Text

Attachment 3 - EP-AA-1002, Revised Radiological Emergency Plan Annex Information for Byron Station
	ML15071A128
Person / Time
Site:	Byron
Issue date:	03/03/2015
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-1002
	Download: ML15071A128 (334)
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ATTACHMENT 3 REVISED RADIOLOGICAL EMERGENCY PLAN ANNEX INFORMATION FOR BYRON STATION EP-AA-1 002 Enclosures 0 0 0 Enclosure 3A -Revised EAL Comparison Matrix Document Enclosure 3B -Revised EAL Red-Line Basis Documents Enclosure 3C -Revised EAL Basis Documents NEI 99-01 Rev 6 Proposed EAL ] Justification AG1 Initiating Condition

-GENERAL EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the General Emergency 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.* 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. Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer: (site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000 mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dose receptor point)3. Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point):* Closed window dose rates greater than 1000 mR/hr expected to continue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than 5000 mrem for one hour of inhalation.

RGI Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mRem TEDE or 5,000 mRem thyroid CDE.Operating Mode Applicability:

1,2,3,4,5,6,D Emergency Action Levels (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. The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PRO3O) > 9.99 E+09 pCi/sec for > 15 minutes (as determined from Unit 1 &2 PF430 or PPDS -Total Noble Gas Release Rate).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.

FD No Change E Difference 1 Deviation 1) Listed site-specific monitors and Threshold values to ensure timely classification.

2) Added the following to bullet #3 " Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "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." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 1x17 procedure matrix used by the SM.Page I of 66 NEI 99-01 Rev 6 Proposed EAL = Justification AS1 Initiating Condition

-SITE AREA EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the General Emergency 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.* 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. Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer: (site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000 mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dose receptor point)3. Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point):* Closed window dose rates greater than 100 mRlhr expected to continue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than 500 mrem for one hour of inhalation.

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 Levels (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. The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PR030)

> 9.99 E+8 pCilsec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS -Total Noble Gas Release Rate).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.

D No Change E Difference 1:1 Deviation 1) Listed site-specific monitors and Threshold values to ensure timely classification.

2) Added the following to bullet #3" Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "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." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 1x17 procedure matrix used by the SM.Page 2 of 66 NEI 99-01 Rev 6 ] Proposed EAL Justification AAI Initiating Condition

-ALERT Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3)Note:* The Emergency Director should declare the Alert 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.* 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. Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer: (site-specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site specific dose receptor point)3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site-specific dose receptor point) for one hour of exposure.4. Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point):* Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.

RAI 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 Levels (EAL): Note:* 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.

The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PR030)

> 9.99 E+07 pCilsec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS -Total Nobel Gas Release Rate).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 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 Z 60 minutes.OR b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.

E-1 No Change M Difference 1 Deviation 1 ) Listed site-specific monitors and Threshold values to ensure timely classification.

2) Added the following to bullet #3 "Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "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." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 lx1 7 procedure matrix used by the SM.3) Calculations were performed, in accordance with (lAW) guidance provided in NEI 99-01 revision 6 EAL AA1, to determine the effluent monitor response for a radioactive liquid release and a WGDT release via the normal site release pathway.The release would contain activity equivalent to provide 1Omrem TEDE or 5Omrem thyroid CDE at the site boundary.

The calculation determined the effluent monitor responses would be >110% of the instruments maximum range and as such, lAW NEI 99-01 Rev 6 guidance, was not included in this EAL.Page 3 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification AU1 Initiating Condition

-UNUSUAL EVENT Release of gaseous or liquid radioactivity greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3 Note:* The Emergency Director should declare the Alert promptly upon determining that 60 minutes 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.* If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated, 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: (site-specific monitor list and threshold values corresponding to 2 times the controlling document limits)2. Reading on ANY effluent radiation monitor greater than 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.3. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times (site-specific effluent release controlling document limits) for 60 minutes or longer.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 Levels (EAL): Note: 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 high alarm setpoint established by a current radioactive release discharge permit for > 60 minutes.OPROO1, Liquid Radwaste Effluent Monitor* OPROO2, Gas Decay Tank Effluent Monitor OPRO10, Station Blowdown Monitor* 1/2 PROWl, Containment Purge Effluent Monitor* Discharge Permit specified monitor OR 2. The sum of readings on the Unit 1 and 2 Aux Bldg Vent WRGMs (1/2 RE-PRO3) > 1.14 E+06 pCi/sec for a 60 minutes (as determined from Unit 1& 2 PF430 or PPDS -Total Noble Gas Release Rate).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.D-' No Change E Difference

[: Deviation 1) Listed site-specific monitors and Threshold values to ensure timely classification.

2) Added the following to bullet #3 "Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "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." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 x1s7 procedure matrix used by the SM.Page 4 of 66 NEI 99-01 Rev 6 Proposed EAL Justification AG2 Initiating Condition

-- GENERAL EMERGENCY Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer Operating Mode Applicability:

All Example Emergency Action Levels: NOTES: The Emergency Director should declare the General Emergency promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded 1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.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.D No Change E Difference 1 Deviation 1) EAL will be used in accordance with the discussion in Section 1.4, NRC Order 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 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 Report to March 12, 2012 Commission Order Modifying Licenses with Regard for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated October 25.2012.Page 5 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification Initiating Condition

-SITE AREA EMERGENCY Spent fuel pool level at (site-specific Level 3 description)

Operating Mode Applicability:

All Example Emergency Action Levels: 1. Lowering of spent fuel pool level to (site-specific Level 3 value).AS2 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).D No Change E Difference 1 Deviation 1) EAL will be used in accordance with the discussion in Section 1.4, NRC Order EA-1 2-051, it is recommended that this EAL be implemented when the enhanced spent fuel pool level instrumentation is available for use. The completion of the 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 Report to March 12, 2012 Commission Order Modifying Licenses with Regard for 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 Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3 1. Uncovery of irradiated fuel in the REFUELING PATHWAY.2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY of the following radiation monitors: (site-specific listing of radiation monitors, and the associated readings, setpoints and/or alarms)3. Lowering of spent fuel pool level to (site-specific Level 2 value).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 Levels (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 R1 Radiation Monitor reading >1000 mRemlhr OR 3. Lowering of spent fuel pool level to (site-specific Level 2 value).FD No Change E Difference 1 Deviation 1) Listed site-specific monitors and Threshold values to ensure timely classification.

2) EAL #3 will be used in accordance with the discussion in Section 1.4, NRC Order 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 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 Report to March 12, 2012 Commission Order Modifying Licenses with Regard for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated October 25,2012.Table RI Fuel Handling Incident Radiation Monitors* Fuel Building Fuel Handling Incident Monitor ORE-AR055* Fuet Building Fuel Handling Incident Monitor ORE-AR056* Containment Fuel Handling Incident Monitor 1/2RE-AR01 1* Containment Fuel Handling Incident Monitor 1/2RE-AR012 Page 7 of'66 NEI 99-01 Rev 6 1 Proposed EAL Justification AU2 Initiating Condition:

UNUSUAL EVENT UNPLANNED loss of water level above irradiated fuel Operating Mode Applicability:

All Example Emergency Action Levels: 1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following: (site-specific level indications).

AND b. UNPLANNED rise in area radiation levels as indicated by ANY of the following radiation monitors.(site-specific list of area radiation monitors)RU2 Initiating Condition:

UNPLANNED loss of water level above irradiated fuel Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Levels (EAL): 1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following

Refueling Cavity water level <23 ft above the Reactor Flange (< 423 ft. indicated level)OR* Spent Fuel Pool water level < 23 ft. above the fuel (<422 ft 9 in indicated level)OR" Indication or report of a drop in water level in the REFUELING PATHWAY.AND b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitor in Table RI.E No Change EI Difference FI Deviation 1 ) Listed site-specific level indication and monitors to ensure timely classification.

Table RI Fuel Handling Incident Radiation Monitors* Fuel Building Fuel Handling Incident Monitor ORE-AR055* Fuel Building Fuel Handling Incident Monitor ORE-ARO56* Containment Fuel Handling Incident Monitor 1/2RE-AR01 1* Containment Fuel Handling Incident Monitor 1/2RE-AR012 Page 8 of 66 NEI 99-01 Rev 6 Proposed EAL Justification AA3 Initiating Condition

-ALERT Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2)Note: 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. Dose rate greater than 15 mR/hr in ANY of the following areas:* Control Room* Central Alarm Station* (other site-specific areas/rooms)

2. An UNPLANNED event results in radiation levels that prevent or significantly impede access to any of the following plant rooms or areas: (site-specific list of plant rooms or areas with entry-related mode applicability identified)

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 Levels (EAL): Note: If the equipment in the room or area listed in Table R3 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted 1. Dose rate greater than 15 mR/hr in ANY of the following areas: W No Change Gence De1 1) Listed site specific plant rooms and areas with identified mode applicability to ensure timely classification.

Table R2 Areas Requiring Continuous Occupancy* Main Control Room -1/2RE-ARO01" Central Alarm Station -(by survey)OR 2. An UNPLANNED event results in radiation levels that prohibit or significantly impede access to any of the following plant rooms or areas: Table R3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Auxiliary Building 426'VCT Valve Aisle Auxiliary Building 401'Curved Wall Area Penetration Area Auxiliary Building 383' Mode 4, 5, and 6 Remote Shutdown Panel Area Auxiliary Building 364'CV Pp areas Curved Wall Area Auxiliary Building 346'RH pump areas Page 9 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU3 Initiating Condition:

UNUSUAL EVENT Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: 1. (Site-specific radiation monitor) reading greater than (site-specific value).OR 2. Sample analysis indicates that a reactor coolant activity value is greater than an allowable limit specified in Technical Specifications.

RU3 Initiating Condition:

Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:

1,2,3,4 Emergency Action Levels (EAL): 1. Gross Failed Fuel Monitor 1/2RE-PRO06 (112 PS206- High Energy) indicating 1-135 concentration

> 5 pClI/cc.OR 2. Sample analysis indicates that: a. Dose Equivalent 1-131 specific coolant activity > 60.0 pCi/gm.OR b. Dose Equivalent XE-1 33 specific coolant activity > 603.0 pCI/gm.D No Change E Difference

[: Deviation 1) Listed site-specific monitor and threshold value to ensure timely classification.

2) Listed this system category EAL in the radiological category EAL section to 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 radiological category vice system category.Page 10 of 66 NEI 99-01 rev 6 Fission Product Barrier Matrix Fission_ _ _ _ _ _ _ _ _ _ Prdc Bare Matrix_ _ _HotMatrix_

GEEA EMREC IEAE MREC LR 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 Clad RC -Reactor Coolant System CT -Containment Sub-Category Loss Potential Loss Loss Potential Loss Loss Potential Loss 2. The capacity of one charging pump in the normal mode is eaceeded due to 1. An automatic or manual SI actuation the of the ing: Core Cooling CSF-Orange Path is required by EITHER of the EITHER of the following:

folloing:a.

UNISOLABLE RCS leakage 1following:

aUNSLBERSlkge A leaking or RUPTURED SG is 1.RCS or SG None conditions exist. OR None Tube Leakage a. UNISOLABLE RCS leakage FAULTED outside of containment.

TueLaaeOR

b. SG tube leakage.OR OR b. SG tube RUPTURE. O 3. RCS Integrity CFS-Red Path conditions exist 1. Core Cooling CSF-Red Path 2. Core Cooling CSF-Orange Path conditions exist. Heat Sink CSF-Red Path conditions Core Cooling CSF-Red Path conditions

2. Inadequate conditions exist. c None ext None exist.AND Functional Restoration Heat Removal 3. Heat Sink CSF-Red Path conditions exist. Procedures not effective in < 15 minutes.exist.1. Containment radiation monitor 3.RCS Activity/ (AR020(21))

reading > 1.95E+03 Containment radiation monitor 3.C ctvt/ R/hr. Containment radiation monitor (AR020(21))

Containment None (AR020(21))

reading None None reading > 4.40E+03 R/hr.Radiation OR2.. Coolant activity as sampled > 25 RJhr.> 300pCi/gm Dose Equivalent I-131.1.Containment isolation is required and EITHER of the following:

3. Containment CSF- Red Path conditions

a. UNPLANNED lowering in containment pressure or rise in exist.radiation monitor readings outside OR of containment in the Emergency

4. Hydrogen concentration inside 4.Containment Directors judgment indicate a loss containment

>5%.Integrity or None None None None of containment integrity.

OR Bypass OR 5. a. Containment pressure >20 psig.b. UNISOLABLE pathway from AND containment to the environment exists. b. Less than one full train of OR containment Spray is operating per design for _>15 minutes.2 Indication of RCS leakage outside of containment

5. Emergenc A. Any Condition in the opinion of A. Any Condition in the opinion of the A. ANY Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the Director the Emergency Director that Emergency Director that indicates Emergency Director that indicates Loss Emergency Director that indicates Emergency Director that indicates Loss Emergency Director that indicates Potential det ndicates Loss of the Fuel Clad Potential Loss of the Fuel Clad Barrier. of the RCS Barrier. Potential Loss of the RCS Barrier, of the Containment Barrier. Loss of the Containment Barrier.Judgment Barrier.Page 11 of 66 Proposed Fission Product Barrier Matrix Fission Product Barrier Matrix Hot Matrix GENERAL EMERGENCY SITE AREA EMERGENCY ALERT P01 Loss of any two barriers AND Loss or Potential Loss of third barrier.P0 B Si Loss or Potentiat Loss of ANY two barriers.ElEEi IR PAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 51h2IAR FC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Category Loss Potential Loss Loss Potential Loss Loss Potential Loss 2. The capacity of one charging pump in the normal mode is exceeded due to EITHER of the following:

1. An automatic or manual SI actuation is a. UNISOLABLE RCS leakage required by EITHER of the foilowing:

Core-Costing CSF -Orange Path OR 1. RCS or SG Tube None conditions exist. a. UNISOLABLE RCS leakage A leaking or RUPTURED SG is FAULTED None Leakage OR b. SG tube leakage. outside of containment.

OR b. SG tube RUPTURE.3. RCS Integrity CFS -Red path conditions exist.2. Core-Cooling CSF -Orange Path conditions exist. Core Cooling CSF-Red Path conditions exist 2. Inadequate Heat 1. Core-Cooling CSF -Red Path OR None Heat Sink CSF -Red Path conditions exist. None AND Functional Restoration Procedures not Removal conditions exist.efctein<5mues

3. Heat Sink CSF -Red Path conditions effective in <15 minutes.exist.1. Containment radiation monitor 3. Containment (AR020(21))

reading

1.95E-03 R/hr.3adings / RCS ORR Nor e Containment radiation monitor (AR020(21))

Containment radiation monitor(AR020(21))

Radiation I RCS OR None reading > 25 R/hir. Nose None reading a 4,4OEe03 R/hr, Activity 2. Coolant activity as sampled>300pCi/gm Dose Equivalent 1-131.1. Containment isolation is required and EITHER of the tollowing:

3. Containment CSF -Red path conditions

a. UNPLANNED lowering in exist.containment pressure or rise in radiation monitor readings outside OR of containment in the Emergency

4. Hydrogen concentration in Containment

> 5%.Directors judgment indicate a loss OR 4. Containment of containment integrity.

Integrity or Bypass None None None None OR5. a. Containment pressure > 20 psg.AND b. UNISOLABLE pathway from containment to the environment

b. Less than one full train of Containment exists. Spray is operating per design for >15 OR minutes.2. Indication of RCS leakage outside of containment

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 Judgment Emergency Director that indicates Loss Emergency Director that indicates Emergency Director that indicates Loss of Emergency Director that indicates Potential Emergency Director that indicates Loss of Director that indicates Potential Loss of the of the Fuel Clad Barrier. Potential Loss of the Fuel Clad Barrier. the RCS Barrier. Loss of the RCS Barrier. the Containment Barrier. Containment Barrier.Page 12 of 66 NEI 99-01 Rev 6 Proposed EAL Justification FC1 FC1 Category:

Fuel Clad Barrier RCS or SG tube leakage Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Potential Loss A. RCS/reactor vessel level less than (site-specific level).Category:

Fuel Clad Barrier RCS or SG tube leakage Operating Mode Applicability:

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

Potential Loss 1. Core-Cooling CSF -Orange Path conditions exist.-f-- No Change [: Difference

[: Deviation 1) Listed site-specific threshold value to ensure timely classification.

Page 13 of 66 NEI 99-01 Rev 6 [ Proposed EAL [ Justification FC2 Category:

Fuel Clad Barrier Inadequate Heat Removal Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Loss A. Core exit thermocouple readings greater than (site-specific temperature value).Potential Loss A. Core exit thermocouple readings greater than (site-specific temperature value).OR B. Inadequate RCS heat removal capability via steam generators as indicated by (site-specific indications).

FC2 Category:

Fuel Clad Barrier RCS Activity Operating Mode Applicability:

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

Loss 1. Core-Cooling CSF -Red Path conditions exist.Potential Loss 2. Core-Cooling CSF -Orange Path conditions exist.OR 3. Heat Sink CSF -Red Path conditions exist.No Change 1:1 Difference 1: Deviation 1) Listed site-specific threshold value to ensure timely classification.

Page 14 of66 NEI 99-01 Rev 6 Proposed EAL Justification FC3 Category:

Fuel Clad Barrier Containment Radiation I RCS Activity Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Loss A. Containment radiation monitor reading greater than (site-specific value).OR B. (Site-specific indications that reactor coolant activity is greater than 300 PCi/gm dose equivalent 1-131).FC3 Category:

Fuel Clad Barrier Containment Radiation

/ RCS Activity Operating Mode Applicability:

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

Loss 1. Containment radiation monitor (AR020(21))

reading > 1.95E+03 R/hr.OR 2. Coolant activity as sampled > 300pCl/gm Dose Equivalent 1-131.E No Change 1 Difference

[: Deviation 1) Listed site-specific monitor and threshold value to ensure timely classification.

Page 15 of 66 NEI 99-01 Rev 6 Proposed EAL [ Justification FC6 Category:

Fuel Clad Barrier Emergency Director Judgment Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

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

Fuel Clad Barrier Emergency Director Judgment Operating Mode Applicability:

1,2,3 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.5 E No Change 1 Difference 1 Deviation Page 16 of 66 NEI 99-01 Rev 6 Proposed EAL Justification RCI Category:

Reactor Coolant System Barrier RCS or SG Tube Leakage Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Loss A. An automatic or manual ECCS (SI) actuation is required by EITHER of the following:

1. UNISOLABLE RCS leakage OR 2. SG tube RUPTURE.Potential Loss A. Operation of a standby charging (makeup) pump is required by EITHER of the following:

1. UNISOLABLE RCS leakage OR 2. SG tube leakage.OR B. RCS cooldown rate greater than (site-specific pressurized thermal shock criteria/limits defined by site-specific indications).

RCl Category:

Reactor Coolant System Barrier RCS or SG Tube Leakage Operating Mode Applicability:

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

Loss 1. An automatic or manual Sl actuation is required by EITHER of the following:

a. UNISOLABLE RCS leakage OR b. SG tube RUPTURE.Potential Loss 2. The capacity of one charging pump in the normal charging mode is exceeded due to EITHER of the following:

a. UNISOLABLE RCS leakage OR b. SG tube leakage.OR 3. RCS Integrity CSF -Red path conditions exist.No Change 1 Difference 1-1 Deviation 1) Listed site-specific threshold value to ensure timely classification.

Page 17 of 66 NEI 99-01 Rev 6 Proposed EAL Justification NEI 99-01 Rev 6 Proposed EAL Justification RC2 Category:

Reactor Coolant System Barrier Inadequate Heat Removal Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Potential Loss A. Inadequate RCS heat removal capability via steam generators as indicated by (site-specific indications).

RC2 Category:

Reactor Coolant System Barrier Inadequate Heat Removal Operating Mode Applicability:

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

Potential Loss Heat Sink CSF -Red Path conditions exist.E No Change 1 Difference 1 Deviation 1) Listed site-specific threshold value to ensure timely classification.

Page 18 of 66 NEI 99-01 Rev 6 Proposed EAL Justification RC3 Category:

Reactor Coolant System Barrier Containment Radiation

/ RCS Activity Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Loss A. Containment radiation monitor reading greater than (site-specific value).RC3 Category:

Reactor Coolant System Barrier RCS Leak Rate Operating Mode Applicability:

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

Loss Containment radiation monitor (AR020(21))

reading > 25 R/hr.No Change 1:1 Difference 1 Deviation 1) Listed site-specific systems and threshold values to ensure timely classification.

Page 19 of 66 NEI 9941 Rev 6 Proposed EAL Justification NEI 99-01 Rev 6 Proposed EAL Justification RC6 Category:

Reactor Coolant System Barrier Emergency Director Judgment Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.RC5 Category:

Reactor Coolant System Barrier Emergency director Judgment Operating Mode Applicability:

1,2,3 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.No Change E Difference 1 Deviation Page 20 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CT1 CT1 Category:

Containment Barrier RCS or SG Tube Leakage Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Loss A. A leaking or RUPTURED SG is FAULTED outside of containment.

Category:

Containment Barrier RCS or SG Tube Leakage Operating Mode Applicability:

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

Loss A leaking or RUPTURED SG is FAULTED outside of containment.

E No Change 1 1 Difference

[: Deviation 1) Listed site-specific threshold values to ensure timely classification.

Page 21 of 66 NEI 99-01 Rev 6 1 Proposed EAL I Justification CT2 Category:

Containment Barrier Inadequate Heat Removal Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

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

AND 2. Restoration procedure not effective within 15 minutes.CT2 Category:

Containment Barrier Inadequate Heat Removal Operating Mode Applicability:

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

Potential Loss Core-Cooling CSF Red Path conditions exist AND Functional Restoration procedures not effective in < 15 minutes No Change 1 Difference 1-- Deviation 1) Listed site-specific threshold values to ensure timely classification.

Page 22 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification CT3 Category:

Containment Barrier Containment Radiation

/ RCS Activity Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Potential Loss A. Containment radiation monitor reading greater than (site-specific value).CT3 Category:

Containment Barrier Containment Radiation

/ RCS Activity Operating Mode Applicability:

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

Potential Loss Containment radiation monitor (AR020(21))

reading > 4.40E+03 R/hr.No Change [: Difference F: Deviation 1) Listed site-specific threshold values to ensure timely classification.

Page 23 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification CT4 Category:

Containment Barrier Containment Integrity or Bypass Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Loss A. Containment isolation is required AND EITHER of the following:

1. Containment integrity has been lost based on Emergency Director judgment.OR 2. UNISOLABLE pathway from the containment to the environment exists.OR B. Indications of RCS leakage outside of containment.

Potential Loss A. Containment pressure greater than (site-specific value)OR B. Explosive mixture exists inside containment OR C. 1. Containment pressure greater than (site-specific pressure setpoint)AND 2. Less than one full train of (site-specific system or equipment) is operating per design for 15 minutes or longer.CT4 Category:

Containment Barrier Containment Integrity or Bypass Operating Mode Applicability:

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

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

a. UNPLANNED lowering in containment pressure or rise in radiation monitor readings outside of containment in the Emergency Director judgment indicate a loss of containment integrity.

OR b. UNISOLABLE pathway from containment to the environment exists.OR 2. Indication of RCS leakage outside of containment Potential Loss 3. Containment CSF -Red path conditions exist.OR 4. Hydrogen concentration in Containment

> 5%.OR 5. a. Containment pressure > 20 psig.AND b. Less than one full train of Containment Spray is operating per design for >15 minutes.W No Change [ j Difference 1 Deviation 1) Listed site-specific monitor and threshold value to ensure timely classification.

Page 24 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CT6 Category:

Containment Barrier Emergency director Judgment Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.CT5 Category:

Containment Barrier Emergency Director Judgment Operating Mode Applicability:

1,2,3 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.E No Change 1 Difference 1 Deviation Page 25 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification SG1 Initiating Condition:

GENERAL EMERGENCY Prolonged loss of all offsite and all onsite AC power to emergency buses.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the General Emergency promptly upon determining that (site-specific hours) has been exceeded, or will likely be exceeded.1 a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses).AND b. EITHER of the following:

Restoration of at least one emergency bus in less than (site-specific hours) is not likely.* (Site-specific indication of an inability to adequately remove heat from the core)MG1 Initiating Condition:

Prolonged loss of all offsite and all onsite AC power to emergency buses.Operating Mode Applicability:

1,2,3,4 Emergency Action Levels (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 unit ESF buses.AND 2. Failure of DG 1A(2A) and DG 1B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3 EITHER of the following:

Restoration of at least one unit ESF bus in < 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is not likely.OR* Core Cooling CFS -Red Path conditions exist F No Change I Difference

--1 Deviation 1) Listed site specific equipment, site specific time based on station blackout coping analysis, and site specific indication to ensure timely classification.

Page 26 of 66 NEI 99-01 Rev 6 J Proposed EAL Justification SS1 Initiating Condition:

SITE AREA EMERGENCY Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes 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.MS1 Initiating Condition:

Loss of all offsite and onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2, 3,4 Emergency Action Levels (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 unit ESF buses.AND 2. Failure of DG 1A(2A) and DG 1B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3. Failure to restore power to at lease one unit ESF bus in< 115 minutes from the time of loss of both offsite and onsite AC power.Wq No Change FIDifference 1-] Deviation 1) Listed site specific equipment to ensure timely classification.

Page 27 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA1I Initiating Condition:

ALERT Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.1. a. AC power capability to (site-specific emergency buses) is reduced to a single power source for 15 minutes or longer.AND b. Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS.MAI 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 Levels (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 unit ESF buses reduced to only one of the following power sources for > 15 minutes.* Affected unit SAT 142-1(242-1)

Affected unit SAT 142-2(242-2)

Emergency Diesel Generator DG 1A(2A)* Emergency Diesel Generator DG 18(28)* Unit crosstie breakers AND 2. Any additional single power source failure will result in a loss of ALL AC power to SAFEY SYSTEMS.F] No Change F IDifference I Deviation 1) Listed site specific equipment to ensure timely classification.

Page 28 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Sul Initiating Condition:

UNUSUAL EVENT Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes 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 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 Levels (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 unit ESF buses for > 15 minutes F]1 No Change [-- Difference 1 Deviation 1) Listed site specific equipment to ensure timely classification.

Page 29 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SG8 Initiating Condition:

GENERAL EMERGENCY Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the General Emergency promptly upon determining that 15 minutes 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.AND Indicated voltage is less than (site-specific bus voltage value) on ALL (site-specific vital DC buses) for 15 minutes or longer.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 Levels (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 unit ESF buses.AND 2. Failure of DG 1A(2A) and DG 1 B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3. Voltage is 4 108 VDC on unit 125 VDC battery buses 111(211) and 112(212).AND 4. All AC and Vital DC power sources have been lost for > 15 minutes.D -No Change MI- Difference FIDeviation

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

2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.Page 30 of 66 NE199-O1 Rev6 Proposed EAL Justification NEI 99-01 Rev 6 Proposed EAL Justification SS8 Initiating Condition:

SITE AREA EMERGENCY Loss of all Vital DC power for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes 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.MS2 Initiating Condition:

Loss of all Vital DC power for 15 minutes or longer.Operating Mode Applicability:

1,2,3,4 Emergency Action Levels (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 < 108 VDC on unit 125 VDC battery buses 111(211) and 112(212) for >15 minutes.D No Change FX] Difference

[- Deviation 1) Listed site specific equipment and site specific value to ensure timely classification.

2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.Page 31 of 66 NEI 99-01 Rev 6 j Proposed EAL I Justification SS5 Initiating Condition:

SITE AREA EMERGENCY Inability to shutdown the reactor causing a challenge to (core cooling [PWR] / RPV water level [BWR]) or RCS heat removal.Operating Mode Applicability:

Power Operation Example Emergency Action Levels: 1. a. An automatic (trip [PWR] / scram [BWRJ) did not shutdown the reactor.AND b. All manual actions to shutdown the reactor have been unsuccessful.

AND c. EITHER of the following conditions exist: 1. (Site-specific indication of an inability to adequately remove heat from the core)OR 2. (Site-specific indication of an inability to adequately remove heat from the RCS)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 Levels (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. Core Cooling CSF-RED Path conditions exist.OR b. Heat Sink CSF-RED Path conditions exist.F No Change WIDifference F Deviation 1) Listed site specific indications to ensure timely classification.

2) Mode 2 included in operating mode applicability as per developer notes.Page 32 of 66 NEI 99-01 Rev 6 ] Proposed EAL Justification SA5 Initiating Condition:

ALERT Automatic or manual (trip [PWR] / scram [BWRJ) 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:

Power Operation Example Emergency Action Levels: 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. An automatic (trip [PWR]/ scram [BWR]) did not shutdown the reactor.AND b. Manual action taken at the reactor control consoles are not successful in shutting down the reactor.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 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 driving in control rods or implementation of boron injection strategies.

1. Automatic or manual Trip did not shutdown the reactor as indicated by Reactor Power > 5%.AND 2. Manual actions taken at the Main Control Board are not successful in shutting down the reactor as indicated by Reactor Power > 5%.D No Change FIDifference FIDeviation

1) Listed site specific indications to ensure timely classification.

2) Mode 2 included in operating mode applicability as per developer notes.Page 33 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU5 Initiating Condition:

UNUSUAL EVENT Automatic or manual (trip [PWRJ / scram [BWR]) fails to shutdown the reactor.Operating Mode Applicability:

Power Operation Example Emergency Action Levels: (1 or 2)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. An automatic (trip [PWR] / scram [BWR]) did not shutdown the reactor.AND b. A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.2. a. A manual trip ([PWRJ / scram [BWRI) did not shutdown the reactor.AND 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 [PWR] / scram [BWR]) is successful in shutting down the reactor.MU3 Initiating Condition:

Automatic or manual trip fails to shutdown the reactor.Operating Mode Applicability:

D- No Change Difference Deviation 1 ) Listed site specific indications to ensure timely classification.

2) Mode 2 included in operating mode applicability as per developer notes.1,2 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 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 Main Control Board 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. EITHER of the following:

1. Subsequent manual action taken at the Main Control Board is successful in shutting down the reactor.OR 2. Subsequent Automatic Trip is successful in shutting down the reactor.Page 34 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SAZ Initiating Condition:

ALERT UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Alert promptly upon determining that 15 minutes has been exceeded.

or will likely be exceeded.1. a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.[see table below][BWR parameter list] [PWR parameter list]Reactor Power Reactor Power RPV Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In Core/Core Exit Temperature Suppression Pool Level Levels in at least (site specific number)steam generators Suppression Pool Temperature Steam Generator Auxiliary or Emergency Feed Water Flow AND b. Any of the following transient events in progress.* Automatic or Manual runback greater than 25% thermal reactor power* Electrical load rejection greater than 25% full electrical load* Reactor Scram [BWR] / trip [PWR]* ECCS (SI) actuation* Thermal power oscillations greater than 10% (BWR]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 Levels (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 An UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes.No Change D Difference F Deviation 1) Listed site specific number of steam generators to ensure timely classification.

Table M1 -Control Room Parameters

Reactor Power* PZR Level* RCS Pressure* In Core/Core Exit Temperature

Narrow Range level in at least one Steam Generator* Steam generator Auxiliary 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 Tdp* Safety Injection Actuation Page 35 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU2 Initiating Condition:

UNUSUAL EVENT UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.[see table below]MU4 Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:

1,2,3,4 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.An UNPLANNED event results in the inability to monitor ANY Table Ml parameters from within the Control Room for > 15 minutes.F1 No Change 1 Difference 1 Deviation 1) Listed site specific number of steam generators to ensure timely classification.

[ BWR parameter list] [ PWR parameter list]Reactor Power Reactor Power RPV Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In Core/Core Exit Temperature nPool Level Levels in at least (site specific Suppression Pnumber) steam generators Steam Generator Auxiliary or Suppression Pool Temperature Emergency Feed Water Flow Table M1 -Control Room Parameters" Reactor Power" PZR Level" RCS Pressure* In Core/Core Exit Temperature

Narrow Range level in at least one Steam Generator Steam generator Auxiliary Feed Water Flow Page 36 of 66 NEI 99-01 Rev 6 Proposed EAL Justification 5A9 Initiating Condition:

ALERT Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: 1. a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* (site-specific hazards)* Other events with similar hazard characteristics as determined by the Shift Manager AND b. EITHER of the following:

1. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.OR 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.MA5 Initiating Condition:

ALERT Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Emergency Action Levels (EAL): Note: 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.'-- No Change M Difference D- Deviation 1) No additional site specific hazard noted 2) Changed the word "needed" to "required" in the IC and to "required by Technical Specification" in the EAL, to be consistent with terminology used by operators and minimize confusion.

3) Added additional not to easily direct the operator to lesser ICs Page 37 of166 NEI 99-01 Rev 6 Proposed EAL Justification SU4 Initiating Condition:

UNUSUAL EVENT RCS leakage for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage greater than (site-specific value) for 15 minutes or longer.2. RCS identified leakage greater than (site-specific value) for 15 minutes or longer 3. Leakage from the RCS to a location outside containment greater than 25 gpm for 15 minutes or longer MU6 Initiating Condition:

RCS leakage for 15 minutes or longer.Operating Mode Applicability:

1,2,3,4 Emergency Action Levels (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 IX No Change E-- Difference FI Deviation 1) Listed site specific values to ensure timely classification.

Page 38 of 66 NEI 99-01 Rev 6 Proposed EAL ] Justification SU6 Initiating Condition:

UNUSUAL EVENT Loss of all onsite or offsite communications capabilities Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods: (site-specific list of communications method 2. Loss of ALL of the following ORO communications s) methods: (site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods: (site-specific list of communications methods)MU7 Initiating Condition:

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

1,2,3,4 Emergency Action Levels (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.

W No Change E Difference

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

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 SU7 Initiating Condition:

UNUSUAL EVENT Failure to isolate containment or loss of containment pressure control. [PWR]Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: (1 or 2)1. a. Failure of containment to isolate when required by an actuation signal.AND b. ALL required penetrations are not closed within 15 minutes of the actuation signal.2. a. Containment pressure greater than (site-specific pressure).

AND b. Less than one full train of (site-specific system or equipment) is operating per design for 15 minutes or longer.MU8 Initiating Condition:

Failure to isolate containment or loss of containment pressure control.Operating Mode Applicability:

1,2,3,4 Emergency Action Levels (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. Containment pressure > 20 psig.AND b. Less than one full train of Containment Spray is operating per design for_> 15 minutes.H1 No Change F -] Difference FIDeviation

1) Listed site specific indications to ensure timely classification.

2) Reworded EAL 1.b to be a positive statement Page 40 of 66 NEI 99-01 Rev 6 Proposed EAL f Justification CA2 Initiating Condition:

ALERT Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Cold Shutdown, Refueling, Defueled Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes 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.CAI Initiating Condition:

Loss of all offsite and onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:

5,6, D Emergency Action Levels (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 off-site AC power to unit ESF buses.AND 2. Failure of DG 1A(2A) and DG 1B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3. Failure to restore power to at least one unit ESF bus in < 15 minutes from the time of loss of both offsite and onsite AC power.No Change E Difference

[ Deviation 1) Listed site specific equipment to ensure timely classification.

Page 41 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU2 Initiating Condition:

UNUSUAL EVENT Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Cold Shutdown, Refueling, Defueled Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.1. a. AC power capability to (site-specific emergency buses) is reduced to a single power source for 15 minutes or longer.AND b. Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS.Cut 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 Levels (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 unit ESF buses reduced to only one of the following power sources for > 15 minutes.* Affected unit SAT 142-1(242-1)

Affected unit SAT 142-2(242-2)

Emergency Diesel Generator DG 1A(2A)* Emergency Diesel Generator DG 1B(2B)* Unit crosstie breakers AND 2. Any additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.E No Change 1: Difference 1 Deviation 1) Listed site specific equipment to ensure timely classification.

Page 42 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CA6 Initiating Condition

-ALERT Hazardous event affecting SAFETY SYSTEM needed for the current operating mode.Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: 1. a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)" Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* (site-specific hazards)* Other events with similar hazard characteristics as determined by the Shift Manager AND b. EITHER of the following:

1. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.OR 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.CA2 Initiating Condition:

Hazardous event affecting SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:

5,6 Emergency Action Levels (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.1 No Change E Difference Deviation 1) No additional site specific hazard noted 2) Changed the word "needed" to "required" in the IC and to "required by Technical Specification" in the EAL, to be consistent with terminology used by operators and minimize confusion.

3) Added additional not to easily direct the operator to lesser ICs Page 43 of 66 NEI 99-01 Rev 6 1Proposed EAL Justification CU4 Initiating Condition:

UNUSUAL EVENT Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.Indicated voltage is less than (site-specific bus voltage value) on required Vital DC buses for 15 minutes or longer.CU3 Initiating Condition:

Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:

5, 6 Emergency Action Levels (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 < 108 VDC on required unit 125 VDC battery buses 111(211) and 112(212) for > 15 minutes.D No Change f Difference 1 Deviation 1) Listed site specific voltage and equipment to ensure timely classification.

2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.Page 44 of 66 NEI 99-01 Rev 6 Proposed EAL J ustification C Initiating Condition:

UNUSUAL EVENT Loss of all onsite or offsite communications capabilities Operating Mode Applicability:

Cold Shutdown, Refueling, Defuled Example Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods: (site-specific list of communications method 2. Loss of ALL of the following ORO communications s) methods: (site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods: (site-specific list of communications methods)~U5 CU4 Initiating Condition:

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

5,6, D Emergency Action Levels (EAL): 1. Loss of ALL Table C1 Onsite communications capability affecting the ability to perform routine operations.

OR 2. Loss of ALL Table Cl Offsite communication capability affecting the ability to perform offsite notifications.

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

M No Change 1 Difference 1 1 Deviation 1) Listed site specific communications methods to ensure timely classification Table C1 -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 j Proposed EAL f Justification CA3 Initiating Condition:

ALERT Inability to maintain the plant in cold shutdown.Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Alert promptly upon determining that the applicable has been exceeded, or will likely be exceeded.1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit) for greater than the duration specified in the following table.2. UNPLANNED RCS pressure increase greater than (site-specific pressure reading). (This EAL does not apply during water-solid plant conditions.

[PWR])CA5 Initiating Condition:

Inability to maintain plant in cold shutdown.Operating Mode Applicability:

5, 6 Emergency Action Levels (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 0 F for > Table C2 duration.OR 2. UNPLANNED RCS pressure rise > 10 psig as a result of temperature rise. (This EAL does not apply during water- solid plant conditions.)

H No Change i -Difference 1 Deviation 1) Listed site specific Technical Specification cold shutdown temperature limit to ensure timely classification.

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

3) Added wording relating the temp and press rise to a loss of decay heat removal capability as per the developer notes for PWR's 4) Added the following note, taken from the basis section of the EAL, to bring it to the attention of the SM/ED when using the "procedure matrix" (11 x17 quick reference control room document) "A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification." Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up Duration Status Intact (but not RCS Reduced Not Applicable 60 minutes*Inventory

[PWR])Not Intact (or at Established 20 minutes*reduced inventory[PWR]) Not Established 0 minutes* If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.

Table C2 -RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up Duration Status Intact Not Applicable 60 minutes*Not Intact Established 20 minutes*OR Reduced Inventory Not Established 0 minutes (<397 ft.) I"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.

Page 46 of 66 NEI 99-01 Rev 6 J Proposed EAL Justification CU3 Initiating Condition:

UNUSUAL EVENT UNPLANNED increase in RCS temperature.

Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit).2. Loss of ALL RCS temperature and (reactor vessel/RCS

[PWR] or RPV[BWR]) level indication for 15 minutes or longer.CU5 Initiating Condition:

UNPLANNED rise in RCS temperature.

Operating Mode Applicability:

5,16 Emergency Action Levels (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

> 2001F.OR 2. Loss of the following for > 15 minutes.* ALL RCS temperature indications AND* ALL RPV level indications H No Change W Difference 1 Deviation 1) Listed site specific Technical Specification cold shutdown temperature limit to ensure timely classification.

2) Changed the word increase to rise in the initiating condition to be consistent with operations language and training.3) Added the following note, taken from the basis section of the EAL, to bring it to the attention of the SM/ED when using the "procedure matrix" (1 1x17 quick reference control room document) "A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification." Page 47 of 66 NEI 99-01 Rev 6 Proposed EAL j Justification CGI Initiating Condition:

GENERAL EMERGENCY Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory affecting fuel clad integrity with containment challenged.

Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptly upon determining that 30 minutes time has been exceeded, or will likely be exceeded.1. a. (Reactor vessel/RCS

[PWR] or RPV [SWRI) vessel level less than (site-specific level) for 30 minutes or longer.AND b. ANY indication from the Containment Challenge Table 2. a.. (Reactor vessel/RCS

[PWR] or RPV [BWRJ) vessel level cannot be monitored for 30 minutes or longer.AND b. Core uncovery is indicated by ANY of the following:

(Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication

[PWR]* UNPLANNED increase in (site-specific sump and/or tank levels) of sufficient magnitude to indicate core uncovery* (Other site-specific indications)

AND c. ANY indication from the Containment Challenge Table).Initiating Condition:

CG6 Loss of reactor vessel / RCS inventory affecting fuel clad integrity with containment challenged.

Operating Mode Applicability:

5,6 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event prompdy upon determining that the applicable time has been exceeded, or will likely be exceeded.1. a. RVLIS indicates 0% Plenum for>30 minutes.OR Reactor Vessel Refueling Level Indicators LT-046 and LT-049 < 392 ft. el. for> 30 minutes.AND b. ANY Containment Challenge Indication (Table C4)OR 2. a. Reactor vessel / RCS level cannot be monitored for > 30 minutes.AND b. Core uncovery is indicated by ANY of the following:

Table C3 indications.

OR* Erratic Source Range Neutron Monitor indication.

OR* 1/2 RE-AR01 1 or 1/2 RE-AR12 Containment Fuel Handling Incident radiation monitors> 3000 mR/hr.AND c. Any Containment Challenge Indication (Table C4)H No Change f Difference 1 Deviation 1) Listed site specific values for level, developer notes indicate the level to be approximately Top of Active Fuel. The min indicated level of the transmitters LT-046 and 049 is 392 ft el. A level of 392 ft el along with RVLIS indicating 0%is being used as the lowest readable level .And allows for an escalation from CS6.2) Listed site specific levels, radiation monitors, and sumps and tanks to ensure timely classification.

3) Listed Explosive mixture in the Containment Challenge Table to ensure timely classification.

Table: Containment Challenge Table* CONTAINMENT CLOSURE not established*

(Explosive mixture) exists inside containment

UNPLANNED increase in containment pressure* Secondary containment radiation monitor reading above (site-specific value) [BWR]* if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not recuired.Table C3 Indications of RCS Leakage* UNPLANNED Containment Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED Tank 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.

Table C4 -Containment Challenge Indications

Hydrogen Concentration in Containment

> 5%* 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 Proposed EAL [Justification CS1 Initiating Condition:

SITE AREA EMERGENCY Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory affecting core decay heat removal capability.

Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Unusual Event promptly upon determining that 30 minutes time has been exceeded, or will likely be exceeded.1. a. CONTAINMENT CLOSURE not established.

AND b. (Reactor vessel/RCS

[PWRJ or RPV [BWR]) level less than (site-specific level).2. a. CONTAINMENT CLOSURE established.

AND b. (Reactor vessel/RCS

[PWRJ or RPV [BWRJ) level less than (site-specific level).3. a. (Reactor vessel/RCS

[PWR] or RPV [BWR]) level cannot be monitored for 30 minutes or longer.AND b. Core uncovery is indicated by ANY of the following:

(Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication

[PWRJ* UNPLANNED increase in (site-specific sump and/or tank levels) of sufficient magnitude to indicate core uncovery* (Other site-specific indications)

CS6 Initiating Condition:

Loss of reactor vessel / RCS inventory affecting core decay heat removal capabilities.

Operating Mode Applicability:

5,6 Emergency Action Levels (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. With CONTAINMENT CLOSURE established EITHER: a. RVLIS indicates 0% Plenum OR b. Reactor Vessel Refueling Level Indicators LT-046 and LT-049 <392 ft el.OR 2. With CONTAINMENT CLOSURE not established EITHER: a. RVLIS < 15% Plenum.OR b. Reactor Vessel Refueling Level Indicators LT-046 and LT-049 <393 ft. el.OR 3. a. Reactor vessel / RCS level cannot be monitored for >30 minutes.AND b. Core uncovery is indicated by any of the following:

Table C3 indications.

OR* Erratic Source Range Neutron Monitor indication.

OR* 1/2 RE-AR011 or 1/2 RE-AR12 Containment Fuel Handling Incident radiation monitors > 3000 mR/hr.H: No Change W Difference 1 Deviation 1) Listed site specific values for level, developer notes indicate the level to be approximately Top of Active Fuel. The min indicated level of the transmitters LT-046 and 049 is 392 ft el. A level of 392 ft el along with RVLIS indicating 0%is being used as the lowest readable level. And allows for an escalation from CA6.2) For Containment closure not established developer notes indicate the level to be 6" below the bottom ID of the RCS loop where it enters the vessel. This level is 391.9' and is below the min indicated level of the transmitters LT-046 and 049, which is 392 ft el. a level of 393 ft el. was chosen as well as < 15%Plenum ( the bottom of the hot leg) this is within the indicated range of the instrument, it also represents a substantial degradation of the condition from the CA6 level criteria and allows for escalation to CG6 as well as lowing for a Containment closure established level, 3) Listed site specific radiation monitors to ensure timely classification

4) Listed site specific sumps and tanks to ensure timely classification Table C3 Indications of RCS Leakage* UNPLANNED Containment Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED Tank (rad waste) 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 49 of 66 NEI 99-01 Rev 6 [Proposed EAL [Justification CAI Initiating Condition:

ALERT Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.1. Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory as indicated by level less than (site-specific level).2. a. (Reactor vessel/RCS

[PWR] or RPV [BWR]) level cannot be monitored for 15 minutes or longer AND b. UNPLANNED increase in (site-specific sump and/or tank) levels due to a loss of (reactor vessel/RCS

[PWR] or RPV [BWRJ) inventory.

CA6 Initiating Condition:

Loss of reactor vessel / RCS inventory Operating Mode Applicability:

5, 6 Emergency Action Levels (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. Loss of reactor vessel / RCS inventory as indicated RVLIS <37% Plenum.OR b. Loss of reactor vessel / RSC inventory as indicated by LT-046 and LT-049 < 393.5 ft. el.OR 2. a. Reactor vessel / RCS level cannot be monitored for > 15 minutes.AND b. Loss of reactor vessel / RCS inventory per Table C3 indications.

F No Change W Difference 1 Deviation 1) Listed site specific levels to ensure timely classification.

The developer notes indicate the levels to correspond to the level required to support RHR pump operation, lAW BOA PRI-10 (LOSS OF RH COOLING) RCS levels of > 37% or 393.5' on LT-046 and LT -049 as necessary to maintain RH pumps operating at reduced inventory conditions.

These levels were chosen to be consistent with the developer notes and the site abnormal operating procedures.

2) Listed site specific sumps and tanks to ensure timely classification.

Table C3 Indications of RCS Leakage* UNPLANNED Containment Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED Tank (rad waste) 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 NEI 99-01 Rev 6 [Proposed EAL Justification Cul Initiating Condition:

UNUSUAL EVENT UNPLANNED loss of (reactor vessel/RCS

[PWR] or RPV [BWRJ) inventory for 15 minutes or longer.Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. UNPLANNED loss of reactor coolant results in (reactor vessel/RCS

[PWRJ or RPV [BWR]) level less than a required lower limit for 15 minutes or longer.2. a. (Reactor vessel/RCS

[PWR] or RPV [BWR]) level cannot be monitored.

AND b. UNPLANNED increase in (site-specific sump and/or tank) levels.CU6 Initiating Condition:

UNPLANNED loss of reactor vessel / RCS inventory for 15 minutes or longer.Operating Mode Applicability:

5, 6 Emergency Action Levels (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 monitored.

AND b. Loss of reactor vessel / RCS inventory per Table C3 indications.

H No Change W Difference I: Deviation 1) Listed site specific sumps and tanks to ensure timely classification.

2) Described "a required lower limit" as a procedurally established lower limit, and listed site specific sumps and tanks to ensure timely classification.

Table C3 Indications of RCS Leakage* UNPLANNED Containment Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED Tank (rad waste) 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 51 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification HG1 Initiating Condition:

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

All Example Emergency Action Levels: 1. a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific security shift supervision).

AND b. EITHER of the following:

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

Reactivity control* Core cooling [PWR] / RPV water level [BWR]* RCS heat removal OR 2. Damage to spent fuel has occurred or is IMMINENT 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 Levels (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 HI safety function cannot be controlled or maintained.

OR b. Damage to spent fuel has occurred or is IMMINENT D No Change M Difference I Deviation 1) List site security shift supervision as Security Force.2) Added descriptors to better explain each safety function and allow for a timely classification.

Table H1 -Safety Functions" Reactivity Control (ability to shutdown the reactor and keep it shutdown)" Core Cooling (ability to cool the core)" RCS Heat Removal (ability to maintain a heatsink)Page 52 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HSI Initiating Condition:

SITE AREA EMERGENCY HOSTILE ACTION within the Protected Area.Operating Mode Applicability:

All Example Emergency Action Levels: A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-security shift supervision).

HS1 Initiating Condition:

HOSTILE ACTION within the Protected Area.Operating Mode Applicability:

1,2, 3,4, 5, 6, D Emergency Action Levels (EAL): A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.F-xl No Change D Difference F-1 Deviation 1) List site security shift supervision as Security Force.Page 53 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HA1 Initiating Condition:

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

All Example Emergency Action Levels: (1 or 2)1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the (site-specific security shift supervision).

2. A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.HAI 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 Levels (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.H -] No Change FIDifference FIDeviation

1) List site security shift supervision as Security Force.Page 54 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HU1 Initiating Condition:

UNUSUAL EVENT Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3)1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the (site-specific security shift supervision).

2. Notification of a credible security threat directed at the site.3. A validated notification from the NRC providing information of an aircraft threat.HU1 Initiating Condition:

Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:

1, 2, 3,4, 5, 6, D Emergency Action Levels (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.W No Change EIDifference F Deviation 1) List site security shift supervision as Security Force.2) Further described credible security threat through listing a site specific procedure.

Page 55 of 66 NEI 99-01 Rev 6 Proposed EAL J ustification HS6 Initiating Condition:

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

All Example Emergency Action Levels: (1 and 2)Note: The Emergency Director should declare the event promptly upon determining that (site-specific number of minutes) has been exceeded, or will likely be exceeded.1. An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown panels and local control stations).

2. Control of ANY of the following key safety functions is not reestablished within (site-specific number of minutes).Reactivity control* Core cooling [PWR] I RPV water level [BWR]* RCS heat removal 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 Levels (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 1/2BOA PRI-5, Control Room Inaccessibility.

AND 2. Control of ANY Table Hi key safety function is not reestablished in < 15 minutes.D No Change FIDifference F Deviation 1) EAL uses the site specific Control Room evacuation procedure to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedure the Control Room would enter should such an event occur, this allows for greater clarity as to when this EAL would apply than if each panel and station used in alternate shutdown were to be listed, 2) Added descriptors to better explain each safety function and allow for a timely classification.

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 room still manned, due to testing or equipment failure.Table HI -Safety Functions* Reactivity Control (ability to shutdown the reactor and keep it shutdown)* Core Cooling (ability to cool the core)" RCS Heat Removal (ability to maintain a heatsink)Page 56 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

ALERT HA6 HA2 D No Change P Difference F Deviation Initiating Condition:

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

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

Operating Mode Applicability:

All Example Emergency Action Levels: An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown panels and local control stations).

Operating Mode Applicability:

1, 2, 3,4, 5, 6,D Emergency Action Levels (EAL): A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per 1/2BOA PRI-5, Control Room Inaccessibility.

1) EAL uses the site specific Control Room evacuation procedure to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedure the Control Room would enter should such an event occur, this allows for greater clarity as to when this EAL would apply than if 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 partial plant control was transferred to outside the control room with the control room still manned, due to testing or equipment failure.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.Operating Mode Applicability:

Initiating Condition:

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

1,2, 3,4, 5, 6, D D No Change F- Difference

[- Deviation 1) Listed site specific list of plant rooms or areas that contain SAFETY SYSTEM equipment to ensure timely classification.

2) The site ISFSI is located within the Plant Protected Area and as such is not specifically addressed in EAL #3 and #4. This is in accordance with the EAL developer notes.3) Added additional note to easily direct the operator to escalation ICs All Example Emergency Action Levels: (1 or 2 or 3 or 4)Note: The Emergency Director should declare the Unusual Event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:

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

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

Field verification of a single fire alarm AND b. The FIRE is located within ANY of the following plant rooms or areas: (site-specific list of plant rooms or areas)2. a. Receipt of a single fire alarm (i.e., no other indications of a FIRE).AND b. The FIRE is located within ANY of the following plant rooms or areas: (site-specific list of plant rooms or areas)AND c. The existence of a FIRE is not verified within 30-minutes of alarm receipt.3. A FIRE within the plant or ISFS [for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.

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 offsite fire response agency to extinguish.

Emergency Action Levels (EAL): Note: 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. 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 Table H2 -Vital Areas* Containment

Auxiliary Building* Fuel Handling Building* Main Steam Tunnels* RWST's* Condensate Storage Tanks* Essential Service Water Cooling Towers 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.

Page 58 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HU2 Initiating Condition:

UNUSUAL EVENT Seismic event greater than OBE levels.Operating Mode Applicability:

All Example Emergency Action Levels: Seismic event greater than Operating Basis Earthquake (OBE) as indicated by: a. (site-specific indication that a seismic event met or exceeded OBE limits)HU4 Initiating Condition:

Seismic event greater than OBE levels.Operating Mode Applicability:

1, 2, 3, 4, 5, 6, D Emergency Action Levels (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 check at panel OPA02J.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.D ' No Change Difference Deviation 1) Listed site specific indication to determining OBE limits have been met or exceeded to ensure timely classification.

2) The seismic panel is located in the Auxiliary Electrical Equipment Room (AEER)which is adjacent to the Main Control Room (MCR) -There is one security card reader door between the AEER and MCR.There is an indicating light (OBE EXCEEDED) on front of OPA02J which illuminates when Operating Basis Earthquake has been exceeded.The approximate time required to get to this panel and provide the indication to the control room is as follows: Need to obtain a key for cabinet -2 minutes Walk back to the room -1 minute Get into the cabinet and look -1 minute Approximately 4 mins total 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 or repair using the guidance in the developer notes provided.4) Added additional compensatory thresholds based on the guidance provided in 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 limit to ensure timely classification when these additional thresholds may not be readily available.

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 will determine classification within 15 mins of the event Page 59 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HA5 HA5 Initiating Condition:

ALERT Initiating Condition:

D No Change F Difference I- Deviation Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

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

1 .a. Release of a toxic, corrosive, asphyxiant or flammable gas into any of the following plant rooms or areas: (site-specific list of plant rooms or areas with entry-related mode applicability identified)

AND b. Entry into the room or area is prohibited or impeded.Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

4,5,6 Emergency Action Levels (EAL): Note: 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 a Table H3 area.1) Listed plant specific rooms and areas with entry related mode applicability to ensure timely classification.

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 concern in Table H-3.Table H3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Auxiliary Building 426'VCT Valve Aisle Auxiliary Building 401'Curved Wall Area Penetration Area Auxiliary Building 383' Mode 4, 5, and 6 Remote Shutdown Panel Area Auxiliary Building 364'CV Pp areas Curved Wall Area Auxiliary Building 346'RH pump areas 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 Initiating Condition:

UNUSUAL EVENT Hazardous Event Operating Mode Applicability:

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

1. A tornado strike within the PROTECTED AREA.2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode.3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.5. (Site-specific list of natural or technological hazard events)HU6 Initiating Condition:

Hazardous Event Operating Mode Applicability:

1,2, 3,4, 5, 6, D Emergency Action Levels (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.-No Change Difference Deviation 1) No site specific list of natural or technological hazard events was noted.2) Changed the word "needed" to "required by Technical Specifications" in the EAL to be consistent with terminology used by operators and minimize confusion.

3) Added additional note to easily direct the operator to escalation ICs Page 61 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HG7 HG7 Initiating Condition:

GENERAL EMERGENCY Initiating Condition:

W No Change F 1Difference F- Deviation Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency.

Operating Mode Applicability:

All Example Emergency Action Levels: 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 off-site for more than the immediate site area.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 Levels (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 off-site for more than the immediate site area..Page 62 of 66 NEI 99-01 Rev 6 Proposed EAL ] Justification HS7 Initiating Condition:

SITE AREA EMERGENCY Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency.

Operating Mode Applicability:

All Example Emergency Action Levels: 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.HS7 M No Change EIDifference F Deviation 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 Levels (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.Page 63 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HA7 HA7 Initiating Condition:

ALERT Initiating Condition:

W-I No Change EIDifference 1 Deviation Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.Operating Mode Applicability:

All Example Emergency Action Levels: 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.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 Levels (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.Page 64 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HU7 Initiating Condition:

UNUSUAL EVENT Other conditions existing which in the judgment of the Emergency director warrant declaration of an UNUSUAL EVENT.Operating Mode Applicability:

All Example Emergency Action Levels: 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.HU7 Initiating Condition:

W No Change F 1Difference F Deviation Other conditions existing 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 Levels (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.Page 65 of 66 NEI 99-01 Rev 6 J Proposed EAL Justification E-HU1 Initiating Condition:

UNUSUAL EVENT Damage to a loaded cask CONFINEMENT BOUNDARY.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.E-HU1 Initiating Condition:

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

1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL): Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading:* > 60 mr/hr (gamma + neutron) on the top of the spent fuel cask OR* > 600 mr/hr (gamma + neutron) on the side of the spent fuel cask, excluding inlet and outlet ducts.W No Change I Difference FIDeviation

1) Listed 2x the site specific cask specific allowable radiation level as per the Certificate of Compliance No. 1014 Appendix A Section 5.7 Page 66 of 66 Bvron Annex Exelon Nuclear 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. The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PR030)> 9.99 E+09 pCi/sec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS -Total Noble Gas Release Rate).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 Month XXXX BY 3-33 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RGI (cont)Emergency Action Level (EAL) (cont): 3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >1000 mRem/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.

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-AA-1 12-500 Emergency Environmental Monitoring

3. EP-EAL-0602 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Byron Station Month XXXX BY 3-34 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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. The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PR030)> 9.99 E+08 pCi/sec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS -Total Noble Gas Release Rate).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 XXXX BY 3-35 EP-AA-1002 (Revision XX)

P renn Annoy I::v-,lrn No iul-azr z n~ vI~nknii~RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1 (cont)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-AA-1 12-500 Emergency Environmental Monitoring

3. EP-EAL-0602 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Byron Station Month XXXX BY 3-36 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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. The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PR030)> 9.99 E+07 pCi/sec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS -Total Noble Gas Release Rate).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 Month XXXX BY 3-37 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RA1 (cont)Emergency Action Level (EAL) (cont): OR 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.

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.This EAL includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit.Escalation of the emergency classification level would be via IC RS1.Month XXXX BY 3-38 EP-AA-1002 (Revision XX)

B-ron Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis Reference(s):

1. NEI 99-01 Rev 6, AA1 2. UFSAR Section 11.5.2.3 3. OBISR 11 .a.3-002, Channel Operation Test of Liquid Radwaste Effluent Radiation Monitor OPRO1J 4. ODCM, CY-BY-170-301, Section 3.0, Liquid Effluents 5. EP-EAL-0602 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Byron Station 6. EP-EAL-0619 Rev. 0, Byron Criteria for Choosing Radiological Liquid Effluents EAL Threshold Values.7. EP-EAL-0624 Rev. 0, Byron Criteria for Choosing Radiological Gaseous Effluents EAL Threshold Values for Waste Gas Decay Tanks Month XXXX BY 3-39 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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: 9 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 high alarm setpoint established by a current radioactive release discharge permit for > 60 minutes." OPROO1, Liquid Radwaste Effluent Monitor" OPROO2, Gas Decay Tank Effluent Monitor" OPRO10, Station Blowdown Monitor" 1/2PROO1, Containment Purge Effluent Monitor" Discharge Permit specified monitor OR 2. The sum of readings on the Unit 1 and 2 Aux Bldg Vent WRGMs (1/2 RE-R030)> 1.14 E+06 pCi/sec for > 60 minutes (as determined from Unit 1 & 2 PF430 or PPDS -Total Noble Gas Release Rate).OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of a 60 minutes.Month XXXX BY 3-40 EP-AA-1002 (Revision XX)

R ren Annov I~v--Inn Nl~g-lnr RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RUl (cont)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.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 RAI.Month XXXX BY 3-41 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RUl (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, AU1 2. UFSAR Section 11.5.2.3 3. OBISR 11 .a.3-002, Channel Operation Test of Liquid Radwaste Effluent Radiation Monitor 0PR01J 4. ODCM, CY-BY-170-301, Section 3.0, Liquid Effluents 5. EP-EAL-0602 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Byron Station Month XXXX BY 3-42 EP-AA-1002 (Revision XX)

Byron Annex Exel.on Nuclear 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 XXXX BY 3-43 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I 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 XXXX BY 3-44 EP-AA-1002 (Revision XX)

Rvron Annex ByronAnnexExelon Nuclear 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 R1 Radiation Monitor reading >1000 mRem/hr OR 3. Lowering of spent fuel pool level to (site specific Level 2 value).Table R1 Fuel Handling Incident Radiation Monitors" Fuel Building Fuel Handling Incident Monitor ORE-AR055" Fuel Building Fuel Handling Incident Monitor ORE-AR056* Containment Fuel Handling Incident Monitor 1/2RE-AR01 1* Containment Fuel Handling Incident Monitor 1/2RE-AR012 Basis: REFUELING irradiated fuel flange.PATHWAY: all the cavities, tubes, canals and pools through which may be moved or stored, but not including the reactor vessel below the 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.CONFINEMENT BOUNDARY:

The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.

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.This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1.Month XXXX BY 3-45 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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.Month XXXX BY 3-46 EP-AA-1002 (Revision XX)

I0ur~ An v PyI::Y nn N, .ran" A ""W^F~InM~rIa Basis 1.2.3.4.5.6.7.RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2 (cont)Reference(s):

NEI 99-01 Rev 6, AA2 UFSAR 11.5.2.2.6, 11.5.2.2.7, 15.7.4, Table 12.3-3 Technical Specification Table 3.3.6-1 1/2 BOA REFUEL-1 Fuel Handling Emergency Unit 1/2 1/2 BOA REFUEL-2 Refueling Cavity or Spent Fuel Pool Level Loss Unit 1/2 TRM 3.9.A, Refueling Operations, Decay Time BAR 1-1-A2, 2-1-A2, CNMT DRAIN LEAK DETECT FLOW HIGH alarm Month XXXX BY 3-47 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 as indicated by ANY of the following: , Refueling Cavity water level < 23 ft. above the Reactor Flange (< 423 ft.indicated level).OR* Spent Fuel Pool water level < 23 ft. above the fuel (< 422 ft. 9 in.indicated level).OR" Indication or report of a drop in water level in the REFUELING PATHWAY.AND b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R1.Table R1 -Fuel Handling Incident Radiation Monitors* Fuel Building Fuel Handling Incident Monitor ORE-AR055* Fuel Building Fuel Handling Incident Monitor ORE-AR056" Containment Fuel Handling Incident Monitor 1/2RE-AR01 1" Containment Fuel Handling Incident Monitor 1/2RE-AR012 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.Month XXXX BY 3-48 EP-AA-1002 (Revision XX)

Bvron AnnexN Bvron Annex Exellnn NucleI~ar RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU2 (cont)Basis (cont): 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.

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. Technical Specifications 3.7.14 3. 1/2 BOA REFUEL-1 Fuel Handling Emergency Unit 1/2 4. 1/2 BOA REFUEL-2 Refueling Cavity Or Spent Fuel Pool Level Loss Unit 1/2 5. BAR 1-1-Cl SPENT FUEL PIT LEVEL HIGH LOW 6. 1/2 BOSR 0.1-6 Unit One(Two) Mode 6 Shiftly and Daily Operating Surveillance

7. BOP RH-8 Filling the Refueling Cavity for Refueling 8. BOP RH-9 Pump Down of the Refueling Cavity to the RWST 9. BOP RC-4 Reactor Coolant System Drain 10. BAR 1-6-C3 REFUELING CAVITY LVL HIGH/LOW Month XXXX BY 3-49 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 R3 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 following Table R2 areas: Table R2 Areas Requiring Continuous Occupancy* Main Control Room- 1/2RE-AR010" Central Alarm Station -(by survey)OR-UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the following Table R3 plant rooms or areas: Table-R3 Areas with Entry Related Mode Appl., .-abilityJ AreaEntry Related Mod Appllab.A uxiliar" Build'Rg*

Mode 4, 5 and 6*Arcas required to establish shutdown cool_)ing Month XXXX BY 3-50 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear Byo ne xeo ula RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Table R3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Auxiliary Building 426'VCT Valve Aisle Auxiliary Building 401'Curved Wall Area Penetration Area Auxiliary Building 383' Mode 4, 5, and 6 Remote Shutdown Panel Area Auxiliary Building 364'CV Pp areas Curved Wall Area Auxiliary Building 346'RH pump areas Month XXXX BY 3-51 EP-AA-1002 (Revision XX)

Byron Annex I=xelon Nuclear B n Annex.....Exelon Nuc.lear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA3 (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 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 R3 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 procedure, 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 XXXX BY 3-52 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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. UFSAR Chapter 3.02, UFSAR Table 3.2-1 Month XXXX BY 3-53 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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. Gross Failed Fuel Monitor 1/2RE-PRO06 (1/2 PS206-High energy) indicating 1-135 concentration

> 5 pCi/cc.OR 2. Sample analysis indicates that: a. Dose Equivalent 1-131 specific coolant activity > 60.0 pCi/gm.OR b. Dose Equivalent XE-133 specific coolant activity>

603.0 pCi/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 Unusual E.Vent is only warranted when actual fuel clad damage is the cause of the l-vated GGolant , ample activity (as determined by lab.. ato-' confirmation).

Fuel clad damage should be assumed to be the cause of elevated Reactor Coolant activity unles 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. Technical Specifications 3.4.16 3. 1/2BOA PRI-4, High Reactor Coolant Activity Unit 1/2 4. PWR Letdown Rad Monitor Setpoint Calculation for Degraded Fuel Indication Month XXXX BY 3-54 EP-AA-1002 (Revision XX)

Bvrnn Ann#_x Bvrnn Annex EXPInn N"H~kanr 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 XXXX BY 3-55 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 XXXX BY 3-56 EP-AA-1 002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FAI 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 XXXX BY 3-57 EP-AA-1002 (Revision XX)

I:xelon Nuclear Bvron Annex Exelon NuceaIer RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FCl Initiating Condition:

RCS or SG Tube Leakage Operating Mode Applicability:

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

POTENTIAL LOSS 1. Core Cooling CSF-Orange Path conditions exist Basis: There is no Loss threshold associated with RCS or SG Tube Leakage.Potential Loss Threshold

1 Basis: Core Cooling -ORANGE indicates subcooling has been lost and that some clad damage may occur.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 2. 1/2 BFR-C.2 Response to Degraded Core Cooling Unit 1/2 Month XXXX BY 3-58 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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. Core-Cooling CSF- Red Path conditions exist.POTENTIAL LOSS 2. Core Cooling CSF-Orange Path conditions exist.OR 3. Heat Sink CSF- Red Path conditions exist.Basis: Loss Threshold

1 Basis This reading indicates temperatures within the core are sufficient to cause significant superheating of reactor coolant.Core Cooling -RED indicates significant superheating and core uncovery and is considered to indicate loss of the Fuel Clad Barrier.Potential Loss Threshold

2 Basis This reading indicates temperatures within the core are sufficient to allow the onset of heat-induced cladding damage.Core Cooling -ORANGE indicates subcooling has been lost and that some clad damage may occur.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. The Heat Sink Critical Safety Function Red path condition exists if narrow range levels in all steam generators (S/Gs)are less than or equal to 10% -Unit 1 (31% adverse containment) and 14% -Unit 2 (34% adverse containment) and total feedwater flow to all S/Gs is less than or equal to 500 gpm. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators by redlJCing total feed flow to less than 500 gpm; during these conditions, classification using this threshold is not warranted.

Meeting this threshold results in a Site Area Emergency because this threshold is identical to RCS Barrier RC 2 Potential Loss threshold; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal Month XXXX BY 3-59 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 (cont)Basis (cont): Meeting this threshold results in a Site Area Emergency because this threshold is identical to RCS Barrier RC 2 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 rise RCS pressure to the point where mass will be lost from the system.Heat Sink -RED when heat sink is required indicates the ultimate heat sink function is under extreme challenge.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 2. 1/2 BST-2 Core Cooling Unit 1/2 3. 1/2 BFR-C.1 Response to Inadequate Core Cooling Unit 1/2 4 1/2 BFR-C.2 Response to Degraded Core Cooling Unit 1/2 5. 1/2 BST-3 Heat Sink Unit 1/2 6. 1/2 BFR H.1, Response to Loss of Secondary Heat Sink Unit 1/2 Month XXXX BY 3-60 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 (AR020(21))

reading > 1.95E+03 R/hr.OR 2. Coolant activity as sampled > 300pCi/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 300pCi/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 PCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete.

Nonetheless, a sample-related threshold is included as a backup to other indications There is no Potential Loss threshold associated with RCS Activity / Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 2. S&L calculation BB-ER-02, Rev 0 3. Core Damage Assessment Methodology (CDAM)Month XXXX BY 3-61 EP-AA-1002 (Revision XX)

Rvrnn AnnexN Rvrnn Annex FYAlnn Nui~clar 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 XXXX BY 3-62 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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. Automatic or manual SI actuation is required by EITHER of the following:

a. UNISOLABLE RCS leakage OR b. Steam Generator tube RUPTURE.POTENTIAL LOSS 2. The capacity of one charging pump in the normal charging mode is exceeded due to EITHER of the following:

a. UNISOLABLE RCS leakage OR b. Steam Generator tube RUPTUREleakage.

OR 3. RCS Integrity CSF- Red Path conditions exist.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.

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 Month XXXX BY 3-63 EP-AA-1002 (Revision XX)

Exelon Nuclear Byron Annex........

Nuc. ea.RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION 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.

RCl (cont)Basis (cont): 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 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).

RCS Integrity

-RED indicates an extreme challenge to the safety function derived from appropriate instrument readings.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 2. NES-G-14.02, Calculation No. BYR99-010

/ BRW-99-0017-1

3. 1/2 BEP-0 Reactor Trip Or Safety Injection Unit 1/2 4. 1/2 BEP-3 Steam Generator Tube Rupture Unit 1/2 5. 1/2 BST-2 Core Cooling Unit 1/2 6. 1/2 BFR-C.1 Response to Inadequate Core Cooling Unit 1/2 7. NES-G-14.02, Calculation No. BYR99-010

/ BRW-99-0017-1

8. UFSAR Fig. 6.3-4 Month XXXX BY 3-64 EP-AA-1002 (Revision XX)

Byron Annex Bvron Annex Exelon Nucle~ar 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 Heat Sink CSF- Red Path conditions exist.Basis: There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold Basis Heat Sink -RED when heat sink is required indicates the ultimate heat sink function is under extreme challenge.

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. The Heat Sink Critical Safety Function Red path condition exists if narrow range levels in all steam generators (S/Gs) are less than or equal to 10% -Unit 1 (31% adverse containment) and 14% -Unit 2 (34%adverse containment) and total feedwater flow to all S/Gs is less than or equal to 500 gpm. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators by redpCing total feed flow to less than 500 gpm; during these conditions, classification using this 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 rise 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. 1/2 BST-3 Heat Sink Unit 1/2 Month XXXX BY 3-65 EP-AA-1002 (Revision XX)

Bvron AnnexNuclear ByronAnnexExelon Nucleamr 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 (AR020(21))

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 Potential Loss threshold associated with RCS Activity / Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month XXXX BY 3-66 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 XXXX BY 3-67 EP-AA-1002 (Revision XX) l3vron Annex I=xelon Nuclear ByronAnnexExelon Nuclea~r 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 A leaking or RUPTURED SG is FAULTED outside of containment.

Basis: 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.

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.b 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 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 XXXX BY 3-68 EP-AA-1002 (Revision XX)

.Bvron Annex ByronAnnexExelon Nuclear 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) do meet this threshold.

Following an SG tube leak or rupture, there may be minor radiological releases through a secondary-side system component (e.g., air ejectors, 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 The capacity of one charging pump in the Site Area Emergency Alert per FAl normal charging mode is per FS1 exceeded (RCS Barrier Potential Loss)Requires an automatic or Site Area Emergency Alert per FAl manual SI actuation (RCS per FS1 Barrier Loss)There is no Potential Loss threshold associated with RCS or SG Tube Leakage.Month XXXX BY 3-69 EP-AA-1002 (Revision XX)

Bvron Annex Exellon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT1 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 2. 1/2 BEP-0 Reactor Trip Or Safety Injection Unit 1/2 3. 1/2 BEP-3 Steam Generator Tube Rupture Unit 1/2 4. 1/2 BOA SEC-8 Steam Generator Tube Leak Unit 1/2 Month XXXX BY 3-70 EP-AA-1002 (Revision XX)

Byron Annex Bvron Annex Exelon Nuclear 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 Core-Cooling CSF- Red Path conditions exist AND Functional 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. 1/2 BST-2 Core Cooling Unit 1/2 3. 1/2 BFR-C.1 Response to Inadequate Core Cooling Unit 1/2 Month XXXX BY 3-71 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 (AR020(21))

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 XXXX BY 3-72 EP-AA-1002 (Revision XX)

Byron AnnexNuclear Bvrnn Annex Exelnn Nucler~I 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 EITHER of the following:

a. UNPLANNED lowering in containment pressure or rise in radiation monitor readings outside of containment in the Emergency Directors judgment indicate a loss of containment integrity.

OR b. UNISOLABLE pathway from containment to the environment exists.OR 2. Indication of RCS leakage outside of containment POTENTIAL LOSS 3. Containment CSF Red Path conditions exist.OR 4. Hydrogen Concentration in Containment

> 5%.OR 5. a. Containment pressure > 20 psig AND b. Less than one full train of Containment Spray is operating per design for>15 minutes.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.

UNISOLABLE:

An open or breached system line that cannot be isolated, remotely or locally.UNPLANNED:

A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.Month XXXX BY 3-73 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (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 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 1.a and 1.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 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.Month XXXX BY 3-74 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont)Basis (cont): 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 containment bypass sequence).

Rises 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, Month XXXX BY 3-75 EP-AA-1002 (Revision XX) 13vron Annex ByronAnnexExelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION flow rates, etc. should be sufficient to determine if RCS mass is being lost outside of the containment.

CT4 (cont)Basis (cont): 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 1.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 Containment CSF RED path indicates an extreme challenge to the safety function derived from appropriate instrument readings and/or sampling results, and thus represents a potential loss of containment.

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 XXXX BY 3-76 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 2. UFSAR Section 15.6.5.2.1

3. NES-G-14.02, Calculation No. BYR99-010

/ BRW-99-0017-1

4. Technical Specifications B 3.6.6, Containment Spray and Cooling Systems 5. 1/2BST-5 Containment Unit 1/2 Month XXXX BY 3-77 EP-AA-1002 (Revision XX)

Bvron Annex Byro Annex... .elon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Figure 3-F-1: PWR Containment Integrity or Bypass Examples* 1.b-Airborne release from* path.way RCP Seal Cooling Month XXXX BY 3-78 EP-AA-1002 (Revision XX)

Rvrnn AnnpxMI Bvrnn AnnexA Fvalnn NMiaiAr 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 XXXX BY 3-79 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG1 Initiating Condition:

Prolonged loss of all offsite and all onsite AC power to emergency buses.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 unit ESF buses.AND 2. Failure of DG 1A(2A) and DG 1 B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3. EITHER of the following:

a. Restoration of at least one unit ESF bus in < 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is not likely.OR b. Core Cooling CSF -Red Path conditions exist.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 XXXX BY 3-80 EP-AA-1002 (Revision XX)

Byron Annex Exelon Nuclear 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 emergency buses 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.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. 20E-0-4001 Station One Line Diagram 3. UFSAR 8.3.1 4. 1/2 BOA ELEC-3 Loss Of 4KV ESF Bus Unit 1/2 5. 1/2 BOA ELEC-4 Loss Of Offsite Power Unit 1/2 6. 1/2 BCA-0.0 Loss Of All AC Power Unit 1/2 7. 1/2 BCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/2 8. 1/2 BCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/2 9. 1/2 BCA-0.3 Response To Opposite Unit Loss Of All AC Power Unit 1/2 10. BOP AP-51, Isolating Unit 1 System AUX Transformer 142-1 & 142-2 While Unit Is At Power 11. BOP AP-52, Restoring Unit 1 System AUX Transformer 142-1 & 142-2 During Power Operation 12. BOP AP-53, Isolating Unit 2 System AUX Transformer 242-1 & 242-2 While Unit Is At Power 13. BOP AP-54, Restoring Unit 2 System AUX Transformer 242-1 & 242-2 During Power Operation 14. Safety Evaluations of the Byron Station and Byron Station Responses to the Station Blackout (SBO) Rule (TAC NOS. 68522, 68523 AND 68515, 68516)15. 1/2 BST-2 Core Cooling Unit 1/2 16. 1/2 BFR-C.1 Response to Inadequate Core Cooling Unit 1/2 17. 1/2 BFR-C.2 Response to Degraded Core Cooling Unit 1/2 Month XXXX BY 3-81 EP-AA-1 002 (Revision XX)

Byron Annex I-xelon Nuclear Bvron Annex Exelnn Nucler~I RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1 Initiating Condition:

Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL): Note: e 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 unit ESF buses.AND 2. Failure of DG 1A(2A) and DG 1B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3. Failure to restore power to at least one unit ESF 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.The emergency buses 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 power losses.Escalation of the emergency classification level would be via ICs RG1, FG1 or MG1.Month XXXX BY 3-82 EP-AA-1002 (Revision XX)

Byron Annex Exellon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, SS1 2. 20E-0-4001 Station One Line Diagram 3. UFSAR 8.3.1 4. 1/2 BOA ELEC-3 Loss Of 4KV ESF Bus Unit 1/2 5. 1/2 BOA ELEC-4 Loss Of Offsite Power Unit 1/2 6. 1/2 BCA-0.0 Loss Of All AC Power Unit 1/2 7. 1/2 BCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/2 8. 1/2 BCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/2 9. 1/2 BCA-0.3 Response To Opposite Unit Loss Of All AC Power Unit 1/2 10. BOP AP-51, Isolating Unit 1 System AUX Transformer 142-1 & 142-2 While Unit Is At Power 11. BOP AP-52, Restoring Unit 1 System AUX Transformer 142-1 & 142-2 During Power Operation 12. BOP AP-53, Isolating Unit 2 System AUX Transformer 242-1 & 242-2 While Unit Is At Power 13. BOP AP-54, Restoring Unit 2 System AUX Transformer 242-1 & 242-2 During Power Operation 14. Safety Evaluations of the Byron Station and Byron Station Responses to the Station Blackout (SBO) Rule (TAC NOS. 68522, 68523 AND 68515, 68516)Month XXXX BY 3-83 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 unit ESF buses reduced to only one of the following power sources for > 15 minutes.* Affected unit SAT 142-1(242-1)

Affected unit SAT 142-2(242-2)

Emergency Diesel Generator DG 1A(2A)* Emergency Diesel Generator DG 1 B(2B)* Unit crosstie breakers 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 MU1.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 XXXX BY 3-84 EP-AA-1002 (Revision XX)

Bvmn AnnexNuclear Bvrnn Annex Exelnn Nuc~lear 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. 20E-0-4001 Station One Line Diagram 3. UFSAR 8.3.1 4. 1/2 BOA ELEC-3 Loss Of 4KV ESF Bus Unit 1/2 5. 1/2 BOA ELEC-4 Loss Of Offsite Power Unit 1/2 6. 1/2 BCA-0.0 Loss Of All AC Power Unit 1/2 7. 1/2 BCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/2 8. 1/2 BCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/2 9. 1/2 BCA-0.3 Response To Opposite Unit Loss Of All AC Power Unit 1/2 10. BOP AP-51, Isolating Unit 1 System AUX Transformer 142-1 & 142-2 While Unit Is At Power 11. BOP AP-52, Restoring Unit 1 System AUX Transformer 142-1 & 142-2 During Power Operation 12. BOP AP-53, Isolating Unit 2 System AUX Transformer 242-1 & 242-2 While Unit Is At Power 13. BOP AP-54, Restoring Unit 2 System AUX Transformer 242-1 & 242-2 During Power Operation 14. Safety Evaluations of the Byron Station and Byron Station Responses to the Station Blackout (SBO) Rule (TAC NOS. 68522, 68523 AND 68515, 68516)Month XXXX BY 3-85 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 unit ESF buses 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. (e.g. unit cross-tie breakers)The emergency buses 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 MAl.Month XXXX BY 3-86 EP-AA-1002 (Revision XX)

Rvrnn AnnpxNuclear Rvrnn Annex Exelnn Nucleanr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU1 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, SU1 2. 20E-0-4001 Station One Line Diagram 3. UFSAR 8.3.1 4. 1/2 BOA ELEC-3 Loss Of 4KV ESF Bus Unit 1/2 5. 1/2 BOA ELEC-4 Loss Of Offsite Power Unit 1/2 6. 1/2 BCA-0.0 Loss Of All AC Power Unit 1/2 7. 1/2 BCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/2 8. 1/2 BCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/2 9. 1/2 BCA-0.3 Response To Opposite Unit Loss Of All AC Power Unit 1/2 10. BOP AP-51, Isolating Unit 1 System AUX Transformer 142-1 & 142-2 While Unit Is At Power 11. BOP AP-52, Restoring Unit 1 System AUX Transformer 142-1 & 142-2 During Power Operation 12. BOP AP-53, Isolating Unit 2 System AUX Transformer 242-1 & 242-2 While Unit Is At Power 13. BOP AP-54, Restoring Unit 2 System AUX Transformer 242-1 & 242-2 During Power Operation Month XXXX BY 3-87 EP-AA-1 002 (Revision XX)

Bvron Annex Exelon Nucleair 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 unit ESF buses.AND 2. Failure of DG 1A(2A) and DG 1 B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3. Voltage is < 108 VDC on unit 125 VDC battery buses 111(211) and 112(212)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 EAL conditions are met.Month XXXX BY 3-88 EP-AA-1002 (Revision XX)

Exelon Nuclear Byron Annex Eeo ula RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG2 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, SG8 2. 20E-0-4001 Station One Line Diagram 3. UFSAR 8.3.1 4. 1/2 BOA ELEC-3 Loss Of 4KV ESF Bus Unit 1/2 5. 1/2 BOA ELEC-4 Loss Of Offsite Power Unit 1/2 6. 1/2 BCA-0.0 Loss Of All AC Power Unit 1/2 7. 1/2 BCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/2 8. 1/2 BCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/2 9. 1/2 BCA-0.3 Response To Opposite Unit Loss Of All AC Power Unit 1/2 10. BOP AP-51, Isolating Unit 1 System AUX Transformer 142-1 & 142-2 While Unit Is At Power 13. BOP AP-52, Restoring Unit 1 System AUX Transformer 142-1 & 142-2 During Power Operation 14. BOP AP-53, Isolating Unit 2 System AUX Transformer 242-1 & 242-2 While Unit Is At Power 13. BOP AP-54, Restoring Unit 2 System AUX Transformer 242-1 & 242-2 During Power Operation 14. Safety Evaluations of the Byron Station and Byron Station Responses to the Station Blackout (SBO) Rule (TAC NOS. 68522, 68523 AND 68515, 68516)15. UFSAR 8.3.2.1.1 16. 6E-0-4001 Station One Line Diagram 17. BAR 1/2-21-El0 125V DC PNL 111/113 (211/213)

VOLT LOW 18. BAR 1/2-22-E10 125V DC PNL 112/114 (212/214)

VOLT LOW 19. 1/2 BOA ELEC -1 Loss of DC Bus Unit 1/2 Month XXXX BY 3-89 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 < 108 VDC on unit 125 VDC battery buses 111(211) and 112(212) 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 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. UFSAR 8.3.2.1.1 3. 6E-0-4001 Station One Line Diagram 4. BAR 1/2-21-ElO 125V DC PNL 111/113 (211/213)

VOLT LOW 5. BAR 1/2-22-ElO 125V DC PNL 112/114 (212/214)

VOLT LOW 6. 1/2 BOA ELEC -1 Loss of DC Bus Unit 1/2 Month XXXX BY 3-90 EP-AA-1002 (Revision XX)

Rlrrrn A nngiv I=vjmlrn fd"Aanr 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. Core Cooling CSF-RED Path conditions exist.OR b. Heat Sink CSF-RED Path conditions exist.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.

If Core Cooling CSF Red Path or Heat Sink CSF Red Path conditions exist prior to a successful reactor shutdown (i.e. < 5% reactor power) then entry is required.The Heat Sink Critical Safety Function Red path condition exists if narrow range levels in all steam generators (S/Gs) are less than or equal to 10% -Unit 1 (31% adverse containment) and 14% -Unit 2 (34% adverse containment) and total feedwater flow to all S/Gs is less than or equal to 500 gpm. If total feed flow is less than 500 gpm due to procedurally directed operator actions then this condition does not apply.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 1Cs/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.Month XXXX BY 3-91 EP-AA-1002 (Revision XX)

Bvron AnnexNuclear Byrn AnexExellnn Nucla~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3 (cont)Basis (cont): 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 FGI.Basis Reference(s):

1. NEI 99-01 Rev 6, SS5 2. 1/2 BST-1 Subcriticality Unit 1/2 3. 1/2 BST-2 Core Cooling Unit 1/2 4. 1/2 BST-3 Heat Sink Unit 1/2 5. 1/2 BFR-S.1 Response to Nuclear Power Generation/ATWS Unit 1/2 6. 1/2 BFR H.1 Response to Loss of Secondary Heat Sink Unit 1/2 7. 1/2 BFR C.1 Response to Inadequate Core Cooling Unit 1/2 Month XXXX BY 3-92 EP-AA-1002 (Revision XX)

Rv rnn AnnoyKIr-lonr~~irnn Annoy Fvolnn MmmrIc2r 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: 0 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 or manual Trip did not shutdown the reactor as indicated by Reactor Power > 5%.AND 2. Manual actions taken at the Main Control Board 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 or manual reactor trip that results in a reactor shutdown, and subsequent operator manual actions taken at the reactor control consoles to shutdown the reactor are also unsuccessful.

This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the reactor control consoles since this event entails a significant failure of the RPS.A manual action at the Main Control Board 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 reactor control consoles (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 Main Control Board".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 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 XXXX BY 3-93 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 FSI. 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. 1/2 BST-1 Subcriticality Unit 1/2 3. 1/2 BFR-S.1 Response to Nuclear Power Generation/ATWS Unit 1/2 4. 1/2 BOSR 0.1-1,2,3 Unit One(Two) Mode 1, 2, & 3 Shiftly and Daily Operating Surveillance Month XXXX BY 3-94 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 Main Control Board 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. EITHER of the following:

1. Subsequent manual action taken at the Main Control Board is successful in shutting down the reactor.OR 2. 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 reactor control consoles 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 reactor control consoles 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 XXXX BY 3-95 EP-AA-1002 (Revision XX)

B-ron Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont)Basis (cont): EAL #2 Basis If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the Main Control Board to shutdown the reactor (e.g., initiate a manual reactor trip using a different switch). Depending upon several factors, the initial or subsequent effort to manually trip the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor trip signal. If a subsequent manual or 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 Main Control Board 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 Main Control Board".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 Main Control Board 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.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU5 2. 1/2 BST-1 Subcriticality Unit 1/2 3. 1/2 BFR-S.1 Response to Nuclear Power Generation/ATWS Unit 1/2 Month XXXX BY 3-96 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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. 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" Narrow Range level in at least one Steam Generator" Steam generator Auxiliary Feed Water Flow AND 2. 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* Safety Injection Actuation Month XXXX BY 3-97 EP-AA-1 002 (Revision XX)

Bvron Annex Exelon Nuclear 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. NEI 99-01 Rev 6, SA2 Month XXXX BY 3-98 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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

Reactor Power 0 PZR Level 0 RCS Pressure* In Core/Core Exit Temperature 0 Narrow Range level in at least one Steam Generator 0 Steam generator Auxiliary 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 XXXX BY 3-99 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 XXXX BY 3-100 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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:* 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 XXXX BY 3-101 EP-AA-1002 (Revision XX)

Byron Annex FyAInn Bvron An nex FyPInn NIr~ionr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS events may require a post-event inspection to determine if the attributes of an explosion are present.Month XXXX BY 3-102 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 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 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 RS1.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 XXXX BY 3-103 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 XXXX BY 3-104 EP-AA-1002 (Revision XX)

Byron Annex Byron Annex Exel.on Nuclear 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. Technical Specifications 3.4.13 & 3.4.14 3. UFSAR. 6.2, 5.2 4. 1/2 BOSR 4.13.1-1 Unit One(Two) Reactor Coolant System Water Inventory Balance 72 Hour Surveillance

5. 1/2 BOL 4.15 LCOAR -RCS Leakage Detection Instrumentation

6. 1/2 BOL 4.13 LCOAR -RCS Operational Leakage 7. 1/2 BOA PRI-1 Excessive Primary Leakage Unit 1/2 8. 1/2 BOSR 0.1-4 Unit One(Two) Mode 4 Shiftly and Daily Operating Surveillance

9. 1/2 BOSR RF-1 Unit One(Two) Containment Floor Drain Monitoring System Non-Routine Surveillance

10. 0/1/2 BOSR XZB-R1, Unit 0/1/2 Meter Zone Banding Month XXXX BY 3-105 EP-AA-1002 (Revision XX)

Bvron Annex SAnnex.......Exelon Nuclear 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 X System Commercial Telephones 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 XXXX BY 3-106 EP-AA-1002 (Revision XX)

Fxelnn r B-ron Annex Fxelvn 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-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) 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. EP-MW-124-1001 Facilities Inventories And Equipment Tests Month XXXX BY 3-107 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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. Containment pressure > 20 psig.AND b. Less than one full train of Containment Spray is operating per design for> 15 minutes.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.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.Month XXXX BY 3-108 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU8 (cont)Basis (cont): 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. 1/2 BST-5 Containment Unit 1/2 Month XXXX BY 3-109 EP-AA-1002 (Revision XX)

.vr.n Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA1 Initiating Condition:

Loss of all offsite and all onsite AC power 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. Loss of ALL offsite AC power to unit ESF buses.AND 2. Failure of DG 1A(2A) and DG 1B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3. Failure to restore power to at least one unit ESF 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.The emergency buses 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 power losses.Escalation of the emergency classification level would be via IC CS6 or RS1.Month XXXX BY 3-110 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA1 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, CA2 2. 20E-0-4001 Station One Line Diagram 3. UFSAR 8.3.1 4. 1/2 BOA ELEC-3 Loss Of 4KV ESF Bus Unit 1/2 5. 1/2 BOA ELEC-4 Loss Of Offsite Power Unit 1/2 6. 1/2 BCA-0.0 Loss Of All AC Power Unit 1/2 7. 1/2 BCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/2 8. 1/2 BCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/2 9. 1/2 BCA-0.3 Response To Opposite Unit Loss Of All AC Power Unit 1/2 10. BOP AP-51, Isolating Unit 1 System AUX Transformer 142-1 & 142-2 While Unit Is At Power 11. BOP AP-52, Restoring Unit 1 System AUX Transformer 142-1 & 142-2 During Power Operation 12. BOP AP-53, Isolating Unit 2 System AUX Transformer 242-1 & 242-2 While Unit Is At Power 13. BOP AP-54, Restoring Unit 2 System AUX Transformer 242-1 & 242-2 During Power Operation 14. Safety Evaluations of the Byron Station and Byron Station Responses to the Station Blackout (SBO) Rule (TAC NOS. 68522, 68523 AND 68515, 68516)Month XXXX BY 3-111 EP-AA-1002 (Revision XX)

Exelon Nuclear B-ron Annex.....on.Nucl.ar 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 unit ESF buses reduced to only one of the following power sources for > 15 minutes.* Affected unit SAT 142-1(242-1)

Affected unit SAT 142-2(242-2)

Emergency Diesel Generator DG 1A(2A)* Emergency Diesel Generator DG 1 B(2B)* Unit crosstie breakers 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.

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 XXXX BY 3-112 EP-AA-1002 (Revision XX)

Bvron Annex Exel.on Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CUl (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. 20E-0-4001 Station One Line Diagram 3. UFSAR 8.3.1 4. 1/2 BOA ELEC-3 Loss Of 4KV ESF Bus Unit 1/2 5. 1/2 BOA ELEC-4 Loss Of Offsite Power Unit 1/2 6. 1/2 BCA-0.0 Loss Of All AC Power Unit 1/2 7. 1/2 BCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/2 8. 1/2 BCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/2 9. 1/2 BCA-0.3 Response To Opposite Unit Loss Of All AC Power Unit 1/2 10. BOP AP-51, Isolating Unit 1 System AUX Transformer 142-1 & 142-2 While Unit Is At Power 11. BOP AP-52, Restoring Unit 1 System AUX Transformer 142-1 & 142-2 During Power Operation 12. BOP AP-53, Isolating Unit 2 System AUX Transformer 242-1 & 242-2 While Unit Is At Power 13. BOP AP-54, Restoring Unit 2 System AUX Transformer 242-1 & 242-2 During Power Operation 14. Safety Evaluations of the Byron Station and Byron Station Responses to the Station Blackout (SBO) Rule (TAC NOS. 68522, 68523 AND 68515, 68516)Month XXXX BY 3-113 EP-AA-1002 (Revision XX)

Bvron Annex Bvron Annex Exelon Nuclear 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: e 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 XXXX BY 3-114 EP-AA-1002 (Revision XX)

Byron Annex I=xelon Nuclear Bvron Annex Ex..lon Nuclear 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 XXXX BY 3-115 EP-AA-1002 (Revision XX)

Bvron Annex Explon Nuclear 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 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 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 XXXX BY 3-116 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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.Voltage is < 108 VDC on required unit 125 VDC battery buses 111(211) and 112(212)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 rise 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 XXXX BY 3-117 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU3 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, CU4 2. UFSAR 8.3.2.1.1 3. 6E-0-4001 Station One Line Diagram 4. 1/2 BOA ELEC -1 Loss of DC Bus Unit 1/2 5. BAR 1/2-21-E10 125V DC PNL 111/113 (211/213)

VOLT LOW 6. BAR 1/2-22-E10 125V DC PNL 112/114 (212/214)

VOLT LOW Month XXXX BY 3-118 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 X System Commercial X X X Telephones 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 XXXX BY 3-119 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4 (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-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) 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. EP-MW-124-1001 Facilities Inventories And Equipment Tests Month XXXX BY 3-120 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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

> 200*F due to loss of decay heat remeval for > Table C2 duration.OR 2. UNPLANNED RCS pressure rise > 10 psig as a result of temperature rise-d-ue te loss of ay heat removal. (This EAL does not apply in solid plant conditions.)

Table C2 -RCS Heat-up Duration Thresholds RCS Containment Closure Heat-up Status Status Duration Intact Not Applicable 60 minutes*Not Intact Established 20 minutes*OR Reduced Not Established 0 minutes Inventory (<397 ft.)* 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 XXXX BY 3-121 EP-AA-1002 (Revision XX)

Rvrnn Annex Ru'rnn Annex Fxelnn NucleIAar RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Month XXXX BY 3-122 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 crpCial 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 XXXX BY 3-123 EP-AA-1002 (Revision XX)

Bvron Annex rn Annex....Exel.on Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, CA3 2. BOP PC-1 Containment Closure Tracking Capability

3. 1/2 BOSR 4.3.1-1 Reactor Coolant System Pressure Temperature Limit Surveillance

4. 1/2 BGP 100-1 Plant Heatup 5. 1/2 BGP 100-5, Plant Shutdown and Cool Down 6. 1/2 BGP 100-6, Unit 1(Unit 2) Refueling Outage Month XXXX BY 3-124 EP-AA-1002 (Revision XX)

P rrnn IPv,',lnn Kl"AI--nr I A~qlPInlinavJ nIMi l sIcI~~r 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

> 200OF due to loss of decay he at remeval.OR 2. Loss of the following for >15 minutes." ALL RCS temperature indications AND* 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 XXXX BY 3-125 EP-AA-1002 (Revision XX)

Byron Annex Brn Annex...Exellon Nuclear 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. Technical Specifications Table 1.1-1 3. 1/2 BOSR 0.1-6 Unit One (Two) Mode 6 Shiftly And Daily Operating Surveillance

4. BOP RH-9 Pump Down of the Refueling Cavity to the RWST 5. BOP RC-4 Reactor Coolant System Drain 6. 1/2 BOSR 3.3.1-1 Unit One (Two) Accident Monitoring Instrumentation Monthly Channel Checks 7. 1/2 BOL 4.15, LCOAR -RCS Leakage Detection Instrumentation

8. 1/2 BOL 4.13, LCOAR -RCS Operational Leakage 9. 1/2 BOSR 4.3.1-1 Reactor Coolant System Pressure / Temperature Limit Surveillance Month XXXX BY 3-126 EP-AA-1002 (Revision XX)

Byron Annex Exelon Nuclear 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. a. RVLIS indicates 0% Plenum for > 30 minutes.OR Reactor Vessel Refueling Level Indicators LT-046 and LT-049 < 392 ft. el. for> 30 minutes.AND b. ANY Containment Challenge Indication (Table C4)OR 2. a. Reactor Vessel level unknow-n cannot be monitored for > 30 minutes.AND 3-. b. 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* 1/2 RE-AR01 1 or 1/2 RE-AR12 Containment Fuel Handling Incident radiation monitors > 3000 mR/hr.AND 4- c. Any Containment Challenge Indication (Table C4)Month XXXX BY 3-127 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Emergency Action Level (EAL) (cont): Table C3 -Indications of RCS Leakage" UNPLANNED Containment Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED Tank level (rad waste) 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.

Table C4 -Containment Challenge Indications

Hydrogen Concentration in Containment

> 5%* 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: 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.

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 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.Month XXXX BY 3-128 EP-AA-1002 (Revision XX)

Bvron Annex ByronAnnexExellon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Basis (cont): 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.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 XXXX BY 3-129 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, CG1 2. BOP PC-i, Containment Closure Tracking Capability

3. UFSAR E.17, 6.2, 6.2.5.2.1 4. BOP RH-9 Pump Down of the Refueling Cavity to the RWST 5. BOP RC-4 Reactor Coolant System Drain 6. 1/2 BOSR 0.1-4 Unit One(Two) Mode 4 Shiftly and Daily Operating Surveillance

7. 1/2 BOSR RF-1 Unit One(Two) Containment Floor Drain Monitoring System Non-Routine Surveillance

8. 0/1/2 BOSR XZB-R1, Unit 0/1/2 Meter Zone Banding 9. 1/2 BGP 100-2 Plant Startup 10. BGP 100-6T4 Core Alteration

/ Fuel Movement Checklist 11. 1/2 BOSR 3.3.1-1 Unit One(Two) Accident Monitoring Instrumentation Monthly Channel Checks 12. 1/2 BFR-C.1, Response to Inadequate Core Cooling Unit 1/2 13. 1/2 BST-5 Containment Unit 1/2 14. NES-G-14.02, Calculation No. BYR99-010

/ BRW-99-0017-1

15. EP-EAL-0501, Estimation Of Radiation Monitor Readings Indicating Core Uncovery During Refueling Month XXXX BY 3-130 EP-AA-1002 (Revision XX)

Byron Annex Exelon Nuclear 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. With CONTAINMENT CLOSURE established EITHER: " RVLIS indicates 0% Plenum OR" Reactor Vessel Refueling Level Indicators LT-046 and LT-049 < 392 ft el.OR 2. With CONTAINMENT CLOSURE not established EITHER:* RVLIS < 15% Plenum OR* Reactor Vessel Refueling Level Indicators LT-046 and LT-049< 393 ft. el.OR 3. a. Reactor Vessel level cannot be monitoredunknowR for >30 minutes.AND b. 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* 1/2 RE-AR01 1 or 1/2 RE-AR12 Containment Fuel Handling Incident radiation monitors > 3000 mR/hr.Month XXXX BY 3-131 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear Byron Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 (cont)Emergency Action Level (EAL) (cont): Table C3 -Indications of RCS Leakage* UNPLANNED Containment Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise*" UNPLANNED Tank level (rad waste) 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: 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.

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.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.

Month XXXX BY 3-132 EP-AA-1002 (Revision XX)

Bvron Annex Exellon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CS6 (cont)Basis (cont): 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.Basis Reference(s):

1. NEI 99-01 Rev 6, CS1 2. UFSAR E.17, 6.2 3. BOP RH-9 Pump Down of the Refueling Cavity to the RWST 4. BOP RC-4 Reactor Coolant System Drain 5. 1/2 BOSR 0.1-4 Unit One (Two) Mode 4 Shiftly and Daily Operating Surveillance

6. 1/2 BOSR RF-1 Unit One (Two) Containment Floor Drain Monitoring System Non-Routine Surveillance

7. 0/1/2 BOSR XZB-R1, Unit 0/1/2 Meter Zone Banding 8. 1/2 BGP 100-2 Plant Startup 9. BGP 100-6T4 Core Alteration

/ Fuel Movement Checklist 10. 1/2 BOSR 3.3.1-1 Unit One (Two) Accident Monitoring Instrumentation Monthly Channel Checks Month XXXX BY 3-133 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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. a. Loss of RCS / Reactor Vessel inventory as indicated RVLIS < 37% Plenum.OR b. Loss of RSC / Reactor Vessel inventory as indicated by LT-046 and LT-049< 393.5 ft. el.OR 2. a. RCS / Reactor Vessel level cannot be monitoredunknown for > 15 minutes.AND b. Loss of RCS / Reactor Vessel inventory per Table C3 indications.

Table C3 -Indications of RCS Leakage" UNPLANNED Containment Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED Tank level (rad wase) 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 XXXX BY 3-134 EP-AA-1002 (Revision XX)

R renn Annay P~--Imrn M, d-lIm-or ir l l An-iiioy Mifbir4io(,r 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.A lowering of water level below indicated RVLIS < 37% Plenum or LT-046 and LT-049 indicating

< 393.5 ft. el. indicates that operator actions have not been successful in restoring and maintaining reactor vessel/RCS 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.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.

The 15-minute duration for the loss of level indication was chosen because it is half of the Threshold 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. UFSAR 6.2 & E.17 3. 1/2 BOSR 0.1-4 Unit One(Two) Mode 4 Shiftly and Daily Operating Surveillance

4. 1/2 BOSR RF-1 Unit One(Two) Containment Floor Drain Monitoring System Non-Routine Surveillance

5. 0/1/2 BOSR XZB-R1, Unit 0/1/2 Meter Zone Banding 6. BOP RH-9 Pump Down of the Refueling Cavity to the RWST 7. BOP RC-4 Reactor Coolant System Drain Month XXXX BY 3-135 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Initiating Condition:

UNPLANNED loss of reactor vessel/RCS inventory for 15 minutes or longer.CU6 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 monitoredunknewn.

AND b. Loss of RCS / Reactor Vessel inventory per Table C3 indications.

Table C3 -Indications of RCS Leakage* UNPLANNED Containment Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED Tank level (rad waste) 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 XXXX BY 3-136 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 (cont)Basis (cont): Refueling evolutions that decrease RCS water inventory are carefully planned and controlled.

An UNPLANNED event that results in water level decreasing below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.EAL #1 recognizes that the minimum required reactor vessel/RCS 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 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.The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.EAL #2 addresses a condition where all means to determine reactor vessel/RCS 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/RCS.

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA6 or CA5.Month XXXX BY 3-137 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 (cont)Basis Reference(s):

1. NEI 99-01, Rev. 6 CUi 2. UFSAR 6.2 & E.17 3. 1/2 BOSR 0.1-4 Unit One (Two) Mode 4 Shiftly and Daily Operating Surveillance

4. 1/2 BOS RF-1 Unit One (Two) Containment Floor Drain Monitoring System Non-Routine Surveillance

5. 0/1/2 BOSR XZB-R1, Unit 0/1/2 Meter Zone Banding 6. BOP RH-9 Pump Down of the Refueling Cavity to the RWST 7. BOP RC-4 Reactor Coolant System Drain Month XXXX BY 3-138 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 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: 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 XXXX BY 3-139 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].Basis Reference(s):

1. NEI 99-01, Rev. 6 HG1 5. Station Security Plan -Appendix C Month XXXX BY 3-140 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 XXXX BY 3-141 EP-AA-1002 (Revision XX)

P Annoy IPvalron MiuJ,,Ilnmr I,1 I II AnllllF.vIIIA nIMl In.11I1 r1 RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 (cont)Basis (cont): 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 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 3. Station Security Plan -Appendix C Month XXXX BY 3-142 EP-AA-1002 (Revision XX)

Rvron Annex Brn Annex....Exelon Nuclear 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 PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.Month XXXX BY 3-143 EP-AA-1002 (Revision XX)

R rrnn Annoy 9=valrn PJ"Aanr RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 (cont)Basis (cont): 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 0BOA Security-I, Security Threat.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 XXXX BY 3-144 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nucl.ear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, HA1 2. SY-AA-101-132, Security Assessment and Response to Unusual Activities

3. Station Security Plan -Appendix C 4. 0BOA Security-i, Security Threat Unit 0 Month XXXX BY 3-145 EP-AA-1002 (Revision XX)

Byron Annex-r- Annex...Exelon Nuclear 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 XXXX BY 3-146 EP-AA-1002 (Revision XX)

Bvron Annex ByronAnnexExelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HUI (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 Basis Addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with SY-AA-101-132, Security Assessment and Response to Unusual Events..EAL #2 Basis 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 OBOA Security-I, Security Threat.EAL #3 Basis 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. Station Security Plan -Appendix C 4. NRC Safeguards Advisory 10/6/01 5. Letter from Mr. B. A. Boger (NRC) to Ms. Lynette Hendricks (NEI) dated 2/4/02 6. OBOA Security-I, Security Threat Unit 0 Month XXXX BY 3-147 EP-AA-1 002 (Revision XX)

Bvron Annex ByronAnnexExelon Nuclear 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 1/2BOA PRI-5, Control Room Inaccessibility.

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.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).

Month XXXX BY 3-148 EP-AA-1002 (Revision XX)

P rr~n Annmy IP'v,',Inn N, gflanr RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 (cont)Basis (cont): Escalation of the emergency classification level would be via IC FG1 or CG6.Basis Reference(s):

1. NEI 99-01, Rev 6 HS6 2. 1/2BOA PRI-5, Control Room Inaccessibility Unit 1/2 Month XXXX BY 3-149 EP-AA-1 002 (Revision XX)

Exelon Nuclear Byron Annex........

Nuclear 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 1/2BOA PRI-5, Control Room Inaccessibility.

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. 1/21BOA PRI-5, Control Room Inaccessibility Unit 1/2 Month XXXX BY 3-150 EP-AA-1002 (Revision XX)

Byron Annex Exelon Nuclear 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:* 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.

Table H2 -Vital Areas" Containment" Auxiliary Building" Fuel Handling Building* Main Steam Tunnels" RWST's* Condensate Storage Tanks* Essential Service Water Cooling Towers Month XXXX BY 3-151 EP-AA-1002 (Revision XX)

Bvron Annex Ex-...n Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)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 This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

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

EAL #3 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.Month XXXX BY 3-152 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)Basis (cont): 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.ISFSI is not specifically addressed in EAL #3 and #4 since it is within the plant PROTECTED AREA and is therefore covered under EALs #3 and #4.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.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. Drawing S-01A Composite Site Plan 3. UFSAR Section 3.02 4. BAP-1 100, Fire Protection Procedure Series Month XXXX BY 3-153 EP-AA-1002 (Revision XX)

Byron AnnexNuclear Bvron Annex Exelnn Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Month XXXX BY 3-154 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 check at panel OPA02J.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: 9 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.SeiGmic eVent > Operating Basis Earthquake (01BE) as indicated by seiSMic check at 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)1.An earthquake greater 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, 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)ublic will remain functional.

An SSE is vibratory ground motion for which certain (generally, safety-related) structures, systems, and components must be designed to remain functional.

Month XXXX BY 3-155 EP-AA-1002 (Revision XX)

Bvron Annex Exellon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY 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. OBOA ENV-4 Earthquake

3. Annunciator 0-38-E5 Accelograph Accel High Month XXXX BY 3-156 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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:

1,2 , 4, 5, 6,-D Emergency Action Level (EAL): Note: 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.Table H3 Arcas with Entry Rclated Mode AppliG"ability Area Entry Related Mode_ _ __ _ _Applil~abhity Auxiliary Bu ilding* Mode 4, 5, and 6*Arcas rcquired to establish shutdown cooling Month XXXX BY 3-157 EP-AA-1002 (Revision XX)

Rvron Annex Exelon Nuclear Bvron Annex ExeIon Nuclea~r RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Table H3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Auxiliary Building 426'VCT Valve Aisle Auxiliary Building 401'Curved Wall Area Penetration Area Auxiliary Building 383' Mode 4, 5, and 6 Remote Shutdown Panel Area Auxiliary Building 364'CV Pp areas Curved Wall Area Auxiliary Building 346'RH pump areas AND 2. Entry into the room or area is prohibited or impeded..Basis:, .. ..This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to 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 Month XXXX BY 3-158 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY 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." 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.Month XXXX BY 3-159 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 (cont)Basis (cont): An asphyxiant is a gas capable of redpCing 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.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.

This EAL does not apply to firefighting activities, that generate smoke or that automatically or manually activate a fire suppression system in an area.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. Drawing S-01A Composite Site Plan 3. UFSAR Section 3.02 4. ACIT 660892-13, Station Halon Discharge IDLH Evaluation Month XXXX BY 3-160 EP-AA-1002 (Revision XX)

Rvron Annex Bvron Annex Exelon Nuclear 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.Basis: PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

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.Month XXXX BY 3-161 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Month XXXX BY 3-162 EP-AA-1002 (Revision XX)

Byron AnnRxNuclear Bvrnn Annex Exellon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 (cont)Basis (cont): 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 aa SAFETY. SYSTEM componPent as a result of leakage is6 an event of lesser i mpact and would be expeGted to cause small and localized damage. The conIsequenc of this type of event is adequately assessed and ad dresscd in accordance with Technical SpedfieatiORS-.

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.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 Month XXXX BY 3-163 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 XXXX BY 3-164 EP-AA-1002 (Revision XX)

R nren Annoy IPvalnn N"Atranr 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 XXXX BY 3-165 EP-AA-1002 (Revision XX)

Byron Annex Exelon Nuclear Byron Annex Exelon Nucilear 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 XXXX BY 3-166 EP-AA-1002 (Revision XX)

Byron Annex Exelon Nuclear 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 XXXX BY 3-167 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY ISFSI MALFUNCTIONS E-HU1 Initiating Condition Damage to a loaded cask CONFINEMENT BOUNDARY.Operating Mode Applicability:

1,2, 3, 4, 5, 6, D Emergency Action Level (EAL): Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading:* > 60mr/hr (gamma + neutron) on the top of the spent fuel cask OR* > 600mr/hr (gamma + neutron) on the side of the spent fuel cask, excluding inlet and outlet ducts Basis: CONFINEMENT BOUNDARY:

The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.

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 an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The word cask, as used in this EAL, refers to the storage container in use at the site for dry storage of irradiated fuel. The issues of concern are the creation of a potential or actual release path to the environment, degradation of any fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.The existence of "damage" is determined by radiological survey. The technical specification multiple of "2 times", which is also used in Recognition Category R IC RU1, is used here to distinguish between non-emergency and emergency conditions.

The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the "on-contact" dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.Security-related events for ISFSls are covered under ICs HU1 and HAl.Basis Reference(s):

1. NEI 99-01, Rev 6 E-HU1 2. Certificate of Compliance No. 1014 Appendix A Section 5.7 Month XXXX BY 3-168 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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. The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PR030)> 9.99 E+09 pCi/sec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS -Total Noble Gas Release Rate).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 Month XXXX BY 3-33 EP-AA-1 002 (Revision XX)

R rnn Annoy Pyninn Nwlanr Ru. I Fv,,rvn m raiu RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG1 (cont)Emergency Action Level (EAL) (cont): 3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >1000 mRem/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.

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-AA-1 12-500 Emergency Environmental Monitoring

3. EP-EAL-0602 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Byron Station Month XXXX BY 3-34 EP-AA-1002 (Revision XX)

P lrnn Annoy IPvInn d,,elanr R~,rnn Ann~v Fv~Inn N.iE-Ia2r 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. The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PR030)> 9.99 E+08 pCi/sec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS -Total Noble Gas Release Rate).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 XXXX BY 3-35 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RSl (cont)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 ODE.Escalation of the emergency classification level would be via IC RG1.Basis Reference(s):

1. NEI 99-01 Rev 6, AS1 2. EP-AA-1 12-500 Emergency Environmental Monitoring

3. EP-EAL-0602 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Byron Station Month XXXX BY 3-36 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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. The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PR030)> 9.99 E+07 pCi/sec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS -Total Noble Gas Release Rate).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 Month XXXX BY 3-37 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont)Emergency Action Level (EAL) (cont): OR 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.

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.This EAL includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit.Escalation of the emergency classification level would be via IC RS1.Month XXXX BY 3-38 EP-AA-1002 (Revision XX)

Bvron Annex Exellon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis Reference(s):

1. NEI 99-01 Rev 6, AA1 2. UFSAR Section 11.5.2.3 3. OBISR 11 .a.3-002, Channel Operation Test of Liquid Radwaste Effluent Radiation Monitor OPR01J 4. ODCM, CY-BY-170-301, Section 3.0, Liquid Effluents 5. EP-EAL-0602 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Byron Station 6. EP-EAL-0619 Rev. 0, Byron Criteria for Choosing Radiological Liquid Effluents EAL Threshold Values.7. EP-EAL-0624 Rev. 0, Byron Criteria for Choosing Radiological Gaseous Effluents EAL Threshold Values for Waste Gas Decay Tanks Month XXXX BY 3-39 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 high alarm setpoint established by a current radioactive release discharge permit for > 60 minutes.* OPROO1, Liquid Radwaste Effluent Monitor* OPROO2, Gas Decay Tank Effluent Monitor* OPRO10, Station Blowdown Monitor* 1/2PROO1, Containment Purge Effluent Monitor* Discharge Permit specified monitor OR 2. The sum of readings on the Unit 1 and 2 Aux Bldg Vent WRGMs (1/2 RE-R030)> 1.14 E+06 pCi/sec for > 60 minutes (as determined from Unit 1 & 2 PF430 or PPDS -Total Noble Gas Release Rate).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 XXXX BY 3-40 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RUI (cont)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.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 RAI.Month XXXX BY 3-41 EP-AA-1002 (Revision XX)

Bvron Annex Exellon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RUI (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, AU1 2. UFSAR Section 11.5.2.3 3. OBISR 11 .a.3-002, Channel Operation Test of Liquid Radwaste Effluent Radiation Monitor OPR01J 4. ODCM, CY-BY-170-301, Section 3.0, Liquid Effluents 5. EP-EAL-0602 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Byron Station Month XXXX BY 3-42 EP-AA-1002 (Revision XX)

Byron Annex Exelon Nuclear 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 XXXX BY 3-43 EP-AA-1002 (Revision XX)

Bvron Annex Exelon Nuclear 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 XXXX BY 3-44 EP-AA-1002 (Revision XX)

Rvrnn AnnpxM Rvrnn Annex FvAinn Nuclear 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 R1 Radiation Monitor reading >1000 mRem/hr OR 3. Lowering of spent fuel pool level to (site specific Level 2 value).Table R1 Fuel Handling Incident Radiation Monitors" Fuel Building Fuel Handling Incident Monitor ORE-AR055* Fuel Building Fuel Handling Incident Monitor ORE-AR056" Containment Fuel Handling Incident Monitor 1/2RE-AR01 1* Containment Fuel Handling Incident Monitor 1/2RE-AR012 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: