field survey samples indicate thyroid CDE greater than 500 mrem for one hour of inhalation. b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.

Table R1 Effluent Monitor Thresholds Effluent Monitor Site Area Emergency RM-G-25 (Cond Offgas) 9.53 E+05 mR/hr RM-A-8GH (Station Vent) 3.09 E+04 cpm RM-G-24 (RB Purge) 5.55 E+04 mR/hr RM-A-14 (ESF Vent) 6.66 E+01 uCi/cc Page 2 of 66

NEI 99-01 Rev 6 1 Proposed EAL Justification AA1 RA1 Initiating Condition - ALERT Initiating Condition:

D No Change E Difference 1-1 Deviation Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 1) Listed site-specific monitors and Threshold values to ensure timely classification.

mrem TEDE or 50 mrem thyroid CDE. mrem TEDE or 50 mrem thyroid CDE.

Operating Mode Applicability: All Operating Mode Applicability: 2) Added "Classification based on effluent monitor readings assumes that a release path to the environment is established." To the third bullet in order to delete the 1.2,3,4, 5, 6, D following from the basis section "Classification based on effluent monitor readings Example Emergency Action Levels: (1 or 2 or 3) Emergency Action Levels (EAL) assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the Note: Note: release path, then the effluent monitor reading is no longer valid for classification

The Emergency Director should declare the Alert promptly upon

The Emergency Director should declare the event promptly upon purposes." This allows for more timely classification since all the basis information determining that the applicable time has been exceeded, or will likely be determining that the applicable time has been exceeded, or will likely be pertaining to Note bullet 3 will be contained in the IC and therefor readily available exceeded. exceeded. on the 1 1x17 procedure matrix used by the SM.

If an ongoing release is detected and the release start time is unknown,

Ifan ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes. 3) Calculations were performed, in accordance with (lAW) guidance provided in NEI assume that the release duration has exceeded 15 minutes.

99-01 revision 6 EAL AA1, to determine the effluent monitor response for a

If the effluent flow past an effluent monitor is known to have stopped due

Classification based on effluent monitor readings assumes that a release radioactive liquid release and a WGDT release via the normal site release pathway.

to actions to isolate the release path, then the effluent monitor reading is path to the environment is established. Ifthe effluent flow past an effluent The release would contain activity equivalent to provide 10mrem TEDE or 50mrem monitor is known to have stopped due to actions to isolate the release path, then thyroid CDE at the site boundary. The calculation determined the effluent monitor no longer valid for classification purposes.

the effluent monitor reading is no longer valid for classification purposes. responses would be >110% of the instruments maximum range and as such, lAW

The pre-calculated effluent monitor values presented in EAL #1 should be

The pre-calculated effluent monitor values presented in EAL #1 should be used for NEI 99-01 Rev 6 guidance, was not included in this EAL.

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

1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15

1. Reading on any of the following radiation monitors greater than the minutes.

reading shown for 15 minutes or longer: OR

2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:

(site-specific monitor list and threshold values) a. > 10 mRem TEDE OR

b. > 50 mRem CDE Thyroid

2. Dose assessment actual meteorology indicates doses greater than 10 OR mrem TEDE or 50 mrem thyroid CDE at or beyond (site specific dose 3. Analysis of a liquid effluent sample indicates a concentration or release rate that receptor point) would result in doses greater than EITHER of the following at or beyond the site boundary

3. Analysis of a liquid effluent sample indicates a concentration or a. 10 mRem TEDE for 60 minutes of exposure release rate that would result in doses greater than 10 mrem TEDE OR or 50 mrem thyroid CDE at or beyond (site-specific dose receptor b. 50 mRem CDE Thyroid for 60 minutes of exposure point) for one hour of exposure. OR

4. Field survey results at or beyond the site boundary indicate EITHER:

4. Field survey results indicate EITHER of the following at or beyond (site a. Gamma (closed window) dose rates > 10 mR/hr are expected to specific dose receptor point): continue for _ 60 minutes.

Closed window dose rates greater than 10 mR/hr expected to OR continue for 60 minutes or longer. b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.

Analysis of field survey samples indicate thyroid CDE greater than Table R1 Effluent Monitor Thresholds 50 mrem for one hour of inhalation. Effluent Monitor Alert RM-G-25 (Cond OfDgas) 9.53 E+04 mR/hr RM-A-8GH (Station Vent) 3.09 E+03 cpm RM-G-24 (RB Purge) 5.55 E+03 mR/hr RM-A-14 (ESF Vent) 6.66 E+00 uCi/cc Page 3 of 66

NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition - UNUSUAL EVENT AU1 Initiating Condition:

RUI D1 No Change E Difference 1 Deviation Release of gaseous or liquid radioactivity greater than 2 times the (site-specific Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 1) Listed site-specific monitors and Threshold values to ensure timely classification.

effluent release controlling document) limits for 60 minutes or longer 60 minutes or longer.

Operating Mode Applicability: All Operating Mode Applicability: 2) Added "Classification based on effluent monitor readings assumes that a release path to the environment is established." To the third bullet in order to delete the 1,2,3,4,5,6, D following from the basis section "Classification based on effluent monitor readings Example Emergency Action Levels: (1 or 2 or 3 Emergency Action Levels (EAL) assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the Note: Note: release path, then the effluent monitor reading is no longer valid for classification

The Emergency Director should declare the Alert promptly upon The Emergency Director should declare the event promptly upon purposes." This allows for more timely classification since all the basis information determining that 60 minutes has been exceeded, or will likely be determining that the applicable time has been exceeded, or will likely be pertaining to Note bullet 3 will be contained in the IC and therefor readily available exceeded. exceeded. on the 11x17 procedure matrix used by the SM.

If an ongoing release is detected and the release start time is unknown,

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes. assume that the release duration has exceeded 60 minutes.

If the effluent flow past an effluent monitor is known to have stopped,

Classification based on effluent monitor readings assumes that a release indicating that the release path is isolated, the effluent monitor reading is path to the environment is established. If the effluent flow past an effluent no longer valid for classification purposes. monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

1. Reading on ANY effluent radiation monitor greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer: 1. Reading on ANY of the following effluent monitors > 2 times alarm (site-specific monitor list and threshold values corresponding to 2 times setpoint established by a current radioactive release discharge permit for a 60 minutes.

the controlling document limits)

RM-L-6, Radwaste Discharge

2. Reading on ANY effluent radiation monitor greater than 2 times the RM-L-12, IWTS/ IWFS Discharge alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer. RM-A-7, Waste Gas Decay Tank Discharge

Discharge Permit specified monitor

3. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times (site-specific effluent release OR controlling document limits) for 60 minutes or longer. 2. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 60 minutes.

OR

3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of Z 60 minutes.

Table R1 Effluent Monitor Thresholds Effluent Monitor Unusual Evet RM-G-25 (Cond Offgas) 1.09 E+03 mR/hr RM-A-8GH (Station Vent) 7.03 E+01 cpm RM-G-24 (RB Purge) 6.34 E+01 mR/hr RM-A-14 (ESF Vent) 7.60 E-02 uCi/cc Page 4 of 66

NEI 99-01 Rev 6 1 Proposed EAL Justification RGZ Initiating Condition -- GENERAL EMERGENCY Initiating Condition: D No Change 1 Difference 1:1 Deviation Spent fuel pool level cannot be restored to at least (site-specific Level 3 description)

Spent fuel pool level cannot be restored to at least (site-specific Level 3 for 60 minutes or longer.

description) for 60 minutes or longer Operating Mode Applicability: 1) EAL will be used in accordance with the discussion in Section 1.4, NRC Order Operating Mode Applicability: All 1,2, 3, 4, 5,6, D EA-12-051, it is recommended that this EAL be implemented when the enhanced spent fuel pool level instrumentation is available for use. The completion of the Example Emergency Action Levels: Emergency Action Level (EAL): enhanced SFP level indicators and need for the inclusion of this EAL is being tracked in accordance with Exelon Generation Company, LLC's Initial Status NOTES: The Emergency Director should declare the General Emergency Note: The Emergency Director should declare the General Emergency promptly Report to March 12, 2012 Commission Order Modifying Licenses with Regard for promptly upon determining that 60 minutes has been exceeded, upon determining that the applicable time has been exceeded, or will likely Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated or will likely be exceeded be exceeded. October 25,2012.

1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 Spent fuel pool level cannot be restored to at least (site-specific Level 3 value) for description) for 60 minutes or longer. 60 minutes or longer.

Page 5 of 66

NEI 99-01 Rev 6 Proposed EAL Justification AS2 RS2 Initiating Condition - SITE AREA EMERGENCY Initiating Condition:

D:1 No Change i-- Difference 1:1 Deviation Spent fuel pool level at (site-specific Level 3 description) Spent fuel pool level at (site-specific Level 3 description).

1) EAL will be used in accordance with the discussion in Section 1.4, NRC Order Operating Mode Applicability: All Operating Mode Applicability: EA-12-051, it is recommended that this EAL be implemented when the enhanced 1,2, 3,4, 5,6, D spent fuel pool level instrumentation is available for use. The completion of the Example Emergency Action Levels: enhanced SFP level indicators and need for the inclusion of this EAL is being Emergency Action Level (EAL): tracked in accordance with Exelon Generation Company, LLC's Initial Status

1. Lowering of spent fuel pool level to (site-specific Level 3 value). Report to March 12, 2012 Commission Order Modifying Licenses with Regard for Lowering of spent fuel pool level to (site-specific Level 3 value).

Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated October 25,2012.

Page 6 of 66

NEI 99-01 Rev 6 Proposed EAL Justification AA2 Initiating Condition - ALERT Initiating Condition: D No Change f Difference IIJ Deviation Significant lowering of water level above, or damage to, irradiated fuel.

Significant lowering of water level above, or damage to, irradiated fuel. 1) Listed site-specific monitors and Threshold values to ensure timely classification.

Operating Mode Applicability: All Operating Mode Applicability:

2) EAL #3 will be used in accordance with the discussion in Section 1.4, NRC 1, 2, 3,4, 5, 6,D Order EA-1 2-051, it is recommended that this EAL be implemented when the Example Emergency Action Levels: (1 or 2 or 3 Emergency Action Levels (EAL) enhanced spent fuel pool level instrumentation is available for use. The completion of the enhanced SFP level indicators and need for the inclusion of this EAL is being

1. Uncovery of irradiated fuel in the REFUELING PATHWAY. 1. Uncovery of irradiated fuel in the REFUELING PATHWAY. tracked in accordance with Exelon Generation Company, LLC's Initial Status OR Report to March 12, 2012 Commission Order Modifying Licenses with Regard for

2. Damage to irradiated fuel resulting in a release of radioactivity from the Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated fuel as indicated by ANY of the following radiation monitors: 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel October 25,2012.

as indicated by ANY Table R1 Radiation Monitor reading >1000 mRemlhr.

(site-specific listing of radiation monitors, and the associated readings, OR setpoints and/or alarms)

3. Lowering of spent fuel pool level to (site-specific Level 2 value).

Table R2 Radiation Monitors RMS Area Monitored Mode ALL RM-G-9 FHB Bridge Rad Monitor 5,6 RM-G-6 RB Auxiliary Bridge Rad Monitor RM-G-7 RB Main Bridge Rad Monitor 5,6 Page 7 of 66

NEI 99-01 Rev 6 1 Proposed EAL Justification AU2 RU2 Initiating Condition: UNUSUAL EVENT Initiating Condition: No Change 1 Difference 1 Deviation UNPLANNED loss of water level above irradiated fuel UNPLANNED loss of water level above irradiated fuel Operating Mode Applicability: All Operating Mode Applicability:

1) Listed site-specific level indication and monitors to ensure timely classification.

1, 2, 3, 4, 5, 6, D Example Emergency Action Levels: Emergency Action Levels (EAL)

1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following:

1. a. UNPLANNED water level drop in the REFUELING PATHWAY.

AND (site-specific level indications).

b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R2.

AND Table R2

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

RMS Area Monitored Mode (site-specific list of area radiation monitors) ALL RM-G-9 FHB Bridge Rad Monitor 5,6 RM-G-6 RB Auxiliary Bridge Rad Monitor RM-G-7 RB Main Bridge Rad Monitor 5,6 Page 8 of 66

NEI 99-01 Rev NEI Proposed EAL 65 99-01 Rev Proposed FAIL Justification AA3 RA3 Initiating Condition - ALERT Initiating Condition: E No Change 1 Difference 1 Deviation Radiation levels that impede access to equipment necessary for normal plant Radiation levels that impede access to equipment necessary for normal plant 1) Listed site specific plant rooms and areas with identified mode applicability to operations, cooldown or shutdown. operations, cooldown or shutdown. ensure timely classification.

Operating Mode Applicability: All Operating Mode Applicability:

1, 2, 3, 4, 5, 6,D Example Emergency Action Levels: (1 or 2) Emergency Action Levels (EAL)

Note: If the equipment in the listed room or area was already inoperable, or out Note: If the equipment in the room or area listed in Table R4 was already inoperable, of service, before the event occurred, then no emergency classification is or out of service, before the event occurred, then no emergency classification is warranted warranted

1. Dose rate greater than 15 mR/hr in ANY of the following areas: 1. Dose rate greater than 15 mR/hr in ANY of the areas contained in Table R3:

Control Room

Central Alarm Station Table R3

(other site-specific areas/rooms)

Areas Requiring Continuous Occupancy

2. An UNPLANNED event results in radiation levels that prevent or

Main Control Room significantly impede access to any of the following plant rooms or areas:

Central Alarm Station - (by survey)

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

OR

2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to any of the following Table R4 plant rooms or areas:

Table R4 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Auxiliary Building 281' shielded area 305' above DH Vaults Modes 4, 5, and 6 Fuel Handling Building 281' IC ES Vlvs MCC Page 9 of 66

NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition: UNUSUAL EVENT SU3 RU3 Initiating Condition:

D1 No Change E- Difference [: Deviation Reactor coolant activity greater than Technical Specification allowable limits. Reactor coolant activity greater than Technical Specification allowable limits. 1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

2) Listed this system category EAL in the radiological category EAL section to Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 maintain consistency with current and previous revisions of Exelon EALs. This will ensure a timely classification since the threshold values are more aligned with the Example Emergency Action Levels: Emergency Action Levels (EAL):

radiological category vice system category.

1. (Site-specific radiation monitor) reading greater than (site-specific value). 1. Letdown Monitor RM-L-1 alert alarm (high or low channel).

OR OR

2. Sample analysis indicates that a reactor coolant activity value is greater than 2. Sample analysis indicates that:

an allowable limit specified in Technical Specifications.

a. Dose Equivalent 1-131 specific coolant activity > 60.0 uCil/gm.

OR

b. Dose Equivalent XE-133 specific coolant activity

> 797.0 uCi/gm.

Page 10 of 66

NEI 99-01 rev 6 Fission Product Barrier Matrix FisoProuc Barie Mari Hot at FG1 Loss of any two barriers AND Loss or Potential Loss of third barrier. 1,2.3,4 FS1 Loss or Potential Loss of ANY two barriers. 1,2.3,4 FAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 1,2,3,4 FC - Fuel C lad RC - Reactor Coolant System CT - Containment Sub-Category Loss Potential Loss Loss Potential Loss Loss Potential Loss A. Operation of a standby charging (makeup) pump is required by EITHER of A. An automatic or manual ECCS (SI) the following:

actuation is required by EITHER of the a. UNISOLABLE RCS leakage A. RCSlreactor vessel level less OR

1. RCSorSG than (site-specific level). following: b. SG tube leakage. A leaking or RUPTURED SG is None Tube Leakage t e e e a. UNISOLABLE RCS leakage OR FAULTED outside of containment.

OR

b. SG tube RUPTUREO B. RCS cooldown rate greater than (site specific pressurized thermal shock criteriallimits defined by site specific indications)

A. Core exit thermocouple readings greater than (site specific A. 1. (site specific criteria for entry into A. Core exit thermocouple temperature value) A. Inadequate RCS heat removal core cooling restoration procedure)

2. Inadequate readings greater than (site OR None capability via steam generators as None AND Heat Removal specific temperature value) B. Inadequate RCS heat removal indicated by (site specific Indications). 2. Functional Restoration Procedures capability via steam generators as indicated by (site specific not effective inc 15 minutes.

indications).

A. Containment radiation monitor reading greater than (site specific 3.RCS Activity/ vwlue) A. Containment radiation monitor A. Containment radiation monitor reading Containment OR None reading greater than (site specific value) None None greater than (site specific value)

Radiation B. (Site specific indications that reactor coolant activity is greater than 300 uCi/gm dose equivalent 1-131).

A.Containment isolation is required AND A. Containment pressure greater than (site EITHER of the following: specific value)

1. Containment integrity has been OR lost based on Emergency Director B. Explosive mixture exists inside judgement. containment.

4.ContainmentORR Integrity or None None None None OR OR Bypass 2. UNISOLABLE pathway from C. 1. Containment pressure greater than containment to the environment (site specific value) exists. AND OR 2. Less than one full train of (site B Indication of RCS leakage outside of specific equipment) is operating containment per design for >15 minutes.

A.Any Condition in the thatopinion of the A. AnyCondition in the

5. Emergency Emergency Director indicates Loss Emergency Director thatopinion of the indicates Potential A.ANYCondition Emergency in that Director the opinion indicatesofLoss the of A.Any Condition Emergency in the Director thatopinion of the indicates Potential A.Any Condition Emergency in the opinion of the Director that indicates Loss of the A.Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Director Judgment of the Fuel Clad Baler. Loss of the Fuel Clad Barrier. the RCS Barrier. Loss of the RCS Barrier. Containment Barrier. Containment Barrer.

Page II of66

Poosed Fission Product Barrier Matrix FG1 Loss of any two barriers AND Loss or Potential Loss of third barrier. n))-[- I FSI Loss or Potential Loss of ANY two barriers. Er]lEER I FA1 ANY Loss or ANY Potential Loss of either Fuel Clad or RCS DEER FC - Fuel Clad RC - Reactor Coolant System CT - Containment Sub-Category Loss Potential Loss Loss Potential Loss Loss Potential Loss

1. RCITS hot leg instruments indicate 3. UNISOLABLE RCS leakage > 150gpm. 1. SG laseleakage >l50gpm 0 inches after lowering trend. 1. RCS leakage results in <250 Sub Cooling OR Margin AND

1. RCS or SG Te Ne AND Leakage None 2. OR 4. a. RCS Pressure > 2450 psig. 2. UNISOLABLE steam release from affected None

2. Steam Generator tube RUPTURE that AND SIG to the environment AND requires/ results in an ESAS actuation.

3. ALL RCP's are secured. b. RCS Pressure not lowering.

1. T - > 1800 °F.

2. 25 °FSuperheat

2. Inadequate Heat 1. T-~a > 1400°F OR None None AND Removal 3. HPI-PORV Cooling in effect. HPI-PORV Cooling in effect. 2. EOP Restoration procedures not effective inu 15 minutes.

1. Containment radiation monitor (RM-G-22 or

3. Containment RM-G-23) reading > 1.95E+03 R/hr. Containment radiation monitor (RM-G-22 or Containment radiation monitor (RM-G-22 or Radiation I RCS OR None RM-G-23) reading > 25 R/hr. None None Activity 2. Coolant activity > 30uCllgm Dose RM-G-23) reading ,4.40E+03 R/hr.

Equivalent 1-131

1. Containment isolation is required and ANY 3. Reactor Building Pressure > 55 psig and of the following: rising.

a. UNPLANNED lowedng in OR containment pressure following initial 4. Hydrogen Concentration in Containment pressure rise a 4%.

OR OR

b. Containment pressure or water level 5. a. Reactor Building pressure response not consistent with LOCA > 30 pstg

4. Containment None None None None conditions. AND Integrity or Bypass OR b. Reactor Building Emergency cooling is

c. UNISOLABLE pathway from less than ANY one of the following containment to the environment conditions:

exists.

OR SPRAY COOLERS

2. Indication of RCS leakage outside of 2 containment. O 3

5. Emergency 1. Any Condition in the opinion of the 2. Any Condition in the opinion of the 1. Any Condition in the opinion of the 2. Any Condition in the opinion of the 1. Any Condition in the opinion of the 2. Any Condition in the opinion of the Emergency Director that indicates Loss of Emergency Director that indicates Emergency Director that indicates Loss of Emergency Director that indicates Potential Emergency Director that indicates Loss of Emergency Director that indicates Potential Director Jadgment the Fuel Clad Barrier. Potential Loss of the Fuel Clad Barner. the RCS Barner. Loss of the RCS Barrier. the Containment Barner. Loss of the Containment Barner.

Page 12 of 66

NEI 99-01 Rev 6 Proposed EAL Justification NEI 990 e rpsd A utfcto FC1 FC1 Category: Fuel Clad Barrier Category: Fuel Clad Barrier E-* No Change 1 Difference [: Deviation RCS or SG tube leakage RCS or SG tube leakage 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Potential Loss Potential Loss A. RCS/reactor vessel level less than (site-specific level). 1. RCITS hot leg instruments indicate 0 inches after lowering trend.

AND

2. In-core thermocouples are unavailable.

AND

3. ALL RCP's are secured.

Page 13 of66

NEI 99-01 Rev 6 Proposed EAL Justification FC2 FC2 Category: Fuel Clad Barrier Category: Fuel Clad Barrier No Change D Difference FIDeviation Inadequate Heat Removal RCS Activity 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

2) Potential Loss #3, The initiation of HPI - PORV cooling creates a controlled Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 opening of the RCS to the RB by an open PORV. This is indicative of the steam Fission Product Barrier (FPB) Threshold: generators inability to remove heat from the RCS and represents a potential Fission Product Barrier Threshold:

challenge to the FC barrier and is considered a potential loss.

Loss Loss A. Core exit thermocouple readings greater than (site-specific temperature value). 1. Tlad > 1400°F Potential Loss Potential Loss A. Core exit thermocouple readings greater than (site-specific temperature value). 2. > 25°F Superheat OR OR B. Inadequate RCS heat removal capability via steam generators as indicated by 3. HPI-PORV Cooling in effect.

(site-specific indications).

Page 14 of 66

NEI 99-01 Rev 6 Proposed EAL -1 Justification FC3 FC3 Category: Fuel Clad Barrier Category: Fuel Clad Barrier E No Change 1 Difference 1 Deviation Containment Radiation / RCS Activity Containment Radiation / RCS Activity 1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Loss Loss A. Containment radiation monitor reading greater than (site-specific value). 1. Containment radiation monitor (RM-G-22 or RM-G-23) reading OR > 1.95E+03 R/hr.

OR B. (Site-specific indications that reactor coolant activity is greater than 300 liCi/gm

2. Coolant activity > 300uClIgm Dose Equivalent 1-131 dose equivalent 1-131).

Page 15 of66

NEI 99-01 Rev 6 Proposed EAL I Justification FC6 FC5 Category: Fuel Clad Barrier Category: Fuel Clad Barrier No Change D Difference 1 Deviation Emergency Director Judgment Emergency Director Judgment Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Loss Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier. the Fuel Clad Barrier.

Potential Loss Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier. Loss of the Fuel Clad Barrier.

Page 16 of 66

NEI 99-01 Rev 6 Proposed EAL I Justification RCI RCI Category: Reactor Coolant System Barrier Category: Reactor Coolant System Barrier H-1 No Change W- Difference [: Deviation RCS or SG Tube Leakage RCS or SG Tube Leakage 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

2) Potential loss threshold #3 is based on the inability to maintain normal liquid Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 inventory within the RCS by normal operation of the Make Up System, when one Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold: Make Up Pump is discharging to the charging header. The need for a second Make Up Pump or the use of the high capacity makeup rate would be indicative of Loss Loss a substantial RCS leak. 120 gpm is the nominal capacity of each Make Up Pump.

However, 150 gpm (high makeup flow alarm setpoint) was selected because it is A. An automatic or manual ECCS (SI) actuation is required by EITHER of the 1. RCS leakage results in <250 Sub Cooling Margin more easily recognized by the operator which will result in a more timely following: OR declaration than performing a calculation.

1. UNISOLABLE RCS leakage OR 2. Steam Generator tube RUPTURE that requires/ results in an ESAS actuation. 3) Potential Loss #4, The pressurizer code safety valves will open between 2450

2. SG tube RUPTURE. psig and 2510 psig(allowance for set pressure and Code Safety valve Potential Loss accumulation). This is the design limit for the RCS and well within tested values Potential Loss

3. UNISOLABLE RCS leakage > 150gpm. (2750 psig). If the RCS heatup is able to keep the pressurizer code safety valves A. Operation of a standby charging (makeup) pump is required by EITHER of the open with pressure either increasing or cycling then the RCS shall be considered a following: OR potential breach.

1. UNISOLABLE RCS leakage

4. a. RCS Pressure > 2450 psig.

OR 4) The proposed EAL provides the Operators with a clear and easily recognizable

2. SG tube leakage. AND entry condition for this EAL without altering the intent of the EAL. The usage of the specified thresholds would ensure timely declaration should this event occur.

OR b. RCS Pressure not lowering.

TMI is using these conditions as entry into this EAL to mimic the concerns of the B. RCS cooldown rate greater than (site-specific pressurized thermal shock Potential Loss of RCS as shown in the Westinghouse CSFT monitoring for criteria/limits defined by site-specific indications). pressurized thermal shock (PTS) through the use of the RCS integrity red path.

These are the same thresholds as what was approved in EAI's based on NEI 99-01 Rev 5.

Page 17 of 66

NEI 99-01 Rev 6 ] Proposed EAL I Justification Category: Reactor Coolant System Barrier Inadequate Heat Removal RC2 Category: Reactor Coolant System Barrier Inadequate Heat Removal RC2 Z - No Change E: Difference -] Deviation 1 ) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

2) The initiation of HPI - PORV cooling creates a controlled opening of the RCS to Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 the RB by an open PORV. The opening of the RCS and the pressure control mode through throttling of the HPI and or MU valves represents a potential challenge to Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

the RCS barrier and is considered a potential loss.

Potential Loss Potential Loss A. Inadequate RCS heat removal capability via steam generators as indicated by HPI-PORV Cooling in effect.

(site-specific indications).

Page 18 of 66

NEI 99-01 Rev 6 Proposed EAL Justification RC3 RC3 Category: Reactor Coolant System Barrier Category: Reactor Coolant System Barrier E No Change 1 Difference 1:1 Deviation Containment Radiation / RCS Activity RCS Leak Rate 1) Listed site-specific systems and threshold values to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Loss Loss A. Containment radiation monitor reading greater than (site-specific value). Containment radiation monitor (RM-G-22 or RM-G-23) reading > 25 R/hr.

Page 19 of 66

NEI 99-01 Rev 6 1 Proposed EAL Justification RC6 RC5 Category: Reactor Coolant System Barrier Category: Reactor Coolant System Barrier E No Change 1:] Difference [: Deviation Emergency Director Judgment Emergency director Judgment Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Loss Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. ANY Condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier. the RCS Barrier.

Potential Loss Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier. 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.

Page 20 of 66

Justification Proposed EAL NEt NEI 99-01 Rev 66 99-al Rev Proposed EAL Justification CTI CT1 Category: Containment Barrier Category: Containment Barrier E-- No Change D Difference 1 Deviation RCS or SG Tube Leakage RCS or SG Tube Leakage 1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

2) In Loss 1. A leakage of 150 gpm was selected based on the following. In order Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 to be in the FPB matrix table there must be a loss or potential loss of the RCS or Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold: FC barriers, this makes the CT barrier an escalation only barrier. MU8 was developed in Rev 6 as the loss of containment UE, replacing the FU1 EAL in Loss Loss revision 5 of NEI 99-01. Tube leakage below 150 gpm is classified lAW Revision 6 EAL MU6 for RCS leakage, To get to the FPB matrix table the plant would need to A. A leaking or RUPTURED SG is FAULTED outside of containment. 1. SG tube leakage > 150gpm experience an RCS leakage greater than the capacity of a M/U pump, for TMI this AND is 150 gpm, if this is occurring and you enter the matrix table for potential Loss of

2. UNISOLABLE steam release from affected S/G to the environment the RCS and if the RCS leakage being experienced is via a S/G tube leak and there is unisolable steam leakage to the environment from that S/G you would immediately escalate to a SAE based on the potential loss of RCS barrier and the loss of the containment barrier. This Loss of the CT barrier would not be considered in the FPB matrix at S/G leakage rates less than 150 gpm since below this level of RCS leakage you would not be in the FPB matrix table.

Page 21 of 66

NEI 99-01 Rev 6 1 Proposed EAL Justification CT2 CT2 Category: Containment Barrier Category: Containment Barrier E No Change 1 Difference 1 Deviation Inadequate Heat Removal Inadequate Heat Removal 1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Potential Loss Potential Loss A. 1. (Site-specific criteria for entry into core cooling restoration procedure) 0

1. Tclad > 1800 F.

AND AND

2. Restoration procedure not effective within 15 minutes.

2. EOP Restoration procedures not effective in < 15 minutes.

Page 22 of 66

NEI 99-01 Rev 6 Proposed EAL Justification CT3 CT3 Category: Containment Barrier Category: Containment Barrier E No Change [: Difference [: Deviation Containment Radiation I RCS Activity Containment Radiation / RCS Activity 1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Potential Loss Potential Loss A. Containment radiation monitor reading greater than (site-specific value). Containment radiation monitor (RM-G-22 or RM-G-23) reading > 4.40E+03 R/hr.

Page 23 of 66

Justification NEI 99-01 Rev 6$ Proposed EAL Proposed EAL Justification CT4 CT4 Category: Containment Barrier Category: Containment Barrier E No Change [IDifference 1 Deviation Containment Integrity or Bypass Containment Integrity or Bypass 1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

2) Provided the indications that the emergency Director would use to determine Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Containment integrity. These are consistent with the current TMI FPB matrix table.

Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Loss Loss A. Containment isolation is required 1. Containment isolation is required and ANY of the following:

AND a. UNPLANNED lowering in containment pressure following initial pressure EITHER of the following: rise

1. Containment integrity has been lost based on Emergency Director OR judgment. b. Containment pressure or water level response not consistent with LOCA OR conditions.

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

B. Indications of RCS leakage outside of containment. OR

2. Indication of RCS leakage outside of containment Potential Loss Potential Loss A. Containment pressure greater than (site-specific value)

OR 3. Reactor Building Pressure > 55 psig and rising.

B. Explosive mixture exists inside containment OR OR 4. Hydrogen Concentration in Containment > 4%.

C. 1. Containment pressure greater than (site-specific pressure setpoint) OR AND 5. a. Reactor Building pressure > 30 psig

2. Less than one full train of (site-specific system or equipment) is operating AND per design for 15 minutes or longer. b. Reactor Building Emergency cooling is less than ANY one of the following conditions:

SPRAY COOLERS 2 0 0 3 1 1 Page 24 of66

NEI 99-01 Rev 6 1 Proposed EAL Justification CT6 CT5 Category: Containment Barrier Category: Containment Barrier E'* No Change E-- Difference 1: Deviation Emergency director Judgment Emergency Director Judgment Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Loss Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier. the Containment Barrier.

Potential Loss Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier. Loss of the Containment Barrier.

Page 25 of 66

NEI 99-01 Rev 6 Proposed EAL Justification SG1I MG1 Initiating Condition: GENERAL EMERGENCY Initiating Condition: M No Change 1 Difference F Deviation Prolonged loss of all offsite and all onsite AC power to emergency buses.

Prolonged loss of all offsite and all onsite AC power to emergency buses.

1) Listed site specific equipment, site specific time based on station blackout Operating Mode Applicability: coping analysis, and site specific indication to ensure timely classification.

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Example Emergency Action Levels:

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the General Emergency promptly upon determining that (site-specific hours) has been exceeded, or will likely be exceeded. Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses). 1. Loss of ALL offsite AC power to Emergency 4KV buses.

AND AND 2. Failure of EG-Y-1A, EG-Y-1 B Emergency Diesel Generators and EG-Y-4 SBO Diesel Generator to supply power to Emergency 4KV buses.

b. EITHER of the following:

AND

" Restoration of at least one emergency bus in less than 3. EITHER of the following:

(site-specific hours) is not likely. a. Restoration of at least one Emergency 4KV bus in < 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is not likely.

OR

" (Site-specific indication of an inability to adequately remove heat from the core) b. > 25°F superheat Page 26 of 66

NEI 99-01 Rev 6 Proposed EAL Justification SS1 MS1 Initiating Condition: SITE AREA EMERGENCY Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or Initiating Condition: H No Change 1-- Difference 1 Deviation longer. 1) Listed site specific equipment to ensure timely classification.

Loss of all offsite and onsite AC power to emergency busses for 15 minutes or longer.

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Example Emergency Action Levels:

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded. Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses) for 15 minutes or longer. 1. Loss of ALL offsite AC Power to Emergency 4KV buses.

AND

2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBO Diesel Generator to supply power to Emergency 4KV buses.

AND

3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutes from the time of loss of both offsite and onsite AC power Page 27 of 66

NEI 99-01 Rev 6 Proposed EAL I Justification SA1I MAI Initiating Condition: ALERT Loss of all but one AC power source to emergency buses for 15 minutes or longer.

Initiating Condition: M No Change FD ifference FD eviation Loss of all but one AC power source to emergency buses for 15 minutes or longer.

1) Listed site specific equipment to ensure timely classification.

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Example Emergency Action Levels:

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded. Note: The Emergency Director should declare the event promptly upon

1. a. AC power capability to (site-specific emergency buses) is reduced to a determining that the applicable time has been exceeded, or will likely be exceeded.

single power source for 15 minutes or longer.

1. AC power capability to Emergency 4KV buses reduced to only one of the AND following power sources for > 15 minutes.

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

Auxiliary Transformer 1A power to SAFETY SYSTEMS.

Auxiliary Transformer 1B

Emergency Diesel Generator EG-Y-1 A

Emergency Diesel Generator EG-Y-1 B

SBO Diesel Generator EG-Y-4 AND

2. Any additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.

Page 28 of 66

NEI 99-01 Rev 6 Proposed EAL ]Justification Sul MUl Initiating Condition: UNUSUAL EVENT Initiating Condition: F_-] No Change E-1 Difference F Deviation Loss of all offsite AC power capability to emergency buses for 15 minutes or longer. Loss of all offsite AC power capability to emergency buses for 15 minutes or longer. 1) Listed site specific equipment to ensure timely classification.

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Example Emergency Action Levels:

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be Note: The Emergency Director should declare the event promptly upon exceeded. determining that the applicable time has been exceeded, or will likely be exceeded.

Loss of ALL offsite AC power capability to (site-specific emergency buses) for 15 minutes or longer Loss of ALL offsite AC power capability to Emergency 4KV busses for

> 15 minutes.

Page 29 of 66

NEI 99-01 Rev 6 Proposed EAL Justification E

SG8 MG2 Initiating Condition: GENERAL EMERGENCY Initiating Condition: 1 No Change M Difference 1-1 Deviation Loss of all AC and Vital DC power sources for 15 minutes or longer.

Loss of all AC and Vital DC power sources for 15 minutes or longer.

1) Listed site specific voltage and equipment to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability: 2) Removed the word "indicated" this will allow for an indication problem to not Power Operation, Startup, Hot Standby, Hot Shutdown cause confusion on the need to declare.

1,2,3,4 Example Emergency Action Levels:

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the General Emergency promptly upon determining that 15 minutes has been exceeded, or will likely be Note: The Emergency Director should declare the event promptly upon exceeded. determining that the applicable time has been exceeded, or will likely be exceeded.

1. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses) for 15 minutes or longer.

1. Loss of ALL offsite AC power to Emergency 4KV buses.

AND AND

2. Failure of EG-Y-1A, EG-Y-1 B Emergency Diesel Generators and EG-Y-4 SBO Indicated voltage is less than (site-specific bus voltage value) on ALL Diesel Generator to supply power to Emergency 4KV buses.

(site-specific vital DC busses) for 15 minutes or longer.

AND

3. Voltage is < 105 VDC on 125 VDC Distribution System 1A and 1B.

AND

4. ALL AC and Vital DC power sources have been lost for >_15 minutes.

Page 30 of 66

NEI 99-01 Rev 6 Proposed EAL Justification SS8 MS2 Initiating Condition: SITE AREA EMERGENCY Loss of all Vital DC power for 15 minutes or longer.

Initiating Condition: D No Change M Difference F 1 Deviation Loss of all Vital DC power for 15 minutes or longer.

1) Listed site specific voltage and equipment to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability: 2) Removed the word "indicated" this will allow for an indication problem to not Power Operation, Startup, Hot Standby, Hot Shutdown cause confusion on the need to declare.

1,2,3,4 Example Emergency Action Levels:

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes time has been exceeded, or Note: The Emergency Director should declare the event promptly upon will likely be exceeded. determining that the applicable time has been exceeded, or will likely be exceeded.

Indicated voltage is less than (site-specific bus voltage value) on ALL Vital DC buses for 15 minutes or longer.

Voltage is < 105 VDC on 125 VDC Distribution System 1A and 1 B for

_>15minutes.

Page 31 of 66

Justification NEI99-01 Rev6 Proposed EAL Justification NEI 99-01 Rev 6 Proposed EAL SS5 Initiating Condition: SITE AREA EMERGENCY Initiating Condition:

MS3 FD1 No Change M Difference F1 Deviation Inability to shutdown the reactor causing a challenge to (core cooling [PWR] / RPV water level [BWR]) or RCS heat removal. Inability to shutdown the reactor causing a challenge to core cooling or RCS heat removal. 1) Listed site specific indications to ensure timely classification.

Operating Mode Applicability: 2) Mode 2 included in operating mode applicability as per developer notes.

Operating Mode Applicability:

3) The initiation of HPI - PORV cooling creates a controlled opening of the RCS to Power Operation 1,2 the RB by an open PORV. This is indicative of the steam generators inability to remove heat from the RCS.

Example Emergency Action Levels:

Emergency Action Levels (EAL):

1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown the reactor. 1. Automatic or Manual Trip did not shutdown the reactor as indicated by Reactor Power > 5%.

AND AND

b. All manual actions to shutdown the reactor have been unsuccessful. 2. ALL manual actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 5%.

AND AND

c. EITHER of the following conditions exist: 3. EITHER of the following conditions exist:

a. Tcld > 14000F.

1. (Site-specific indication of an inability to adequately remove heat from the core) OR

b. HPI-PORV Cooling in effect.

OR

2. (Site-specific indication of an inability to adequately remove heat from the RCS)

Page 32 of66

NEI 99-01 Rev 6 1 Proposed EAL Justification 5A5 MA3 Initiating Condition: ALERT Automatic or manual (trip [PWR] / scram [BWRJ) fails to shutdown the reactor, and Initiating Condition: F No Change W Difference FIDeviation subsequent manual actions taken at the reactor control consoles are not Automatic or manual trip fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down 1) Listed site specific indications to ensure timely classification.

successful in shutting down the reactor.

the reactor.

2) Mode 2 included in operating mode applicability as per developer notes.

Operating Mode Applicability:

Power Operation 1,2 Example Emergency Action Levels:

Emergency Action Levels (EAL):

Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually Note: A manual action is any operator action, or set of actions, which causes the driving in control rods or implementation of boron injection strategies. control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown the reactor. 1. Automatic Trip did not shutdown the reactor as indicated by Reactor Power

> 5%.

AND AND

2. Manual actions taken at the Console Center are not successful in shutting

b. Manual action taken at the reactor control consoles are not down the reactor as indicated by Reactor Power> 5%.

successful in shutting down the reactor.

Page 33 of 66

Justification NEI99-01 Rev6 Proposed EAL Justification NEI 99-01 Rev 6 Proposed EAL SU5 MU3 Initiating Condition: UNUSUAL EVENT Initiating Condition: [D No Change FIDifference 1-1 Deviation Automatic or manual (trip [PWRJ / scram [BWR]) fails to shutdown the reactor.

Automatic or manual trip fails to shutdown the reactor.

1) Listed site specific indications to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability: 2) Mode 2 included in operating mode applicability as per developer notes.

Power Operation 1,2 Example Emergency Action Levels: (1 or 2)

Emergency Action Levels (EAL):

Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually Note: A manual action is any operator action, or set of actions, which causes the driving in control rods or implementation of boron injection strategies. control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. a. An automatic (trip [PWRI / scram [BWR]) did not shutdown the

1. a. Automatic Trip did not shutdown the reactor as indicated by Reactor reactor.

Power > 5%.

AND AND

b. Subsequent manual action taken at the Console Center is successful in

b. A subsequent manual action taken at the reactor control consoles is shutting down the reactor.

successful in shutting down the reactor.

OR

2. a. Manual Trip did not shutdown the reactor as indicated by Reactor Power

2. a. A manual trip ([PWR] / scram [BWRI) did not shutdown the reactor. > 5%.

AND AND

b. Subsequent automatic Trip is successful in shutting down the reactor.

b. EITHER of the following:

1. A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.

OR

2. A subsequent automatic (trip [PWRJ / scram [BWR]) is successful in shutting down the reactor.

Page 34 of 66

NEI 99-01 Rev 6 j Proposed EAL I Justification S2 MA4 Initiating Condition: ALERT Initiating Condition:

[q No Change EIDifference FIDeviation UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress. UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress. 1) Listed site specific number of steam generators to ensure timely classification.

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1.2,3,4 Example Emergency Action Levels:

Note: The Emergency Director should declare the Alert promptly upon determining that Emergency Action Levels (EAL):

15 minutes has been exceeded, or will likely be exceeded.

Note: The Emergency Director should declare the event promptly upon

1. a. An UNPLANNED event results in the inability to monitor one or more of the following determining that the applicable time has been exceeded, or will likely be parameters from within the Control Room for 15 minutes or longer. exceeded.

[see table below]

1. a An UNPLANNED event results in the inability to monitor ANY Table MI

[BWR parameter list] [PWR parameter list] parameters from within the Control Room for > 15 minutes.

Reactor Power Reactor Power Table M1 Control Room Parameters RPV Level RCS Level

Reactor Power

PZR Level RPV Pressure RCS Pressure

RCS Pressure

In Core/Core Exit Temperature Primary Containment Pressure In Core/Core Exit Temperature

Level in at least one OTSG.

Levels in at least (site specific number)

OTSG Emergency Feed Water Flow Suppression Pool Level steam generators Steam Generator Auxiliary or Suppression Pool Temperature Emergency Feed Water Flow AND AND b. ANY Table M2 transient in progress.

b. Any of the following transient events in progress.

Table M2 Significant Transients

Automatic or Manual runback greater than 25% thermal reactor power

Electrical load rejection greater than 25% full electrical load

Automatic Turbine Runback >25% thermal reactor power

Reactor Scram [BWRI / trip [PWR]

Electrical Load Rejection >25% full electrical load

ECCS (SI) actuation

Thermal power oscillations greater than 10% [BWRJ

Reactor Trip

ESAS Actuation

" Thermal Power oscillations > 10%

Page 35 of 66

NE199-01 Rev 6 Proposed EAL Justification SU2 W*

MU4 Initiating Condition: UNUSUAL EVENT Initiating Condition: No Change FIDifference FIDeviation UNPLANNED loss of Control Room indications for 15 minutes or longer.

UNPLANNED loss of Control Room indications for 15 minutes or longer.

1) Listed site specific number of steam generators to ensure timely classification.

Operating Mode Applicability:

Power Operation. Startup, Hot Standby, Hot Shutdown 1,2,3,4 Example Emergency Action Levels:

Note: The Emergency Director should declare the Unusual Event promptly upon Emergency Action Levels (EAL):

determining that 15 minutes has been exceeded, or will likely be exceeded. Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be An UNPLANNED event results in the inability to monitor one or more of the exceeded.

following parameters from within the Control Room for 15 minutes or longer.

[see table below] UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes.

[ BWR parameter list] [ PWR parameter list]

Table M1 Control Room Parameters Reactor Power Reactor Power

Reactor Power RPV Level RCS Level

PZR Level

RCS Pressure RPV Pressure RCS Pressure

In Core/Core Exit Temperature Primary Containment Pressure In Core/Core Exit Temperature

Level in at least one OTSG.

OTSG Emergency Feed Water Flow Levels in at least (site specific Suppression Pool Level number) steam generators Steam Generator Auxiliary or Suppression Pool Temperature Emergency Feed Water Flow Page 36 ol'66

NEI 99-01 Rev 6 Proposed EAL Justification SA9 MA5 Initiating Condition: ALERT Hazardous event affecting a SAFETY SYSTEM needed for the current Initiating Condition: ALERT Hazardous event affecting a SAFETY SYSTEM required for the current FI] No Change M Difference DI eviation operating mode. operating mode. 1) No additional site specific hazards noted Operating Mode Applicability: Operating Mode Applicability:

2) Changed the word "needed" to "required" in the IC and "required by Technical Specification" in the EAL to be consistent with terminology used by operators and Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 minimize confusion.

Example Emergency Action Levels: Emergency Action Levels (EAL):

3) Added additional note to easily direct the operator to lesser ICs Note: If it is determined that the conditions of MA5 are not met then assess the

1. a. The occurrence of ANY of the following hazardous events:

event via HU3, HU4, or HU6.

Seismic event (earthquake)

1. The occurrence of ANY of the following hazardous events:

Internal or external flooding event

High winds or tornado strike

Seismic event (earthquake)

FIRE

Internal or external flooding event

EXPLOSION

High winds or tornado strike

(site-specific hazards)

FIRE

Other events with similar hazard characteristics as

EXPLOSION determined by the Shift Manager

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

b. EITHER of the following: AND

1. Event damage has caused indications of degraded 2. EITHER of the following:

performance in at least one train of a SAFETY SYSTEM needed for the current operating mode. a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM OR required by Technical Specifications for the current operating mode.

2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode. OR

b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.

Page 37 of 66

NEI 99-01 Rev 6 1 Proposed EAL Justification SU4 Initiating Condition: UNUSUAL EVENT Initiating Condition:

MU6 H7-q No Change 1 Difference F-1 Deviation RCS leakage for 15 minutes or longer.

RCS leakage for 15 minutes or longer.

1) Listed site specific values to ensure timely classification, Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Example Emergency Action Levels: (1 or 2 or 3)

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be Note: The Emergency Director should declare the event promptly upon exceeded. determining that the applicable time has been exceeded, or will likely be exceeded.

1. RCS unidentified or pressure boundary leakage greater than (site-specific 1. RCS unidentified or pressure boundary leakage > 10 gpm for> 15 value) for 15 minutes or longer.

minutes

2. RCS identified leakage greater than (site-specific value) for 15 minutes or OR longer

2. RCS identified leakage >25 gpm for > 15 minutes

3. Leakage from the RCS to a location outside containment greater than 25 OR gpm for 15 minutes or longer

3. Leakage from the RCS to a location outside containment >25 gpm for

> 15 minutes Page 38 of 66

NEI 99-01 Rev 6 [Proposed EAL Justification SU6 MU7 Initiating Condition: UNUSUAL EVENT Initiating Condition: [- No Change I Difference F- Deviation Loss of all onsite or offsite communications capabilities Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

1) Listed site specific communication methods to ensure timely classification.

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Example Emergency Action Levels: (1 or 2 or 3)

Emergency Action Levels (EAL):

1. Loss of ALL of the following onsite communication methods:

1. Loss of ALL Table M3 Onsite communications capability affecting the (site-specific list of communications method ability to perform routine operations.

2. Loss of ALL of the following ORO communications s) methods: OR (site-specific list of communications methods) 2. Loss of ALL Table M3 Offsite communication capability affecting the ability to perform offsite notifications.

3. Loss of ALL of the following NRC communications methods:

OR (site-specific list of communications methods)

3. Loss of ALL Table M3 NRC communication capability affecting the ability to perform NRC notifications.

Table M3 Communications Capability System Onsite Offsite NRC Radios X Plant page X Plant Telephone System X Commercial Telephones X X X NARS X ENS X X HPN X X Satellite phones X X Page 39 of 66

NEI 99-01 Rev 6 Proposed EAL ]Justification Sul MU8 Initiating Condition: UNUSUAL EVENT Initiating Condition: FD No Change [x]Difference FIDeviation Failure to isolate containment or loss of containment pressure control. [PWR]

Failure to isolate containment or loss of containment pressure control.

1) Listed site specific indications to ensure timely classification.

Operating Mode Applicability:

2) Reworded EAL 1.b to be a positive statement Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3,4 Example Emergency Action Levels: (1 or2)

Emergency Action Levels (EAL):

1. a. Failure of containment to isolate when required by an actuation signal. 1. a. Failure of containment to isolate when required by an actuation signal.

AND AND

b. ANY required penetration remains open > 15 minutes of the actuation

b. ALL required penetrations are not closed within 15 minutes of the signal.

actuation signal. OR

2. a. Containment pressure greater than (site-specific pressure). 2. a. Reactor Building pressure > 30 psig AND AND b. Reactor Building Emergency cooling is less than ANY one of the following conditions for > 15 minutes:

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

SPRAY COOLERS 2 0 0 3 Page 40 of 66

NEI 99-01 Rev 6 Proposed EAL Justification CA2 CAI Initiating Condition: ALERT Initiating Condition: W No Change 1 Difference 1 1 Deviation Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or Loss of all offsite and onsite AC power to emergency busses for 15 minutes or 1) Listed site specific equipment to ensure timely classification.

longer. longer.

Operating Mode Applicability: Operating Mode Applicability:

Cold Shutdown, Refueling, Defueled 5,6, D Example Emergency Action Levels: Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Unusual Event promptly upon Note: The Emergency Director should declare the event promptly upon determining determining that 15 minutes time has been exceeded, or will likely be that the applicable time has been exceeded, or will likely be exceeded.

exceeded.

1. Loss of ALL offsite AC power to Emergency 4KV buses.

Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses) for 15 minutes or longer. AND

2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBO Diesel Generator to supply power to Emergency 4KV buses.

AND

3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutes from the time of loss of both offsite and onsite AC power.

Page 41 of166

NEI 99-01 Rev 6 Proposed EAL I Justification CU2 Cul Initiating Condition: UNUSUAL EVENT Initiating Condition: E* No Change 1 Difference [:] Deviation Loss of all but one AC power source to emergency buses for 15 minutes or longer. Loss of all but one AC power source to emergency buses for 15 minutes or Operating Mode Applicability: longer. 1) Listed site specific equipment to ensure timely classification.

Cold Shutdown, Refueling, Defueled Operating Mode Applicability:

Example Emergency Action Levels: 5,6, D Note: The Emergency Director should declare the Unusual Event promptly upon Emergency Action Levels (EAL):

determining that 15 minutes time has been exceeded, or will likely be exceeded. Note: The Emergency Director should declare the event promptly upon

1. a. AC power capability to (site-specific emergency buses) is reduced to a determining that the applicable time has been exceeded, or will likely be single power source for 15 minutes or longer. exceeded.

AND

1. AC power capability to Emergency 4KV buses reduced to only one of the

b. Any additional single power source failure will result in loss of all AC following power sources for > 15 minutes.

power to SAFETY SYSTEMS.

" Auxiliary Transformer 1A

" Auxiliary Transformer 1B

" Emergency Diesel Generator EG-Y-1A

" Emergency Diesel Generator EG-Y-1 B

" SBO Diesel Generator EG-Y-4 AND

2. ANY additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.

Page 42 of 66

NEI 99-01 Rev 6 j Proposed EAL ]Justification Initiating Condition - ALERT CA6 Initiating Condition:

CA2 D No Change M Difference Deviation Hazardous event affecting SAFETY SYSTEM needed for the current operating Hazardous event affecting SAFETY SYSTEM required for the current operating mode. mode. 1) No additional site specific hazards noted Operating Mode Applicability: Operating Mode Applicability:

2) Changed the word "needed" to "required" in the IC and "required by Cold Shutdown, Refueling 5,6 Technical Specification" in the EAL to be consistent with terminology used by Example Emergency Action Levels: Emergency Action Levels (EAL): operators and minimize confusion.

1. a. The occurrence of ANY of the following hazardous events: Note: If it is determined that the conditions of CA2 are not met then assess the event via HU3, HU4, or HU6. 3) Added additional note to easily direct the operator to lesser ICs

Seismic event (earthquake)

1. The occurrence of ANY of the following hazardous events:

Internal or external flooding event

High winds or tornado strike

Seismic event (earthquake)

Internal or external flooding event

FIRE

High winds or tornado strike

EXPLOSION

" FIRE

(site-specific hazards)

" EXPLOSION

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

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

b. EITHER of the following: AND

1. Event damage has caused indications of degraded 2. EITHER of the following:

performance in at least one train of a SAFETY SYSTEM a. Event damage has caused indications of degraded needed for the current operating mode. performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current OR operating mode.

2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current OR operating mode. b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.

Page 43 of 66

NEI 99-01 Rev 6 Proposed EAL Justification CU4 CU3 Initiating Condition: UNUSUAL EVENT No Change Difference Deviation Initiating Condition:

Loss of Vital DC power for 15 minutes or longer. Loss of Vital DC power for 15 minutes or longer.

Operating Mode Applicability: Operating Mode Applicability: 1) Listed site specific voltage and equipment to ensure timely classification.

Cold Shutdown, Refueling 5, 6 2) Removed the word "indicated" this will allow for an indication problem to not Example Emergency Action Levels: Emergency Action Levels (EAL): cause confusion on the need to declare.

Note: The Emergency Director should declare the Unusual Event promptly upon Note: The Emergency Director should declare the event promptly upon determining that 15 minutes time has been exceeded, or will likely be determining that the applicable time has been exceeded, or will likely be exceeded. exceeded.

Indicated voltage is less than (site-specific bus voltage value) on required Vital DC Voltage is < 105 VDC on required 125 VDC Distribution System 1A and 1B for buses for 15 minutes or longer. > 15 minutes.

Page 44 of 66

NEI 99-01 Rev 6 Proposed EAL ]Justification CU5 CU4 Initiating Condition: UNUSUAL EVENT Initiating Condition:

E No Change 1 Difference 1 Deviation Loss of all onsite or offsite communications capabilities Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability: Operating Mode Applicability: 1) Listed site specific communications methods to ensure timely classification Cold Shutdown, Refueling, Defuled 5,6, D Example Emergency Action Levels: (1 or 2 or 3) Emergency Action Levels (EAL):

1. Loss of ALL of the following onsite communication methods: 1. Loss of ALL Table C1 Onsite communications capability affecting the (site-specific list of communications method ability to perform routine operations.

2. Loss of ALL of the following ORO communications s) methods: OR (site-specific list of communications methods) 2. Loss of ALL Table Cl Offsite communication capability affecting the ability to perform offsite notifications.

3. Loss of ALL of the following NRC communications methods:

OR (site-specific list of communications methods)

3. Loss of ALL Table C1 NRC communication capability affecting the ability to perform NRC notifications.

Table Cl Communications Capability System Onsite Offsite NRC Radios X Plant page X Plant Telephone System X Commercial Telephones X X X NARS X ENS X X HPN X X Satellite phones X X Page 45 of 66

NEI 99-01 Rev 6 Proposed EAL Justification CA3 CA5 Initiating Condition: ALERT Initiating Condition: -- ' No Change W Difference 1 Deviation Inability to maintain the plant in cold shutdown. Inability to maintain plant in cold shutdown.

1) Listed site specific Technical Specification cold shutdown temperature limit to Operating Mode Applicability: Operating Mode Applicability:

ensure timely classification.

Cold Shutdown, Refueling 5, 6

2) Listed site specific pressure reading to enhance timely classification.

Example Emergency Action Levels: (1 or 2) Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Alert promptly upon Note: The Emergency Director should declare the event promptly upon 3) Added wording relating the temp and press rise to a loss of decay heat removal determining that the applicable has been exceeded, or will likely be determining that the applicable time has been exceeded, or will likely be capability as per the developer notes for PWR's exceeded. exceeded.

4) Added the following note, taken from the basis section of the EAL, to bring it to

1. UNPLANNED increase in RCS temperature to greater than (site-specific A momentary UNPLANNED excursion above the Technical Specification the attention of the SM/ED when using the "procedure matrix" (1 1x17 quick Technical Specification cold shutdown temperature limit) for greater than cold shutdown temperature limit when heat removal function is available reference control room document) "A momentary UNPLANNED excursion above the duration specified in the following table. does not warrant classification. the Technical Specification cold shutdown temperature limit when heat removal 0

2. UNPLANNED RCS pressure increase greater than (site-specific pressure 1. UNPLANNED rise in RCS temperature > 200 F for > Table C2 duration. function is available does not warrant classification."

reading). (This EAL does not apply during water-solid plant conditions.

OR

[PWRJ)

2. UNPLANNED RCS pressure rise > 10 psig as a result of temperature Table: RCS Heat-up Duration Thresholds rise. (This EAL does not apply during water- solid plant conditions.)

RCS Status Containment Closure Heat-up Duration Status Table C2 - RCS Heat-up Duration Thresholds Intact (but not RCS Status Containment Closure Heat-up Duration RCS Reduced Not Applicable 60 minutes* Status Inventory [PWR]) Intact Not Applicable 60 minutes*

Not Intact (or at Established 20 minutes* Not Intact reduced inventory Not Established 0 minutes Established 20 minutes*

[PWR])

OR

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

Reduced Inventory Not Established 0 minutes If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not apolicable.

Page 46 of 66

NEI 99-01 Rev 6 ]Proposed EAL Justification CU3 CU5 Initiating Condition: UNUSUAL EVENT Initiating Condition: H: No Change Z Difference 1 Deviation UNPLANNED increase in RCS temperature. UNPLANNED rise in RCS temperature. 1) Listed site specific Technical Specification cold shutdown temperature limit Operating Mode Applicability: Operating Mode Applicability: to ensure timely classification.

Cold Shutdown, Refueling 5,6 2) Changed the word increase to rise in the initiating condition to be consistent Example Emergency Action Levels: (1 or 2) Emergency Action Levels (EAL): with operations language and training.

Note: The Emergency Director should declare the Unusual Event promptly Note: The Emergency Director should declare the event promptly upon 3) Added the following note, taken from the basis section of the EAL, to bring it upon determining that 15 minutes time has been exceeded, or will likely determining that the applicable time has been exceeded, or will likely to the attention of the SM/ED when using the "procedure matrix" (11x17 quick be exceeded. be exceeded. reference control room document) "Amomentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat

1. UNPLANNED increase in RCS temperature to greater than (site-specific A momentary UNPLANNED excursion above the Technical Technical Specification cold shutdown temperature limit). removal function is available does not warrant classification."

Specification cold shutdown temperature limit when heat removal function is available does not warrant classification.

2. Loss of ALL RCS temperature and (reactor vessel/RCS [PWR] or RPV

[BWRJ) level indication for 15 minutes or longer. 1. UNPLANNED rise in RCS temperature > 2000 F.

OR

2. Loss of the following for > 15 minutes.

ALL RCS temperature indications AND

ALL RPV level indications Page 47 of 66

NEI 99-01 Rev 6 [Proposed EAL [Justification CGI CG6 Initiating Condition: GENERAL EMERGENCY Initiating Condition: --- No Change W Difference [: Deviation Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory affecting fuel clad Loss of reactor vessel / RCS inventory affecting fuel clad integrity with integrity with containment challenged. containment challenged. 1) EAL 1 not included as per guidance in developer notes since top of active Operating Mode Applicability: Operating Mode Applicability: fuel is below level indication lowest value.

Cold Shutdown, Refueling 5,6 2) Listed site specific radiation monitors to ensure timely classification Example Emergency Action Levels: (1 or 2) Emergency Action Levels (EAL):

3) Listed site specific sumps and tanks to ensure timely classification Note: The Emergency Director should declare the Unusual Event promptly Note: The Emergency Director should declare the event promptly upon upon determining that 30 minutes time has been exceeded, or will likely determining that the applicable time has been exceeded, or will likely be 4) Listed Explosive mixture in the Containment Challenge Table to ensure be exceeded. exceeded. timely classification

1. a. (Reactor vessel/RCS [PWRI or RPV [BWR]) vessel level less than (site- 1. a. Reactor Vessel / RCS level cannot be monitored for >30 minutes.

specific level) for 30 minutes or longer.

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

b. ANY indication from the Containment Challenge Table

Table C3 indications of a sufficient magnitude to indicate core

2. a.. (Reactor vessel/RCS [PWR] or RPV [BWR]) vessel level cannot be uncovery monitored for 30 minutes or longer.

OR AND

Erratic Source Range Neutron Monitor indication.

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

OR

(Site-specific radiation monitor) reading greater than (site-specific value)

Radiation Monitor RM-G-6 or RM-G-7 reading > 3 R/hr.

Erratic source range monitor indication [PWRJ AND UNPLANNED increase in (site-specific sump and/or tank levels) of c.ANY Containment Challenge Indication (Table C4) sufficient magnitude to indicate core uncovery Table C3 Indications of RCS Leakage

(Other site-specific indications)

AND

UNPLANNED Reactor Building Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

c. ANY indication from the Containment Challenge Table).

UNPLANNED BWST level rise*

UNPLANNED RCDT level dse*

Table: Containment Challenge Table

UNPLANNED rise in RCS makeup

CONTAINMENT CLOSURE not established*

Observation of leakage or inventory loss

(Explosive mixture) exists inside containment *Rise in level is attributed to a loss of reactor vesselIRCS inventory.

UNPLANNED increase in containment pressure

Secondary containment radiation monitor reading above (site-specific value) [BWRJ Table C4 Containment Challenge Indications ifCONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is

Hydrogen Concentration in Containment > 4%

not required.

UNPLANNED rise in containment pressure

CONTAINMENT CLOSURE not established*

'if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.

Page 48 of 66

NEI 99-01 Rev 6 J Proposed EAL J Justification CS1 CS6 Initiating Condition: SITE AREA EMERGENCY Initiating Condition: H:1 No Change E Difference FII Deviation Loss of (reactor vessel/RCS [PWR] or RPV [BWRJ) inventory affecting core Loss of reactor vessel / RCS inventory affecting core decay heat removal 1) EAL 1 not included as per guidance in developer notes since 6" below decay heat removal capability. capabilities. bottom ID of RCS loop is below level indication lowest value.

Operating Mode Applicability: Operating Mode Applicability:

2) EAL 2 not included as per guidance in developer notes since top of active Cold Shutdown, Refueling 5,6 fuel is below level indication lowest value,.

Example Emergency Action Levels: (1 or 2 or 3) Emergency Action Levels (EAL):

3) Listed site specific radiation monitors to ensure timely classification Note: The Emergency Director should declare the Unusual Event promptly Note: The Emergency Director should declare the event promptly upon upon determining that 30 minutes time has been exceeded, or will likely determining that the applicable time has been exceeded, or will likely 4) Listed site specific sumps and tanks to ensure timely classification be exceeded. be exceeded.

1. a. CONTAINMENT CLOSURE not established.

AND 1. Reactor vessel level cannot be monitored for >30 minutes.

b. (Reactor vessel/RCS [PWR] or RPV [BWR]) level less than (site- AND specific level).

2. Core uncovery is indicated by any of the following:

2. a. CONTAINMENT CLOSURE established.

Table C3 indications of a sufficient magnitude to indicate core AND uncovery

b. (Reactor vessel/RCS [PWR] or RPV [BWR]) level less than (site- OR specific level).

Erratic Source Range Neutron Monitor indication.

3. a. (Reactor vessel/RCS [PWR] or RPV [BWR]) level cannot be OR monitored for 30 minutes or longer.

Radiation Monitors RM-G-6 or RM-G-7 reading > 3 R/hr.

AND

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

(Site-specific radiation monitor) reading greater than (site- Table C3 Indications of RCS Leakage specific value)

UNPLANNED Reactor Building Sump level rise*

Erratic source range monitor indication [PWR]

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED increase in (site-specific sump and/or tank

UNPLANNED BWST level rise*

UNPLANNED RCDT level rise*

levels) of sufficient magnitude to indicate core uncovery

UNPLANNED rise in RCS makeup

(Other site-specific indications) Observation of leakage or inventory loss

Rise in level is attributed to a loss of reactor vessel/RCS inventory.

Page 49 of 66

NEI 99-01 Rev 6 JProposed EAL j Justification Initiating Condition: ALERT CAI Initiating Condition:

CA6 H No Change W Difference El Deviation Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory Loss of reactor vessel / RCS inventory Operating Mode Applicability: Operating Mode Applicability: 1) Listed site specific levels to ensure timely classification.

Cold Shutdown, Refueling 5, 6 2) Listed site specific sumps and tanks to ensure timely classification.

Example Emergency Action Levels: (1 or 2) Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Unusual Event promptly Note: The Emergency Director should declare the event promptly upon upon determining that 15 minutes time has been exceeded, or will likely determining that the applicable time has been exceeded, or will likely be exceeded. be exceeded.

1. Loss of (reactor vessel/RCS [PWR] or RPV [BWRJ) inventory as 1. Loss of Reactor Vessel / RCS inventory as indicated by RCS level indicated by level less than (site-specific level). < 0 inches on Draindown Level indicator.

2. a. (Reactor vessel/RCS [PWRJ or RPV [BWR]) level cannot be OR monitored for 15 minutes or longer

2. a. Reactor vessel / RCS level cannot be monitored for_> 15 minutes.

AND AND

b. UNPLANNED increase in (site-specific sump and/or tank) levels due to a loss of (reactor vessel/RCS [PWRJ or RPV [BWR]) inventory. b. Loss of reactor vessel / RCS inventory per Table C3 indications.

Table C3 Indications of RCS Leakage

UNPLANNED Reactor Building Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED BWST level rise*

UNPLANNED RCDT level rise*

UNPLANNED rise in RCS makeup

Observation of leakage or inventory loss

Rise in level is attributed to a loss of reactor vessel/RCS inventory.

Page 50 of 66

NE199-O1 Rev 6 Proposed EAL Justification Cul CU6 Initiating Condition: UNUSUAL EVENT Initiating Condition: D No Change E Difference I: Deviation UNPLANNED loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory for UNPLANNED loss of reactor vessel / RCS inventory for 15 minutes or longer.

15 minutes or longer. 1) Described "a required lower limit" as a procedurally established lower limit, Operating Mode Applicability:

Operating Mode Applicability: and listed site specific sumps and tanks to ensure timely classification.

5, 6 Cold Shutdown, Refueling Emergency Action Levels (EAL):

Example Emergency Action Levels: (1 or 2)

Note: The Emergency Director should declare the event promptly upon Note: The Emergency Director should declare the Unusual Event promptly upon determining that the applicable time has been exceeded, or will likely be determining that 15 minutes has been exceeded, or will likely be exceeded.

exceeded.

1. UNPLANNED loss of reactor coolant results in the inability to restore

1. UNPLANNED loss of reactor coolant results in (reactor vessel/RCS and maintain reactor vessel / RCS level to

[PWR] or RPV [BWR]) level less than a required lower limit for 15 > procedurally established lower limit for >15 minutes.

minutes or longer.

OR

2. a. (Reactor vessel/RCS [PWRJ or RPV [BWR]) level cannot be monitored. 2. a. Reactor vessel / RCS level cannot be monitored.

AND AND

b. UNPLANNED increase in (site-specific sump and/or tank) levels. b. Loss of reactor vessel / RCS inventory per Table C3 indications.

Table C3 Indications of RCS Leakage

" UNPLANNED Reactor Building Sump level rise*

" UNPLANNED Auxiliary Bldg. Sump level rise*

" UNPLANNED BWST level dse*

" UNPLANNED RCDT level rse*

" UNPLANNED rise in RCS makeup

" Observation of leakage or inventory loss

Rise in level is attributed to a loss of reactor vessel/RCS inventory.

Page 51 of 66

NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition: GENERAL EMERGENCY HG1 Initiating Condition:

HG1 D1 No Change M Difference 1 Deviation HOSTILE ACTION resulting in loss of physical control of the facility. HOSTILE ACTION resulting in loss of physical control of the facility. 1) List site security shift supervision as Security Force.

2) Added descriptors to better explain each safety function and allow for a Operating Mode Applicability: Operating Mode Applicability: timely classification.

All 1,2, 3,4, 5,6, D Example Emergency Action Levels: Emergency Action Levels (EAL):

1 a. A HOSTILE ACTION is occurring or has occurred within the 1. A notification from the Security Force that a HOSTILE ACTION is occurring or has PROTECTED AREA as reported by the (site-specific security shift occurred within the PROTECTED AREA.

supervision).

AND AND

2. a. ANY Table H1 safety function cannot be controlled or maintained.

b. EITHER of the following:

1. ANY of the following safety functions cannot be controlled or OR maintained.

b. Damage to spent fuel has occurred or is IMMINENT

Reactivity control Core cooling [PWR] I RPV water level [BWR]

RCS heat removal Table H1 Safety Functions OR

Reactivity Control (ability to shut down the reactor and keep it shutdown)

2. Damage to spent fuel has occurred or is IMMINENT

Core Cooling (ability to cool the core)

RCS Heat Removal (ability to maintain heat sink)

Page 52 of 66

NEI 99-01 Rev 6 Proposed EAL [Justification HSI HSI Initiating Condition: SITE AREA EMERGENCY Initiating Condition: I, No Change I Difference -1 Deviation HOSTILE ACTION within the Protected Area. HOSTILE ACTION within the Protected Area.

1) List site security shift supervision as Security Force.

Operating Mode Applicability: Operating Mode Applicability:

All 1, 2, 3, 4, 5, 6, D Example Emergency Action Levels: Emergency Action Levels (EAL):

A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREA A notification from the Security Force that a HOSTILE ACTION is occurring or has as reported by the (site-security shift supervision). occurred within the PROTECTED AREA.

Page 53 of 66

NEI 99-01 Rev 6 1 Proposed EAL Justification HA1 HAI Initiating Condition: ALERT Initiating Condition: No Change ] Difference FIDeviation HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes. threat within 30 minutes. 1 )List site security shift supervision as Security Force.

Operating Mode Applicability: Operating Mode Applicability:

All 1, 2, 3,4, 5,6, D Example Emergency Action Levels: (1 or 2) Emergency Action Levels (EAL):

1. A HOSTILE ACTION is occurring or has occurred within the OWNER 1. A validated notification from NRC of an aircraft attack threat < 30 minutes CONTROLLED AREA as reported by the (site-specific security shift from the site.

supervision).

OR

2. A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.

2. Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.

Page 54 of 66

NEI 99-01 Rev 6 Proposed EAL Justification MUl Initiating Condition: UNUSUAL EVENT Initiating Condition:

HU1 F-D No Change - Difference -1 Deviation Confirmed SECURITY CONDITION or threat.

Confirmed SECURITY CONDITION or threat.

1) List site security shift supervision as Security Force.

Operating Mode Applicability:

2) Further described credible security threat through listing a site specific All procedure.

1,2, 3,4, 5,6, D Example Emergency Action Levels: (1 or 2 or 3)

Emergency Action Levels (EAL):

1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the (site-specific security shift supervision). 1. Notification of a credible security threat directed at the site as determined per SY-AA-101-132, Security Assessment and Response to Unusual Activities.

OR

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

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

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

OR

3. Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.

Page 55 of 66

NEI 99-01 Rev 6 HS6 Proposed EAL HS2

{

Justification Initiating Condition: SITE AREA EMERGENCY Initiating Condition: FH1No Change W Difference I- Deviation Inability to control a key safety function from outside the Control Room. Inability to control a key safety function from outside the Control Room.

1) EAL uses the site specific Control Room evacuation procedures to effectively list all of the alternate locations, panels, and stations requested by Operating Mode Applicability: Operating Mode Applicability: the developer notes. This would be the procedures the Control Room would enter should such an event occur, this allows for greater clarity as to when All 1,2, 3,4, 5, 6, D this EAL would apply than if each panel and station used in alternate shutdown were to be listed, Example Emergency Action Levels: (1 and 2) Emergency Action Levels (EAL):

2) Added descriptors to better explain each safety function and allow for a Note: The Emergency Director should declare the event promptly upon determining Note: The Emergency Director should declare the event promptly upon determining timely classification.

that (site-specific number of minutes) has been exceeded, or will likely be that the applicable time has been exceeded, or will likely be exceeded.

exceeded. 3) Changed "An event" to" A Control Room evacuation" to remove confusion if partial plant control was transferred to outside the control room with the control

1. A Control Room evacuation has resulted in plant control being transferred from the room still manned, due to testing or equipment failure.

1. An event has resulted in plant control being transferred from the Control Control Room to alternate locations per OP-TM-EOP-020, Cooldown from Outside Room to (site-specific remote shutdown panels and local control stations). the Control Room.

AND

2. Control of ANY of the following key safety functions is not reestablished within (site-specific number of minutes). 2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.

Reactivity control Core cooling [PWR] I RPV water level [BWR] Table H1 Safety Functions

RCS heat removal

Reactivity Control (ability to shut down the reactor and keep it shutdown)

Core Cooling (ability to cool the core)

RCS Heat Removal (ability to maintain heat sink)

Page 56 of 66

NEI 99-01 Rev 6 Proposed EAL Justification HA6 HA2 Initiating Condition: ALERT Initiating Condition: FD No Change F Difference F Deviation Control Room evacuation resulting in transfer of plant control to alternate locations. Control Room evacuation resulting in transfer of plant control to alternate locations.

1) EAL uses the site specific Control Room evacuation procedures to effectively list all of the alternate locations, panels, and stations requested by the developer Operating Mode Applicability: Operating Mode Applicability: notes. This would be the procedures the Control Room would enter should such an event occur, this allows for greater clarity as to when this EAL would apply than if All 1, 2, 3,4, 5,6, D each panel and station used in alternate shutdown were to be listed,

2) Changed "An event" to" A Control Room evacuation" to remove confusion if Example Emergency Action Levels: Emergency Action Levels (EAL): partial plant control was transferred to outside the control room with the control An event has resulted in plant control being transferred from the Control Room to room still manned, due to testing or equipment failure.

(site-specific remote shutdown panels and local control stations). A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per OP-TM-EOP-020, Cooldown from Outside the Control Room.

Page 57 of 66

NEI 99-01 Rev 6 Proposed EAL [Justification HU4 HU3 Initiating Condition: UNUSUAL EVENT FIRE potentially degrading the level of safety of the plant.

Initiating Condition: F-1 No Change W Difference 1 Deviation FIRE potentially degrading the level of safety of the plant.

1) Listed site specific list of plant rooms or areas that contain SAFETY SYSTEM Operating Mode Applicability: equipment to ensure timely classification.

Operating Mode Applicability:

All 2) Added additional note to easily direct the operator to escalation ICs 1, 2, 3,4, 5, 6, D Example Emergency Action Levels: (1 or 2 or 3 or 4)

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Unusual Event promptly upon determining that the applicable time has been Note: The Emergency Director should declare the event promptly upon exceeded, or will likely be exceeded. 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 Escalation of the emergency classification level would be via IC CA2 or FIRE detection indications: MA5

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

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

1. a. A FIRE in any Table H2 area is not extinguished in <15-minutes of ANY

Field verification of a single fire alarm of the following FIRE detection indications:

AND

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

b. The FIRE is located within ANY of the following plant rooms or areas:

Receipt of multiple (more than 1) fire alarms or indications (site-specific list of plant rooms or areas)

Field verification of a single fire alarm OR

2. a. Receipt of a single fire alarm (i.e., no other indications of a FIRE).

2. a. Receipt of a single fire alarm in any Table H2 area (i.e., no other AND indications of a FIRE).

b. The FIRE is located within ANY of the following plant rooms or areas: AND (site-specific list of plant rooms or areas) b. The existence of a FIRE is not verified in <30-minutes of alarm receipt.

AND OR

c. The existence of a FIRE is not verified within 30-minutes of alarm receipt. 3. A FIRE within the plant PROTECTED AREA not extinguished in <60-minutes of the initial report, alarm or indication.

3. A FIRE within the plant or ISFS1 [for plants with an ISFSI outside the plant OR Protected Area] PROTECTED AREA not extinguished within 60-minutes of 4. A FIRE within the plant PROTECTED AREA that requires firefighting the initial report, alarm or indication. support by an offsite fire response agency to extinguish.

4. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA that requires firefighting support by an Table H2 Vital Areas offsite fire response agency to extinguish.

Reactor Building

Intake Building

Intermediate Building

Control Tower

Auxiliary and Fuel Handling Buildings

1A and 1B Diesel Generator Buildings

BWST

CST Page 58 of 66

NEI 99-01 Rev 6 Proposed EAL Justification HU2 HU4 Initiating Condition: UNUSUAL EVENT Seismic event greater than OBE levels.

Initiating Condition: F No Change W Difference 1 Deviation Seismic event greater than OBE levels.

1) Listed site specific indication to determining OBE limits have been met or Operating Mode Applicability: exceeded to ensure timely classification.

Operating Mode Applicability:

All 2) The seismic panel located in the MCR. Once the Threshold Seismic condition is 1,2, 3,4, 5, 6, D detected an alarm on PRF-1-2 will sound in the MCR and the monitor will start analyzing, a few minutes later a second alarm will actuate if the monitor detects an Example Emergency Action Levels: OBE seismic event has been exceeded, PRF-1-3.

Emergency Action Levels (EAL): Allindications are available real time in the MCR.

Seismic event greater than Operating Basis Earthquake (OBE) as indicated by: Note: Escalation of the emergency classification level would be via IC CA2 or

a. (site-specific indication that a seismic event met or exceeded OBE limits) MA5 3) Developed a compensatory EAL for use during periods when the seismic monitoring system capable of detecting an OBE is out of service for maintenance For emergency classification if EAL 2.b is not able to be confirmed, then the occurrence of a seismic event is confirmed in manner deemed or repair using the guidance in the developer notes provided.

appropriate by the Shift Manager or Emergency Director in < 15 mins of

4) Added additional compensatory thresholds based on the guidance provided in the event. US NRC Reg. Guide 1.166, Pre-Earthquake Planning and Immediate Nuclear Power Plant Operator Earthquake Actions Appendix A, also added a 15 min time

1. Seismic event > Operating Basis Earthquake (OBE) as indicated by seismic limit to ensure timely classification when these additional thresholds may not be readily available.

Alarms PRF-1-3 Operating Basis earthquake.

OR 5) Added additional notes to easily direct the operator to the escalation ICs, as well as to ensure if unable to determine size of earthquake lAW 2.b then the SM / ED

2. When Seismic Monitoring Equipment is not available: will determine classification within 15 mins of the event

a. Control Room personnel feel an actual or potential seismic event.

AND

b. ANY one of the following confirmed in < 15 mins of the event:

The earthquake resulted in Modified Mercalli Intensity (MMI) > VI and occurred < 3.5 miles of the plant.

The earthquake was magnitude > 6.0

The earthquake was magnitude > 5.0 and occurred < 125 miles of the plant.

Page 59 of 66

NEI 99-01 Rev 6 1 Proposed EAL (Justification HA5 HA5 Initiating Condition: ALERT Initiating Condition:

D No Change M Difference F1 Deviation Gaseous release impeding access to equipment necessary for normal plant Gaseous release impeding access to equipment necessary for normal plant operations, operations, coofdown or shutdown. cooldown or shutdown. 1) Listed plant specific rooms and areas with entry related mode applicability to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability: 2) The Operating Mode Applicability of this EAL has been revised from All Modes to modes 4, 5, and 6 due to the mode applicability of the areas of All 4,5,6 concern in Table H-3.

Example Emergency Action Levels: Emergency Action Levels (EAL):

Note: If the equipment in the listed room or area was already inoperable, or out Note: If the equipment in the listed room or area was already inoperable, or out of of service, before the event occurred, then no emergency classification is service, before the event occurred, then no emergency classification is warranted. warranted.

1. a. Release of a toxic, corrosive, asphyxiant or flammable gas into any I. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area.

of the following plant rooms or areas:

(site-specific list of plant rooms or areas with entry-related mode applicability identified) Table R4 Areas with Entry Related Mode Applicability AND Area Entry Related Mode Applicability

b. Entry into the room or area is prohibited or impeded. Auxiliary Building 281' shieVded area 305'above DH Vaults Modes 4, 5, and 6 Fuel Handling Building 281' 1C ES VIvs MCC AND

2. Entry into the room or area is prohibited or impeded Page 60 of 66

NEI 99-01 Rev 6 Proposed EAL Justification HU3 HU6 Initiating Condition: UNUSUAL EVENT Initiating Condition: D No Change M Difference F- Deviation Hazardous Event Hazardous Event

1) Included river water level as part of the site-specific list of natural or Operating Mode Applicability: technological hazard events. The EAL values selected are the current Approved Operating Mode Applicability: UE EAL values.

All 1, 2,3,4, 5, 6, D

2) Changed the word "needed" to "required by Technical Specifications" in the EAL Example Emergency Action Levels: (1 or 2 or 3 or 4) to be consistent with terminology used by operators and minimize confusion.

Emergency Action Levels (EAL):

Note: EAL #3 does not apply to routine traffic impediments such as fog, snow, 3) Added additional note to easily direct the operator to escalation ICs ice, or vehicle breakdowns or accidents.

Note: EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

I. A tornado strike within the PROTECTED AREA.

Escalation of the emergency classification level would be via IC CA2 or

2. Internal room or area flooding of a magnitude sufficient to require manual MA5 or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode.

1. Tornado strike within the PROTECTED AREA.

3. Movement of personnel within the PROTECTED AREA is impeded due to OR an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release). 2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by

4. A hazardous event that results in on-site conditions sufficient to prohibit Technical Specifications for the current operating mode.

the plant staff from accessing the site via personal vehicles. OR

5. (Site-specific list of natural or technological hazard events) 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).

OR

4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.

OR

5. Abnormal river water level at the intake Pump and Screen House, as indicated by EITHER:

a. > 300 ft. el. (high level)

OR

b. < 274 ft. el. (low level)

Page 61 of 66

NEI 99-01 Rev 6 1 Proposed EAL Justification HG8 HG7 Initiating Condition: GENERAL EMERGENCY Initiating Condition: W'* No Change F Difference F- Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency. declaration of a General Emergency.

Operating Mode Applicability: Operating Mode Applicability:

All 1,2, 3,4, 5,6, D Example Emergency Action Levels: Emergency Action Levels (EAL):

Other conditions exist which in the judgment of the Emergency Director indicate 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 that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment 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 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 the facility. Releases can be reasonably expected to exceed EPA Protective Guideline exposure levels off-site for more than the immediate site area. Action Guideline exposure levels off-site for more than the immediate site area..

Page 62 of 66

NEI 99-01 Rev 6 Proposed EAL Justification HS8 HS7 Initiating Condition: SITE AREA EMERGENCY Initiating Condition: FI- No Change EIDifference [-1 Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency. declaration of a Site Area Emergency.

Operating Mode Applicability: Operating Mode Applicability:

All 1, 2, 3, 4, 5, 6, D Example Emergency Action Levels: Emergency Action Levels (EAL):

Other conditions exist which in the judgment of the Emergency Director indicate 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 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 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 that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not 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 expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary. Guideline exposure levels beyond the site boundary.

Page 63 of 66

NEI 99-01 Rev 6 JProposed EAL j Justification Initiating Condition: ALERT HA6 Initiating Condition:

HA7 W No Change FIDifference F Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert. declaration of an Alert.

Operating Mode Applicability: Operating Mode Applicability:

All 1,2,3,4,5,6, D Example Emergency Action Levels: Emergency Action Levels (EAL):

Other conditions exist which in the judgment of the Emergency Director indicate 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 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 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 involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels. limited to small fractions of the EPA Protective Action Guideline exposure levels.

Page 64 of 66

NEI 99-01 Rev 6 Proposed EAL Justification HU7 HU7 Initiating Condition: UNUSUAL EVENT Initiating Condition: No Change EIDifference FI Deviation Other conditions existing which in the judgment of the Emergency director warrant declaration of an UNUSUAL EVENT. Other conditions existing which in the judgment of the Emergency director warrant declaration of an UNUSUAL EVENT.

Operating Mode Applicability:

All 1,2, 3,4, 5, 6, D Example Emergency Action Levels:

Other conditions exist which in the judgment of the Emergency Director indicate Emergency Action Levels (EAL):

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

Page 65 of 66

NEI 99-01 Rev 6 1 Proposed EAL I Justification E-HU1 Initiating Condition: UNUSUAL EVENT D No Change M Difference i-- Deviation Damage to a loaded cask CONFINEMENT BOUNDARY.

TMI Station does not have an ISFSl, Operating Mode Applicability:

All Example Emergency Action Levels:

Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specific technical specification allowable radiation level) on the surface of the spent fuel cask.

Page 66 of 66

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRem TEDE or 5000 mRem thyroid CDE.

Operating Mode Applicability:

1,2,3, 4,5,6, D Emergency Action Level (EAL):

Notes:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

" If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

" Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for_> 15 minutes.

OR

2. Dose assessment Using actual meteorology indicates doses at or beyond the site boundary of EITHER:

a. > 1000 mRem TEDE OR

b. > 5000 mRem CDE Thyroid OR

3. Field survey results at or beyond the site boundary indicate EITHER:

a. Gamma (closed window) dose rates >1000 mR/hr are expected to continue for > 60 minutes.

OR

b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.

Month 20XX TMI 3-32 EP-AA-1009 (Revision XX)

Throa Win lainnd -Qffafinn Annov IPvalh-n N r~lanr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RGI (cont)

Emergency Action Level (EAL) (cont):

Table R1 Effluent Monitor Thresholds Effluent Monitor General Emergency RM-G-25 (Cond Offgas) 9.53 E+06 mR/hr RM-A-8GH (Station Vent) 3.09 E+05 cpm RM-G-24 (RB Purge) 5.55 E+05 mR/hr RM-A-14 (ESF Vent) 6.66 E+02 uCi/cc Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at the EPA PAG of 1000 mRem while the 5000 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Basis Reference(s):

1. NEI 99-01 Rev 6, AG1

2. EP-EAL-0609 Revision 1, Criteria for Choosina Radioloaical Gaseous Effluent EAL Threshold Values, Three Mile Island

3. EP-AA-1 12-500 Emergency Environmental Monitoring

4. FSAR Section 11.4 Radiation Monitoring System

5. EP-AA-1 10-200 Dose Assessment

6. EP-AA-1 10-201 On Shift Dose Assessment Month 20XX TMI 3-33 EP-AA-1009 (Revision XX)

FY*Inn Nl Jr.l*_*r Three Mile kIslnd Station Annex Fvginn NuclerIAr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDE or 500 mRem thyroid CDE.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Notes:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

" If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for> 15 minutes.

OR

2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:

a. > 100 mRem TEDE OR

b. > 500 mRem CDE Thyroid OR

3. Field survey results at or beyond the site boundary indicate EITHER:

a. Gamma (closed window) dose rates >100 mR/hr are expected to continue for > 60 minutes.

OR

b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.

Month 20XX TMI 3-34 EP-AA-1009 (Revision XX)

Thrgg%Milo lalnnrl Afnfinn Annov I::y~lt~n hN,,lo-r Tkr~ Milo IQI2neI ~+~+tnn Annav Fvainn N. .~In~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RSl (cont)

Emergency Action Level (EAL) (cont):

Table R1 Effluent Monitor Thresholds Effluent Monitor Site Area Emergency RM-G-25 (Cond Offgas) 9.53 E+05 mR/hr RM-A-8GH (Station Vent) 3.09 E+04 cpm RM-G-24 (RB Purge) 5.55 E+04 mR/hr RM-A-14 (ESF Vent) 6.66 E+01 uCi/cc Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).

It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1000 mRem while the 500 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC RG1.

Basis Reference(s):

1. NEI 99-01 Rev 6, AS1

2. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values, Three Mile Island

3. EP-AA-1 12-500 Emergency Environmental Monitoring

4. FSAR Section 11.4 Radiation Monitoring System

5. EP-AA-1 10-200 Dose Assessment

6. EP-AA-1 10-201 On Shift Dose Assessment Month 20XX TMI 3-35 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RA1 Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRem TEDE or 50 mRem thyroid CDE.

Operating Mode Applicability:

1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Notes:

" The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

" If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

" Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 15 minutes.

OR

2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:

a. > 10 mRem TEDE OR

b. > 50 mRem CDE Thyroid OR

3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary

a. 10 mRem TEDE for 60 minutes of exposure OR

b. 50 mRem CDE Thyroid for 60 minutes of exposure OR Month 20XX TMI 3-36 EP-AA-1009 (Revision XX)

Thran Mila lalnnrl -Qfnfitn Annov P:yalnn N, r~lar Thrgia Mllg~ I~6nrI ~hat.r~n Annav Fv~Inn N.mrI~zir TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont)

Emergency Action Level (EAL) (cont):

4. Field survey results at or beyond the site boundary indicate EITHER:

a. Gamma (closed window) dose rates > 10 mR/hr are expected to continue for > 60 minutes.

OR

b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.

Table RI Effluent Monitor Thresholds Effluent Monitor Alert RM-G-25 (Cond Offgas) 9.53 E+04 mR/hr RM-A-8GH (Station Vent) 3.09 E+03 cpm RM-G-24 (RB Purge) 5.55 E+03 mR/hr RM-A-14 (ESF Vent) 6.66 E+00 uCi/cc Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1000 mRem while the 50 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC RS1.

Month 20XX TMI 3-37 EP-AA-1009 (Revision XX)

Thraga Milo lainnd -Qfnfinn Annav I::v,*lnn Khularl~

Tkr~ MiIa IcI2nrI ~t2tiriin Annav Fv~Inn MiirIc2r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RA1 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, AA1

2. OP 1101-2.1 Radiation Monitoring System Setpoints

3. FSAR Section 11.4 Radiation Monitoring System

4. OP-TM-MAP-CO101, Radiation Level HI

5. EP-EAL-0609, Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values, Three Mile Island

6. EP-EAL-0616, Revision 0, Three Mile Island Criteria for Choosing Radiological Liquid Effluent EAL Threshold Values

7. EP-EAL-0622, Revision 0, Three Mile Island Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values for Waste Gas Decay Tanks Month 20XX TMI 3-38 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU1 Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.

Operating Mode Applicability:

1,2,3, 4,5,6, D Emergency Action Level (EAL):

Notes:

" The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.

" Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

1. Reading on ANY of the following effluent monitors > 2 times alarm setpoint established by a current radioactive release discharge permit for > 60 minutes.

" RM-L-6, Radwaste Discharge

" RM-L-12, IWTS / IWFS Discharge

" RM-A-7, Waste Gas Decay Tank Discharge

" Discharge Permit specified monitor OR

2. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 60 minutes.

OR

3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of > 60 minutes.

Month 20XX TMI 3-39 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Exelon Nuclear Nuclear Three Mile Island Station Annex TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RUl (cont)

Emergency Action Level (EAL) (cont):

Table R1 Effluent Monitor Thresholds Effluent Monitor Unusual Evet RM-G-25 (Cond Offgas) 1.09 E+03 mR/hr RM-A-8GH (Station Vent) 7.03 E+01 cpm RM-G-24 (RB Purge) 6.34 E+01 mR/hr RM-A-14 (ESF Vent) 7.60 E-02 uCi/cc Basis:

This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

EAL #1 Basis This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).

The effluent monitors listed are those normally used for planned discharges. If a discharge is performed using a different flowpath or effluent monitor other than those listed (e.g., a portable or temporary effluent monitor), then the declaration criteria will be based on the monitor specified in the Discharge Permit.

EAL #2 Basis This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous effluent pathways.

Month 20XX TMI 3-40 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU1 (cont)

Basis (cont):

EAL #3 Basis This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).

Escalation of the emergency classification level would be via IC RA1.

Basis Reference(s):

1. NEI 99-01 Rev 6, AU1

2. OP 1101-2.1 Radiation Monitoring System Setpoints

3. FSAR Section 11.4 Radiation Monitoring System

4. Offsite Dose Calculation (ODCM)

5. OP-TM-MAP-CO101, Radiation Level HI

6. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values, Three Mile Island Month 20XX TMI 3-41 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG2 Initiating Condition:

Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Note: The Emergency Director should declare the General Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

Spent fuel pool level cannot be restored to at least (site-specific Level 3 value) for 60 minutes or longer.

Basis:

This IC addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment.

It is recognized that this IC would likely not be met until well after another General Emergency IC was met; however, it is included to provide classification diversity.

Basis Reference(s):

1. NEI 99-01 Rev 6, AG2 Month 20XX TMI 3-42 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS2 Initiating Condition:

Spent fuel pool level at (site-specific Level 3 description).

Operating Mode Applicability:

1,2, 3,4, 5, 6, D Emergency Action Level (EAL):

Lowering of spent fuel pool level to (site-specific Level 3 value).

Basis:

This IC addresses a significant loss of spent fuel pool inventory control and makeup capability leading to IMMINENT fuel damage. This condition entails major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

It is recognized that this IC would likely not be met until well after another Site Area Emergency IC was met; however, it is included to provide classification diversity.

Escalation of the emergency classification level would be via IC RG1 or RG2.

Basis Reference(s):

1. NEI 99-01 Rev 6, AS2 Month 20XX TMI3-43 EP-AA-1 009 (Revision XX)

Three Mile Island Station Annex Exelon Exelon Nuclear Nuclear Three Mile Island Station Annex TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2 Initiating Condition:

Significant lowering of water level above, or damage to, irradiated fuel.

Operating Mode Applicability:

1,2, 3,4, 5, 6, D Emergency Action Level (EAL):

1. Uncovery of irradiated fuel in the REFUELING PATHWAY.

OR

2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R2 Radiation Monitor reading >1000 mRem/hr.

OR

3. Lowering of spent fuel pool level to (site specific Level 2 value).

Table R2 Radiation Monitors RMS Area Monitored Mode RM-G-9 FHB Bridge Rad Monitor ALL RM-G-6 RB Auxiliary Bridge Rad Monitor 5, 6 RM-G-7 RB Main Bridge Rad Monitor 5, 6 Basis:

REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.

IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

Month 20XX TMI 3-44 EP-AA-1 009 (Revision XX)

Three Mile Island Station Annex Exellon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2 (cont)

Basis (cont):

EAL #1 Basis:

This EAL escalates from RU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations.

While an area radiation monitor could detect a rise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

EAL #2 Basis:

This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).

EAL #3 Basis:

Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.

Escalation of the emergency would be based on either Recognition Category R or C ICs.

Basis Reference(s):

1. NEI 99-01 Rev 6, AA2

2. Operating Procedure OP-TM-MAP-C0105 RCS Draindown LVL HI/LO

3. OP-TM-MAP-CO101, Radiation Level HI

4. UFSAR, Section 14.2.2.1 - "Fuel Handling Accident" 5 Technical Specification 3.8.11 (Reactor Cavity Level)

6. Operating Procedure OP 1101-2.1 Radiation Monitoring System Setpoints Month 20XX TMI 3-45 EP-AA-1009 (Revision XX)

Throa Milo kinnd Rfnfinn Annoy I:=alnn Nii-lan*r Thr~ MiI~ I~Iz~nrI ~tz~tinn Anngiv Fvalnn MIIr102r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU2 Initiating Condition:

UNPLANNED loss of water level above irradiated fuel.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

1. a. UNPLANNED water level drop in the REFUELING PATHWAY.

AND

b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R2.

Table R2 Radiation Monitors RMS Area Monitored Mode RM-G-9 FHB Bridge Rad Monitor ALL RM-G-6 RB Auxiliary Bridge Rad Monitor 5, 6 RM-G-7 RB Main Bridge Rad Monitor 5, 6 Basis:

UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.

This IC addresses a loss in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.

A water level loss will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available) or from any other temporarily installed monitoring instrumentation. A significant drop in the water level may also cause a rise in the radiation levels of adjacent areas that can be detected by monitors in those locations.

Month 20XX TMI 3-46 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU2 (cont)

Basis (cont):

The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may rise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

Escalation of the emergency classification level would be via IC RA2.

Basis Reference(s):

1. NEI 99-01 Rev 6, AU2

2. UFSAR, Section 14.2.2.1 - "Fuel Handling Accident"

3. OP-TM-MAP-CO 105 RCS Draindown

4. OP 1202-12, Excessive Radiation Levels

5. OP 1101-2.1 Radiation Monitoring System Setpoints

6. Technical Specification 3.8.11 (Reactor Cavity Level)

Month 20XX TMI 3-47 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA3 Initiating Condition:

Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.

Operating Mode Applicability:

1,2, 3,4, 5, 6, D Emergency Action Level (EAL):

Note:

If the equipment in the room or area listed in Table R4 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.

1. Dose rate > 15 mR/hr in ANY of the areas contained in Table R3:

Table R3 Areas Requiring Continuous Occupancy

Main Control Room

" Central Alarm Station - (by survey)

OR

2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the following Table R4 plant rooms or areas:

Table R Areas with Entry Related Mode Appli,.abinlty AraEntry Related Md

__ Appllosabi Reactor B3uild ing* Modes 4, 5, and 6 lntcrmedfiate Bidig Modes 4, 5, and 6 Au xiliarFy Building* Modes 4, 5, and 6 Fuel Handling Building* Modes 41, 5, and 6

,Areas requ~ired to establish shutdoWn cool~fing Month 20XX TMI 3-48 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Table R4 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Auxiliary Building 281' shielded area 305' above DH Vaults Modes 4, 5, and 6 Fuel Handling Building 281' 1C ES Vlvs MCC Month 20XX TMI 3-49 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RA3 (cont)

.Basi:..s:

UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedures. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the increased radiation levels and determine if another IC may be applicable.

Assuming all plant equipment is operating as designed, normal operation is capable from the Main Control Room (MCR). The plant is also able to transition into a hot shutdown condition from the MCR, therefore Table R4 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown.

This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including the Control Room.

For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the elevated radiation levels preclude the ability to place shutdown cooling in service. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g.,

installing temporary shielding beyond that required by procedures, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).

An emergency declaration is not warranted if any of the following conditions apply.

" The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation rise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.

The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.).

Month 20XX TMI 3-50 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA3 (cont)

Basis (cont):

" The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

" The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.

Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.

Basis Reference(s):

1. NEI 99-01 Rev 6, AA3

2. FSAR Section 5.01 Class I Structures, Components, and Systems

3. OP-TM-MAP-CO101, Radiation Level HI Month 20XX TMI 3-51 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU3 Initiating Condition:

Reactor coolant activity greater than Technical Specification allowable limits.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

1. Letdown Monitor RM-L-1 alert alarm (high or low channel).

OR

2. Sample analysis indicates that:

a. Dose Equivalent 1-131 specific coolant activity > 60.0 uCi/gm.

OR

b. Dose Equivalent XE-1 33 specific coolant activity > 797.0 uCi/gm.

Basis:

This IC addresses a reactor coolant activity value that exceeds an allowable limit specified in Technical Specifications. This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant.

Conditions that cause the specified monitor to alarm that are not related to fuel clad degradation should not result in the declaration of an Unusual Event.

This EAL addresses site-specific radiation monitor readings that provide indication of a degradation of fuel clad integrity.

An Unu"sual Event is only warranted when actual fuel clad damIage s the cause of th.

elevated coolant sample activity (as determined by laboratory confirmation). Fuel cla damage should be assumed to be the cause of elevated ReaGcet Coolant activity unless another cause is known.

Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category R ICs.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU3

2. Operating Procedure 1101-2.1 Radiation Monitoring System Setpoints

3. FSAR Section 11.4.4, Liquid Monitoring Subsystem

4. OP-TM-MAP-CO101, Radiation Level HI

5. Technical Specifications 3.1.4, Reactor Coolant System Activity Month 20XX TMI 3-52 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FG1 Initiating Condition:

Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.

Basis:

Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the General Emergency classification level each barrier is weighted equally.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX TMI 3-53 EP-AA-1 009 (Revision XX)

Thraa RAila lainnei -Qfmfien Annav IPvalnn N,,-laqr Thr~ MiIe~ IeI~neI Q*~i*i,~n Ann~v Fv~Inn MuitIci~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FS1 Initiating Condition:

Loss or Potential Loss of ANY two barriers.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.

Basis:

Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the Site Area Emergency classification level, each barrier is weighted equally.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX TMI 3-54 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FA1 Initiating Condition:

ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.

Basis:

Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the Alert classification level, Fuel Cladding and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability. Note that the loss or potential loss of Containment barrier in combination with loss or potential loss of either Fuel Cladding or RCS barrier results in declaration of a Site Area Emergency under EAL FS1.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX TMI 3-55 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC1 Initiating Condition:

RCS or SG Tube Leakage Operating Mode Applicability:

1,2,3,4 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS

1. RCITS hot leg instruments indicate 0 inches after lowering trend.

AND

2. In-core thermocouples are unavailable.

AND

3. ALL RCP's are secured.

Basis:

There is no Loss threshold associated with RCS or SG Tube Leakage.

Potential Loss Threshold #1 Basis:

This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3

2. FSAR 7.3.2.2.c.10.d

3. OP-TM-EOP-008, RCS Superheated

4. OP-TM-EOP-010, Emergency Procedure Rules Guides and Graphs Month 20XX TMI 3-56 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 Initiating Condition:

Inadequate Heat Removal Operating Mode Applicability:

1,2,3,4 Fission Product Barrier (FPB) Threshold:

LOSS

1. Tclad > 1400°F POTENTIAL LOSS

2. > 25 0 F Superheat OR

3. HPI-PORV Cooling in effect.

Basis:

Loss Threshold #1 Basis This reading indicates temperatures within the core are sufficient to cause significant superheating of reactor coolant.

Potential Loss Threshold #2 Basis This reading indicates temperatures within the core are sufficient to allow the onset of heat-induced cladding damage.

Potential Loss Threshold #3 Basis This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted.

Meeting this threshold results in a Site Area Emergency because this threshold is identical to RCS Barrier RC2 Potential Loss threshold; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and raise RCS pressure to the point where mass will be lost from the system.

Month 20XX TMI 3-57 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3

2. OS-24 Attachment D

3. OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer

4. OP-TM-EOP-008, RCS Superheated

5. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs

6. OS-24, Conduct of Operations during Abnormal and Emergency Events Month 20XX TMI 3-58 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Thre taton Mil AnexExelon Isand Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC3 Initiating Condition:

Containment Radiation / RCS Activity Operating Mode Applicability:

1,2,3,4 Fission Product Barrier (FPB) Threshold:

LOSS

1. Containment radiation monitor (RM-G-22 or RM-G-23) reading > 1.95E+03 R/hr.

OR

2. Coolant activity > 300uCi/gm Dose Equivalent 1-131 Basis:

Loss Threshold #1 Basis:

The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals 300gCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.

The radiation monitor reading in this threshold is higher than that specified for RCS Barrier RC3 Loss Threshold since it indicates a loss of both the Fuel Clad Barrier and the RCS Barrier. Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.

Loss Threshold #2 Basis:

This threshold indicates that RCS radioactivity concentration is greater than 300 [iCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.

It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications There is no Fuel Clad Barrier Potential Loss threshold associated with RCS Activity /

Containment Radiation.

Month 20XX TMI 3-59 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC3 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3

2. OP-TM-MAP-CO101, Radiation Level HI

3. FSAR Section 11.4.4, Liquid Monitoring System Description

4. Calculation C3640-98-034, Prediction of the Response of RM-G-6 and 7 to Fuel Damage

5. Core Damage Assessment Methodology (CDAM)

Month 20XX TMI 3-60 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC5 Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1,2,3,4 Fission Product Barrier (FPB) Threshold:

LOSS

1. Any condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.

POTENTIAL LOSS

2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.

Basis:

Loss Threshold #1 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is lost.

Potential Loss Threshold #2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX TMI 3-61 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RCl Initiating Condition:

RCS or SG Tube Leakage Operating Mode Applicability:

1,2,3,4 Fission Product Barrier (FPB) Threshold:

LOSS

1. RCS leakage results in < 250 Sub Cooling Margin OR

2. Steam Generator tube RUPTURE that requires / results in an ESAS actuation.

1. Automatic ormanual

) ESAS actuation is required by, EITHER of the fellewing:

a. UNISOLABLE RCS leakage OR

b. Steamn Generator tube RUPTURE.

POTENTIAL LOSS

2. UNISOLABLE RCS leakage > 150gpm.

OR

3. HPI DORN! Co,'ing in effe,.

OR

43. a. RCS Pressure > 2450 psig.

AND

b. RCS Pressure not lowering.

Basis:

UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally.

RUPTURE(D): The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

Month 20XX TMI 3-62 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC1 (cont)

Basis (cont):

Failure to isolate the leak, within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

Loss Threshold #1 Basis This threshold is based on an UNISOLABLE RCS leak of sufficient size to require an automatic or manual actuation of the Emergency Core Cooling System (ECCS). This condition clearly represents a loss of the RCS Barrier.

This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

A steam generator with primary-to-secondary leakage of sufficient magnitude to require a safety injection is considered to be RUPTURED. If a RUPTURED steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier CT1 Loss threshold will also be met.

Potential Loss Threshold #2 Basis This threshold is based on an UNISOLABLE RCS leak that results in the inability to maintain pressurizer level within specified limits by operation of a normally used charging (makeup) pump, but an ECCS (SI) actuation has not occurred. The threshold is met when an operating procedure, or operating crew supervision, directs that a standby charging (makeup) pump be placed in service to restore and maintain pressurizer level.

This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier CT1 Loss Threshold

1 will also be met.

Potential Loss Threshold #3 Basis This condition indicates an extreme challenge to the integrity of the RCS pressure boundary due to pressurized thermal shock - a transient that causes rapid RCS cooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized).

Month 20XX TMI 3-63 EP-AA-1 009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RCl (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3

2. OP-TM-EOP-010 Emergency Procedure Rules, Guides And Graphs

3. OP-TM-EOP-002 Loss of 25°F Subcooled Margin

4. OP-TM-MAP-D031, MU Flow HI

5. OP-TM-EOP-005, OTSG Tube Leakage Month 20XX TMI 3-64 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC2 Initiating Condition:

Inadequate Heat Removal Operating Mode Applicability:

1,2,3,4 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS HPI-PORV Cooling in effect.

Basis:

There is no Loss threshold associated with Inadequate Heat Removal.

Potential Loss Threshold Basis HPI-PORV Cooling in effect indicates a Lack of Primary to Secondary Heat Transfer capability.

This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted.

Meeting this threshold results in a Site Area Emergency because this threshold is identical to Fuel Clad Barrier FC2 Potential Loss Threshold #3; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and raise RCS pressure to the point where mass will be lost from the system.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3

2. OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer Month 20XX TMI 3-65 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC3 Initiating Condition:

Containment Radiation / RCS Activity Operating Mode Applicability:

1,2,3,4 Fission Product Barrier (FPB) Threshold:

LOSS Containment radiation monitor (RM-G-22 or RM-G-23) reading > 25 R/hr.

Basis:

Loss Threshold Basis The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier FC3 Loss threshold #1 since it indicates a loss of the RCS Barrier only.

There is no RCS Potential Loss threshold associated with RCS Activity / Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3

2. EP-EAL-061 1, Criteria for Choosing Containment Radiation Monitor Reading Indicative of Loss of RCS Barrier Month 20XX TMI 3-66 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC5 Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1,2,3,4 Fission Product Barrier (FPB) Threshold:

LOSS

1. Any condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.

POTENTIAL LOSS

2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.

Basis:

Loss Threshold #1 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is lost.

Potential Loss Threshold #2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX TMI 3-67 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT1 Initiating Condition:

RCS or SG Tube Leakage Operating Mode Applicability:

1,2,3,4 Fission Product Barrier (FPB) Threshold:

LOSS

1. SG tube leakage > 150gpm AND

2. UNISOLABLE steam release from the affected S/G to the environment.SG-is FAULTED outside of conRtain mont.

Basis:

FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

RUPTURE(D): The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

Loss Threshold Basis This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAULTED outside of containment. The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the thresholds for RCS Barrier RC1 Potential Loss Threshold 2 and Loss Threshold 1.b, respectively. This condition represents a bypass of the containment barrier.

FAULTED is a defined term within the NEI 99-01 methodology; this determination is not necessarily dependent upon entry into, or diagnostic steps within, an EOP. For example, if the pressure in a steam generator is decreasing uncontrollably [part of the FAULTED definition] and the faulted steam generator isolation procedure is not entered because EOP user rules are dictating implementation of another procedure to address a higher priority condition, the steam generator is still considered FAULTED for emergency classification purposes.

The FAULTED criterion establishes an appropriate lower bound on the size of a steam release that may require an emergency classification. Steam releases of this size are readily observable with normal Control Room indications. The lower bound for this aspect of the containment barrier is analogous to the lower bound criteria specified in IC RU3 for the fuel clad barrier (i.e., RCS activity values) and IC MU6 for the RCS barrier (i.e., RCS leak rate values).

This threshold also applies to prolonged steam releases necessitated by operational considerations such as the forced steaming of a leaking or RUPTURED steam Month 20XX TMI 3-68 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exellon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION generator directly to atmosphere to cooldown the plant, or to drive an auxiliary (emergency) feed water pump. These types of conditions will result in a significant and Month 20XX TMI 3-69 EP-AA-1009 (Revision XX)

I=xnlnn N Hc.leRr Three MileIsahnd Station Annex ExeIon Nucler~I TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT1 (cont)

Basis (cont):

sustained release of radioactive steam to the environment (and are thus similar to a FAULTED condition). The inability to isolate the steam flow without an adverse effect on plant cooldown meets the intent of a loss of containment.

Steam releases associated with the expected operation of a SG power operated relief valve or safety relief valve do not meet the intent of this threshold. Such releases may occur intermittently for a short period of time following a reactor trip as operators process through emergency operating procedures to bring the plant to a stable condition and prepare to initiate a plant cooldown. Steam releases associated with the unexpected operation of a valve (e.g., a stuck-open safety valve) meets this threshold.

Following an SG tube leak or rupture, there may be minor radiological releases through a secondary-side system component (e.g., air ejectors, glad seal exhausters, valve packing, etc.). These types of releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.

The emergency classification levels resulting from primary-to-secondary leakage, with or without a steam release from the FAULTED SG, are summarized below.

Affected SG is FAULTED Outside of Containment?

Primary to Secondary Yes No Leak Rate Less than or equal to 25 No classification No classification gpm Greater than 25 gpm Unusual Event per Unusual Event per MU6 MU6 Greater than 150 gpm.

The capacity of one makeup pump in the normal Site Area Emergency Alert per FA1 charging mode is exceeded per FS1 (RCS BarrierPotential Loss)

Requires an automatic or Site Area Emergency Alert per FA1 manual ESAS actuation per FS1 (RCS BarrierLoss)

There is no Potential Loss threshold associated with RCS or SG Tube Leakage.

Month 20XX TMI 3-70 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT1 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3

2. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs

3. OP-TM-EOP-005, OTSG Tube Leakage

4. OP-TM-EOP-001, Reactor Trip Month 20XX TMI 3-71 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT2 Initiating Condition:

Inadequate Heat Removal Operating Mode Applicability:

1,2,3,4 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS

1. Tclad _>1800 0 F.

AND

2. EOP Restoration procedures not effective in < 15 minutes.

Basis:

IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

There is no Loss threshold associated with Inadequate Heat Removal.

Potential Loss Threshold Basis This condition represents an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure. For this condition to occur, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. If implementation of a procedure(s) to restore adequate core cooling is not effective (successful) within 15 minutes, it is assumed that the event trajectory will likely lead to core melting and a subsequent challenge of the Containment Barrier.

The restoration procedure is considered "effective" if core exit thermocouple readings are decreasing and/or if reactor vessel level is increasing. Whether or not the procedure(s) will be effective should be apparent within 15 minutes. The Emergency Director should escalate the emergency classification level as soon as it is determined that the procedure(s) will not be effective.

Severe accident analyses (e.g., NUREG-1 150) have concluded that function restoration procedures can arrest core degradation in a significant fraction of core damage scenarios, and that the likelihood of containment failure is very small in these events.

Given this, it is appropriate to provide 15 minutes beyond the required entry point to determine if procedural actions can reverse the core melt sequence.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3

2. OP-TM-EOP-008, RCS Superheated

3. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs

4. OP-TM-EOP-006, LOCA Cooldown Month 20XX TMI 3-72 EP-AA-1009 (Revision XX)

Thrao Milin laIinnd Rtnfinn Annov I::val'*n N,,-l--nr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 Initiating Condition:

Containment Radiation / RCS Activity Operating Mode Applicability:

1,2,3,4 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS Containment radiation monitor (RM-G-22 or RM-G-23) reading > 4.40E+03 R/hr.

Basis:

There is no Loss threshold associated with RCS Activity / Containment Radiation.

Potential Loss Threshold Basis The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that 20% of the fuel cladding has failed.

This level of fuel clad failure is well above that used to determine the analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds.

NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately 20%

in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the emergency classification level to a General Emergency.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3

2. Core Damage Assessment Methodology (CDAM)

Month 20XX TMI 3-73 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 Initiating Condition:

Containment Integrity or Bypass Operating Mode Applicability:

1,2,3,4 Fission Product Barrier (FPB) Threshold:

LOSS

1. Containment isolation is required and ANY of the following:

a. UNPLANNED lowering in containment pressure following initial pressure rise OR

b. Containment pressure or water level response not consistent with LOCA conditions.

OR

c. UNISOLABLE pathway from containment to the environment exists.

CntainRmct is-lationR is required and EITHER of the follo.i n

a. UNPLANNED loern incotai~nment pressure or rase in radiation mon)itorF readings os contaeinment in the Emegncyv, Directors Iudgment existisa a loss of oISOLABLEf OR OR

2. Indication of RCS leakage outside of containment POTENTIAL LOSS

3. Reactor Building Pressure > 55 psig and rising.

OR

4. Hydrogen Concentration in Containment > 4%.

OR

5. a. Reactor Building pressure > 30 psig AND

b. Reactor Building Emergency cooling is less than ANY one of the following conditions:

SPRAY COOLERS 2 0 0 3 1 1 Month 20XX TMI 3-74 EP-AA-1009 (Revision XX)

Throa Milo lainnd -Qfnfinn Annoy PyI=:,nn P,,rlanr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont)

Basis:

FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally.

Failure to isolate the leak, within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

Loss Threshold #1 Basis These thresholds address a situation where containment isolation is required and one of two conditions exists as discussed below. Users are reminded that there may be accident and release conditions that simultaneously meet both loss thresholds l.a and l.b.

1.a - Containment integrity has been lost, i.e., the actual containment atmospheric leak rate likely exceeds that associated with allowable leakage (or sometimes referred to as design leakage). Following the release of RCS mass into containment, containment pressure will fluctuate based on a variety of factors; a loss of containment integrity condition may (or may not) be accompanied by a noticeable drop in containment pressure. Recognizing the inherent difficulties in determining a containment leak rate during accident conditions, it is expected that the Emergency Director will assess this threshold using judgment, and with due consideration given to current plant conditions, and available operational and radiological data (e.g., containment pressure, readings on radiation monitors outside containment, operating status of containment pressure control equipment, etc.).

Refer to the middle piping run of Figure 3-F-1. Two simplified examples are provided.

One is leakage from a penetration and the other is leakage from an in-service system valve. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure.

Another example would be a loss or potential loss of the RCS barrier, and the simultaneous occurrence of two FAULTED locations on a steam generator where one fault is located inside containment (e.g., on a steam or feedwater line) and the other outside of containment. In this case, the associated steam line provides a pathway for the containment atmosphere to escape to an area outside the containment.

Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components. These Month 20XX TMI 3-75 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont)

Basis (cont):

releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.

1.b - Conditions are such that there is an UNISOLABLE pathway for the migration of radioactive material from the containment atmosphere to the environment. As used here, the term "environment" includes the atmosphere of a room or area, outside the containment, that may, in turn, communicate with the outside-the-plant atmosphere (e.g., through discharge of a ventilation system or atmospheric leakage). Depending upon a variety of factors, this condition may or may not be accompanied by a noticeable drop in containment pressure.

Refer to the top piping run of Figure 3-F-1. In this simplified example, the inboard and outboard isolation valves remained open after a containment isolation was required (i.e.,

containment isolation was not successful). There is now an UNISOLABLE pathway from the containment to the environment.

The existence of a filter is not considered in the threshold assessment. Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.

Leakage between two interfacing liquid systems, by itself, does not meet this threshold.

Refer to the bottom piping run of Figure 3-F-1. In this simplified example, leakage in an RCP seal cooler is allowing radioactive material to enter the Auxiliary Building. The radioactivity would be detected by the Process Monitor. If there is no leakage from the closed water cooling system to the Auxiliary Building, then no threshold has been met.

If the pump or system piping developed a leak that allowed steam/water to enter the Auxiliary Building, then loss threshold 2 would be met. Depending upon radiation monitor locations and sensitivities, this leakage could be detected by any of the four monitors depicted in the figure and cause threshold 1.a to be met as well.

Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components. Minor releases may also occur if a containment isolation valve(s) fails to close but the containment atmosphere escapes to a closed system. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.

The status of the containment barrier during an event involving steam generator tube leakage is assessed using Containment Barrier CT1 Loss threshold.

Loss Threshold #2 Basis Containment sump, temperature, pressure and/or radiation levels will rise if reactor coolant mass is leaking into the containment. If these parameters have not increased, then the reactor coolant mass may be leaking outside of containment (i.e., a Month 20XX TMI 3-76 EP-AA-1009 (Revision XX)

Throa Milo leinnd Rtntinn Annov Pyaletn H"Annr Thr~ MiI~ IQI2nrI ~t2tinn Ann~v Fvalnn M.uI102r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont)

Basis (cont):

containment bypass sequence). Raises in sump, temperature, pressure, flow and/or radiation level readings outside of the containment may indicate that the RCS mass is being lost outside of containment.

Unexpected elevated readings and alarms on radiation monitors with detectors outside containment should be corroborated with other available indications to confirm that the source is a loss of RCS mass outside of containment. If the fuel clad barrier has not been lost, radiation monitor readings outside of containment may not rise significantly; however, other unexpected changes in sump levels, area temperatures or pressures, flow rates, etc. should be sufficient to determine if RCS mass is being lost outside of the containment.

Refer to the middle piping run of Figure 3-F-1. In this simplified example, a leak has occurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building.

Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause loss threshold l.a to be met as well. To ensure proper escalation of the emergency classification, the RCS leakage outside of containment must be related to the mass loss that is causing the RCS Barrier RC1 Loss Threshold l.a and/or Potential Loss threshold 2.a to be met.

Potential Loss Threshold #3 Basis If containment pressure exceeds the design pressure, there exists a potential to lose the Containment Barrier. To reach this level, there must be an inadequate core cooling condition for an extended period of time; therefore, the RCS and Fuel Clad barriers would already be lost. Thus, this threshold is a discriminator between a Site Area Emergency and General Emergency since there is now a potential to lose the third barrier.

Potential Loss Threshold #4 Basis The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a potential loss of the Containment Barrier.

Potential Loss Threshold #5 Basis This threshold describes a condition where containment pressure is greater than the set point at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. This threshold represents a potential loss of containment in that containment heat removal/depressurization systems (e.g., containment sprays, ice condenser fans, etc.,

but not including containment venting strategies) are either lost or performing in a degraded manner.

Month 20XX TMI 3-77 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3

2. FSAR Section 6.6 Reactor Building Pressure-Time Response

3. Technical Specifications 3.5.3, Engineered Safeguards Protection System Actuation Setpoints

4. FSAR Section 6.3.3, Actuation

5. FSAR Section 6.5.3, Hydrogen Generation

6. OP-TM-EOP-006, LOCA Cooldown

7. 1302-5.25 Reactor Building Sump Level

8. FSAR Section 5.2 Reactor Building

9. FSAR Section 9.2, Chemical Addition and Sampling System

10. OP-TM-EOP-002, Loss of 250 F Subcooling Margin

11. OP-TM-EOP-006, LOCA Cooldown

12. OP-TM-EOP-010, Emergency Procedure Rules, Guides and Graphs

13. OP-TM-MAP-D0301, High Make-up Flow Month 20XX TMI 3-78 EP-AA-1009 (Revision XX)

Eeo ula Three Mile Island Station Annex RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Figure 3-F-1: PWR Containment Integrity or Bypass Examples InsideMonitor Effluent Inside Auxiliary Building ----- Vent Containment Vent Damper Open valve Open valve Damper La -

Monitorne Open valve Open valveP

.4. .. . . .

Interfaceponleakage 'from*rees t* otid Rt lProcess i Monitor ,,.*.-*

* **Closed Sealak LaP- ibre. . 'eaka Cooling Wall Open valve Open valve Pump System Seal Cooling Month 20XX TMVI 3-79 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT5 Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1,2,3,4 Fission Product Barrier (FPB) Threshold:

LOSS

1. Any condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.

POTENTIAL LOSS

2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.

Basis:

Loss Threshold #1 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is lost.

Potential Loss Threshold #2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX TMI 3-80 EP-AA-1009 (Revision XX)

Thron Milo lalnnin !Zfnfinn Annov 9::v~mlnn K, ,-Ianr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG1 Initiating Condition:

Prolonged loss of all offsite and all onsite AC power to emergency busses.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. Loss of ALL offsite AC power to Emergency 4KV buses.

AND

2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBO Diesel Generator to supply power to Emergency 4KV buses.

AND

3. EITHER of the following:

a. Restoration of at least one Emergency 4KV bus in < 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is not likely.

OR

b. > 25°F superheat Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a prolonged loss of all power sources to AC emergency buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A prolonged loss of these buses will lead to a loss of any fission product barriers. In addition, fission product barrier monitoring capabilities may be degraded under these conditions.

The EAL should require declaration of a General Emergency prior to meeting the thresholds for IC FG1. This will allow additional time for implementation of offsite protective actions.

Escalation of the emergency classification from Site Area Emergency will occur if it is projected that power cannot be restored to at least one AC emergency bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and Month 20XX TMI 3-81 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG1 (cont)

Basis (cont):

event trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers.

The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation. Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public.

The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.

Basis Reference(s):

1. NEI 99-01 Rev 6, SG1

2. OP-TM-EOP-010 Emergency Procedure Rules, Guides And Graphs

3. FSAR Section 8.2.2 Unit Distribution System

4. FSAR Section 8.2.3 Sources of Auxiliary Power

5. FSAR Section 8.5 Station Blackout

6. Technical Specification Section 3.7, Unit Electric Power System

7. 1107-1 Normal Electrical System

8. 11 07-2A Emergency Electrical - 4KV and 480 Volt

9. OP-TM-AOP-020 Loss Of Station Power

10. 1107-3 Diesel Generator

11. 1107-9 SBO Diesel Generator

12. OP-TM-EOP-008 RCS Superheated

13. OS-24, Conduct of Operation during Abnormal and Emergency Events Month 20XX TMI 3-82 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1 Initiating Condition:

Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. Loss of ALL offsite AC Power to Emergency 4KV buses.

AND

2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBO Diesel Generator to supply power to Emergency 4KV buses.

AND

3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutes from the time of loss of both offsite and onsite AC power Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via ICs RG1, FG1, MG1, or MG2.

Month 20XX TMI 3-83 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, SS1

2. FSAR Section 8.2.3, Sources of Auxiliary Power

3. Technical Specification Section 3.7, Unit Electric Power System

4. 1107-1 Normal Electrical System

5. 1107-2A Emergency Electrical - 4KV and 480 Volt

6. OP-TM-AOP-020 Loss Of Station Power

7. 1107-3 Diesel Generator

8. 1107-9 SBO Diesel Generator

9. FSAR Section 8.2.2, Unit Distribution System

10. FSAR Section 8.5, Station Blackout Month 20XX TMI 3-84 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA1 Initiating Condition:

Loss of all but one AC power source to emergency buses for 15 minutes or longer.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. AC power capability to Emergency 4KV buses reduced to only one of the following power sources for > 15 minutes.

Auxiliary Transformer 1A

Auxiliary Transformer 1 B

Emergency Diesel Generator EG-Y-1A

Emergency Diesel Generator EG-Y-1 B

SBO Diesel Generator EG-Y-4 AND

2. Any additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment. This IC provides an escalation path from IC MUl.

An "AC power source" is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.

A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).

Month 20XX TMI 3-85 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA1 (cont)

Basis (cont):

" A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from the unit main generator.

A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an offsite power source.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.

Escalation of the emergency classification level would be via IC MS1.

Basis Reference(s):

1. NEI 99-01 Rev 6, SA1

2. FSAR Section 8.2.3, Sources of Auxiliary Power

3. FSAR Section 8.5, Station Blackout

4. Technical Specification Section 3.7, Unit Electric Power System

5. 1107-1 Normal Electrical System

6. 11 07-2A Emergency Electrical - 4KV and 480 Volt

7. OP-TM-AOP-020 Loss Of Station Power

8. 1107-3 Diesel Generator

9. 1107-9 SBO Diesel Generator

10. FSAR Section 8.2.2, Unit Distribution System Month 20XX TMI 3-86 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU1 Initiating Condition:

Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

Loss of ALL offsite AC power capability to Emergency 4KV busses for > 15 minutes.

Basis:

This IC addresses a prolonged loss of offsite power. The loss of offsite power sources renders the plant more vulnerable to a complete loss of power to AC emergency buses.

This condition represents a potential reduction in the level of safety of the plant.

For emergency classification purposes, "capability" means that an offsite AC power source(s) is available to the emergency buses, whether or not the buses are powered from it.

The emergency busses of the affected unit can be powered from the unaffected unit through the crosstie breakers. Unit crosstie is considered an adequate source of offsite power when evaluating this EAL.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power.

Escalation of the emergency classification level would be via IC MAI.

Basis Reference(s):

1. NEI 99-01 Rev 6, SUl

2. FSAR Section 8.2.3, Sources of Auxiliary Power

3. Technical Specification Section 3.7, Unit Electric Power System

4. 1107-1 Normal Electrical System

5. 11 07-2A Emergency Electrical - 4KV and 480 Volt

6. OP-TM-AOP-020 Loss Of Station Power

7. 1107-3 Diesel Generator

8. 1107-9 SBO Diesel Generator

9. FSAR Section 8.2.2, Unit Distribution System Month 20XX TMI 3-87 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG2 Initiating Condition:

Loss of all AC and Vital DC power sources for 15 minutes or longer.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. Loss of ALL offsite AC power to Emergency 4KV buses.

AND

2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBO Diesel Generator to supply power to Emergency 4KV buses.

AND

3. Voltage is < 105 VDC on 125 VDC Distribution System 1A and lB.

AND

4. ALL AC and Vital DC power sources have been lost for >15 minutes.

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A loss of Vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both AC and DC power will lead to multiple challenges to fission product barriers.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. The 15-minute emergency declaration clock begins at the point when all EALs are met.

Month 20XX TMI 3-88 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG2 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, SG8

2. FSAR Section 8.2.2.6, 250/125 VDC System

3. 1107-2C Vital DC Electrical System

4. OP-TM-AOP-023, A DC System Failure

5. OP-TM-AOP-024, B DC System Failure

6. FSAR Section 8.2.2, Unit Distribution System

7. FSAR Section 8.2.3, Sources of Auxiliary Power

8. Technical Specification Section 3.7, Unit Electric Power System

9. 1107-1 Normal Electrical System

10. 1107-2A Emergency Electrical - 4KV and 480 Volt

11. OP-TM-AOP-020 Loss Of Station Power

12. 1107-3 Diesel Generator

13. 1107-9 SBO Diesel Generator

14. FSAR Section 8.5, Station Blackout Month 20XX TMI 3-89 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS2 Initiating Condition:

Loss of all vital DC power for 15 minutes or longer.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

Voltage is < 105 VDC on 125 VDC Distribution System 1A and 1B for

>15 minutes.

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECOS. These are typically systems classified as safety-related.

This IC addresses a loss of Vital DC power which compromises the ability to monitor and control SAFETY SYSTEMS. In modes above Cold Shutdown, this condition involves a major failure of plant functions needed for the protection of the public.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via ICs RG1, FG1 or MG3.

Basis Reference(s):

1. NEI 99-01 Rev 6, SS8

2. FSAR Section 8.2.2.6, 250/125 VDC System

3. 11 07-2C Vital DC Electrical System

4. OP-TM-AOP-023, A DC System Failure

5. OP-TM-AOP-024, B DC System Failure Month 20XX TMI 3-90 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3 Initiating Condition:

Inability to shutdown the reactor causing a challenge to core cooling or RCS heat removal.

Operating Mode Applicability:

1,2 Emergency Action Level (EAL):

1. Automatic or Manual Trip did not shutdown the reactor as indicated by Reactor Power > 5%.

AND

2. ALL manual actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 5%.

AND

3. EITHER of the following conditions exist:

a. Tclad > 1400°F.

OR

b. HPI-PORV Cooling in effect.

Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, all subsequent operator manual actions, both inside and outside the Control Room including driving in control rods and boron injection, are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.

In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs. This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Escalation of the emergency classification level would be via IC RG1 or FG1.

Month 20XX TMI 3-91 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, SS5

2. OP-TM-EOP-004, Lack of Primary-to-Secondary Heat Transfer

3. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs

4. OP-TM-EOP-001, Reactor Trip

5. 1102-4 Power Operation

6. OP-TM-641-000- Reactor Protection System (RPS/DSS)

Month 20XX TMI 3-92 EP-AA-1009 (Revision XX)

FY*lnn N.r.l*_* r Throp Milo kIslnd Staition Annex FyoInn NI.Iar~I2 TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 Initiating Condition:

Automatic or manual trip fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.

Operating Mode Applicability:

1,2 Emergency Action Level (EAL):

Note:

A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. Automatic Trip did not shutdown the reactor as indicated by Reactor Power > 5%.

AND

2. Manual actions taken at the Console Center are not successful in shutting down the reactor as indicated by Reactor Power > 5%.

Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic reactor trip that results in a reactor shutdown, and subsequent operator manual actions taken at the Console Center to shutdown the reactor are also unsuccessful. This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the Console Center since this event entails a significant failure of the RPS.

A manual action at the Console Center is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip. This action does not include manually driving in control rods or implementation of boron injection strategies. If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the Console Center (e.g., locally opening breakers). Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the Console Center".

The plant response to the failure of an automatic reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged enough to cause a challenge to the core cooling or RCS heat removal safety functions, the emergency Month 20XX TMI 3-93 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 (cont)

Basis (cont):

classification level will escalate to a Site Area Emergency via IC MS3. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC MS3 or FS1, an Alert declaration is appropriate for this event.

It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL are included to ensure a timely emergency declaration.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Basis Reference(s):

1. NEI 99-01 Rev 6, SA5

2. OP-TM-EOP-004, Lack of Primary-to-Secondary Heat Transfer

3. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs

4. OP-TM-EOP-001, Reactor Trip

5. 1102-4 Power Operation

6. OP-TM-641-000- Reactor Protection System (RPS/DSS)

Month 20XX TMI 3-94 EP-AA-1009 (Revision XX)

I=x*_lon Nucl*=ar Three Mile kIslnd Station Annex Exelnn NucleIar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 Initiating Condition:

Automatic or manual trip fails to shutdown the reactor.

Operating Mode Applicability:

1,2 Emergency Action Level (EAL):

Note:

A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. a. Automatic Trip did not shutdown the reactor as indicated by Reactor Power

> 5%.

AND

b. Subsequent manual action taken at the Console Center is successful in shutting down the reactor.

OR

2. a. Manual Trip did not shutdown the reactor as indicated by Reactor Power > 5%.

AND

b. Subsequent automatic Trip is successful in shutting down the reactor.

Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual action taken at the Console Center or an automatic trip is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.

EAL #1 Basis Following the failure on an automatic reactor trip, operators will promptly initiate manual actions at the Console Center to shutdown the reactor (e.g., initiate a manual reactor trip). If these manual actions are successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems.

Month 20XX TMI 3-95 EP-AA-1009 (Revision XX)

Throo Milo Icinnd -Qfnfirn Annoy I=v,',lt'n khig-l--*r Thra~ MiI~ IQI2nrI ~*2fifln Anngiv Fv~Lnn NiirIc~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont)

Basis (cont):

EAL #2 Basis If an initial manual reactor trip is unsuccessful, a concurrent plant condition, may lead to the generation of an automatic reactor trip signal. If a subsequent automatic trip is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems.

A manual action at the Console Center is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip). This action does not include manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the Console Center".

The plant response to the failure of an automatic or manual reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the Console Center are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC MA3. Depending upon the plant response, escalation is also possible via IC FAI. Absent the plant conditions needed to meet either IC MA3 or FA1, an Unusual Event declaration is appropriate for this event.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Should a reactor trip signal be generated as a result of plant work (e.g., RPS setpoint testing), the following classification guidance should be applied.

" If the signal generated as a result of plant work causes a plant transient that creates a real condition that should have included an automatic reactor trip and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.

" If the signal generated as a result of plant work does not cause a plant transient but should have generated an RPS trip signal and the trip failure is determined through other means (e.g., assessment of test results), then this IC and the EALs are not applicable and no classification is warranted.

Month 20XX TMI 3-96 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, SU5

2. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs

3. OP-TM-EOP-001, Reactor Trip

4. 1102-4 Power Operation

5. OP-TM-641-000- Reactor Protection System (RPS/DSS)

Month 20XX TMI 3-97 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex I=x*lon Nuclear Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA4 Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. a. UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes.

Table M1 Control Room Parameters

" Reactor Power

PZR Level

" RCS Pressure

In Core/Core Exit Temperature

Level in at least one OTSG.

OTSG Emergency Feed Water Flow AND

b. ANY Table M2 transient in progress.

Table M2 Significant Transients

" Automatic Turbine Runback >25% thermal reactor power

" Electrical Load Rejection >25% full electrical load

" Reactor Trip

" ESAS Actuation

Thermal Power oscillations > 10%

Month 20XX TMI 3-98 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA4 (cont)

Basis:

UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fission product barrier challenge is reduced. It thus represents a potential substantial degradation in the level of safety of the plant.

As used in this EAL, an "inability to monitor" means that values for any of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, computer point, digital and recorder source within the Control Room.

An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine any of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for any of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation of the emergency classification level would be via ICs FS1 or IC RS1.

Basis Reference(s):

1. NE 199-01 Rev 6, SA2 Month 20XX TMI 3-99 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4 Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes.

Table M1 Control Room Parameters 0 Reactor Power 0 PZR Level 0 RCS Pressure 0 In Core/Core Exit Temperature 0 Level in at least one OTSG.

0 OTSG Emergency Feed Water Flow Basis:

UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. This condition is a precursor to a more significant event and represents a potential degradation in the level of safety of the plant.

As used in this EAL, an "inability to monitor" means that values for any of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room. An event involving a loss of plant indications, Month 20XX TMI 3-100 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exellon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4 (cont)

Basis (cont):

annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine any of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for any of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation of the emergency classification level would be via IC MA4.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU2 Month 20XX TMI 3-101 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA5 Initiating Condition:

Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

Note:

0 If it is determined that the conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.

1. The occurrence of ANY of the following hazardous events:

Seismic event (earthquake)

Internal or external flooding event

High winds or tornado strike

" FIRE

" EXPLOSION

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

2. EITHER of the following:

a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.

OR

b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.

Basis:

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such Month 20XX TMI 3-102 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS events may require a post-event inspection to determine if the attributes of an explosion are present.

Month 20XX TMI 3-103 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exellon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA5 (cont)

Basis (cont):

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.

EAL #2.a Basis This EAL addresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

EAL #2.b Basis This EAL addresses damage to a SAFETY SYSTEM component that is required to be operable by Technical Specifications for the current operating mode, and is not in operation or readily apparent through indications alone, as well as damage to a structure containing SAFETY SYSTEM components. Operators will make this determination based on the totality of available event and damage report information.

This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level would be via IC FS1 or RSI.

If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.

Basis Reference(s):

1. NEI 99-01, Rev 6 SA9 Month 20XX TMI 3-104 EP-AA-1009 (Revision XX)

Throcn Milo Ici~nnr R*2tienn Annoy IPvaltn N iielan*r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU6 Initiating Condition:

RCS leakage for 15 minutes or longer.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. RCS unidentified or pressure boundary leakage > 10 gpm for > 15 minutes.

OR

2. RCS identified leakage >25 gpm for > 15 minutes.

OR

3. Leakage from the RCS to a location outside containment >25 gpm for > 15 minutes.

Basis:

UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally.

Failure to isolate the leak, within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

This IC addresses RCS leakage which may be a precursor to a more significant event.

In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant.

EAL #1 and EAL #2 Basis These EALs are focused on a loss of mass from the RCS due to "unidentified leakage",

"pressure boundary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications).

EAL #3 Basis This EAL addresses a RCS mass loss caused by an UNISOLABLE leak through an interfacing system. These EALs thus apply to leakage into the containment, a secondary-side system (e.g., steam generator tube leakage) or a location outside of containment.

The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications. Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation). EAL #1 uses a lower value that reflects the greater significance of unidentified or pressure boundary leakage.

Month 20XX TMI 3-105 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU6 (cont)

Basis (cont):

The release of mass from the RCS due to the as-designed/expected operation of a relief valve does not warrant an emergency classification. An emergency classification would be required if a mass loss is caused by a relief valve that is not functioning as designed/expected (e.g., a relief valve sticks open and the line flow cannot be isolated).

The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible.

Escalation of the emergency classification level would be via ICs of Recognition Category R or F.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU4

2. OP-TM-220-251 RCS Leak Rate Determination

3. OP-TM-220-252, Primary - To - Secondary Leakrate Determination

4. OP-TM-PRF1-0405 RB Sump Level HI

5. UFSAR 6.4.3, Bases of Leakage Estimate

6. UFSAR 6.4.4, Design Basis Leakage

7. OP-TM-AOP-050, Reactor Coolant Leakage

8. Technical Specification 3.1.6, Leakage and Table 4.1-2, Minimum Equipment Test Frequency Month 20XX TMI 3-106 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU7 Initiating Condition:

Loss of all On-site or Off-site communications capabilities.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

1. Loss of ALL Table M3 Onsite communications capability affecting the ability to perform routine operations.

OR

2. Loss of ALL Table M3 Offsite communication capability affecting the ability to perform offsite notifications.

OR

3. Loss of ALL Table M3 NRC communication capability affecting the ability to perform NRC notifications.

Table M3 Communications Capability System Onsite Offsite NRC Radios X Plant page X Plant Telephone System X Sound Powered Phoe*s X Commercial Telephones X X X NARS X ENS X X HPN X X Satellite phones X X Basis:

This IC addresses a significant loss of on-site, offsite, or NRC communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

Month 20XX TMI 3-107 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU7 (cont)

Basis (cont):

EAL #1 Basis Addresses a total loss of the communications methods used in support of routine plant operations.

EAL #2 Basis Addresses a total loss of the communications methods used to notify all OROs of an emergency declaration. The OROs referred to here are listed in procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form.

EAL #3 Basis Addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU6

2. 1105-12 Communications System

3. FSAR Section 7.4.4, Communication Month 20XX TMI 3-108 EP-AA-1009 (Revision XX)

Throa Milo kinnd -Qf-nfinn Annov I=volenn H,,r-lanr Thr~ MiI~ IQI2nrI ~t2tinn Annoy Fvalnn Mu.rIo~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU8 Initiating Condition:

Failure to isolate containment or loss of containment pressure control.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL):

1. a. Failure of containment to isolate when required by an actuation signal.

AND

b. ANY required penetration remains open > 15 minutes of the actuation signal.

OR

2. a. Reactor Building pressure > 30 psig AND

b. Reactor Building Emergency cooling is less than ANY one of the following conditions for > 15 minutes:

SPRAY COOLERS 2 0 0 3 1 1 Basis:

This IC addresses a failure of any containment penetrations to automatically isolate (close) when required by an actuation signal. It also addresses an event that results in high containment pressure with a concurrent failure of containment pressure control systems. Absent challenges to another fission product barrier, either condition represents potential degradation of the level of safety of the plant.

EAL #1 Basis The containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); a failure resulting from testing or maintenance does not warrant classification. The determination of containment and penetration status - isolated or not isolated - should be made in accordance with the appropriate criteria contained in the plant AOPs and EOPs. The 15-minute criterion is included to allow operators time to manually isolate the required penetrations, if possible.

Month 20XX TMI 3-109 EP-AA-1009 (Revision XX)

I=Y*lnn Ntr.l*r Three Mile kIslnd Station Annex Pvalnn MNirlI2r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU8 (cont)

Basis (cont):

EAL #2 Basis Addresses a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. The inability to start the required equipment indicates that containment heat removal/depressurization systems (e.g., containment sprays or ice condenser fans) are either lost or performing in a degraded manner.

This event would escalate to a Site Area Emergency in accordance with IC FS1 if there were a concurrent loss or potential loss of either the Fuel Clad or RCS fission product barriers.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU7

2. FSAR Section 6.6 Reactor Building Pressure-Time Response

3. Technical Specifications 3.5.3, Engineered Safeguards Protection System Actuation Setpoints

4. FSAR Section 6.3.3, Actuation

5. FSAR Section 6.5.3, Hydrogen Generation

6. OP-TM-EOP-006, LOCA Cooldown

7. 1302-5.25 Reactor Building Sump Level

8. FSAR Section 5.2 Reactor Building

9. FSAR Section 9.2, Chemical Addition and Sampling System

10. OP-TM-EOP-002, Loss of 25 0F Subcooling Margin

11. OP-TM-EOP-006, LOCA Cooldown

12. OP-TM-EOP-010, Emergency Procedure Rules, Guides and Graphs

13. OP-TM-MAP-D0301, High Make-up Flow Month 20XX TMI 3-110 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA1 Initiating Condition:

Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.

Operating Mode Applicability:

5,6, D Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. Loss of ALL offsite AC power to Emergency 4KV buses.

AND

2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBO Diesel Generator to supply power to Emergency 4KV buses.

AND

3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutes from the time of loss of both offsite and onsite AC power.

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink.

When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore an emergency bus to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via IC CS6 or RS1.

Month 20XX TMI 3-111 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA1 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, CA2

2. FSAR Section 8.2.2, Unit Distribution System

3. FSAR Section 8.2.3, Sources of Auxiliary Power

4. Technical Specification Section 3.7, Unit Electric Power System

5. 1107-1 Normal Electrical System

6. 1107-2A Emergency Electrical - 4KV and 480 Volt

7. OP-TM-AOP-020 Loss Of Station Power

8. 1107-3 Diesel Generator

9. 1107-9 SBO Diesel Generator

10. FSAR Section 8.5, Station Blackout Month 20XX TMI 3-112 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS cul Initiating Condition:

Loss of all but one AC power source to emergency buses for 15 minutes or longer.

Operating Mode Applicability:

5,6, D Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. AC power capability to Emergency 4KV buses reduced to only one of the following power sources for > 15 minutes.

" Auxiliary Transformer 1A

" Auxiliary Transformer 1B

" Emergency Diesel Generator EG-Y-1A

" Emergency Diesel Generator EG-Y-1 B

" SBO Diesel Generator EG-Y-4 AND

2. ANY additional single power source failure will result in a loss of ALLAC power to SAFETY SYSTEMS.

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.

When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the increased time available to restore another power source to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.

Month 20XX TMI 3-113 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CUI (cont)

Basis (cont):

An "AC power source" is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.

" A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).

A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from the unit main generator.

" A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an offsite power source.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.

The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA1.

Basis Reference(s):

1. NEI 99-01 Rev 6 CU2

2. FSAR Section 8.2.2, Unit Distribution System

3. FSAR Section 8.2.3, Sources of Auxiliary Power

4. Technical Specification Section 3.7, Unit Electric Power System

5. 1107-1 Normal Electrical System

6. 11 07-2A Emergency Electrical - 4KV and 480 Volt

7. OP-TM-AOP-020 Loss Of Station Power

8. 1107-3 Diesel Generator

9. 1107-9 SBO Diesel Generator

10. FSAR Section 8.5, Station Blackout Month 20XX TMI 3-114 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 Initiating Condition:

Hazardous event affecting SAFETY SYSTEM required for the current operating mode.

Operating Mode Applicability:

5,6 Emergency Action Level (EAL):

Note:

If it is determined that the conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.

1. The occurrence of ANY of the following hazardous events:

" Seismic event (earthquake)

" Internal or external flooding event

" High winds or tornado strike

" FIRE

" EXPLOSION

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

2. EITHER of the following:

a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.

OR

b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.

Basis:

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such Month 20XX TMI 3-115 EP-AA-1009 (Revision XX)

Throp Milo W-nnd Rtntirm Annov Pvalrn Khi#-1,nnr Thr~ MiI~ IQI2nrI ~t2tinn Annav Fv~Ii~n Mi .i4a~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS events may require a post-event inspection to determine if the attributes of an explosion are present.

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

Month 20XX TMI 3-116 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 (cont)

Basis (cont):

VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.

EAL #2.a Basis Addresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

EAL #2.b Basis Addresses damage to a SAFETY SYSTEM component that is required to be operable by Technical Specifications for the current operating mode, and is not in operation or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level would be via IC CS6 or RS1.

If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.

Basis Reference(s):

1. NEI 99-01 Rev 6, CA6 Month 20XX TMI 3-117 EP-AA-1009 (Revision XX)

Throp Milo lainnd Rfnfinn Annoy Pynilnn Ni r~lanr Thr~ MiI~ IQI2nrI ~t~tinn Anng~v Fv~~Inn N.irI~ar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU3 Initiating Condition:

Loss of Vital DC power for 15 minutes or longer.

Operating Mode Applicability:

5,6 Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

Indicated voltage is < 105 VDC on required 125 VDC Distribution System 1A and I B for > 15 minutes.

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a loss of Vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions raise the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant.

As used in this EAL, "required" means the Vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.

For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Depending upon the event, escalation of the emergency classification level would be via IC CA6 or CA5, or an IC in Recognition Category R.

Month 20XX TMI 3-118 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU3 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, CU4

2. FSAR Section 8.2.2.6, 250/125 VDC System

3. 1107-2C Vital DC Electrical System

4. OP-TM-AOP-023, A DC System Failure

5. OP-TM-AOP-024, B DC System Failure Month 20XX TMI 3-119 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Thre Mil Isand taton AnexExelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4 Initiating Condition:

Loss of all onsite or offsite communications capabilities.

Operating Mode Applicability:

5,6, D Emergency Action Level (EAL):

1. Loss of ALL Table C1 Onsite communications capability affecting the ability to perform routine operations.

OR

2. Loss of ALL Table C1 Offsite communication capability affecting the ability to perform offsite notifications.

OR

3. Loss of ALL Table C1 NRC communication capability affecting the ability to perform NRC notifications.

Table C1 Communications Capability System Onsite Offsite NRC Radios X Plant page X Plant Telephone System X Sound Powered Phones X Commercial Telephones X X X NARS X ENS X X HPN X X Satellite phones X X Basis:

This IC addresses a significant loss of on-site, offsite, or NRC communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

EAL #1 addresses a total loss of the communications methods used in support of routine plant operations.

Month 20XX TMI 3-120 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4 (cont)

Basis (cont):

EAL #2 Basis Addresses a total loss of the communications methods used to notify all OROs of an emergency declaration. The OROs referred to here are listed in procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form.

EAL #3 Basis Addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

Basis Reference(s):

1. NEI 99-01 Rev 6, CU5

2. 1105-12 Communications System

3. FSAR Section 7.4.4, Communication Month 20XX TMI 3-121 EP-AA-1009 (Revision XX)

Thrain RAila lainnei Rfnfinn Annav Pvalnn Khirlanr SII1 5 IMliI5 mIQmuiiTBI t3-i2ii nmTcmm*,V T Basisi l TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 Initiating Condition:

Inability to maintain the plant in cold shutdown.

Operating Mode Applicability:

5,6 Emergency Action Level (EAL):

Note:

" The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

" A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification.

1. UNPLANNED rise in RCS temperature > 200OF due to loss of decay heat remevvafor > Table C2 duration.

OR

2. UNPLANNED RCS pressure rise > 10 psig as a result of temperature rise due to lesse.f decay heat removal. (This EAL does not apply in solid plant conditions.)

Table C2 RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up Status Duration Intact Not Applicable 60 minutes*

Not Intact Established 20 minutes*

OR Reduced Inventory Not Established 0 minutes

If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not applicable.

Month 20XX TMI 3-122 EP-AA-1009 (Revision XX)

Thran Milo Icinnd Afnfinn Annoy P~yaleln K,,r-lanr Thr*~a MiI~ I~I2nd ~*2tinn Anni~v Fvalnn Ma.rI~~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 (cont)

Basis:

UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, etc.).

This IC addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant.

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact, or RCS inventory is reduced (e.g., mid-loop operation in PWRs). The 20-minute criterion was included to allow time for operator action to address the temperature rise.

The RCS Heat-up Duration Thresholds table also addresses a rise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature rise without a substantial degradation in plant safety.

Finally, in the case where there is a rise in RCS temperature, the RCS is not intact or is at reduced inventory, and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) the evaporated reactor coolant may be released directly into the Containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel.

EAL #2 Basis Provides a pressure-based indication of RCS heat-up.

Escalation of the emergency classification level would be via IC CS6 or RS1.

Month 20XX TMI 3-123 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, CA3

2. Technical Specifications sections: 1.2.1, 1.7.a and c

3. Technical Specifications sections: 3.6.12.a

4. Technical Specifications sections: 3.6.5

5. Technical Specifications sections: 3.8.6

6. Technical Specifications sections: 1.2.1, 1.7.a and c, 3.6.12.a, 3.6.5, 3.8.6

7. 1101-3 Containment Integrity and Access Limits

8. OP-TM-EOP-030, Loss of Decay Heat Removal

9. Outage Fuel Protection Criteria Document Month 20XX TMI 3-124 EP-AA-1009 (Revision XX)

Thrga Milo Icinnd Atnfinn Annoy I=ylen N,,rlanr Thrg~ MiI~ IQI2nrI ~t~tinn Annc&v Fvalnn MmarI~2r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU5 Initiating Condition:

UNPLANNED rise in RCS temperature Operating Mode Applicability:

5,6 Emergency Action Level (EAL):

Note:

" The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

" A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification.

1. UNPLANNED rise in RCS temperature > 200°F due to loss of decay hct Femeval.

OR

2. Loss of the following for >15 minutes.

ALL RCS temperature indications AND 0 ALL RCS level indications Basis:

UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

This IC addresses an UNPLANNED rise in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level, represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to IC CA5.

RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, etc.).

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

Month 20XX TMI 3-125 EP-AA-1009 (Revision XX)

Fx*_lnn Niml*r Three MileIsldzand Station Annex FvAlnn Nuc~Iipar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU5 (cont)

Basis (cont):

EAL #1 involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

During an outage, the level in the reactor vessel will normally be maintained above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at reduced inventory may result in a rapid rise in reactor coolant temperature depending on the time after shutdown.

EAL #2 reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA5 based on exceeding plant configuration-specific time criteria.

Basis Reference(s):

1. NEI 99-01 Rev 6, CU3

2. 1103-11 RCS Water Level Control

3. FSAR Section 7.3.2, Non-Nuclear Instrumentation

4. 1302-6.6 RCS Temp/Press, TSAT Monitor, ATWS and DSS Calibration

5. NEI 99-01 Rev 5, CU4

6. OP-TM-EOP-030, Loss of Decay Heat Removal Month 20XX TMI 3-126 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exellon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 Initiating Condition:

Loss of reactor vessel/RCS inventory affecting fuel clad integrity with containment challenged.

Operating Mode Applicability:

5,6 Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. Reactor Vessel / RCS level unknewn cannot be monitored for > 30 minutes.

AND 2L a. Core uncovery is indicated by ANY of the following:

" Table C3 indications of a sufficient magnitude to indicate core uncovery.

OR

" Erratic Source Range Neutron Monitor indication.

OR

" Radiation Monitor RM-G-6 or RM-G-7 reading > 3 R/hr.

AND 3.. b. ANY Containment Challenge Indication (Table C4)

Table C3 Indications of RCS Leakage

UNPLANNED Reactor Bldg Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED BWST level rise*

UNPLANNED RCDT level rise*

UNPLANNED rise in RCS makeup

Observation of leakage or inventory loss

Rise in level is attributed to a loss of reactor vessel/RCS inventory.

Month 20XX TMI 3-127 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Exelon Nuclear Nuclear Three Mile Island Station Annex TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont)

Emergency Action Level (EAL) (cont):

Table C4 Containment Challenge Indications

Hydrogen Concentration in Containment > 4%

UNPLANNED rise in containment pressure

" CONTAINMENT CLOSURE not established*

if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.

Basis:

UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA Protective Action Guidelines (PAG) exposure levels offsite for more than the immediate site area.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

Month 20XX TMI 3-128 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CG6 (cont)

Basis (cont):

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access.

During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.

The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.

These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Month 20XX TMI 3-129 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, CG1

2. 1103-11 RCS Water Level Control

3. 1101-3 Containment Integrity and Access Limits

4. OP-TM-EOP-030, Loss of Decay Heat Removal

5. FSAR Sections 5.2, Reactor Building

6. FSAR Sections 6.5.2, Hydrogen Monitoring

7. FSAR-Sections 6.5.3, Hydrogen Generation

8. Technical Specifications 3.5.5, Accident Monitoring Instrumentation

9. EP-AEL-0501, Estimation of Radiation Monitor Readings Indicating Core Uncovery During Refuel

10. 1301-1 Shift and Daily Checks, Data Sheet 3 Month 20XX TMI 3-130 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex I=x*lon Ntml*_*r Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 Initiating Condition:

Loss of reactor vessel/RCS inventory affecting core decay heat removal capability.

Operating Mode Applicability:

5,6 Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. Reactor Vessel / RCS level cannot be monitored unknown-for >30 minutes.

AND

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

" Table C3 indications of a sufficient magnitude to indicate core uncovery.

OR

Erratic Source Range Neutron Monitor indication.

OR

" Radiation Monitors RM-G-6 or RM-G-7 reading > 3 R/hr.

Table C3 Indications of RCS Leakage

UNPLANNED Reactor Bldg Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED BWST level rise*

" UNPLANNED RCDT level rise*

UNPLANNED rise in RCS makeup

Observation of leakage or inventory loss

Rise in level is attributed to a loss of reactor vessel/RCS inventory.

Month 20XX TMI 3-131 EP-AA-1009 (Revision XX)

Thron Milo IQI2nrI _t2*fnfin Annoy I=vjmlnn N"Aanr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CS6 (cont)

Basis:

UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.

The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.

These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Escalation of the emergency classification level would be via IC CG6 or RG1.

Month 20XX TMI 3-132 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, CS1

2. OP-TM-PRF1-0405 RB Sump Level Hi

3. 1101-3 Containment Integrity and Access Limits

4. 1301-1 Shift and Daily Checks, Data Sheet 3

5. 1103-11 RCS Water Level Control

6. OP-TM-EOP-030, Loss of Decay Heat Removal Month 20XX TMI 3-133 EP-AA-1009 (Revision XX)

Thron Milo lalfinri -Qf2finn Annav I::Ynlnn KI,iilazr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA6 Initiating Condition:

Loss of reactor vessel/RCS inventory.

Operating Mode Applicability:

5,6 Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. Loss of Reactor Vessel / RCS inventory as indicated by RCS level

< 0 inches on Draindown Level indicator.

OR

2. a. Reactor Vessel / RCS level cannot be monitoredunknown for> 15 minutes.

AND

b. Loss of Reactor Vessel / RCS inventory per Table C3 indications.

Table C3 Indications of RCS Leakage

" UNPLANNED Reactor Bldg Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED BWST level rise*

UNPLANNED RCDT level rise*

UNPLANNED rise in RCS makeup

Observation of leakage or inventory loss

Rise in level is attributed to a loss of reactor vessel/RCS inventory.

Month 20XX TMI 3-134 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA6 (cont)

Basis:

UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.

EAL #1 Basis A lowering of water level below 0 inches on Draindown Level indicator indicates that operator actions have not been successful in restoring and maintaining reactor vessel/ROS water level. The heat-up rate of the coolant will rise as the available water inventory is reduced. A continuing drop in water level will lead to core uncovery.

Although related, EAL #1 is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). A rise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA5.

EAL #2 Basis The inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/ROS.

The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS6 If the reactor vessel/RCS inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS6.

Basis Reference(s):

1. NEI 99-01 Rev 6, CA1

2. OP-TM-PRFl-0405 RB Sump Level Hi

3. 1301-1 Shift and Daily Checks, Data Sheet 3

4. 1103-11 RCS Water Level Control

5. OP-TM-EOP-030, Loss of Decay Heat Removal Month 20XX TMI 3-135 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Thre Mil Isand taton AnexExelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 Initiating Condition:

UNPLANNED loss of reactor vessel/RCS inventory for 15 minutes or longer.

Operating Mode Applicability:

5,6 Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. UNPLANNED loss of reactor coolant results in the inability to restore and maintain Reactor Vessel / RCS level to > procedurally established lower limit for > 15 minutes.

OR

2. a. Reactor Vessel / RCS level cannot be monitoredunknown.

AND

b. Loss of Reactor Vessel / RCS inventory per Table C3 indications.

Table C3 Indications of RCS Leakage

UNPLANNED Reactor Bldg Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

" UNPLANNED BWST level rise*

" UNPLANNED RCDT level rise*

" UNPLANNED rise in RCS makeup

Observation of leakage or inventory loss

Rise in level is attributed to a loss of reactor vessel/RCS inventory.

Basis:

UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor reactor vessel/RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.

Month 20XX TMI 3-136 EP-AA-1009 (Revision XX)

l::Y*Inn Nir.l*nr Three Mile kIslnd Station Annex Fvalnn MNirlInr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 (cont)

Basis (cont):

The procedurally established lower limit is not an operational band established above the procedural limit to allow for operator action prior to exceeding the procedural limit, but it is the procedurally established lower limit.

Refueling evolutions that lower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level decreasing below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.

EAL #1 Basis Recognizes that the minimum required reactor vessel/ROS level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.

The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.

EAL #2 Basis Addresses a condition where all means to determine reactor vessel/ROS level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/ROS.

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA6 or CA5.

Basis Reference(s):

1. NEI 99-01, Rev. 6 CU1

2. Technical Specification 3.1.6. Leakage

3. OP-TM-220-251 RCS Leak Rate Determination Using PPC

4. OP-TM-220-252, Primary - To - Secondary Leakrate Determination (OTSG Leakage): Normal Operations

5. OP-TM-MAP-C0105 RCS Draindown LVL HI/LO

6. OP-TM-PRFl-0405 RB Sump Level HI

7. UFSAR 6.4.3, Bases of Leakage Estimate

8. 1103-11 RCS Water Level Control

9. OP-TM-EOP-030, Loss of Decay Heat Removal Month 20XX TMI 3-137 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG1 Initiating Condition:

HOSTILE ACTION resulting in loss of physical control of the facility.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

1. A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.

AND

2. a. ANY Table H1 safety function cannot be controlled or maintained.

OR

b. Damage to spent fuel has occurred or is IMMINENT Table HI Safety Functions

Reactivity Control (ability to shut down the reactor and keep it shutdown)

Core Cooling (ability to cool the core)

RCS Heat Removal (ability to maintain heat sink)

Basis:

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.

PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

Month 20XX TMI 3-138 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG1 (cont)

Basis (cont):

HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

This IC addresses 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

1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls, etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot be maintained.

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 QualificationPlan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

contained in non-public documents such as the Security Plan.

Basis Reference(s):

1. NEI 99-01, Rev. 6 HG1

2. Security and Safeguards Contingency Plan Station Security Plan - Appendix C Month 20XX TMI 3-139 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 Initiating Condition:

HOSTILE ACTION within the PROTECTED AREA.

Operating Mode Applicability:

1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL):

A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.

Basis:

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.

PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

Month 20XX TMI 3-140 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Dm*VmV .... *vmv*m Thre Mil Isand taton AnexExellon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HSI (cont)

Basis (cont):

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and QualificationPlan, 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, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR

§ 50.72.

Escalation of the emergency classification level would be via IC HG1.

Basis Reference(s):

1. NEI 99-01 Rev 6, HS1

2. Security and Safeguards Contingency Plan Station Security Plan - Appendix C Month 20XX TMI 3-141 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 Initiating Condition:

HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

1. A validated notification from NRC of an aircraft attack threat < 30 minutes from the site.

OR

2. Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.

Basis:

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.

PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.

OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons entering for official business.

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the Month 20XX TMI 3-142 EP-AA-1009 (Revision XX)

Threka Milo Icinnd Atnfirn Annoy IPvalrn Ik il" ar Thrn~~ MiIg~ IQI2nrI ~t2tinn Ann~w ~v~Inn Mnr.I~~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 (cont)

Basis (cont):

This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact. Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions.

This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.

Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.

EAL #1 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with OP-TM-AOP-008, Security Threat /

Intrusion.

EAL #2 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.

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRC.

In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.

Escalation of the emergency classification level would be via IC HS1.

Month 20XX TMI 3-143 EP-AA-1009 (Revision XX)

Throa Mila leinnA -Qfnfinn Annoy P=,-Ilr~n khtl~-hmr Thr~ Milo IQI2nr4 ~t2tinn Annoy ~voI,~n Mm ij~Io~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, HA1

2. Security and Safeguards Contingency Plan Station Security Plan - Appendix C

3. OP-TM-AOP-008, Security Threat / Intrusion Month 20XX TMI 3-144 EP-AA-1009 (Revision XX)

Throa RAila Icinnd -qfnfien Annov IPvlnn Niiri-lar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU1 Initiating Condition:

Confirmed SECURITY CONDITION or threat.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

1. Notification of a credible security threat directed at the site as determined per SY-AA-101-132, Security Assessment and Response to Unusual Activities.

OR

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

OR

3. Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.

Basis:

SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.

PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.

Month 20XX TMI 3-145 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HUl (cont)

Basis (cont):

This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety.

Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.

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 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with SY-AA-101-132.

EAL #2 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with OP-TM-AOP-008, Security Threat / Intrusion.

EAL #3 references Security Force because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR

§ 2.39 information.

Escalation of the emergency classification level would be via IC HAl.

Basis Reference(s):

1. NEI 99-01 Rev 6, HU1

2. SY-AA-101-132, Security Assessment and Response to Unusual Activities

3. Security And Safeguards Contingency Plan Station Security Plan - Appendix C Month 20XX TMI 3-146 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex ThreeMile3I2lanLStatiExelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 Initiating Condition:

Inability to control a key safety function from outside the Control Room.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per OP-TM-EOP-020, Cooldown from Outside the Control Room.

AND

2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.

Table H1 Safety Functions

Reactivity Control (ability to shut down the reactor and keep it shutdown)

Core Cooling (ability to cool the core)

RCS Heat Removal (ability to maintain heat sink)

Basis:

The time period to establish control of the plant starts when either:

a. Control of the plant is no longer maintained in the Main Control Room OR

b. The last Operator has left the Main Control Room.

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plan control to alternate locations is a precursor to a challenge to any fission product barriers within a relatively short period of time.

Month 20XX TMI 3-147 EP-AA-1009 (Revision XX)

Thrgg%Milo lalnnrl -Q+m+itn Annov I=vnlrn Pd"Aanr Tkr~ MiIa IcI~inrI ~*~ir~n Ann~v Fv~Irhn N. irI~ar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 (cont)

Basis (cont):

The determination of whether or not "control" is established at the remote safe shutdown location(s) is based on Emergency Director judgment. The Emergency Director is expected to make a reasonable, informed judgment within 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).

Escalation of the emergency classification level would be via IC FG1 or CG6.

Basis Reference(s):

1. NEI 99-01, Rev 6 HS6

2. OP-TM-EOP-020, Cooldown from Outside the Control Room Month 20XX TMI 3-148 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA2 Initiating Condition:

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

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per OP-TM-EOP-020, Cooldown from Outside the Control Room.

Basis:

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety.

Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations. The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel.

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

Escalation of the emergency classification level would be via IC HS2.

Basis Reference(s):

1. NEI 99-01, Rev 6 HA6

2. OP-TM-EOP-020, Cooldown from Outside the Control Room Month 20XX TMI 3-149 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 Initiating Condition:

FIRE potentially degrading the level of safety of the plant.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Note:

9 The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

Escalation of the emergency classification level would be via IC CA2 or MA5

1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of the following FIRE detection indications:

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

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

" Field verification of a single fire alarm OR

2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of a FIRE).

AND

b. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.

OR 3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication.

OR 4 A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

Month 20XX TMI 3-150 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex II*VIVl I I I*VIV*I Thre Mil Isand taton AnexExelnn Nucler~I TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)

Emergency Action Level (EAL) (cont):

Table H2 Vital Areas 0 Reactor Building 0 Intake Building 0 Intermediate Building 0 Control Tower 0 Auxiliary and Fuel Handling Buildings 0 1A and 1B Diesel Generator Buildings 0 BWST

CST Basis:

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

EAL #1 Basis The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.

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

EAL #2 Basis 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.

Month 20XX TMI 3-151 EP-AA-1 009 (Revision XX)

Three Mile Island Station Annex FvpInn Ni.eIorIsr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)

Basis (cont):

A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.

If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.

EAL #3 Basis In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.

EAL #4 Basis If a FIRE within the plant PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish.

Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.

Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part:

Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."

When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.

Month 20XX TMI 3-152 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)

Basis (cont):

Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MA5.

Basis Reference(s):

1. NEI 99-01, Rev 6 HU4

2. FSAR Figure 2.1-3, Extended Plot Plan TMINS

3. FSAR Section 5.1, Class I Structures, Components, and Systems

4. OP-TM-AOP-001, Fire

5. OP-TM-EOP-020, Cooldown Outside of Control Room Month 20XX TMI 3-153 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 Initiating Condition:

Seismic event greater than OBE levels.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Note:

" Escalation of the emergency classification level would be via IC CA2 or MA5

" For emergency classification if EAL 2.b is not able to be confirmed, then the occurrence of a seismic event is confirmed in manner deemed appropriate by the Shift Manager or Emergency Director in < 15 mins of the event.

1. Seismic event > Operating Basis Earthquake (OBE) as indicated by seismic Alarms PRF-1-3 Operating Basis earthquake.

OR

2. When Seismic Monitoring Equipment is not available:

a. Control Room personnel feel an actual or potential seismic event.

AND

b. ANY one of the following confirmed in < 15 mins of the event:

" The earthquake resulted in Modified Mercalli Intensity (MMI) > VI and occurred

< 3.5 miles of the plant.

" The earthquake was magnitude > 6.0

" The earthquake was magnitude > 5.0 and occurred < 125 miles of the plant.

SeiSP*iG event > Operati÷ng Basis Ert*hquk

... 01-3E)Q as indi*-ted by S-eiSM;* A'a....

PRF 1 3 Operating Basis earthquake and PRF-1-2 Threshold Seismic Conditin Basis:

This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (OBE)'. An earthquake greater 1 An OBE is vibratory ground motion for which those features of a nuclear power plant necessary for continued operation without undue risk to the health and safety of the public will remain functional.

Month 20XX TMI 3-154 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exallon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY than an OBE but less than a Safe Shutdown Earthquake (SSE) 2 should have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections). Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety of the plant.

Event verification with external sources should not be necessary during or following an OBE. Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (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, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration.

EAL #2.b and the accompanying note is included to ensure that a declaration does not result from felt vibrations caused by a non-seismic source (e.g., a dropped load). The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., call to USGS, check internet source, etc.) however, the verification action must not preclude a timely emergency declaration. This guidance recognizes that it may cause the site to declare an Unusual Event while another site, similarly affected but with readily available OBE indications in the Control Room, may not.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MA5.

Basis Reference(s):

1. NEI 99-01, Rev 6 HU2

2. OP-TM-AOP-003, Earthquake

3. PRF 1-3 Operating Bases Earthquake

4. PRF 1-2 Threshold Seismic Event 2 An SSE is vibratory ground motion for which certain (generally, safety-related) structures, systems, and components must be designed to remain functional.

Month 20XX TMI 3-155 EP-AA-1 009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 Initiating Condition:

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

Operating Mode Applicability:

-, 2, 3, 4, 5, 6,-D Emergency Action Level (EAL):

Note:

1 If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.

1. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area.

Tal-e H3 Area Entry Related Mode AppliGability a BuildngModes,5,and6 Intermediateudn Modes 4, 5, and 6 Areas with Au3i5iar' Entry BuildHig* Related Mode ModesApplicabilit, 4,5, and 6 Fuel Handling Building* Modes 4, 5, and 6

Aesrequired to establish shutdown cooling Table H3 Areas with Entry Related Mode Applicability 2Area Entry Related Mode Area Applicability Auxiliary Building 281' shielded area 305' above DH Vaults Modes 4, 5, and 6 Fuel Handling Building 28 1' 1iCES Vlvs MOO AND

2. Entry into the room or area is prohibited or impeded Month 20XX TMI 3-156 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exellon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 (cont)

Basis:

This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedures. This condition represents an actual or potential substantial degradation of the level of safety of the plant.

Assuming all plant equipment is operating as designed, normal operation is capable from the Main Control Room (MCR). The plant is also able to transition into a hot shutdown condition from the MCR, therefore Table H3 is a -list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown. This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

This Table does not include the Control Room since adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas.

An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the gaseous release preclude the ability to place shutdown cooling in service. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.

Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

An emergency declaration is not warranted if any of the following conditions apply.

The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release). For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.

Month 20XX TMI 3-157 EP-AA-1009 (Revision XX)

I::x*_lnn Niml*_*r Three Mile kIslnd Stamtion Annex FvAlnn NMilarIA, TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 (cont)

Basis (cont):

" The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).

The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

" The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

This EAL does not apply to firefighting activities that generate smoke or that automatically or manually activate a fire suppression system in an area.

The Operating Mode Applicability of this EAL has been revised from All Modes to modes 4, 5, and 6 due to the mode applicability of the areas of concern in Table H-3. In the future should the areas of concern in Table H-3 be revised then the Operating Mode Applicability of this EAL should be reevaluated.

Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.

Basis Reference(s):

1. NEI 99-01, Rev 6 HA5

2. FSAR Figure 2.1-3, Extended Plot Plan TMINS

3. FSAR Section 5.1, Class I Structures, Components, and Systems

4. NEI 99-01, Rev. 5 HA3

5. OP-TM-406-901, Hazardous Material Release

6. AR-660892, Station Halon and IDLH Evaluations

7. 29CFR1910.134(b) and 29CFR1910.134(d)(2)(iii)

Month 20XX TMI 3-158 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 Initiating Condition:

Hazardous Event Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Note:

EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

Escalation of the emergency classification level would be via IC CA2 or MA5

1. Tornado strike within the PROTECTED AREA.

OR

2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating mode.

OR

3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).

OR

4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.

OR

5. Abnormal river water level at the intake Pump and Screen House, as indicated by EITHER:

a. > 300 ft. el. (high level)

OR

b. < 274 ft. el. (low level)

Basis:

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

Month 20XX TMI 3-159 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

Month 20XX TMI 3-160 EP-AA-1009 (Revision XX)

Throa Milo Ici~nnd Rfnfinn Annoy I:vo-lrnI~n n"l,-nr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 (cont)

Basis (cont):

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

EAL 1 Basis Addresses a tornado striking (touching down) within the Protected Area.

EAL #2 Basis Addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.

Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode. Manual isolation of power to a SAFETY SYSTEM com..p*onent as a result of is an event of lesser im.pact aRd wou~ld be expected to cause small and localized damage. The conRsequence of this type of event is adequately assessed and addressed in accordance with Technical EAL #3 Basis Addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.

EAL #4 Basis Addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.

This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.

Month 20XX TMI 3-161 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 (cont)

Basis (cont):

EAL #5 Basis:

The level of the Susquehanna River is approaching flood stage; flood stage is defined as 302 ft el. at the Intake Pump and Screen House.

A low river water condition below 274 ft el. requires a Technical Specification 3.0.1 plant shutdown per OP-TM-AOP-005 and is a precursor to a more serious condition.

Escalation of the emergency classification level would be based on ICs in Recognition Categories R, F, M, H or C.

Basis Reference(s):

1. NEI 99-01, Rev 6 HU3

2. OP-TM-AOP-005 River Water System Failures

3. OP-TM-AOP-002, Flood

4. OP-TM-AOP-004, Tornado / High Winds Month 20XX TMI 3-162 EP-AA-1009 (Revision XX)

Fx*_lon N Hc.lp_:*r Three Mile kIsland Station Annex FvAlnn Nucler~I TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY.

Operating Mode Applicability:

1,2,3, 4,5,6, D Emergency Action Level (EAL):

Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

Basis:

IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a General Emergency.

Basis Reference(s):

1. NEI 99-01, Rev 6 HG7 Month 20XX TMI 3-163 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

Basis:

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a Site Area Emergency.

Basis Reference(s):

1. NEI 99-01, Rev 6 HS7 Month 20XX TMI 3-164 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Basis:

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.

Basis Reference(s):

1. NEI 99-01, Rev 6 HA7 Month 20XX TMI 3-165 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an UNUSUAL EVENT.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

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

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an UNUSUAL EVENT.

Basis Reference(s):

1. NEI 99-01, Rev 6 HU7 Month 20XX TMI 3-166 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRem TEDE or 5000 mRem thyroid CDE.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Notes:

" The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

" If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for> 15 minutes.

OR

2. Dose assessment Using actual meteorology indicates doses at or beyond the site boundary of EITHER:

a. > 1000 mRem TEDE OR

b. > 5000 mRem CDE Thyroid OR

3. Field survey results at or beyond the site boundary indicate EITHER:

a. Gamma (closed window) dose rates >1000 mR/hr are expected to continue for > 60 minutes.

OR

b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.

Month 20XX TMI 3-32 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG1 (cont)

Emergency Action Level (EAL) (cont):

Table R1 Effluent Monitor Thresholds Effluent Monitor General Emergency RM-G-25 (Cond Offgas) 9.53 E+06 mR/hr RM-A-8GH (Station Vent) 3.09 E+05 cpm RM-G-24 (RB Purge) 5.55 E+05 mR/hr RM-A-14 (ESF Vent) 6.66 E+02 uCi/cc Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at the EPA PAG of 1000 mRem while the 5000 mRem thyroid ODE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Basis Reference(s):

1. NEI 99-01 Rev 6, AG1

2. EP-EAL-0609 Revision 1. Criteria for Choosina Radioloaical Gaseous Effluent EAL Threshold Values, Three Mile Island

3. EP-AA-1 12-500 Emergency Environmental Monitoring

4. FSAR Section 11.4 Radiation Monitoring System

5. EP-AA-1 10-200 Dose Assessment

6. EP-AA-1 10-201 On Shift Dose Assessment Month 20XX TMI 3-33 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDE or 500 mRem thyroid CDE.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Notes:

" The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

" Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Readings on ANY Table R1 Effluent Monitor > Table RI value for_> 15 minutes.

OR

2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:

a. > 100 mRem TEDE OR

b. > 500 mRem CDE Thyroid OR

3. Field survey results at or beyond the site boundary indicate EITHER:

a. Gamma (closed window) dose rates >100 mR/hr are expected to continue for > 60 minutes.

OR

b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.

Month 20XX TMI 3-34 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1 (cont)

Emergency Action Level (EAL) (cont):

Table R1 Effluent Monitor Thresholds Effluent Monitor Site Area Emergency RM-G-25 (Cond Offgas) 9.53 E+05 mR/hr RM-A-8GH (Station Vent) 3.09 E+04 cpm RM-G-24 (RB Purge) 5.55 E+04 mR/hr RM-A-14 (ESF Vent) 6.66 E+01 uCi/cc Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).

It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1000 mRem while the 500 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC RG1.

Basis Reference(s):

1. NEI 99-01 Rev 6, AS1

2. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values, Three Mile Island

3. EP-AA-1 12-500 Emergency Environmental Monitoring

4. FSAR Section 11.4 Radiation Monitoring System

5. EP-AA-1 10-200 Dose Assessment

6. EP-AA-1 10-201 On Shift Dose Assessment Month 20XX TMI 3-35 EP-AA-1009 (Revision XX)

Thron Milo lainnd -Qfnfien Annov Pvaletn Niir-lanr Thraa Milo IQI2nrI ~m*inn Ann~v Fv~Inn Mmmr~I~ir TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRem TEDE or 50 mRem thyroid CDE.

Operating Mode Applicability:

1,2, 3,4, 5, 6, D Emergency Action Level (EAL):

Notes:

" The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

" If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

" The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.

OR

2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:

a. > 10 mRem TEDE OR

b. > 50 mRem CDE Thyroid OR

3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary

a. 10 mRem TEDE for 60 minutes of exposure OR

b. 50 mRem CDE Thyroid for 60 minutes of exposure OR Month 20XX TMI 3-36 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Nuclear taton Mil Thre Isand AnexExelon TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont)

Emergency Action Level (EAL) (cont):

4. Field survey results at or beyond the site boundary indicate EITHER:

a. Gamma (closed window) dose rates > 10 mR/hr are expected to continue for > 60 minutes.

OR

b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.

Table R1 Effluent Monitor Thresholds Effluent Monitor Alert RM-G-25 (Cond Offgas) 9.53 E+04 mR/hr RM-A-8GH (Station Vent) 3.09 E+03 cpm RM-G-24 (RB Purge) 5.55 E+03 mR/hr RM-A-14 (ESF Vent) 6.66 E+00 uCi/cc Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1000 mRem while the 50 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC RS1.

Month 20XX TMI 3-37 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, AA1

2. OP 1101-2.1 Radiation Monitoring System Setpoints

3. FSAR Section 11.4 Radiation Monitoring System

4. OP-TM-MAP-CO101, Radiation Level HI

5. EP-EAL-0609, Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values, Three Mile Island

6. EP-EAL-0616, Revision 0, Three Mile Island Criteria for Choosing Radiological Liquid Effluent EAL Threshold Values

7. EP-EAL-0622, Revision 0, Three Mile Island Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values for Waste Gas Decay Tanks Month 20XX TMI 3-38 EP-AA-1 009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU1 Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Notes:

" The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

1. Reading on ANY of the following effluent monitors > 2 times alarm setpoint established by a current radioactive release discharge permit for > 60 minutes.

" RM-L-6, Radwaste Discharge

" RM-L-12, IWTS / IWFS Discharge

" RM-A-7, Waste Gas Decay Tank Discharge

" Discharge Permit specified monitor OR

2. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 60 minutes.

OR

3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of > 60 minutes.

Month 20XX TMI 3-39 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Exelon Nuclear Nuclear Three Mile Island Station Annex TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RUl (cont)

Emergency Action Level (EAL) (cont):

Table R1 Effluent Monitor Thresholds Effluent Monitor Unusual Evet RM-G-25 (Cond Offgas) 1.09 E+03 mR/hr RM-A-8GH (Station Vent) 7.03 E+01 cpm RM-G-24 (RB Purge) 6.34 E+011 mR/hr RM-A-14 (ESF Vent) 7.60 E-02 uCi/cc Basis:

This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

EAL #1 Basis This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).

The effluent monitors listed are those normally used for planned discharges. If a discharge is performed using a different flowpath or effluent monitor other than those listed (e.g., a portable or temporary effluent monitor), then the declaration criteria will be based on the monitor specified in the Discharge Permit.

EAL #2 Basis This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous effluent pathways.

Month 20XX TMI 3-40 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU1 (cont)

Basis (cont):

EAL #3 Basis This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).

Escalation of the emergency classification level would be via IC RA1.

Basis Reference(s):

1. NEI 99-01 Rev 6, AU1

2. OP 1101-2.1 Radiation Monitoring System Setpoints

3. FSAR Section 11.4 Radiation Monitoring System

4. Offsite Dose Calculation (ODCM)

5. OP-TM-MAP-CO101, Radiation Level HI

6. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values, Three Mile Island Month 20XX TMI 3-41 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG2 Initiating Condition:

Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Note: The Emergency Director should declare the General Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

Spent fuel pool level cannot be restored to at least (site-specific Level 3 value) for 60 minutes or longer.

Basis:

This IC addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment.

It is recognized that this IC would likely not be met until well after another General Emergency IC was met; however, it is included to provide classification diversity.

Basis Reference(s):

1. NEI 99-01 Rev 6, AG2 Month 20XX TMI 3-42 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS2 Initiating Condition:

Spent fuel pool level at (site-specific Level 3 description).

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Lowering of spent fuel pool level to (site-specific Level 3 value).

Basis:

This IC addresses a significant loss of spent fuel pool inventory control and makeup capability leading to IMMINENT fuel damage. This condition entails major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

It is recognized that this IC would likely not be met until well after another Site Area Emergency IC was met; however, it is included to provide classification diversity.

Escalation of the emergency classification level would be via IC RG1 or RG2.

Basis Reference(s):

1. NEI 99-01 Rev 6, AS2 Month 20XX TMI3-43 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2 Initiating Condition:

Significant lowering of water level above, or damage to, irradiated fuel.

Operating Mode Applicability:

1,2, 3,4, 5, 6, D Emergency Action Level (EAL):

1. Uncovery of irradiated fuel in the REFUELING PATHWAY.

OR

2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R2 Radiation Monitor reading >1000 mRem/hr.

OR

3. Lowering of spent fuel pool level to (site specific Level 2 value).

Table R2 Radiation Monitors RMS Area Monitored Mode RM-G-9 FHB Bridge Rad Monitor ALL RM-G-6 RB Auxiliary Bridge Rad Monitor 5, 6 RM-G-7 RB Main Bridge Rad Monitor 5, 6 Basis:

REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.

IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

Month 20XX TMI 3-44 EP-AA-1009 (Revision XX)

l:Y*_Inn Nnm.l*_nr Three Mile kIslnd Station Annex FvAlnn Nm~r-Ionr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2 (cont)

Basis (cont):

EAL #1 Basis:

This EAL escalates from RU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations.

While an area radiation monitor could detect a rise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

EAL #2 Basis:

This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).

EAL #3 Basis:

Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.

Escalation of the emergency would be based on either Recognition Category R or C ICs.

Basis Reference(s):

1. NEI 99-01 Rev 6, AA2

2. Operating Procedure OP-TM-MAP-C0105 RCS Draindown LVL HI/LO

3. OP-TM-MAP-CO101, Radiation Level HI

4. UFSAR, Section 14.2.2.1 - "Fuel Handling Accident" 5 Technical Specification 3.8.11 (Reactor Cavity Level)

6. Operating Procedure OP 1101-2.1 Radiation Monitoring System Setpoints Month 20XX TMI 3-45 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Exelon Nuclear Nuclear Three Mile Island Station Annex TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU2 Initiating Condition:

UNPLANNED loss of water level above irradiated fuel.

Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):

1. a. UNPLANNED water level drop in the REFUELING PATHWAY.

AND

b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R2.

Table R2 Radiation Monitors RMS Area Monitored Mode RM-G-9 FHB Bridge Rad Monitor ALL RM-G-6 RB Auxiliary Bridge Rad Monitor 5,6 RM-G-7 RB Main Bridge Rad Monitor 5, 6 Basis:

UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.

This IC addresses a loss in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.

A water level loss will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available) or from any other temporarily installed monitoring instrumentation. A significant drop in the water level may also cause a rise in the radiation levels of adjacent areas that can be detected by monitors in those locations.

Month 20XX TMI 3-46 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU2 (cont)

Basis (cont):

The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may rise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

Escalation of the emergency classification level would be via IC RA2.

Basis Reference(s):

1. NEI 99-01 Rev 6, AU2

2. UFSAR, Section 14.2.2.1 - "Fuel Handling Accident"

3. OP-TM-MAP-C0105 RCS Draindown

4. OP 1202-12, Excessive Radiation Levels

5. OP 1101-2.1 Radiation Monitoring System Setpoints

6. Technical Specification 3.8.11 (Reactor Cavity Level)

Month 20XX TMI 3-47 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA3 Initiating Condition:

Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.

Operating Mode Applicability:

1,2,3, 4,5,6, D Emergency Action Level (EAL):

Note:

If the equipment in the room or area listed in Table R4 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.

1. Dose rate > 15 mR/hr in ANY of the areas contained in Table R3:

Table R3 Areas Requiring Continuous Occupancy

" Main Control Room

" Central Alarm Station - (by survey)

OR

2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the following Table R4 plant rooms or areas:

Table R4 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Auxiliary Building 281' shielded area 305' above DH Vaults Modes 4, 5, and 6 Fuel Handling Building 281' 1C ES Vlvs MCC Month 20XX TMI 3-48 EP-AA-1009 (Revision XX)

Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RA3 (cont)

Basi s:..