View source for RA-14-032, Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. LGS 3-70 Page LGS 3-155

{{Adams
| number = ML14164A069
| issue date = 05/30/2014
| title = Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. LGS 3-70 Page LGS 3-155
| author name = 
| author affiliation = Exelon Generation Co, LLC
| addressee name = 
| addressee affiliation = NRC/FSME, NRC/NMSS
| docket = 05000352, 05000353
| license number = 
| contact person = 
| case reference number = RA-14-032, RS-14-115, TMI-14-046
| document report number = EP-AA-1008
| package number = ML14164A053
| document type = Emergency Preparedness-Emergency Plan
| page count = 193
}}

=Text=
{{#Wiki_filter:I imprirnk (tanarnfinn Afiqfinn Annoy I=yelnn r Fyokinn N"t-loar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA59 Initiating Condition:
Hazardous event affecting a SAFETY SYSTEM needed-required for the current operating mode.Operating Mode Applicability:
1,2,3 Emergency Action Level (EAL): (4- 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 vpecific, hazard,)" Other events with similar hazard characteristics as determined by the Shift Manager AND 2.1a, EITHER of the following:
a.4-. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed-required by Technical Specifications for the current operating mode.OR b.2-. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed-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 events may require a post-event inspection to determine if the attributes of an explosion are present.Month 20XX LGS 3-70 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exellon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS 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, nae l-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.EA.14 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 SeeiGeoperation 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. -OAL1-b-h.
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 sewiGeloperation or readily apparent through indications alone, er-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 RAS1.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.Month 20XX LGS 3-71 EP-AA-1008 (Revision XX)
I imarirk rZanarnfin -Qfnfitn Annav I::alnn I~dl,,rl~RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis Reference(s): 
'1. NEI 99-01, Rev 6 SA9 2. UFSAR Section 2.5, Geology and Seimology 3. UFSAR Section 3.4.1, Flood Protection
: 4. UFSAR Section 6.2.1.1.1, Design Bases 5. UFSAR Section 9.2.6.4.2, Spray Pond Water Requirements
: 6. DBD L-S-46, Meteorological and Seismic Monitoring Systems 7. DBD L-T-17, Dynamic Qualification Program 8. Specification NE-0294, "Fire Safe Shutdown Analysis Specification" 9. SE-5 Earthquake
: 10. SE-4 Flood 11. SE-9, Preparation for Severe Weather Month 20XX LGS 3-72 EP-AA-1008 (Revision XX)
F:Yalnn Nnne-llnr Simeric~k Ganaratinn Station Annex vInNuIi2 RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU641 Initiating Condition:
RCS leakage for 15 minutes or longer.Operating Mode Applicability:
1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual Event vent promptly upon determining that the applicable time 45 iniites-has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage in the DrywellgFeater-than
> 10 gpm for > 15 minutes. (site spec.ifc value) for, 15 minute, Or lon.ger.OR 2. RCS identified leakage in the Drywell greater-than->25 gpm for > 15 minutes.(site-Specifc value) f, 15 minuter, r OR 3. Leakage from the RCS to a location outside the Drywellfntainme 
>25 gpm for >15 minutes ge. ater than 25 gpm for 1 -5 Minutes Or long.Basis: UNISOLABLE:
An open or breached system line that cannot be isolated, remotely or locally.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 steam gen.rator 
&#xf7;,tube leakage iR a PIR) 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 Month 20XX LGS 3-73 EP-AA-1008 (Revision XX)
I imarirnk rpncargting Atntion Annex~ Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS 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.The release of mass from the RCS due to the as-designed/expected operation of a-any relief valve does not warrant an emergency classification.
FcrFBWR'.,Aa stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is not applicable to this EAL.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 RA or F.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU4 2. Technical Specifications 3.4.3, Reactor Coolant System Leakage 3. Technical Specifications 3.9.8, Water Level -Reactor Vessel 4. DBD L-S-34, Radwaste System 5. OT-101 High Pressure 6. T-102 Primary Containment Control, Table DW/T-1 7. GP-6.1 U/1 (U/2) Shutdown Operations 
-Refueling, Core Alteration and Core Off-Loading
: 8. DBD L-S-16, Reactor Instrumentation System (RIS)9. ST-6-107-596-*
liywelwDrywell Floor Drain Sump/Equipment Drain Tank Surveillance Log Month 20XX LGS 3-74 EP-AA-1008 (Revision XX)
ExAIon Nuclear Limeric~k 
&#xa3;GAneratina Station Annex Exelon Nucla~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU76 Initiating Condition:
Loss of all On-site or Off-site communications capabilities.
Operating Mode Applicability:
1,2,3 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 Station Radio X Plant Public Address (PA) X Prelude System X X Station Phones X X x Satellite Phones X X X NARS X HPN X X ENS X X 1. Loss of ALL of the following onsite communication mnethods: (sito specific list of communications method 2. Loss of ALL of the following OROQ communn'Aications 
: 6) meAt~ho~ds6 (s0iteA e__9Acific liSt Of communications mnethods)Month 20XX LGS 3-75 EP-AA-1008 (Revision XX)
I=YAInn  Sim.vrit.k vn.r..in A.t-tin Annv. Evxinn Nv. uclar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS 23 I-oss oef ALLI of the NRC cmmunication methods: (site spocifict list- of comnctosmothods)
Basis: This IC addresses a significant loss of on-site,-O-offsite, or NRC communications capabilities.
While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).EAL #1 Basis aAddresses a total loss of the communications methods used in support of routine plant operations.
EAL #2 Basis aAddresses a total loss of the communications methods used to notify all OROs of an emergency declaration.
The OROs referred to here are listed in procedure EP-MA-1 14-1 00-F-01, State / Local Event Notification Form. (soo Notes)-.EAL #3 Basis aAddresses 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. UFSAR Section 9.5.2, Communication Systems 3. SE-12 Loss of Communications Month 20XX LGS 3-76 EP-AA-1008 (Revision XX)
I imarink ranarnfinn Afnfinn Annoy Fvalnn N.nla~r I imaarir~k 
(~ong~rn*inn 
~t~atinn Ann~v Fvalnn hI..t~Iaar RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CA121 Initiating Condition:
Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.Operating Mode Applicability:
4,5, D Emergency Action Level (EAL): Note: The Emergency Director should declare the AleFt-vent promptly upon determining that the applicable time 15 minutes time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to unit 4KV Safeguards Buses.AND 2. Failure of Dl1(21), D12(22), D13(23), and D14(24) Emergency Diesel Generators to supply power to unit 4KV Safeguards Buses.AND 3. Failure to restore power to at least one unit 4KV Safeguards bus in < 15 minutes from the time of loss of both offsite and onsite AC power.Loes of ALL offs*te ane ALL A,-'-nsite AC Power to (site specifc emergency buses) fo1 4-5 min*utes Or longer.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.Month 20XX LGS 3-77 EP-AA-1008 (Revision XX)
I imgwir-k f.anarnfin -Q#nfinn Anngiv I:=alnn kl"anrlr I m~rjI,(anr$in~~+rn n~vF~n uMI~RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation of the emergency classification level would be via IC CS64- or RAS1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, CA2 2. UFSAR Section 8.2, Offsite Power System 3. E 10-20 Loss of Offsite Power 4. DBD L-S-05, 4KV System 5. DBD L-T-03, Electrical Issues Month 20XX LGS 3-78 EP-AA-1008 (Revision XX)
Fyplnn Nimloa=r Simerick (GAneratinn Sta~tion AnnexFA~nNu~a RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS Cu12i Initiating Condition:
Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:
4,5, D Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual Ev,-tevent promptly upon determining that the applicable time 15-mwtes-has been exceeded, or will likely be exceeded.1. AC power capability to unit 4KV Safeguards Buses reduced to only one of the following power sources for > 15 minutes.* 101 Safeguards Transformer
* 201 Safeguards Transformer SD1 1(21) Diesel Generator* D12(22) Diesel Generator* D13(23) Diesel Generator* D14(24) Diesel Generator AND 2. ANY additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.A LAI: !; ;.r-.. k- -AI .4. i.;.- .,.-.; .- --w ,,.,-*. .,.,4,,-,.., .....I-.t v FrwV. 31, ".'PCI ty t ,,,d .to ..t .a ,,, " ,, vor ,,vr ,v M........
t v t ,.-,,,"S a power source for 15 minutes, or longer.AND b. Any additional single poWor source failure Will recult iR loss of all AG power to 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 Month 20XX LGS 3-79 EP-AA-1008 (Revision XX) 
-7 Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS 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.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 CA12.Basis Reference(s):
: 1. NEI 99-01 Rev 6 CU2 2. UFSAR Section 8.2, Offsite Power System 3. E 10-20 Loss of Offsite Power 4. DBD L-S-05, 4KV System 5. DBD L-T-03, Electrical Issues Month 20XX LGS 3-80 EP-AA-1008 (Revision XX)I Limeric~k Generatinn Station Annex Exeoln Nucle~ar RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CA26 Initiating Condition:
Hazardous event affecting SAFETY SYSTEM nieeded-required for the current operating mode.Operating Mode Applicability:
4,5 Emergency Action Level (EAL): 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 2.b. EITHER of the following:
a.. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed-required by Technical Specifications for the current operating mode.OR b. 2 The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed-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 events may require a post-event inspection to determine if the attributes of an explosion are present.Month 20XX LGS 3-81 EP-AA-1008 (Revision XX)
Limerick Generating-Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS 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, needed-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.E.A b--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 Seivioperation 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-I 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 eeVice peration 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 CS64- or RASI.If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):
: 1. NEI 99-01 Rev 6, CA6 Month 20XX LGS 3-82 EP-AA-1008 (Revision XX)
Nuclear Limeric~k Generatinn Station Annex Exelon Nucleanr RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU34 Initiating Condition:
Loss of Vital DC power for 15 minutes or longer.Operating Applicability:
4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual Even-tvent promptly upon determining that the applicable time 15 minutes time has been exceeded, or will likely be exceeded.Voltage is < 108 VDC on required 125 VDC battery busses 1(2)FA, FB, FC, FD for > 15 minutes.Ind-iated g lss than (site Specii bu6 V9otage Value) On required Vital DG besforF 15 minutes or logRer.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 increase 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 CA64- or CA53, or an IC in Recognition Category RA.Basis Reference(s):
: 1. NEI 99-01 Rev 6, CU4 2. UFSAR Section 8.3.2, DC Power Systems Month 20XX LGS 3-83 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS
: 3. DBD P-L-01A, 125/250 VDC System 4. E-1(2)FA Loss of Division I Safeguard 125/250V DC BUS 1FA 5. E-1(2)FB Loss of Division II Safeguard 125/250V DC BUS 1FB 6. E-1(2)FC Loss of Division III Safeguard 125/250V DC BUS 1FC 7. E-1(2)FD Loss of Division IV Safeguard 125/250V DC BUS 1FD Month 20XX LGS 3-84 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU45 I Initiating Condition:
Loss of all onsite or offsite communications capabilities.
Operating Mode Applicability:
4,5, 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 Station Radio X Plant Public Address (PA) X Prelude System X X Station Phones X X X Satellite Phones X X X NARS X HPN X X ENS X X J I _ _ _ _ l I
* _ JP LI -- In _ !-- ----tL ....... ."-- --..... ll-- -- -I--to LOSS,;&#xfd;. EOT MAL !La r-T ftne T~I OW% flO T. ur W.m1iato T-i ..FT 1 w dT..JI. L *XA 1 t ---. ...--- .tsite specdk list Of GOMMUnIcatiOnS..
metnoa)') Inr of Al I ~-I kAth faljnru~na R Q a~cirm nialm rnmu,+d. -(cite 69ocific-lisit of co-emmunicationA moethoe&4 Month 20XX LGS 3-85 EP-AA-1008 (Revision XX)
Simeric~k Gener~atinn Station Annexv Exelln Nucle~ar RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS
: 2. Lss of ALL of the followiOng NRC OM comuications_
m~ethods Basis: This IC addresses a significant loss of on-site, -er-offsite, or NRC communications capabilities.
While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).EAL #1 Basis aAddresses a total loss of the communications methods used in support of routine plant operations.
EAL #2 Basis aAddresses a total loss of the communications methods used to notify all OROs of an emergency declaration.
The OROs referred to here are listed in procedure EP-MA-1 14-1 00-F-01, State / Local Event Notification Form (see Developer Notes).EAL #3 Basis aAddresses 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. UFSAR Section 9.5.2, Communication Systems 3. SE-12 Loss of Communications Month 20XX LGS 3-86 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CA53 Initiating Condition:
Inability to maintain the plant in cold shutdown.Operating Mode Applicability:
4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the AleFtevent promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature 
> 200OF due to loss removal for > Table C2 duration.of decay heat 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*Not Established 0 minutes* If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not applicable.
OR 2. UNPLANNED RPV pressure rise > 10 psig as a result of temperature rise due to loss of decay heat removal.1. UN PLA~NNED increasce in RCS temperature to greater than (site specific T~ankn na I Qnaneifnh2tin naldabutdaw ,r~~.n tarna rntu ,rn Nmet! famr a ranar than'. tha 14 1. r. A ; 9&#xfd; 9-ii ki tit-Clt 'dH tPpt:b 0 "t 0 vdw "q to m Month 20XX LGS 3-87 EP-AA-1008 (Revision XX)
I::xalon NudAar Limericvk Gnrartinv Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS T-a-ble: RDCS3 Hatup Du,-.ratian Thresholds Cona- nn Me n t C I --u-re ______RCSStau.Status Heat up Dur-ation reducod not liappliGa IN -tIA- A-Not intact (or at red ucod ~stabhlhs 20 monutes*mivelteFy-fPW4R])
Not Eistablished 9 inutes* If an RCS heat rcmeyal system is in opcration within this time frame and RCS temperatur~e is being reducod, the EAL is not applicable-.
.UNIPn ANINE RCS prssure inr.ease greatr mthan (site reading). (This =AL= doer, not apply durinig water- so0lid plant conditions.
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 (primary or secondary for BWR) 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, or steam line nozzle plugs, 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 an 4iR-easerise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact.7 Or RCS is- reduced (e.g., mid loop operation in The 20-minute criterion was included to allow time for operator action to address the temperature The RCS Heat-up Duration Thresholds table also addresses ao iRGeaserise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not Month 20XX LGS 3-88 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature ieaserise without a substantial degradation in plant safety.Finally, in the case where there is aw i4reaserise in RCS temperature, the RCS is not intact Or is at redued in.ento.; 
[P.., Rj, 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 provides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS64- or RASI.Basis Reference.():
: 1. NEI 99-01 Rev 6, CA3 2. Technical Specifications LCO 3.6.5.1, Reactor Enclosure Secondary Containment Integrity 3. Technical Specifications Table 1.2, Operational Conditions
: 4. DBD L-S-16, Reactor Instrumentation System (RIS)5. UFSAR Section 6.2, Containment Systems 6. UFSAR Section 6.3, Emergency Core Cooling Systems 7. Technical Specifications LCO 3.6.1.1, Primary Containment Integrity 8. ST-6-107-640
: 9. ST-6-107-641
: 10. GP-6.2, Shutdown Operations-Shutdown Conditions Tech Spec Actions Month 20XX LGS 3-89 EP-AA-1008 (Revision XX)
I imariek (' Zonarnfinn Afnfinn AnnaX ExAIon Nuclear I im~ri~k (onanmtin 
~~atin An~vExelnn Nuclea~r RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU53 Initiating Condition:
UNPLANNED ieaeerise in RCS temperature Operating Mode Applicability:
4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual Eventevent promptly upon determining that the applicable time 1-5-- iutee-has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature 
> 200OF due to loss of decay heat removal.OR 2. Loss of the following for >15 minutes.ALL RCS temperature indications AND* ALLRPV water level indications
: 1. UNPLA.NNED incr~easr.e in RCS G temperature to greater than (site specific Technic~al Specification cold shutdol.wnfl temperature limit).-2. Loss of ALL RCS temperature and reactor vesseVRCS; lev.el indication for 15 minutes Or longer.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 (primary or secondary for BWR) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.
This IC addresses an UNPLANNED iRreaserise 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 Month 20XX LGS 3-90 EP-AA-1008 (Revision XX)
I=xAInn  Simeric~k CGAneratinn Station Anne~x Exelnn ucleanr RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS 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 CA53.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, or steam line nozzle plugs, 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.
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 inGreaserise 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 CA64- based on an inventory loss or IC CA53 based on exceeding plant configuration-specific time criteria.Month 20XX LGS 3-91 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):
: 1. NEI 99-01 Rev 6, CU3 2. T-102, Primary Containment Control -Bases 3. DBD L-S-16, Reactor Instrumentation System (RIS)4. ST-6-107-640-*
RX Vessel Temperature and Pressure Monitoring
: 5. GP-6.1 U/1(U/2) Shutdown Operations 
-Refueling, Core Alteration and Core Off-Loading
: 6. ST-6-107-641-*
RX Vessel Temperature and Pressure Monitoring with no RHR Shutdown Cooling Loops in Operation 7. GP-6.2, Shutdown Operations-Shutdown Conditions Tech Spec Actions Month 20XX LGS 3-92 EP-AA-1008 (Revision XX) l=xAInn N.nlAar Limeric~k (GAnerztinn Staition Annex Exelnn Nuclezar RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CG64-Initiating Condition:
Loss of RPV inventory affecting fuel clad integrity with containment challenged.
Operating Mode Applicability:
4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the Gen-ral -- --ergecye vent promptly upon determining that the applicable time 3Q-miites-has been exceeded, or will likely be exceeded.1. a. RPV water level < -161 inches (TAF) for > 30 minutes.AND b. ANY Containment Challenge Indication (Table C4)OR 2. a. RPV water level unknown 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" ANY Table C5 Refuel Floor Area Radiation Monitor >3 R/hr.AND c. ANY Containment Challenge Indication (Table C4)I Month 20XX LGS 3-93 EP-AA-1008 (Revision XX)
Limeric~k Generatina Station Annex Exeonn Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression Pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.
Table C4 Containment Challenge Indications
* Primary Containment Hydrogen Concentration 
> 6% and Oxygen > 5%.* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established*
* Any Secondary Containment radiation monitor > T-103 / SAMP Max Safe Op Value (MSO).* 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.Table C5 Refuel Floor ARM's" RIS29-M1-1(2)K600, Drywell Head Laydown" RIS30-M1-1(2)K600, Dryer / Separator Area" RIS31-M1-1(2)K600, Spent Fuel Pool* RIS32-Ml-1(2)K600, New Fuel storage Vault* RIS33-M1-1(2)K600, Pool Plug Laydown i. a. (Reactor v:occolRCS level less than (site sepoific leveol) for 30 mninutec orF AND 19. ANY andicatien from the Cotanen hallenge Table (see below).2. .Racator veccoU1CSZ level cnnont be4 monitored for 30 min-toc or longer.Month 20XX LGS 3-94 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSb. Cor ucoinve ry is indicated by ANY of the fowl.ng: e (Site specific radiation moenitor-)
reading greater- thant (site speeific value)* Eratic source range moenitor-indicationt UUNPLANNED inAcrease in (qite s i ump and/ot r tank) levels of suffiente magnitde to indicate ore unover]n I (Other site speeifin indications)
AND G. ANY ondicatien roem the Containment challenge Table (see belw).CoGntainment Challengo Table CONTAINMENT CLOSURE not establishedl (Explosive mixture) eKists inside contiffnment-UNPLANNED inemase in containmentupressrfe TI IC ONTAINdrENT CLOSURE a ii e established prino to rXccoding the 30 minute time limit, then declaration of a Genecral Eim gen .t required.Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.IMMINENT:
The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary for BWR) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.
This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged.
This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity.
Releases can be reasonably expected to exceed EPA Protective Action Guidelines (PAG) exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.Month 20XX LGS 3-95 EP-AA-1008 (Revision XX)
Limerick Generi inn Station Annex Exelnn Nucler~I RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS 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.
EAL 2.a 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 RP-V-IleyeIRPV water 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 RPV.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
Month 20XX LGS 3-96 EP-AA-1008 (Revision XX)
I imarirk I'Ziangarnfin
_Qfnfinn Annov PginY~rn , nr~lanr RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):
: 1. NEI 99-01 Rev 6, CG1 2. T-102 Primary Containment Control -Bases 3. T-103 Secondary Containment Control -Bases 4. DBD P-S-20, Neutron Monitoring System 5. DBD L-T-02, Containment, Section 3.2.14 6. Technical Specifications 3.6.1.1, Primary Containment Integrity 7. Technical Specifications 3.6.5.1, Reactor Enclosure Secondary Containment Integrity 8. UFSAR section 6.2.1.1.3.1, Summary Evaluation
: 9. EP-AEL-0501, Estimation of Radiation Monitor Readings Indicating Core Uncovery During Refuel 10. T-101 RPV Control -Bases 11. SAMP-2, Containment and Radioactivity Release Control Month 20XX LGS 3-97 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CS641 Initiating Condition:
Loss of RPV inventory affecting core decay heat removal capability.
Operating Mode Applicability:
4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the Sit.eArea F.-=r-.e..,yevent promptly upon determining that the applicable time 320minutes-has been exceeded, or will likely be exceeded.1. With CONTAINMENT CLOSURE not established, RPV water level < -129 inches OR 2. With CONTAINMENT CLOSURE established, RPV water level < -161 inches (TAF).OR 3. a. RPV water level unknown 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" ANY Table C5 Refuel Floor Area radiation Monitor >3 R/hr.Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression Pool level rise*" UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.
Month 20XX LGS 3-98 EP-AA-1008 (Revision XX)
I imprink ranamfinn Atnfinn Annoy Fvalnn N~i-lonr Ill Im ik I I bn VII n I III A nbvFvln .iVhUu RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS Table C5 Refuel Floor ARM's" RIS29-M1-1(2)K600, Drywell Head Laydown* RIS30-M 1-1 (2)K600, Dryer / Separator Area" RIS31-M1-1(2)K600, Spent Fuel Pool* RIS32-M1-1(2)K600, New Fuel storage Vault" RIS33-M1-1(2)K600, Pool Plug Laydown I I" I I:4. .-G 0N-44.....N 1-08~~r L4 RLUnot esi O btp IGI clp.-AM level)-1 :2 ,-R CONTlAINMlNlT C S1 I ,tlhoI-AND Ho 0 m 0XI 0 1 11 4.1&#xfd;k efl -V60 Gmto-VN1 0APve.+00-CH f t r&#xfd;IA&#xfd; ---% I r-1 A &#xfd;&#xfd;l .I-(I'&#xb6;eac~or ansei~r-a~
I-'V'I-I r t-&#xfd;i--'..
tT'.'m ao.o Cflfl0 mi moitrnoTo .iu mAnuto oFr longor.--------------
0- -- ---.. .AMD k ('r% .rn.,n nn&#xb6;GaII A 1.IV ^f *ka 11* *** j l*-------------------
C W I UILV I '..... -r o 1;4fatic seurce range monitor ma1ication
-, b'- '' ~9 pr~~~A tiinueffa tn tsite ,peecii SUfM3 aflWEr- funilH feVefi, 0.-u ,IlCIIte!- -- .-- -I f ma~niiucio w inui~uie v~re uncuven,'* 1= *" \.uiner ~ne succino inaicanonsi Month 20XX LGS 3-99 EP-AA-1008 (Revision XX)
I::yAInn N.nlAar Limerick (GAnerstinn Station Annex Exelnn Nuclesar RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS 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 (primary or secondary for BWR) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.
This IC a 6;4-9Rgant and prolonged I,. of R\ ;R " inntorcontrol ,a'nd , makeup apability lading to IMMINENT fuel damag. 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 difference in the specified RCS/reactor vessel levels of EALs #1-b and#2- reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.
In EAL #3.a, 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 RPV-levyeRPV water 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 RPV.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 CG4-6 or ARGI.Month 20XX LGS 3-100 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):
: 1. NEI 99-01 Rev 6, CS1 2. Technical Specification Table 3.3.2-2 3. T-101 RPV Control -Bases 4. T-102 Primary Containment Control -Bases 5. T-103 Secondary Containment Control -Bases 6. DBD P-S-20, Neutron Monitoring System 7. DBD L-T-02, Containment, Section 3.2.14 8. Technical Specifications 3.6.1.1, Primary Containment Integrity 9. Technical Specifications 3.6.5.1, Reactor Enclosure Secondary Containment Integrity 10. DBD L-S-34, Radwaste System Month 20XX LGS 3-101 EP-AA-1008 (Revision XX)
Nuclaar Limeric.k Station Annex Exmvon  RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA641 Initiating Condition:
Loss of RPV inventory.
Operating Mode Applicability:
4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the event AleFt-promptly upon determining that the applicable time 46r-miuttes-has been exceeded, or will likely be exceeded.1. a. Loss of RPV inventory as indicated by level < -38 inches.OR 2. a. RPV water level unknown for > 15 minutes.AND b. Loss of RPV inventory per Table C3 indications.
Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression Pool level rise*" UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory..Losof reacotor esoRCinntr'ass ind-ic-ated by level loss than (Site specsific Ieive+)2. a. Reactor veSselIROS level cannot be monitored for 15 mninutes Or longer AND b. UNPLvANNED in.cease in (site specific sump and/or tank) levels due t loss of reactor vossel/RCS inventor;-.
Month 20XX LGS 3-102 EP-AA-1008 (Revision XX)
I imariek rtanarnfinn Afnfinn Annoy F:yalnn Nnnr~la=r I imorirgvw (vnwvzutiww vt~winn Animw FvInvw N w  RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS 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.F-er-EAL #1T Basis-aA lowering of water level below -38 inches (site level) indicates that operator actions have not been successful in restoring and maintaining RPV water level. The heat-up rate of the coolant will if, feaserise as the available water inventory is reduced.A continuing deGrease-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). Ae i rise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA53.Fef-EAL #2 Basis ,4The inability to monitor RP-V-LeveIRPV water 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 RPV.The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS64-If the RPV iwent.e--water level continues to lower, then escalation to Site Area Emergency would be via IC CS64.Basis Reference(s):
: 1. NEI 99-01 Rev 6, CA1 2. Technical Specification Table 3.3.2-2 3. Technical Specification 3.4.3, Reactor Coolant System Leakage 4. ARC-MCR-213-E3 Div 1 Reactor Lo-Lo-Lo Level 5. DBD L-S-16, Reactor Instrumentation System (RIS)6. DBD L-S-34, Radwaste System 7. T-102 Primary Containment Control Month 20XX LGS 3-103 EP-AA-1008 (Revision XX)
I:l(Alnn N.nlAAr Limericvk vwvneaw-tinn Station Annex Exvavwn Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU6- I Initiating Condition:
UNPLANNED loss of RPV inventory for 15 minutes or longer.Operating Mode Applicability:
4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual E.ventevent promptly upon determining that the applicable time 15-*nutes--has been exceeded, or will likely be exceeded.1. UNPLANNED loss of reactor coolant results in the inability to restore and maintain RPV water level to above the procedurally established lower limit for> 15 minutes.OR 2. a. RPV water level unknown AND b. Loss of RPV inventory per Table C3 indications.
Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise*" UNPLANNED Suppression Pool level rise*" UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.
: 1. UNPLAlNNED 1loS Of reactor coolant reSultS in reactor vessel!ROS level less than a r ed Wer limit for 15 mnuteqs; r longer.i&#xfd;. a. KeaGTor vessovn-z.i level cannot DO monnoreG.-
AND la UNI-'LA1414M~
inGrease in 6118 WeDCITI SUmo anwor ialK~ levels.113a. 8is:-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 20XX LGS 3-104 EP-AA-1008 (Revision XX)
ExAIon Nuclear Limeric~k Generatinn Station Annex Exellon Nuclea~r RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS 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 RPV IevIRPV water 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.The procedurally established lower limit is not an operational band established above the procedural limit to allow for operator action prior to exceeding the procedural limit, but it is the procedurally established lower limit.Refueling evolutions that 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 Basis fRecognizes that the minimum required RPV-leveIRPV water level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented.
This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.EAL #2 Basis aAddresses a condition where all means to determine RI2-Veve!RPV water 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 RPV.Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA6-4 or CA53.Basis Reference(s):
: 1. NEI 99-01, Rev. 6 CU1 2. Technical Specification Table 3.3.2-2 3. ST-6-107-596-1 DiywellDrywell Floor Drain Sump/Equipment Drain Tank Surveillance
: 4. Technical Specification 3.4.3, Reactor Coolant Leakage 5. Technical Specifications 3.9.8, Water Level -Reactor Vessel 6. DBD L-S-34, Radwaste System 7. OT-101 High gFyweliDrywell Pressure 8. T-102 Primary Containment Control, Table DW/T-1 9. GP-6.1 U/1(2) Shutdown Operations 
-Refuel Core Alterations 
& Core Off-loading Month 20XX LGS 3-105 EP-AA-1008 (Revision XX)
Nuclear Limeric. k G. neratinn Stantion *Exmn Nii..Inler RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS
: 10. DBD L-S-16, Reactor Instrumentation System (RIS)Month 20XX LGS 3-106 EP-AA-1008 (Revision XX)
I imarink (.anarnfinn Afnfinn Annoy Fvnlnn NimP.Ionr I imiwir~k (~nr2tinn 
~t~tinn Anng~v Fv~Inn NiIr~In2r 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, D Emergency Action Level (EAL): 1. A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.AND 2. a. ANY Table H1 safety function cannot be controlled or maintained.
OR b. Damage to spent fuel has occurred or is IMMINENT Table HI Safety Functions" Reactivity Control (ability to shut down the reactor and keep it shutdown)" RPV Water Level (ability to cool the core)RCS Heat Removal (ability to maintain heat sink)I 1 .a. A. HU V LL N :+K A" N 16 occurrina or nAM occurrea WRnIn Mne PdW I t6 I L A D1A rc rv,mA~r k.~ +k~ t +t if, I.tu t k ft rl nriullilUlWlrt 
*..- I w3pT c c bpwk ki owba %-- -bt b rdV 5/f.AND b. EITHER of the follow.n.
ha, ocured:.I1. A.NY o-nf t-h e follo(wing sgafety functionrb c-annot be8 conrolldo" Reactivity control" Coe e~alfing" RCS heat remoeval 044 2. Damage to SpenRt fuel has occurred or is IMMINENT.Month 20XX LGS 3-107 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY 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.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].Emergenc~y plans and implementing procedures are public documents; thorefore, E=ALes should not inorporI9Ate S-ecurity soesitive ifraonThic nlue informat4ion that may be adI'_ta :ious t a potenti .uch as the partic.-uar.
tcifll__in throat Or threat Icatien. Security censitivo infermation should be Month 20XX LGS 3-108 EP-AA-1008 (Revision XX)
I imarirnk rwangarnainn Atatinn Annoy Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY contained in non public documents such a466 the Security Plan.Basis Reference(s):
: 1. NEI 99-01, Rev. 6 HGI 5. Station Security Plan -Appendix C Month 20XX LGS 3-109 EP-AA-1008 (Revision XX)
Limerick Generatina Station 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, D Emergency Action Level (EAL): A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.1. A HOSTILE ACTION is -c-urring Or has ocurr-ed within thc PROTECTED-AREA. as reported by the (site specific.
secr.ity shift supervision).
'Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment.
Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Month 20XX LGS 3-110 EP-AA-1008 (Revision XX) l:xAlon N.clAar Limeric~k Genergating Stsation Annex Exelnon NucleIAar RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY 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 HA1. 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 &sect; 73.71 or 10 CFR&sect; 50.72.cAEmorgncy plans and implementing procedures are public docauments; therefore, EAI~s shouldd not incorpor~ateA S-ecrmity 6eonsitiye information.
This inclu-des inform=at-ion that mnay be advantageous to a potetial aadhg.'esary, SUch as the particulars concerning a specific threat Or threat location.
Security sensitiv:e infor~mation should be-cnandi non public documnents suc-h as the SecUrity Plan.Escalation of the emergency classification level would be via IC HGI.Basis Reference(s):
1I. NEI 99-01 Rev 6, HSi 3. Station Security Plan -Appendix C Month 20XX LGS 3-111 EP-AA-1008 (Revision XX)
Limerick Generating Station AnnayNiilaln=r LimArir~k 
(~AnArsatinn 
~tntinn Anni~w Fv~Inn N.ar~I~~ar 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, D Emergency Action Level (EAL): 1. A validated notification from NRC of an aircraft attack threat < 30 minutes from the site.1. A HOST4LE ACTION4 is eouring or- has occurred within the OWNER CONTRLLEDAREAas reported by the (site specific security shift super-vision).
OR 2. Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.A v.alidated notificationl from NRC of an aircraft attack threat within 30 minutes et the ste 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.Month 20XX LGS 3-112 EP-AA-1008 (Revision XX)
I imprink rvanarnfinn Stntinn Annoy I=yAInn  I imrir~ (~n~r~tnn 
~atin Annv Falnn WiIt-lcgr RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT 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.
This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).
The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR &sect; 73.71 or 10 CFR &sect; 50.72.EAL #1 Basis 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 SE-23, Security Threat.EAL #2 Basis--is-aApplicable 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.Month 20XX LGS 3-113 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY EA.L #2 add_..s....
tho the imp.ct of an ai-rcaft on the plant, and the anticipated arri'..a!
time is within -30_ minutes. The intent of this EA'_ is to enSUre that threant reaed noific-ationAs -are ma-d-e i~n -a timely manner son that plant personnel and OROL; arc in a heightened state oif readiness.
T~his EA Is met when the threat reated information ha been valid-ated in accordance with (site specific procedure).
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.I_ I! _ J ....... *-- *L Z- --- fiA I -hmnrnnn~'!
nrnnn inn imninmenrino nrocnaure~
are nunuc nocumnnrn:
inereroro.
tJ~Lc ............................
~--should I Security senitie IThis il in othat m:aV be wdatgos to a Detential advcesar:.
such aS the Darticulars conernn a--v fha ok~'~ r thrpmt Inntn Rianud, ,Rjh, ti inf,~rvvatfo em ik' he rnentainM n* 5L U*5b SdS5-------- -----9-Escalation of the emergency classification level would be via IC HS1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, HA1 2. Station Security Plan -Appendix C 3. SE-23 Security Threat Month 20XX LGS 3-114 EP-AA-1008 (Revision XX)
LimArit~k fl~nari~tinn 
~tsatinn Annax Limerick Generatinn Station 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, D Emergency Action Level (EAL): 1. Notification of a credible security threat directed at the site as determined per SY-AA-1 01-132, Security Assessment and Response to Unusual Activities.
: 1. A SECURITY CONDITION that does not inolve a HO1STILE ACTION&#xfd;T as r.eported by the (site specific security shift supe...ision).
OR 2. A validated notification from the NRC providing information of an aircraft threat.2. Notification of a cr-edible security threat dir-eeted at the site.OR 3. Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.3 A notification from the NRIC inform;ation of an a-r..aft threat.-.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.Month 20XX LGS 3-115 EP-AA-1008 (Revision XX)
Simeric~k Generatinn Station Annex Exelon NuclIear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.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 &sect; 73.71 or 10 CFR &sect; 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.
roforoncos .pecific socu.ity shift OR) bocauso these are the individuals trainedto c fhat a securiy eventi occuFrring or has ...urrod. oecuity event confirmation and c.ntroilled-due to the nat-ure Of nd 10 FR &sect; 2.39 "nfmatien.
EAL #2 Basis aAddresses 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 SE-23, Security Threat (site specifc p.O.edure).
add .esses the .e..,pt of a credible security threat. The credibility of the threat is assessed in accordance with (site specific pr49reduwe)-
EAL #3 Basis fReferences Security Force(site specific security shift .upeision) -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 &sect; 2.39 information.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 (site-specific procedure).
Month 20XX LGS 3-116 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Em~ergency P18Ac and implementing procodure aro public dOcum~ents; thoreforo, EJ\Lc h nt Securlity Ion iti'.Ie information.
Thi, iIcludic i nhis rm ion thit m-ay be advantageous to a pe ntial+adea+,', uh as the paticular6' concerig. 
, epeci thea or.throat location.
Security cencritiov informnation- -hould be cOntai f ha rtrna ;ned in non public, dUcmentl 1Uch a. the 8GuriF-., Plan.Escalation of the emergency classification level would be via IC HA1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, HU1 2. Station Security Plan -Appendix C 3. SY-AA-1 01-132, Security Assessment and Response to Unusual Activities Month 20XX LGS 3-117 EP-AA-1008 (Revision XX)
Fvtalnn Nau-Inar Limerick GAn.r.tinn St1ation Annex ..alnn 111.11 RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS26 Initiating Condition:
Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:
1, 2, 3, 4, 5, D Emergency Action Level (EAL): Note: The Emergency Director should declare the Site Arpa Eme..e.G--yvent promptly upon determining that (site spoGific number of the applicable time Mifutes) -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: " SE-1, Remote Shutdown OR" SE-6, Alternate Remote Shutdown AND 2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.Table HI Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)I. a. An ovent has roculted in plant conrol1 being tranefeFred panels, and locna!contro stations).
from the Control Room to (site epecific remote shutdow AND b. Control oif ANY of tho following key safet functiens is not reectablished within (cite re~oific number of minutes).-
9 ReactiVity control* ..^&^. r&#xa3;)lAIl::)l I heat I8 IV JI V ww l i v "J Month 20XX LGS 3-118 EP-AA-1008 (Revision XX)
I=xAIon  Limeric~k Generatinn Sta~tion Annex Exeoln Nuclekiar RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY 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 one or moroany-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 (the site-. .pe..f timefGF ef) 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).
Escalation of the emergency classification level would be via IC FG1 or CG6--.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HS6 2. SE-1, Remote Shutdown 3. SE-6, Alternate Remote Shutdown Month 20XX LGS 3-119 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA26 Initiating Condition:
Control Room evacuation resulting in transfer of plant control to alternate locations.
Operating Mode Applicability:
1, 2, 3,4,5, D Emergency Action Level (EAL): A Control room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per: " SE-1, Remote Shutdown OR" SE-6, Alternate Remote Shutdown An event has roculted in plant cOntro beinig traneferrod fromA the Conrol1 Room to (SiteremOteA ohtW, pane'ls and lecal control 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 HS26.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HA6 2. SE-1, Remote Shutdown 3. SE-6, Alternate Remote Shutdown Month 20XX LGS 3-120 EP-AA-1008 (Revision XX)
I imariek rtanarnfinn Afnfinn Annoy Fvalnn Niemlanr I img~rir~k 
(~n~r~a*inn 
~t2tinn Annoy Fwalnn .ir~Io~r RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU34 Initiating Condition:
FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:
1, 2, 3, 4, 5, D Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual Eenttvent promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of the following FIRE detection indications:
S 0 0 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" Reactor Enclosure (when inerted the Drywell is exempt)" Control Enclosure" Diesel Generator Enclosure" Spray Pond Pump House / Spray Network OR 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 2.3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication.
Month 20XX LGS 3-121 EP-AA-1008 (Revision XX)
I imprirk rj&nPrafingqfskfinnAnnPX Fvplnn Nw-Ia~r I,,,,v,,v.k ( ..v, .=.=-il .v,=in -- RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY OR 4 A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.
(4\ -- A i~rll"Jlr" : kl/rV"lr --,,,I.:-- -,,: J , L,:.. 4 C .. _ --4 .A I.I 4L I ,-I I HI J a. A~ r-Im is 1401 extneuised T nl MU~AL n.LIII IUr QIIIUU ANY etJ th UI IIU:ui1R~i FIRE detection idctos 0 0 %r+,ss f-.rv. tha f.iald (o ~ae .-otua nintn v P, ..1 Z&#xfd;W lafnwT&#xfd;Jwa W&#xfd; ax&#xfd; a-!j w A* ~~.IJL
* It I~uUt5~.~* 
~I 5 .. -LI SLAIN 5/ .5. SL.I I S II IV 0 riiiu YeFIRIIUUiU[1 of a sina.jle TIL; UIUI i AND Lo. -tH 1=1 ft'. ;L. Iu0..tuu~t W~.;H;;I fl-f; t~ t; tL110WH. V**~ CttFDPIPO 
~S (site specific liSt Of plant rooms or areas)--Z -- &#xfd;z a ReCOmyT ef a sinaio rire aiarmT ii.e.. SO efnRe indicatiw%
of a Fu-1i ---- -- --- --AIND-1W Vig I f I I J gI csite soeGII:H list OT roo mOr aleas4 A kll'll.AND-c. The existene- of a FIRE is not within 30 meinutes of alalrm receipt.(3) A FIRE within the plant or ISE=Si [for- Plants with aon IfWSI o-utside the pln Dr,-'jpp4=a 1212C)= .. PikprI oiAhiv Arl mnt itp Qfthin Wfiial renort alarmA Or inldigatiOn I-., -9 IAN A W~itflifl e niant or IN-I-N! =Fn WaRn?5 mlm Anf !IIk-NI PFl!T~tpyd me flwflfl\'/5 P...te.tedAr.ea.
PR O TED AR.EA that requires fir.fi.htinaMCI r"suoort by an___ --L." .... :__ L on-Uita Trem Fesoons aaoncGV r exunaIRR ---------,-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 Month 20XX LGS 3-122 EP-AA-1008 (Revision XX)
Limeric~k Genersatinn Station Annex Exelon N~uelanr RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY 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. This extonds to a FIRE= ..cur. g ihin the Month 20XX LGS 3-123 EP-AA-1008 (Revision XX) l::yAInn  Limeric~k flenerainn Stsation Annex Ex.eInn Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY PRTEC TED A RE A of arn IS I,-loated -outsd -ahMe plant PROTE/"CTED A REA4.[Sentence for plants with an ISFS-RI ounsid-a the plant Pm0tectdAmea]
EAL #4 Basis If a FIRE within the plant or iSFSI [fo 1plant6 with an ISESI oL'.s.de the plant&#xf7;P..ec.e Areal-PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded.
The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish.
Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part: Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions." When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.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 CA26 or MSA50.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HU4 2. Specification NE-0294, "Fire Safe Shutdown Analysis Specification" Month 20XX LISS 3-124 EP-AA-1008 (Revision XX)
I imarie-k rZonaratin Afnfinn Annow FxAlnn  I imkriie (~n~rninn 
*~tin An~v xelon Nucler~i RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU42 Initiating Condition:
Seismic event greater than OBE levels.Operating Mode Applicability:
1, 2,3,4, 5, D Emergency Action Level (EAL): Seismic event > Operating Basis Earthquake (OBE) as indicated by: " ARC-MCR-00C693, WINDOW B1, OBE EXCEEDED alarmed OR* OBE red light is lit at panel 00C693 SemicFi event greater than Operating Basis Earthquakc (0BE) as indicatedby
: a. (site specific indication that a eei vent met or eXceeded OBEF limits)Basis: This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (OBE)'. 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, 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.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA26 or MA5.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.
MoSEi irtoygon ointhforXLG 3h125 cran(eerally, 008et (revisineX)
Month 20XX LGS 3-125 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY S"g.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HU2 2. SE-5, Earthquake
: 3. ARC-MCR-00C693 B1, OBE Exceeded Month 20XX LGS 3-126 EP-AA-1008 (Revision XX)
I imarink (tanarnfinn Afnfinn Annoy I:=Yalnn Ni~rlan=r 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, 3,4,5, 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 a Table H3 area.Table H3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Enclosure Modes 3, 4, and 5 AND 2. Entry into the room or area is prohibited or impeded No-te: If the equipment in the li-teAd- room Or area wars already inoperable or out of veer-ie before the eent occurred, then no emnergency classification is wa~ante4d-(1) a. Release of a toxiccroie asphyxiant Or flammable gas into any of the following plant roome or areae:&#xfd;~.!LL. ~J.... -IA.J ~...J.~F'~'iT ~1'T"'iI'f- " I~W 'I~f FW'~' FV-~1 ~ W, -~ffI11 appliailt ietiid--ANQ h. Entry into the room or area is. Drahibitod or imoodo 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.
Maintain normal plant operation, Or ..quir. d for a norm.al plant coodown and shutdown.
This Month 20XX LGS 3-127 EP-AA- 1008 (Revision XX)
Limarick r-anarating Agginn Annoy Fvalnn NnMar~l: I imnrir~k (~An~rsatinn 
~t~tinn Ann~v Fwailnn Miur~h'~zar RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY condition represents an actual or potential substantial degradation of the level of safety of the plant.Table H3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown.
This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
This Table does not include the Control Room since adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas.An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the gaseous release preclude the ability to place shutdown cooling in serviceat the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
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 20XX LGS 3-128 EP-AA-1008 (Revision XX)
I imarid-k ranarafinn Atnfinn AnnoyNuclear I imrii~ (~n~r2inn t~tnn An~vExelnn Nuclea~r RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment.
This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that generate smoke, that automatically or manually activate a fire suppression system in an area, or to intentional inerting of containment.
Escalation of the emergency classification level would be via Recognition Category RA, C or F ICs.Basis Reference(s):
: 1. NEI 99-01, Rev 6HA5 Month 20XX LGS 3-129 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU63 Initiating Condition:
Hazardous Event Operating Mode Applicability:
1, 2,3,4,5, 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.
: 1. Tornado strike within the PROTECTED AREA.OR 2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating mode.OR 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).OR 4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.OR Not&: EAI 93 does no9t apply to- roautinge traffic impediments Asuc-h as fog, snow, ice, or vehicle beakdW OF... or aidentG-.(1) A tornado WI;thin t he PROTECTED AREA.(2) Internal room or aarea flooeding of a magnitude suffic-ient to reqir manal or automatic ectIca irsolation of a SAFETY&#xfd; SYSTE:M copoen needed for the, current operafing m vde.(3) Movement of personnel wvithin the PROTIEC-TED AREA. isipdddue to an v ffsite evenIt involving hazardous m Vaterial (o.g., an oflite chemlical Spoil Or toxic la Fellease*7V Month 20XX LGS 3-130 EP-AA-1008 (Revision XX)
I imprink rtanpmfinn Afnfinn Annoy IFvalnn MN~arlr I imarir~k (~c&n~r~a*inn 
~t~atinn Ann~v Fv~Inn N.it~Ig~ar RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY (4) A hazardou, evont that results in on site conditions 6uf49cion to prohibit the plant.staff from. _accessing tho site v.ia personal41 yehocles (5) (Site specific list o-f naturaal Or tecGhnological hazard events)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 aAddresses a tornado striking (touching down) within the Protected Area.EAL #2 Basis aAddresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode. Manual isolation of power to a SAFETY SYSTEM component as a result of leakage is an event of lesser impact and would be expected to cause small and localized damage. The consequence of this type of event is adequately assessed and addressed in accordance with Technical Specifications.
EAL #3 Basis aAddresses 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 aAddresses 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 Month 20XX LGS 3-131 EP-AA-1008 (Revision XX)
I imri- 9' Znarnfinn -Q*ninn Annoy I::Yalnn  U RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY 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.'Al 95 addressoe (sito Escalation of the emergency classification level would be based on ICs in Recognition Categories RA, F, M9, H or C.Basis Reference~s):
: 1. NEI 99-01, Rev 6 HU3 2. UFSAR Section 3.4.1, Flood Protection
: 3. UFSAR Section 6.2.1.1.1, Design Bases 4. SE-5 Earthquake 5 SE-4 Flood 6. SE-9 Preparation for Severe Weather Month 20XX LGS 3-132 EP-AA-1008 (Revision XX)
Exelon Nuclear Limerick floneratinn Station Annex Exelnn 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, D Emergency Action Level (EAL): (41) Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.Basis: IMMINENT:
The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a General Emergency.
Basis Reference(s):
: 1. NEI 99-01, Rev 6 HG7 Month 20XX LGS 3-133 EP-AA-1008 (Revision XX)
I imprink rpnprntinn Afatinn Annoy IFyalnn NMin-Ionr 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, D Emergency Action Level (EAL): (-14 Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a Site Area Emergency.
Basis Reference(s):
: 1. NEI 99-01, Rev 6 HS7 Month 20XX LGS 3-134 EP-AA-1008 (Revision XX)
I imariek rZonarnfin Atatinn Annov Fyalnn Niiela2r I im~riuk (~n~r~*inn 
~*~*inn Annoy Fvolnn MEII,102r 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, D Emergency Action Level (EAL): (-1-) Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HA7 Month 20XX LGS 3-135 EP-AA-1008 (Revision XX)
I=xAInn  Limenrick tGAnerztinn Station Annex Exelnn Nucler~I 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 (NOU-UNUSUAL EVENT.Operating Mode Applicability:
1, 2, 3, 4, 5, D Emergency Action Level (EAL): (1-) Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.
No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an NQUE-UNUSUAL EVENT.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HU7 Month 20XX LGS 3-136 EP-AA-1008 (Revision XX)
I im~rit* (~An~ratinn 
~t*tinn AnnAY I::Yalnn Nind-la==r Limerick Goneratinn Station Annex RECOGNITION CATEGORY ISFSI MALFUNCTIONS E-HU1 Initiating Condition Damage to a loaded cask CONFINEMENT BOUNDARY.Operating Mode Applicability:
1, 2,3,4,5, D Emergency Action Level (EAL): Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading:* > 1400 mremlhr on the HSM or HSM-H front surface (applicable to type 1 61BTH DSC only)OR* > 800 mremlhr at 3 ft from the HSM surface (applicable to 61BT DSC only)OR* > 200 mremlhr on the HSM or HSM-H door centerline OR* > 40 mrem/hr on the end shield wall exterior (1-.
to a loaded ca.k CONFINEMENT BOUNDARY a6 indicated by an on contact radiation reading greater than (2 times the site specific.
cask epecific technical 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 one Or moreany fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.Month 20XX LGS 3-134 EP-AA-1008 (Revision XX)
I imariwi- (' Znarnfinn
_Qffirn Annav IPvalnn khu-lanr RECOGNITION CATEGORY ISFSI MALFUNCTIONS The existence of "damage" is determined by radiological survey. The technical specification multiple of "2 times", which is also used in Recognition Category RA IC RAU, 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 ISFSIs are covered under ICs HU1 and HA1.Basis Reference(s):
: 1. NEI 99-01, Rev 6 E-HU1 2. Limerick Generating Station ISFSI 1OCFR72.212 Evaluation Rev 6 Attachment 1 3. OU-LG-643, Transport of Loaded Transfer Cask and 61 BT dry shielded Canister to Transfer Trailer, to ISFSI, and Alignment/Insertion into Horizontal Storage Module" Month 20XX LGS 3-135 EP-AA-1008 (Revision XX)
I imckrie-k rZangarnfin 4Z*n*ien Annoy I:=Y--Inn khtt-lanr I imcrie4 (~ancr~*inn 
~*~tie~n Ann~v Fv~iInn Muui-Io~r Table LGS 3-2: LGS EAL Technical Basis Action Level Technical Basis Page Index General Site Area Alert Unusual Event EAL Pg. EAL Pg. EAL Pg. EAL Pg.RG1 3-33 RS1 3-35 RA1 3-37 RU1 3-40_ RA2 3-43 RU2 3-45_ _RA3 3-47 RU3 3-50 FG1 3-51 FS1 3-52 FA1 3-53 1 1 Fuel Clad RCS Containment FC1 3-54 FC2 3-55 RC2 3-59 CT2 3-66 RC3 3-61 CT3 3-67 RC4 3-62 FC5 3-57 RC5 3-64 CT5 3-69 CT6 3-70 FC7 3-58 RC7 3-65 CT7 3-73 MG1 3-74 MS1 3-76 MA1 3-78 MUW 3-80 MG2 3-81 MS2 3-83 MS3 3-84 MA3 3-86 MU3 3-88 MA4 3-91 MU4 3-94 MA5 3-96 MU6 3-99 MU7 3-101 CA1 3-103 CU1 3-105 CA2 3-107 CU3 3-109 CU4 3-111 CA5 3-113 CU5 3-115 CG6 3-117 CS6 3-121 CA6 3-124 CU6 3-126 HG1 3-129 HS1 3-131 HA1 3-133 HU1 3-136 HS2 3-138 HA2 3-140 HU3 3-141 HU4 3-145 HA5 3-146 HU6 3-148 HG7 3-150 HS7 3-151 HA7 3-152 HU7 3-153 I I I E-HU1 3-154 Month 20XX LGS 3-32 EP-AA-1008 (Revision XX)
Limerick Generatincl Station 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, D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.
If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
: 1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 1000 mRem TEDE OR b. > 5000 mRem CDE Thyroid OR 3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >1000 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.
Month 20XX LGS 3-33 EP-AA-1008 (Revision XX) r Limeric~k (GAneratinn Station Annex FwaeInn NuleIzar RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG1 (cont)Emergency Action Level (EAL) (cont): Table R1 Effluent Monitor Thresholds Release Path General Emergency North Stack (WR Monitor: RIX-26-076-4) 1.92 E+08 uCi/sec South Stack (Unit 1: RY26-185A-3 
/ 2.71 E-01 uCi/sec RY26-185-B-3 or Unit 2: RY26-285A-3 
/RY26-285-B-3)
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, AGI 2. LGS ODCM 3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Limerick Generating Station 4. DBD L-S-43, Radiation Monitoring System Month 20XX LGS 3-34 EP-AA-1008 (Revision XX) 

Simeric~k Gecnea~rtincn Station Annex~ ExvInn NucleI~ar 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, D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to the environment is established.
If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
: 1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 100 mRem TEDE OR b. > 500 mRem CDE Thyroid OR 3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >100 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.
Month 20XX LGS 3-35 EP-AA-1008 (Revision XX)
Limerick Generatinq Station Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1 (cont)Emergency Action Level (EAL) (cont): Table R1 Effluent Monitor Thresholds Release Path Site Area Emergency North Stack (WR Monitor: RIX-26-076-4) 1.92 E+07 uCi/sec South Stack (Unit 1: RY26-185A-3 
/ 2.71 E-02 uCi/sec RY26-185-B-3 or Unit 2: RY26-285A-3 
/RY26-285-B-3)
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. LGS ODCM 3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Limerick Generating Station 4. DBD L-S-43, Radiation Monitoring System Month 20XX LGS 3-36 EP-AA-1008 (Revision XX)
Limerick Generatinci Station Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RA1 Initiating Condition:
Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRem TEDE or 50 mRem thyroid CDE.Operating Mode Applicability:
1, 2, 3,4, 5, D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to the environment is established.
If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
: 1. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 15 minutes.OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 10 mRem TEDE OR b. > 50 mRem CDE Thyroid OR 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary a. 10 mRem TEDE for 60 minutes of exposure OR b. 50 mRem CDE Thyroid for 60 minutes of exposure OR Month 20XX LGS 3-37 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exellon Nuclear Limric.G...a.n Stat..on.Anne.........Nuclea.
RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont)Emergency Action Level (EAL) (cont): 4. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates > 10 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.
Table R1 Effluent Monitor Thresholds Release Path Alert North Stack (WR Monitor: RIX-26-076-4) 1.92 E+06 uCi/sec South Stack (Unit 1: RY26-185A-3 
/ 2.71 E-03 uCi/sec RY26-185-B-3 or Unit 2: RY26-285A-3 
/RY26-285-B-3)
Basis: This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases.
Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.
The TEDE dose is set at 1% of the EPA PAG of 1000 mRem while the 50 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Escalation of the emergency classification level would be via IC RS1.Month 20XX LGS 3-38 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, AA1 2. LGS ODCM 3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Limerick Generating Station 4. L-S-43 Radiation Monitoring System 5. ARC-BOP-0AC304 C1 Liquid Radwaste Discharge Rad Monitor Hi Hi 6. ARC-MCR-003 El North Stack Hi-Hi Radiation 7. ARC-MCR-003 F1 Units 1&2 South Stack Hi-Hi Radiation 8. EP-EAL-0615 Revision 0, Limerick Criteria for Choosing Radiological Liquid Effluent EAL Threshold Values Month 20XX LGS 3-39 EP-AA-1008 (Revision XX)
I imerink r--pprpting -qfzitinn,&nnPy IFYalnn Mitnllnr 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, D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.
If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.1. Reading on ANY of the following effluent monitors > 2 times alarm setpoint established by a current radioactive release discharge permit for 60 minutes.9 Radwaste Discharge Effluent Monitor (RR63-OR001)
OR e Discharge Permit specified monitor OR 2. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 60 minutes: Table R1 Effluent Monitor Thresholds Release Path Unusual Event North Stack (WR Monitor: RIX-26-076-4) 2.20 E+04 uCi/sec South Stack (Unit 1: RY26-185A-3 
/ 3.09 E-05 uCilsec RY26-185-B-3 or Unit 2: RY26-285A-3 
/RY26-285-B-3)
OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of > 60 minutes.Month 20XX LGS 3-40 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / 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 RA1.Month 20XX LGS 3-41 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RUI (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, AU1 2. LGS ODCM 3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Limerick Generating Station 4. L-S-43 Radiation Monitoring System 5. ARC-BOP-0AC304 C1 Liquid Radwaste Discharge Rad Monitor Hi Hi 6. ARC-MCR-1 09 A2 1 Service Water Rad Monitor Hi-Hi 7. ARC-MCR-01 1 C-4 RHRSW Rad Monitor Hi-Hi 8. ARC-MCR-003 El North Stack Hi-Hi Radiation 9. ARC-MCR-003 F1 Units 1&2 South Stack HI-Hi Radiation Month 20XX LGS 3-42 EP-AA-1008 (Revision XX) l=xelnn N r Limerick Generatina Sta~tion Annex FvAlnn Nucler~I 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, D Emergency Action Level (EAL): 1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R2 Radiation Monitor reading >1000 mRem/hr.Table R2 Refuel Floor ARM's* RIS29-M1-1(2)K600, Drywell Head Laydown* RIS30-M1-1(2)K600, Dryer / Separator Area* RIS31-M1-1(2)K600, Spent Fuel Pool" RIS32-M1-1(2)K600, New Fuel storage Vault" RIS33-M1-1(2)K600, Pool Plug Laydown Basis: REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.IMMINENT:
The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.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-HUI.Month 20XX LGS 3-43 EP-AA-1008 (Revision XX)
I iminritkrI, V'anrtafinn Qftx*iIn Anncav Pvg%1^n Kl"A-Igs&#xfd;r 23 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).
Escalation of the emergency would be based on either Recognition Category R or C ICs.Basis Reference(s):
: 1. NEI 99-01 Rev 6, AA2 2. ON-120 Fuel Handling Problems 3. DBD L-S-43, Radiation Monitoring System 4. ARC MCR 112-15 Fuel Pool Storage Hi/Lo Level 5. DBD L-S-16, Reactor Instrumentation System (RIS)6. DBD L-S-52, Fuel Pool Cooling and Cleanup System Month 20XX LGS 3-44 EP-AA-1008 (Revision XX) 

L ime~rick Ge~nerating Staition Annex Fyelnn Nmmr-loar 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, D Emergency Action Level (EAL): 1. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following:
* Refueling Cavity water level < 484 inches.OR" Spent Fuel Pool level < 22 feet above seated irradiated fuel.OR* Indication or report of a drop in water level in the REFUELING PATHWAY.AND 2. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R2.Table R2 Refuel Floor ARM's" RIS29-M1-1(2)K600, Drywell Head Laydown" RIS30-M1 -1 (2)K600, Dryer / Separator Area" RIS31-M1-1(2)K600, Spent Fuel Pool* RIS32-M1-1(2)K600, New Fuel storage Vault" RIS33-M1-1(2)K600, Pool Plug Laydown Month 20XX LGS 3-45 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex l=xelon Nuclear Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU2 (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.REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.This IC addresses a loss in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.A water level loss will be primarily determined by indications from available level instrumentation.
Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available) or from any other temporarily installed monitoring instrumentation.
A significant drop in the water level may also cause a rise in the radiation levels of adjacent areas that can be detected by monitors in those locations.
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 3.9.8 3. ON-120 Fuel Handling Problems 4. DBD L-S-16, Reactor Instrumentation System (RIS)5. DBD L-S-52, Fuel Pool Cooling and Cleanup System 6. ARC MCR 112-15 Fuel Pool Storage Hi/Lo Level 7. GP-6.1 U/1(2) Shutdown Operations 
-Refuel Core Alterations 
& Core Off-loading Month 20XX LGS 3-46 EP-AA-1008 (Revision XX)
Limerick Generating Station 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, D Emergency Action Level (EAL): Note:* If the equipment in the room or area listed in Table R4 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.
: 1. Dose rate > 15 mR/hr in ANY of the areas contained in Table R3: Table R3 Areas Requiring Continuous Occupancy* Main Control Room" Central Alarm Station -(by survey)OR 2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the areas contained in Table R4: Table R4 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Enclosure*
Modes 3, 4, and 5* Areas required to establish shutdown cooling Month 20XX LGS 3-47 EP-AA-1008 (Revision XX)
NuP.lenr Simeric~k Generating Station Annex Exelnn Nui~clear 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.
Table R4 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown.
This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including the Control Room.For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time and the elevated radiation levels preclude the ability to place shutdown cooling in service.The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding beyond that required by procedures, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation rise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.* The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.).Month 20XX LGS 3-48 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Fxelnn Nucler~I 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 Table 7.7-2, Locations for Area Radiation Monitor Sensors 3. SE-1 Remote Shutdown 4. SE-6 Alternate Remote Shutdown 5. SE-8 Fire 6. DBD L-S-43, Radiation Monitoring System Month 20XX LGS 3-49 EP-AA-1 008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RU3 Initiating Condition:
Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:
1,2,3.Emergency Action Level (EAL): 1. Air Ejector discharge radiation monitor (RISH 26 1(2)K601 A, B) Hi-Hi alarm.OR 2. Specific coolant activity > 4.0 uCIIgm Dose equivalent 1-131.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 Event is only warranted when actual fuel clad damage is the cause of the elevated coolant sample activity (as determined by laboratory confirmation).
Fuel clad damage should be assumed to be the cause of elevated Reactor Coolant activity unless another cause is known.Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category R ICs.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU3 2. Technical Specifications 3.4.5, Specific Activity 3. Technical Specifications 3.4.5, Basis 4. UFSAR Table 11.5-1, Process and Effluent Radiation Monitoring Systems 5. DBD L-S-43, Radiation Monitoring System 6. ARC MCR 109-G1, Air Ejector Offgas Discharge HI-HI Radiation Month 20XX LGS 3-50 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear 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 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-2 Month 20XX LGS 3-51 EP-AA-1008 (Revision XX)
Limerick Generating Station 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 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-2 Month 20XX LGS 3-52 EP-AA-1008 (Revision XX) r Simeric~k (GAneratinn Station Annex FwAlnn Nuclea&r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FA1 Initiating Condition:
ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.Operating Mode Applicability:
1,2,3 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-2 Month 20XX LGS 3-53 EP-AA-1 008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC1 Initiating Condition:
RCS Activity Operating Mode Applicability:
1,2,3 Fission Product Barrier (FPB) Threshold:
LOSS Coolant activity > 300 uCi/gm Dose Equivalent 1-131.Basis: This threshold indicates that RCS radioactivity concentration is greater than 300 [iCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete.
Nonetheless, a sample-related threshold is included as a backup to other indications.
There is no Potential Loss threshold associated with RCS Activity.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX LGS 3-54 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 Initiating Condition:
RPV Water Level Operating Mode Applicability:
1,2,3 Fission Product Barrier (FPB) Threshold:
LOSS 1. Plant conditions indicate Primary Containment flooding is required.POTENTIAL LOSS 2. RPV water level cannot be restored and maintained 
> -161 inches (TAF).OR 3. RPV water level cannot be determined.
Basis: Loss Threshold 
#1 Basis The Loss threshold represents the EOP requirement for primary containment flooding.This is identified in the BWROG EPGs/SAGs when the phrase, "Primary Containment Flooding Is Required," appears. Since a site-specific RPV water level is not specified here, the Loss threshold phrase, "Primary containment flooding required," also accommodates the EOP need to flood the primary containment when RPV water level cannot be determined and core damage due to inadequate core cooling is believed to be occurring.
Potential Loss Threshold 
#2 and #3 Basis This water level corresponds to the top of the active fuel and is used in the EOPs to indicate a challenge to core cooling.The RPV water level threshold is the same as RCS Barrier RC2 Loss threshold.
Thus, this threshold indicates a Potential Loss of the Fuel Clad barrier and a Loss of the RCS barrier that appropriately escalates the emergency classification level to a Site Area Emergency.
This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV water level cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization.
EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate Month 20XX LGS 3-55 EP-AA-1008 (Revision XX)
Simerick Generatinn Sta~tion Annex Fxellnn Nucler~I RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 (cont)Basis (cont): RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this Fuel Clad barrier Potential Loss is met only after either: 1) the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory.
The term "cannot be restored and maintained above" means the value of RPV water level is not able to be brought above the specified limit (top of active fuel). The determination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation below the limit; the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained.Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level in order to reduce reactor power. Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority.
For such events, ICs MA3 or MS3 will dictate the need for emergency classification.
Since the loss of ability to determine if adequate core cooling is being provided presents a significant challenge to the fuel clad barrier, a potential loss of the fuel clad barrier is specified.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-2 2. T-1 11 Level Restoration 
/ Steam Cooling- BASES 3. T-1 17 Level/Power Control -BASES Month 20XX LGS 3-56 EP-AA-1008 (Revision XX)
No  Limeric~k Generating Staition Annex Fvainn him-lanr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC5 Initiating Condition:
Primary Containment Radiation Operating Mode Applicability:
1,2,3 Fission Product Barrier (FPB) Threshold:
LOSS Drywell radiation monitor reading > 1.90 E+02 R/hr.Basis: The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals 300 pCi/gm dose equivalent 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 RC5 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.
There is no Fuel Clad Barrier Potential Loss threshold associated with Primary Containment Radiation.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-2 2. Core Damage Assessment Methodology
: 3. Technical Specifications Table 3.3.7.5-1, Accident Monitoring Instrumentation
: 4. DBD L-S-43, Radiation Monitoring System 5. ST-2-026-418-1 Accident Monitoring 
-Primary Containment Post -LOCA Radiation Division IIl Calibration (RE-26-191A)
: 6. ST-0-026-640-*
Alternate Monitoring for Inop Post-LOCA Radiation Monitors Month 20XX LGS 3-57 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC7.Initiating Condition:
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.Basis: Loss Threshold 
#1 Basis This threshold addresses any other factors that are to 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-2 Month 20XX LGS 3-58 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC2 Initiating Condition:
RPV Water Level Operating Mode Applicability:
1,2,3 Fission Product Barrier (FPB) Threshold:
LOSS 1. RPV water level cannot be restored and maintained 
> -161 inches (TAF).OR 2. RPV water level cannot be determined.
Basis: This water level corresponds to the Top of Active Fuel (TAF) and is used in the EOPs to indicate challenge to core cooling.The RPV water level threshold is the same as Fuel Clad Barrier FC2 Potential Loss threshold.
Thus, this threshold indicates a Loss of the RCS barrier and Potential Loss of the Fuel Clad barrier and that appropriately escalates the emergency classification level to a Site Area Emergency.
This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV water level cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this RCS barrier Loss is met only after either: 1) the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory.
The term, "cannot be restored and maintained above," means the value of RPV water level is not able to be brought above the specified limit (top of active fuel). The determination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation beyond the limit; the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained.Month 20XX LGS 3-59 EP-AA-1008 (Revision XX)
N  Limeric~k Generatinn Station Annex Exelnn Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC2 (cont)Basis (cont): Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level in order to reduce reactor power. Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority.
For such events, ICs MA3 or MS3 will dictate the need for emergency classification.
There is no RCS Potential Loss threshold associated with RPV Water Level.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-2 2. T-BAS, TRIPS / SAMPS -Bases 3. T 101, RPV Control 4. T-1 11, Level Restoration 
/ Steam Cooling Month 20XX LGS 3-60 EP-AA-1008 (Revision XX)
Limerick Generatinq Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC3 Initiating Condition:
Primary Containment Pressure Operating Mode Applicability:
1,2,3 Fission Product Barrier (FPB) Threshold:
LOSS 1. Drywell pressure > 1.68 psig.AND 2. Drywell pressure rise is due to RCS leakage Basis: The > 1.68 psig primary containment pressure is the Drywell high pressure setpoint which indicates a LOCA by automatically initiating ECCS.The second threshold condition focuses the fission product barrier loss threshold on a failure of the RCS instead of the non-LOCA malfunctions that may adversely affect primary containment pressure.
Pressures of this magnitude can be caused by non-LOCA events such as a loss of Drywell cooling or inability to control primary containment vent/purge.
The release of mass from the RCS due to the as-designed/expected operation of any relief valve does not warrant an emergency classification.
A stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered either identified or unidentified leakage by Technical Specification and, therefore, is not applicable to this EAL.There is no Potential Loss threshold associated with Primary Containment Pressure.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-2 2. T-101 RPV Control 3. T-102 Primary Containment Control -Bases Month 20XX LGS 3-61 EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexN  Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC4 Initiating Condition:
RCS Leak Rate Operating Mode Applicability:
1,2,3 Fission Product Barrier (FPB) Threshold:
LOSS 1. UNISOLABLE Main Steam Line (MSL), HPCI, Feedwater, RWCU, or RCIC line break.OR 2. Emergency RPV Depressurization is required.POTENTIAL LOSS 3. UNISOLABLE primary system leakage that results in EITHER of the following:
: a. Secondary Containment area temperature 
> T-103 / SAMP, Max Norm Op Value (MNO).OR b. Secondary Containment area radiation level > T-103 / SAMP, Max Norm Op Value (MNO).Basis: UNISOLABLE:
An open or breached system line that cannot be isolated, remotely or locally.Classification of a system break over system leakage is based on information available to the Control Room from the event. Indications that should be considered are: " Reports describing magnitude of steam or water release." Use of system high flow alarms / indications, if available,* Significant changes in makeup requirements," Abnormal reactor water level changes in response to the event.The use of the above indications provides the Control Room the bases to determine that the on going event is more significant than the indications that would be expected from system leakage and therefore should be considered a system break.Loss Threshold 
#1 Basis Large high-energy lines that rupture outside primary containment can discharge significant amounts of inventory and jeopardize the pressure-retaining capability of the RCS until they are isolated.
If it is determined that the ruptured line cannot be promptly isolated, the RCS barrier Loss threshold is met.Month 20XX LGS 3-62 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC4 (cont)Basis (cont): Loss Threshold 
#2 Basis Emergency RPV Depressurization in accordance with the EOPs is indicative of a loss of the RCS barrier. If Emergency RPV Depressurization is performed, the plant operators are directed to open safety relief valves (SRVs) and keep them open. Even though the RCS is being vented into the suppression pool, a Loss of the RCS barrier exists due to the diminished effectiveness of the RCS to retain fission products within its boundary.Potential Loss Threshold 
#3 Basis Potential loss of RCS based on primary system leakage outside the primary containment is determined from EOP temperature or radiation Max Normal Operating values in areas such as main steam line tunnel, RCIC, HPCI, etc., which indicate a direct path from the RCS to areas outside primary containment.
A Max Normal Operating value is the highest value of the identified parameter expected to occur during normal plant operating conditions with all directly associated support and control systems functioning properly.The indicators reaching the threshold barriers and confirmed to be caused by RCS leakage from a primary system warrant an Alert classification.
A primary system is defined to be the pipes, valves, and other equipment which connect directly to the RPV such that a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system.In general, multiple indications should be used to determine if a primary system is discharging outside Primary Containment.
For example, a high area radiation condition does not necessarily indicate that a primary system is discharging into the Reactor Building since this may be caused by radiation shine from nearby steam lines or the movement of radioactive materials.
Conversely, a high area radiation condition in conjunction with other indications (e.g. room flooding, high area temperatures, reports of steam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into the Reactor Building.An UNISOLABLE leak which is indicated by Max Normal Operating values escalates to a Site Area Emergency when combined with Containment Barrier CT6 Loss Threshold#1 (after a containment isolation) and a General Emergency when the Fuel Clad Barrier criteria is also exceeded.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-2 2. SAMP-2, Containment and Radioactivity Release Control 3. T-103, Secondary Containment Control Month 20XX LGS 3-63 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC5 Initiating Condition:
Primary Containment radiation Operating Mode Applicability:
1,2,3 Fission Product Barrier (FPB) Threshold:
LOSS Drywell radiation monitor reading > 10OR/hr.Basis: The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier FC5 Loss Threshold since it indicates a loss of the RCS Barrier only.There is no RCS Potential Loss threshold associated with Primary Containment Radiation.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-2 2. EP-EAL-061 1, Criteria for Choosing Containment Radiation Monitor Reading Indicative of Loss of RCS Barrier Month 20XX LGS 3-64 EP-AA-1008 (Revision XX)
Limeric. k Ge.n. ratinn Stvatin Annex Fv.inn Nucle!w mar RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC7 Initiating Condition:
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 Barrier.POTENTIAL LOSS 2. Any condition in the opinion of the Emergency Director that of the RCS Barrier.indicates Loss of the RCS indicates Potential Loss Basis: Loss Threshold 
#1 Basis This threshold addresses any other factors that are to 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-2 Month 20XX LGS 3-65 EP-AA-1008 (Revision XX) r Limeric~k Generatinn Station Annex FvA-Inn NuclerIzi RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT2 Initiating Condition:
RPV Water Level Operating Mode Applicability:
1,2,3 Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSS Plant conditions indicate Primary Containment flooding is required.Basis: The Potential Loss threshold is identical to the Fuel Clad Barrier FC2 Loss threshold RPV Water Level. The Potential Loss requirement for Primary Containment Flooding indicates adequate core cooling cannot be restored and maintained and that core damage is possible.
BWR EPGs/SAGs specify the conditions that require primary containment flooding.
When primary containment flooding is required, the EPGs are exited and SAGs are entered. Entry into SAGs is a logical escalation in response to the inability to restore and maintain adequate core cooling.PRA studies indicate that the condition of this Potential Loss threshold could be a core melt sequence which, if not corrected, could lead to RPV failure and increased potential for primary containment failure. In conjunction with the RPV water level Loss thresholds in the Fuel Clad and RCS barrier columns, this threshold results in the declaration of a General Emergency..Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-2 2. T-BAS (INTRO) Introduction To Trips And Samps -Bases 3. T-1 11, Level Restoration 
/ Steam Cooling -Bases 4. T-116, RPV Flooding -Bases 5. T-1 17, Level/Power Control -Bases Month 20XX LGS 3-66 EP-AA-1008 (Revision XX)
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.2..RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 Initiating Condition:
Primary Containment Conditions Operating Mode Applicability:
1,2,3 Fission Product Barrier (FPB) Threshold:
LOSS 1. UNPLANNED rapid drop in primary containment pressure following primary containment pressure rise.OR 2. Primary containment pressure response not consistent with LOCA conditions.
POTENTIAL LOSS 3. Drywell pressure > 55 psig and rising.OR 4. a. Drywell or Suppression Pool Hydrogen concentration 
> 6%.AND b. Drywell or Suppression Pool Oxygen concentration 
> 5%.OR 5. Heat Capacity Limit (T-102 Curve SP/T-1) exceeded.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.Loss Threshold 
#1 and #2 Basis Rapid UNPLANNED loss of primary containment pressure (i.e., not attributable to Drywell spray or condensation effects) following an initial pressure rise indicates a loss of primary containment integrity.
Primary containment pressure should rise as a result of mass and energy release into the primary containment from a LOCA. Thus, primary containment pressure not increasing under these conditions indicates a loss of primary containment integrity.
These thresholds rely on operator recognition of an unexpected response for the condition and therefore a specific value is not assigned.
The unexpected (UNPLANNED) response is important because it is the indicator for a containment bypass condition.
A pressure suppression bypass path would not be an indication of a containment breach.Month 20XX LGS 3-67 EP-AA-1008 (Revision XX)
Limerick Generatinq Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 (cont)Basis (cont): Potential Loss Threshold 
#3 Basis The threshold pressure is the primary containment internal design pressure.
Structural acceptance testing demonstrates the capability of the primary containment to resist pressures greater than the internal design pressure.
A pressure of this magnitude is greater than those expected to result from any design basis accident and, thus, represent a Potential Loss of the Containment barrier.Potential Loss Threshold 
#4 Basis If hydrogen concentration reaches or exceeds the lower flammability limit, as defined in plant EOPs, in an oxygen rich environment, a potentially explosive mixture exists. If the combustible mixture ignites inside the primary containment, loss of the Containment barrier could occur.Potential Loss Threshold 
#5 Basis The HCTL is a function of RPV pressure, suppression pool temperature and suppression pool water level. It is utilized to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant and therefore, the inability to maintain plant parameters below the limit constitutes a potential loss of containment.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-2 2. UFSAR Section 6.2.1 3. DBD L-T-12, Design Basis Accidents, Transients and Events 4. DBD L-S-25A, Primary Containment Pressure Suppression System 5. DBD L-T-02, Containment, Section 3.2.14 6. T-102 Primary Containment Control -Bases Month 20XX LGS 3-68 EP-AA-1008 (Revision XX)
PIni~nn N~i-lonr Simeric~k (GAneratinn Station Annex vIn ~mrI2 RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT5 Initiating Condition:
Primary Containment Radiation Operating Mode Applicability:
1,2,3 Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSS Drywell radiation monitor reading > 4.35 E+02 R/hr.Basis: There is no Loss threshold associated with Primary Containment Radiation.
The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary 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-2 2. Core Damage Assessment Methodology
: 3. Technical Specifications Table 3.3.7.5-1 4. DBD L-S-43, Radiation Monitoring System 5. ST-2-026-418-1 Accident Monitoring 
-Primary Containment Post -LOCA Radiation Division III Calibration (RE-26-191A)
: 6. ST-0-026-640-*
Alternate Monitoring for Inop Post-LOCA Radiation Monitors Month 20XX LGS 3-69 EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexNuclear Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT6 Initiating Condition:
Primary Containment Isolation Failure Operating Mode Applicability:
1,2,3 Fission Product Barrier (FPB) Threshold:
LOSS 1. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal.OR 2. Intentional Primary Containment venting/purging per EOPs or SAGs due to accident conditions.
OR 3. UNISOLABLE primary system leakage that results in EITHER of the following:
: a. Secondary Containment area temperature 
> T-103 / SAMP Max Safe Op Value (MSO).OR b. Secondary Containment area radiation level > T-103 / SAMP Max Safe Op Value (MSO).Basis: UNISOLABLE:
An open or breached system line that cannot be isolated, remotely or locally.These thresholds address incomplete containment isolation that allows an UNISOLABLE direct release to the environment.
Loss Threshold 
#1 Basis The use of the modifier "direct" in defining the release path discriminates against release paths through interfacing liquid systems or minor release pathways, such as instrument lines, not protected by the Primary Containment Isolation System (PCIS).Leakage into a closed system is to be considered only if the closed system is breached and thereby creates a significant pathway to the environment.
Examples include unisolable Main Steamline, HPCI or RCIC steamline breaks, unisolable RWCU system breaks, and unisolable containment atmosphere vent paths.Examples of "downstream pathway to the environment" could be through the Turbine/Condenser, or direct release to the Turbine or Reactor Building.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.Month 20XX LGS 3-70 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT6 (cont)Basis (cont): Following the leakage of RCS mass into primary containment and a rise in primary containment pressure, there may be minor radiological releases associated with allowable primary containment leakage through various penetrations or system components.
Minor releases may also occur if a primary containment isolation valve(s)fails to close but the primary containment atmosphere escapes to an enclosed system.These releases do not constitute a loss or potential loss of primary containment but should be evaluated using the Recognition Category R ICs.Loss Threshold 
#2 Basis EOPs may direct primary containment isolation valve logic(s) to be intentionally bypassed, even if offsite radioactivity release rate limits will be exceeded.
Under these conditions with a valid primary containment isolation signal, the containment should also be considered lost if primary containment venting is actually performed.
Intentional venting of primary containment for primary containment pressure or combustible gas control to the secondary containment and/or the environment is a Loss of the Containment.
Venting for primary containment pressure control when not in an accident situation (e.g., to control pressure below the Drywell high pressure scram setpoint) does not meet the threshold condition.
Loss Threshold 
#3 Basis The Max Safe Operating Temperature and the Max Safe Operating Radiation Level are each the highest value of these parameters at which neither: (1) equipment necessary for the safe shutdown of the plant will fail, nor (2) personnel access necessary for the safe shutdown of the plant will be precluded.
EOPs utilize these temperatures and radiation levels to establish conditions under which RPV depressurization is required.The temperatures and radiation levels should be confirmed to be caused by RCS leakage from a primary system. A primary system is defined to be the pipes, valves, and other equipment which connect directly to the RPV such that a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system.In general, multiple indications should be used to determine if a primary system is discharging outside Primary Containment.
For example, a high area radiation condition does not necessarily indicate that a primary system is discharging into the Reactor Building since this may be caused by radiation shine from nearby steam lines or the movement of radioactive materials.
Conversely, a high area radiation condition in conjunction with other indications (e.g. room flooding, high area temperatures, reports of steam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into the Reactor Building.In combination with RCS Barrier RC4 Potential Loss Threshold 
#3 this threshold would result in a Site Area Emergency.
Month 20XX LGS 3-71 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT6 (cont)Basis (cont): There is no Potential Loss threshold associated with Primary Containment Isolation Failure.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-2 2. T-103, Secondary Containment Control 3. T-102, Primary Containment Control 4. T-200, Primary Containment Emergency Vent Procedure 5. T-228, Inerting / Purging Primary Containment Month 20XX LGS 3-72 EP-AA-1008 (Revision XX)
Limerick Generatinq Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT7 Initiating Condition:
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.Basis: Loss Threshold 
#1 Basis This threshold addresses any other factors that are to 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-2 Month 20XX LGS 3-73 EP-AA-1008 (Revision XX)
Simeric~k Generatinn Station Annex FvApinn Nula~r~I RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG1 Initiating Condition:
Prolonged loss of all Off-site and all On-Site AC power to emergency busses.Operating Mode Applicability:
1,2,3 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 4 KV Safeguards Buses.AND 2. Failure of D11(21) and D12(22), D13(23), and D14(24) Emergency Diesel Generators to supply power to unit 4KV Safeguards Buses.AND 3. EITHER of the following:
: a. Restoration of at least one unit 4KV safeguards Bus in < 2 hours is not likely.OR b. RPV water level cannot be restored and maintained 
> -186 inches.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
This IC addresses a prolonged loss of all power sources to AC emergency buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A prolonged loss of these buses will lead to a loss of ANY fission product barriers.
In addition, fission product barrier monitoring capabilities may be degraded under these conditions.
The EAL should require declaration of a General Emergency prior to meeting the thresholds for IC FG1. This will allow additional time for implementation of offsite protective actions.Escalation of the emergency classification from Site Area Emergency will occur if it is projected that power cannot be restored to at least one AC emergency bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and Month 20XX LGS 3-74 EP-AA-1008 (Revision XX)
Limerick Generatina Station 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 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. UFSAR Section 8.2, Offsite Power System 3. E 10/20 Loss of Offsite Power 4. DBD L-S-05, 4KV System 5. DBD L-T-03, Electrical Issues 6. T-101 RPV Control Month 20XX LGS 3-75 EP-AA-1008 (Revision XX)
Limeric~k Generatinn Station Annex FvYplnn N.Jionchr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1 Initiating Condition:
Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.Operating Mode Applicability:
1,2,3 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 4KV Safeguards Buses.AND 2. Failure of D11(21), D12(22), D13(23), and D14(24) Emergency Diesel Generators to supply power to unit 4KV Safeguards Buses.AND 3. Failure to restore power to at least one unit 4KV Safeguards bus in < 15 minutes from the time of loss of both offsite and onsite AC power.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. In addition, fission product barrier monitoring capabilities may be degraded under these conditions.
This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation of the emergency classification level would be via ICs RG1, FG1, MG1, or MG2.Month 20XX LGS 3-76 EP-AA-1008 (Revision XX) 

Simeric~k (GAnea~tinn Stamtion Annex Fyolem N~ialr&ipr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1 (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, SS1 2. UFSAR Section 8.2, Offsite Power System 3. E 10/20 Loss of Offsite Power 4. DBD L-S-05, 4KV System 5. DBD L-T-03, Electrical Issues 6. T-101 RPV Control Month 20XX LGS 3-77 EP-AA-1 008 (Revision XX)
Limerick Generatina Station 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 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 4KV Safeguards Buses reduced to only one of the following power sources for > 15 minutes.* 101 Safeguards Transformer
* 201 Safeguards Transformer
* Dl1(21) Diesel Generator* D12(22) Diesel Generator SD13(23) Diesel Generator* D14(24) Diesel Generator AND 2. ANY additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.
This IC provides an escalation path from IC MUl.An "AC power source" is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.o A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).
Month 20XX LGS 3-78 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear 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, SAl 2. UFSAR Section 8.2, Offsite Power System 3. E 10/20 Loss of Offsite Power 4. DBD L-S-05, 4KV System 5. DBD L-T-03, Electrical Issues Month 20XX LGS 3-79 EP-AA-1008 (Revision XX)
Limerick Generating Station 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 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 4KV Safeguards 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.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 MA1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU1 2. UFSAR Section 8.2, Offsite Power System 3. E 10/20 Loss of Offsite Power 4. DBD L-S-05, 4KV System 5. DBD L-T-03, Electrical Issues Month 20XX LGS 3-80 EP-AA-1008 (Revision XX)
Simeric~k Generatinn Station Annex Fyi-Inn NuI~clar 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 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 4KV safeguards Buses.AND 2. Failure of D11(21), D12(22), D13(23), and D14(24) Emergency Diesel Generators to supply power to unit 4KV Safeguards Buses.AND 3. Voltage is < 105 VDC on unit 125 VDC battery busses 1(2)FA, FB, FC, and FD.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 20XX LGS 3-81 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG2 (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, SG8 2. UFSAR Section 8.3.2, DC Power Systems 3. DBD P-L-01A, 125/250 VDC System 4. E-1(2)FA Loss of Division I Safeguard 125/250V DC BUS 1FA 5. E-1(2)FB Loss of Division II Safeguard 125/250V DC BUS 1FB 6. E-1(2)FC Loss of Division III Safeguard 125/250V DC BUS 1FC 7. E-1(2)FD Loss of Division IV Safeguard 125/250V DC BUS 1FD 8. UFSAR Section 8.2, Offsite Power System 9. E 10/20 Loss of Offsite Power 10. DBD L-S-05, 4KV System 11. DBD L-T-03, Electrical Issues Month 20XX LGS 3-82 EP-AA-1 008 (Revision XX)
Limerick Generating Station Annex Exelon Nucle;RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS Initiating Condition:
Loss of all vital DC power for 15 minutes or longer..Operating Mode Applicability:
1,2,3 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.ar 2 Voltage is < 105 VDC on 125 VDC battery busses 1(2)FA, FB, FC, and FD 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 MG2.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SS8 2. UFSAR Section 8.3.2, DC Power Systems 3. DBD P-L-01A, 125/250 VDC System 4. E-1(2)FA Loss of Division I Safeguard 125/250V DC BUS 1FA 5. E-1(2)FB Loss of Division II Safeguard 125/250V DC BUS 1FB 6. E-1(2)FC Loss of Division III Safeguard 125/250V DC BUS 1FC 7. E-1(2)FD Loss of Division IV Safeguard 125/250V DC BUS 1FD Month 20XX LGS 3-83 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3 Initiating Condition:
Inability to shutdown the reactor causing a challenge to RPV water level or RCS heat removal.Operating Mode Applicability:
1,2 Emergency Action Level (EAL): 1. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 4%.AND 2. ALL manual / ARI actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 4%.AND 3. EITHER of the following conditions exist: " RPV water level cannot be restored and maintained 
> -186 inches.OR" Heat Capacity Limit (T-102 Curve SP/T-1) exceeded.Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, all subsequent operator manual actions, both inside and outside the Control Room including driving in control rods and boron injection, are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.
In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs.
This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor.A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.Escalation of the emergency classification level would be via IC RG1 or FG1.Month 20XX LGS 3-84 EP-AA-1 008 (Revision XX)
Limerick Generating Station Annex RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis Reference(s):
: 1. NEI 99-01 Rev 6, SS5 2. T-101 RPV Control -Bases 3. T-1 17 Level/Power Control -Bases 4. T-1 02 Primary Containment Control -Bases Exelon Nuclear MS3 (cont)Month 20XX LGS 3-85 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 Initiating Condition:
Automatic or manual scram fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:
1,2 Emergency Action Level (EAL): Note:* A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.
: 1. Automatic or manual scram did not shutdown the reactor as indicated by Reactor Power > 4%.AND 2. Manual / ARI actions taken at the Reactor Console are not successful in shutting down the reactor as indicated by Reactor Power > 4%.Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, and subsequent operator manual actions taken at the reactor 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 consoles since this event entails a significant failure of the RPS.A manual action at the reactor consoles 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 scram. 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 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 reactor consoles".
Taking the Reactor Mode Switch to Shutdown is considered to be a manual scram action.Month 20XX LGS 3-86 EP-AA-1008 (Revision XX)
Limeric~k GeAnerating Station An nex Fv0Ilnn NM1ionI~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 Basis (cont): The plant response to the failure of an automatic or manual reactor scram 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 RPV water level or RCS heat removal safety functions, the emergency 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. T-101 RPV Control -Bases 3. T-1 17 Level/Power Control -Bases Month 20XX LGS 3-87 EP-AA-1008 (Revision XX)
Simeric~k Generatinn Station Annex ExaInn NucleIar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 Initiating Condition:
Automatic or manual scram 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 scram did not shutdown the reactor as indicated by Reactor Power > 4%.AND b. Subsequent manual / ARI action taken at the Reactor Console is successful in shutting down the reactor.OR 2. a. Manual scram did not shutdown the reactor as indicated by Reactor Power> 4%.AND b. EITHER of the following:
: 1. Subsequent manual / ARI action taken at the Reactor Console is successful in shutting down the reactor.OR 2. Subsequent automatic scram / ARI 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 scram that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor consoles or an automatic scram 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.Month 20XX LGS 3-88 EP-AA-1008 (Revision XX)
Limerick Generatinq Station Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont)Basis (cont): EAL #1 Basis Following the failure on an automatic reactor scram, operators will promptly initiate manual actions at the reactor consoles to shutdown the reactor (e.g., initiate a manual reactor scram). 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.EAL #2 Basis If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor consoles to shutdown the reactor (e.g., initiate a manual reactor scram/ARI using a different switch). Depending upon several factors, the initial or subsequent effort to manually scram the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor scram signal. If a subsequent manual or automatic scram/ARI 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 reactor consoles 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 scram). 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 reactor consoles".
Taking the Reactor Mode Switch to Shutdown is considered to be a manual scram action.The plant response to the failure of an automatic or manual reactor scram 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 reactor consoles 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 FA1. 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.Month 20XX LGS 3-89 EP-AA-1008 (Revision XX)
I:yelnn N  Limerick Generatinn Station Annex Exelnn NucleIar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont)Basis (cont): Should a reactor scram 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 created a real condition that should have included an automatic reactor scram 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 scram signal and the scram 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. T-101 RPV Control 3. Technical Specifications Table 3.3.1.1-1 Month 20XX LGS 3-90 EP-AA-1008 (Revision XX)
I imario-k (Zanarnfin Atntinn Annoy I::valnn kl~dlrlr I imaria-Ie 
(~~n~rzitinn 
~t2tinn Ann~v Fv~Inn NI. mrI~~r 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 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 parameter from within the Control Room for > 15 minutes.Table M1 Control Room Parameters" Reactor Power" RPV Water Level* RPV Pressure" Drywell Pressure* Suppression Pool Level* Suppression Pool Temperature AND 2. ANY Table M2 transient in progress.Table M2 Significant Transients
* Automatic or Manual Runback > 25% thermal reactor power" Electrical Load Rejection 
> 25% full electrical load* Reactor Scram* ECCS Actuation" Thermal Power oscillations 
> 10%Month 20XX LGS 3-91 EP-AA-1008 (Revision XX)
LimArir~k 
~~AnAr~ltinn 
~t~tinn Annn'~ Limerick Generatinn Station Annex Fvalnn N"d-lanr 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, RPV water level 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 RPV water 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.Month 20XX LGS 3-92 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exellon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA4 (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, SA2 2. DBD L-T-06, Human Factors, Section 6.1.1 3. T-101 RPV Control 4. T-102 Primary Containment Control 5. ON-122, Loss of Main Control Room Annunciators 
-Bases Month 20XX LGS 3-93 EP-AA-1 008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear Limerik.Ge.ratln Staio.AnexEx .o.Nucea RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4 Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:
1,2,3 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" RPV Water Level* RPV Pressure* Drywell Pressure* Suppression Pool Level* Suppression Pool Temperature 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.Month 20XX LGS 3-94 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4 (cont)Basis (cont): 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 IC MA4.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU2 2. DBD L-T-06, Human Factors, Section 6.1.1 3. T-101 RPV Control 4. T-102 Primary Containment Control 5. ON-122, Loss of Main Control Room Annunciators 
-Bases Month 20XX LGS 3-95 EP-AA-1008 (Revision XX)
I imerirnk r~ener~atinn St~ation Annex Fvalnn Niiltpa~r 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 Emergency Action Level (EAL): 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 events may require a post-event inspection to determine if the attributes of an explosion are present.Month 20XX LGS 3-96 EP-AA-1008 (Revision XX)
I::Y#_lnn N r I imprirck (Generatinn Rtation Annex FYAlnn NmurlI2r 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.Month 20XX LGS 3-97 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA5 (cont)Basis Reference(s):
: 1. NEI 99-01, Rev 6 SA9 2. UFSAR Section 2.5, Geology and Seimology 3. UFSAR Section 3.4.1, Flood Protection
: 4. UFSAR Section 6.2.1.1.1, Design Bases 5. UFSAR Section 9.2.6.4.2, Spray Pond Water Requirements
: 6. DBD L-S-46, Meteorological and Seismic Monitoring Systems 7. DBD L-T-17, Dynamic Qualification Program 8. Specification NE-0294, "Fire Safe Shutdown Analysis Specification" 9. SE-5 Earthquake
: 10. SE-4 Flood 11. SE-9, Preparation for Severe Weather Month 20XX LGS 3-98 EP-AA-1008 (Revision XX)
L imeric~k Generatina Station Annex FvAlnn Nucler~I RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU6 Initiating Condition:
RCS leakage for 15 minutes or longer.Operating Mode Applicability:
1,2,3 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 in the Drywell > 10 gpm for> 15 minutes.OR 2. RCS identified leakage in the Drywell >25 gpm for > 15 minutes.OR 3. Leakage from the RCS to a location outside the Drywell >25 gpm for > 15 minutes.Basis: UNISOLABLE:
An open or breached system line that cannot be isolated, remotely or locally.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 or a location outside of containment.
The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications.
Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation).
EAL #1 uses a lower value that reflects the greater significance of unidentified or pressure boundary leakage.Month 20XX LGS 3-99 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU6 (cont)Basis (cont): The release of mass from the RCS due to the as-designed/expected operation of any relief valve does not warrant an emergency classification.
A stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered either identified or unidentified leakage by Technical Specification and, therefore, is not applicable to this EAL.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 3.4.3, Reactor Coolant System Leakage 3. Technical Specifications 3.9.8, Water Level -Reactor Vessel 4. DBD L-S-34, Radwaste System 5. OT-101 High Drywell Pressure 6. T-102 Primary Containment Control, Table DW/T-1 7. GP-6.1 U/I (U/2) Shutdown Operations 
-Refueling, Core Alteration and Core Off-Loading
: 8. DBD L-S-16, Reactor Instrumentation System (RIS)9. ST-6-107-596-*
Drywell Floor Drain Sump/Equipment Drain Tank Surveillance Log Month 20XX LGS 3-100 EP-AA-1008 (Revision XX)
FxAInn r Limeric=k ==-ting Station Annex Fxvwwn Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU7 Initiating Condition:
Loss of all On-site or Off-site communications capabilities.
Operating Mode Applicability:
1,2,3 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 Station Radio X Plant Public Address (PA) X Prelude System X X Station Phones X X X Satellite Phones X X X NARS X HPN X X ENS X X Basis: This IC addresses a significant loss of on-site, offsite, or NRC communications capabilities.
While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).Month 20XX LGS 3-101 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU7 (cont)Basis (cont): EAL #1 Basis Addresses a total loss of the communications methods used in support of routine plant operations.
EAL #2 Basis Addresses a total loss of the communications methods used to notify all OROs of an emergency declaration.
The OROs referred to here are listed in procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form.EAL #3 Basis Addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU6 2. UFSAR Section 9.5.2, Communication Systems 3. SE-12 Loss of Communications Month 20XX LGS 3-102 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA1 Initiating Condition:
Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.Operating Mode Applicability:
4,5, 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 4KV Safeguards Buses.AND 2. Failure of D11(21), D12(22), D13(23), and D14(24) Emergency Diesel Generators to supply power to unit 4KV Safeguards Buses.AND 3. Failure to restore power to at least one unit 4KV Safeguards bus in< 15 minutes from the time of loss of both offsite and onsite AC power.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink.When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore an emergency bus to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation of the emergency classification level would be via IC CS6 or RS1.Month 20XX LGS 3-103 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex .xe..n  RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CAI (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, CA2 2. UFSAR Section 8.2, Offsite Power System 3. E 10-20 Loss of Offsite Power 4. DBD L-S-05, 4KV System 5. DBD L-T-03, Electrical Issues Month 20XX LGS 3-104 EP-AA-1 008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear 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:
4,5, 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 4KV Safeguards Buses reduced to only one of the following power sources for > 15 minutes.* 101 Safeguards Transformer
* 201 Safeguards Transformer
* D1l1(21) Diesel Generator* D12(22) Diesel Generator* D13(23) Diesel Generator* D14(24) Diesel Generator 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 20XX LGS 3-105 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CUI (cont)Initiating Condition:
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 CAl.Basis Reference(s):
: 1. NEI 99-01 Rev 6 CU2 2. UFSAR Section 8.2, Offsite Power System 3. E 10-20 Loss of Offsite Power 4. DBD L-S-05, 4KV System 5. DBD L-T-03, Electrical Issues Month 20XX LGS 3-106 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex I=xnlon  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:
4,5 Emergency Action Level (EAL): 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 events may require a post-event inspection to determine if the attributes of an explosion are present.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
Month 20XX LGS 3-107 EP-AA-1008 (Revision XX)
I impri(ck (GAneratinn Stamtion Annex Fvainn INmI-io2r 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 RSI.If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):
: 1. NEI 99-01 Rev 6, CA6 Month 20XX LGS 3-108 EP-AA-1008 (Revision XX)
Limerick Generatina Station 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:
4,5 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Voltage is < 105 VDC on required 125 VDC battery busses 1(2)FA, FB, FC, and FD 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 increase the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.
For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification.
Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Depending upon the event, escalation of the emergency classification level would be via IC CA6 or CA5, or an IC in Recognition Category R.Month 20XX LGS 3-109 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU3 (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, CU4 2. UFSAR Section 8.3.2, DC Power Systems 3. DBD P-L-01A, 125/250 VDC System 4. E-1(2)FA Loss of Division I Safeguard 125/250V DC BUS 1FA 5. E-1(2)FB Loss of Division II Safeguard 125/250V DC BUS 1FB 6. E-1(2)FC Loss of Division III Safeguard 125/250V DC BUS 1FC 7. E-1(2)FD Loss of Division IV Safeguard 125/250V DC BUS 1FD Month 20XX LGS 3-110 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4 Initiating Condition:
Loss of all onsite or offsite communications capabilities.
Operating Mode Applicability:
4,5, 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 Cl 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 Station Radio X Plant Public Address (PA) X Prelude System X X Station Phones X X X Satellite Phones X X X NARS X HPN X X ENS X X Basis: This IC addresses a significant loss of on-site, offsite, or NRC communications capabilities.
While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).EAL #1 Basis Addresses a total loss of the communications methods used in support of routine plant operations.
Month 20XX LGS 3-111 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4 (cont)Basis (cont): EAL #2 Basis Addresses a total loss of the communications methods used to notify all OROs of an emergency declaration.
The OROs referred to here are listed in procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form.EAL #3 Basis Addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, CU5 2. UFSAR Section 9.5.2, Communication Systems 3. SE-12 Loss of Communications Month 20XX LGS 3-112 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 Initiating Condition:
Inability to maintain the plant in cold shutdown.Operating Mode Applicability:
4,5 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 rise in RCS temperature 
> 200OF due to loss of decay heat removal for > Table C2 duration.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*Not Established 0 minutes* If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not applicable.
OR 2. UNPLANNED RPV pressure rise > 10 psig as a result of temperature rise due to loss of decay heat removal.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 (primary or secondary) 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, or steam line nozzle plugs, etc.).Month 20XX LGS 3-113 EP-AA-1008 (Revision XX)
I imariek rZgznarntin Atntinn Annoy I=valrn Mm-latar I im~riri, (~n~r2tinn 
~t2tinn Ann~v FvMnn NmmuIc~r RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 (cont)Basis (cont): 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. The 20-minute criterion was included to allow time for operator action to address the temperature rise.The RCS Heat-up Duration Thresholds table also addresses a rise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature rise without a substantial degradation in plant safety.Finally, in the case where there is a rise in RCS temperature, the RCS is not intact , 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 provides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS6 or RS1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, CA3 2. Technical Specifications LCO 3.6.5.1, Reactor Enclosure Secondary Containment Integrity 3. Technical Specifications Table 1.2, Operational Conditions
: 4. DBD L-S-16, Reactor Instrumentation System (RIS)5. UFSAR Section 6.2, Containment Systems 6. UFSAR Section 6.3, Emergency Core Cooling Systems 7. Technical Specifications LCO 3.6.1.1, Primary Containment Integrity 8. ST-6-107-640
: 9. ST-6-107-641
: 10. GP-6.2, Shutdown Operations-Shutdown Conditions Tech Spec Actions Month 20XX LGS 3-114 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex l=xelon Nuclear Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU5 Initiating Condition:
UNPLANNED rise in RCS temperature Operating Mode Applicability:
4,5 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 rise in RCS temperature 
> 200OF due to loss of decay heat removal.OR 2. Loss of the following for >15 minutes." ALL RCS temperature indications AND* ALL RPV water 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 (primary or secondary) 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, or steam line nozzle plugs, etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.
Month 20XX LGS 3-115 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex I:xelon Nuclear Exelon 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. T-102, Primary Containment Control -Bases 3. DBD L-S-16, Reactor Instrumentation System (RIS)4. ST-6-107-640-*
RX Vessel Temperature and Pressure Monitoring
: 5. GP-6.1 U/1(U/2) Shutdown Operations 
-Refueling, Core Alteration and Core Off-Loading
: 6. ST-6-107-641-*
RX Vessel Temperature and Pressure Monitoring with no RHR Shutdown Cooling Loops in Operation 7. GP-6.2, Shutdown Operations-Shutdown Conditions Tech Spec Actions Month 20XX LGS 3-116 EP-AA-1008 (Revision XX)
F=Yplnn  Limeric~k Generatinn Station AnnexFxnnNiIAm RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 Initiating Condition:
Loss of RPV inventory affecting fuel clad integrity with containment challenged.
Operating Mode Applicability:
4,5 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. RPV water level < -161 inches (TAF) for > 30 minutes.AND b. ANY Containment Challenge Indication (Table C4)OR 2. a. RPV water level unknown 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* ANY Table C5 Refuel Floor Area Radiation Monitor >3 R/hr.AND c. ANY Containment Challenge Indication (Table C4)Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression Pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.
Month 20XX LGS 3-117 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Emergency Action Level (EAL) (cont): Table C4 Containment Challenge Indications
* Primary Containment Hydrogen Concentration 
> 6% and Oxygen > 5%.* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established*
* Any Secondary Containment radiation monitor > T-103 / SAMP Max Safe Op Value (MSO).* 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.Table C5 Refuel Floor ARM's" RIS29-M1-1(2)K600, Drywell Head Laydown" RIS30-Ml -1 (2)K600, Dryer / Separator Area* RIS31-Mi-1(2)K600, Spent Fuel Pool* RIS32-M1-1(2)K600, New Fuel storage Vault* RIS33-M1-1(2)K600, Pool Plug Laydown Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.IMMINENT:
The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary for BWR) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.
Month 20XX LGS 3-118 EP-AA-1008 (Revision XX)
Limerick Generatinq Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Basis (cont): This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged.
This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity.
Releases can be reasonably expected to exceed EPA Protective Action Guidelines (PAG) exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment.
If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.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.
In EAL 2.a 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 RPV water 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 RPV.Month 20XX LGS 3-119 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Basis (cont): 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.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, CG1 2. T-102 Primary Containment Control -Bases 3. T-103 Secondary Containment Control -Bases 4. DBD P-S-20, Neutron Monitoring System 5. DBD L-T-02, Containment, Section 3.2.14 6. Technical Specifications 3.6.1.1, Primary Containment Integrity 7. Technical Specifications 3.6.5.1, Reactor Enclosure Secondary Containment Integrity 8. UFSAR section 6.2.1.1.3.1, Summary Evaluation
: 9. EP-AEL-0501, Estimation of Radiation Monitor Readings Indicating Core Uncovery During Refuel 10. T-101 RPV Control -Bases 11. SAMP-2, Containment and Radioactivity Release Control Month 20XX LGS 3-120 EP-AA-1008 (Revision XX)
I imerie-k (GAnerntinn Station Annex FvaInn Nuclekar RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 Initiating Condition:
Loss of RPV inventory affecting core decay heat removal capability.
Operating Mode Applicability:
4,5 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. With CONTAINMENT CLOSURE not established, RPV water level < -129 inches OR 2. With CONTAINMENT CLOSURE established, RPV water level < -161 inches (TAF).OR 3. a. RPV water level unknown 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* ANY Table C5 Refuel Floor Area Radiation Monitor >3 R/hr.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression Pool level rise** UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.
Month 20XX LGS 3-121 EP-AA-1008 (Revision XX)
Limeric~k Gener~atina Station Annex Fxelnn Nucler~I RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 (cont)Emergency Action Level (EAL) (cont): Table C5 Refuel Floor ARM's* RIS29-M1-1(2)K600, Drywell Head Laydown* RIS30-M1-1(2)K600, Dryer / Separator Area" RIS31-M1-1(2)K600, Spent Fuel Pool* RIS32-M1-1(2)K600, New Fuel storage Vault* RIS33-M1-1(2)K600, Pool Plug Laydown 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 (primary or secondary for BWR) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.
The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.
Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.
The difference in the specified RCS/reactor vessel levels of EALs #1 and #2 reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.
Month 20XX LGS 3-122 EP-AA-1008 (Revision XX) ime~rick (Generatinn Station Annex Fyalon N,~rIippr RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CS6 (cont)Basis (cont): In EAL #3.a, 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 RPV water 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 RPV.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. Technical Specification Table 3.3.2-2 3. T-101 RPV Control -Bases 4. T-102 Primary Containment Control -Bases 5. T-103 Secondary Containment Control -Bases 6. DBD P-S-20, Neutron Monitoring System 7. DBD L-T-02, Containment, Section 3.2.14 8. Technical Specifications 3.6.1.1, Primary Containment Integrity 9. Technical Specifications 3.6.5.1, Reactor Enclosure Secondary Containment Integrity 10. DBD L-S-34, Radwaste System Month 20XX LGS 3-123 EP-AA-1008 (Revision XX)
Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA6 Initiating Condition:
Loss of RPV inventory.
Operating Mode Applicability:
4,5 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 RPV inventory as indicated by level < -38 inches.OR 2. a. RPV water level unknown for > 15 minutes.AND b. Loss of RPV inventory per Table C3 indications.
Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise*" UNPLANNED Suppression Pool level rise*" UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV 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 conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier).
This condition represents a potential substantial reduction in the level of plant safety.EAL #1 Basis A lowering of water level below -38 inches indicates that operator actions have not been successful in restoring and maintaining RPV water level. The heat-up rate of the coolant will rise as the available water inventory is reduced. A continuing decrease in water level will lead to core uncovery.Month 20XX LGS 3-124 EP-AA-1008 (Revision XX) r Limeric~k Generatinn Station Annex FxeInn NuclerIAm RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA6 (cont)Basis (cont): Although related, EAL #1 is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). A rise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA5.EAL #2 Basis The inability to monitor RPV water 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 RPV.The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS6 If the RPV water 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. Technical Specification Table 3.3.2-2 3. Technical Specification 3.4.3, Reactor Coolant System Leakage 4. ARC-MCR-213-E3 Div 1 Reactor Lo-Lo-Lo Level 5. DBD L-S-16, Reactor Instrumentation System (RIS)6. DBD L-S-34, Radwaste System 7. T-102 Primary Containment Control Month 20XX LGS 3-125 EP-AA-1008 (Revision XX) mvimmriemk vnermtinn Stamtion Annex Fva.nn Mllutlor RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 Initiating Condition:
UNPLANNED loss of RPV inventory for 15 minutes or longer.Operating Mode Applicability:
4,5 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 RPV water level to above the procedurally established lower limit for > 15 minutes.OR 2. a. RPV water level unknown AND b. Loss of RPV inventory per Table C3 indications.
Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise*" UNPLANNED Suppression Pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.
Month 20XX LGS 3-126 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 (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 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 RPV water 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.The procedurally established lower limit is not an operational band established above the procedural limit to allow for operator action prior to exceeding the procedural limit, but it is the procedurally established lower limit.Refueling evolutions that 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 Basis Recognizes that the minimum required RPV water level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented.
This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.EAL #2 Basis Addresses a condition where all means to determine RPV water 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 RPV.Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA6 or CA5.Month 20XX LGS 3-127 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 (cont)Basis Reference(s):
: 1. NEI 99-01, Rev. 6 CU1 2. Technical Specification Table 3.3.2-2 3. ST-6-107-596-1 Drywell Floor Drain Sump/Equipment Drain Tank Surveillance
: 4. Technical Specification 3.4.3, Reactor Coolant Leakage 5. Technical Specifications 3.9.8, Water Level -Reactor Vessel 6. DBD L-S-34, Radwaste System 7. OT-101 High Drywell Pressure 8. T-102 Primary Containment Control, Table DW/T-1 9. GP-6.1 U/1(2) Shutdown Operations 
-Refuel Core Alterations 
& Core Off-loading
: 10. DBD L-S-16, Reactor Instrumentation System (RIS)Month 20XX LGS 3-128 EP-AA-1008 (Revision XX)
Limeric~k (Generatinn Stamtion Annex FvAImnn N~tlorIAi 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, D Emergency Action Level (EAL): 1. A notification from the Security Force that a HOSITLE 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)* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.IMMINENT:
The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.Month 20XX LGS 3-129 EP-AA-1008 (Revision XX)
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~t2tinn Ann~v ~v~Iv~n M.ur~In~r 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 20XX LGS 3-130 EP-AA-1008 (Revision XX)
N r Limeric~k (GAneratinn Station Annex Fwainn Nw-lorIAa 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, 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.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].Month 20XX LGS 3-131 EP-AA-1 008 (Revision XX)
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~*~tinn Ann~v Fw~Inn Nmma~I~2r RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 (cont)Basis (cont): 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 &sect; 73.71 or 10 CFR&sect; 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 20XX LGS 3-132 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex I=xelon  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, 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 20XX LGS 3-133 EP-AA-1008 (Revision XX)
Limerick Generatinci Station Annex Exelon Nuclear 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 &sect; 73.71 or 10 CFR &sect; 50.72.EAL #1 Basis 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 SE-23, Security Threat.EAL #2 Basis 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 HSI.Month 20XX LGS 3-134 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, HA1 2. Station Security Plan -Appendix C 3. SE-23 Security Threat Month 20XX LGS 3-135 EP-AA-1008 (Revision XX)
Limerick Generating Station 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, 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.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 &sect; 73.71 or 10 CFR &sect; 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Month 20XX LGS 3-136 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex I=xelon Nuclear Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HUl (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.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 Activities.
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 SE-23, 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 &sect; 2.39 information.
Escalation of the emergency classification level would be via IC HA1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, HU1 2. Station Security Plan -Appendix C 3. SY-AA-1 01-132, Security Assessment and Response to Unusual Activities Month 20XX LGS 3-137 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon 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, 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: " SE-1, Remote Shutdown OR* SE-6, Alternate Remote Shutdown 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)* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Basis: The time period to establish control of the plant starts when either: a. Control of the plant is no longer maintained in the Main Control Room OR b. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plan control to alternate locations is a precursor to a challenge to any fission product barriers within a relatively short period of time.Month 20XX LGS 3-138 EP-AA-1008 (Revision XX)
I imaria-Ie r~onarntinn -qttinn Annov Fvalem N"nlanr a -RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 (cont)Basis (cont): The determination of whether or not "control" is established at the remote safe shutdown location(s) is based on Emergency Director judgment.
The Emergency Director is expected to make a reasonable, informed judgment within 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).
Escalation of the emergency classification level would be via IC FG1 or CG6.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HS6 2. SE-1, Remote Shutdown 3. SE-6, Alternate Remote Shutdown Month 20XX LGS 3-139 EP-AA-1 008 (Revision XX)
Limerick Generating Station AnnexNuclear Exelon 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, D Emergency Action Level (EAL): A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per: " SE-1, Remote Shutdown OR" SE-6, Alternate Remote Shutdown 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. SE-1, Remote Shutdown 3. SE-6, Alternate Remote Shutdown Month 20XX LGS 3-140 EP-AA-1008 (Revision XX)
Simeric~k Generatinn Stt~ion Annex ExueInn Nucler~I 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, 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 FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of the following FIRE detection indications:
S 0 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* Reactor Enclosure (when inerted the Drywell is exempt)" Control Enclosure* Diesel Generator Enclosure* Spray Pond Pump House / Spray Network OR 2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of a FIRE).AND b. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.OR 3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication.
OR 4 A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.
Month 20XX LGS 3-141 EP-AA-1008 (Revision XX)
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~t~tinn AnnAYN  Limerick Generatinn Station Annex Exi-Inn 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.Month 20XX LGS 3-142 EP-AA-1008 (Revision XX)
I imarir-k rganarntin At2tinn Annoy I=voln~n  I mrii (nrtin~tain n~v~a~n*aIa RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)Basis (cont): If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.
EAL #3 Basis In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.EAL #4 Basis If a FIRE within the plant PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded.
The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish.
Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part: Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions." When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.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.
Month 20XX LGS 3-143 EP-AA-1008 (Revision XX) r I imerirk r~enprgntinn Atption Annax Expinn Nuirclnr RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)Basis (cont): 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. Specification NE-0294, "Fire Safe Shutdown Analysis Specification" Month 20XX LGS 3-144 EP-AA-1008 (Revision XX)
Limerick Generating Station 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, D Emergency Action Level (EAL): Seismic event > Operating Basis Earthquake (OBE) as indicated by:* ARC-MCR-00C693, WINDOW B1, OBE EXCEEDED alarmed OR* OBE red light is lit at panel 00C693 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, 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.
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. SE-5, Earthquake
: 3. ARC-MCR-00C693 B1, OBE Exceeded 1 An OBE is vibratory ground motion for which those features of a nuclear power plant necessary for continued operation without undue risk to the health and safety of the public will remain functional.
An SSE is vibratory ground motion for which certain (generally, safety-related) structures, systems, and components must be designed to remain functional.
Month 20XX LGS 3-145 EP-AA-1008 (Revision XX) 

Simeric~k Gener~atinn Stamtion Annex Fxeinn Nuclea~r 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, 3, 4, 5, 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. Release of a toxic, corrosive, asphyxiant or flammable gas in a Table H3 area.Table H3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Enclosure*
Modes 3, 4, and 5*Areas required to establish shutdown cooling 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.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.Month 20XX LGS 3-146 EP-AA-1008 (Revision XX)
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* t* t* *r. **f l.RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 (cont)Basis (cont): An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the gaseous release preclude the ability to place shutdown cooling in service. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
An emergency declaration is not warranted if any of the following conditions apply.* The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release).
For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4." The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).* The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
* The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment.
This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that generate smoke, that automatically or manually activate a fire suppression system in an area, or to intentional inerting of containment.
Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.Basis Reference(s):
: 1. NE 99-01, Rev 6 HA5 Month 20XX LGS 3-147 EP-AA-1008 (Revision XX)
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~t~$inn Ann0w Fvg~Inn M..r~I0~r RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 Initiating Condition:
Hazardous Event Operating Mode Applicability:
1, 2,3,4,5, 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.
: 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.Month 20XX LGS 3-148 EP-AA-1008 (Revision XX)
Limeric~k (GAneratinn St~ation Annex FvAInn N"H~Ianr RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 (cont)Basis (cont): EAL #1 Basis Addresses a tornado striking (touching down) within the Protected Area.EAL #2 Basis Addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode. Manual isolation of power to a SAFETY SYSTEM component as a result of leakage is an event of lesser impact and would be expected to cause small and localized damage. The consequence of this type of event is adequately assessed and addressed in accordance with Technical Specifications.
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 2. UFSAR Section 3.4.1, Flood Protection
: 3. UFSAR Section 6.2.1.1.1, Design Bases 4. SE-5 Earthquake 5 SE-4 Flood 6. SE-9 Preparation for Severe Weather Month 20XX LGS 3-149 EP-AA-1008 (Revision XX)
Limerick Generatina Station 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, D Emergency Action Level (EAL): Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.
Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.Basis: IMMINENT:
The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a General Emergency.
Basis Reference(s):
: 1. NEI 99-01, Rev 6 HG7 Month 20XX LGS 3-150 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex ExAIon  Exelon Nuclear 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, D Emergency Action Level (EAL): Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a Site Area Emergency.
Basis Reference(s):
: 1. NEI 99-01, Rev 6 HS7 Month 20XX LGS 3-151 EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexNuclear Exelon Nuclear 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, D Emergency Action Level (EAL): Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HA7 Month 20XX LGS 3-152 EP-AA-1008 (Revision XX)
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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, D Emergency Action Level (EAL): Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.
No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an UNUSUAL EVENT.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HU7 Month 20XX LGS 3-153 EP-AA-1008 (Revision XX)
Limerick Generating Station 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, D Emergency Action Level (EAL): Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading:* > 1400 mrem/hr on the HSM or HSM-H front surface (applicable to type 1 61BTH DSC only)OR* > 800 mrem/hr at 3 ft from the HSM surface (applicable to 61 BT DSC only)OR 0 > 200 mrem/hr on the HSM or HSM-H door centerline OR* > 40 mremlhr on the end shield wall exterior.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.Month 20XX LGS 3-154 EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY ISFSI MALFUNCTIONS E-HU1 (cont)Basis (cont): Security-related events for ISFSIs are covered under ICs HU1 and HA1.Basis Reference(s):
: 1. NEI 99-01, Rev 6 E-HU1 2. Limerick Generating Station ISFSI 1OCFR72.212 Evaluation Rev 6 Attachment 1 3. OU-LG-643, Transport of Loaded Transfer Cask and 61 BT Dry Shielded Canister to Transfer Trailer, to ISFSI, and Alignment/Insertion into Horizontal Storage Module" Month 20XX LGS 3-155 EP-AA-1008 (Revision XX)}}