NG-18-0090, Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. (: Difference between revisions

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{{Adams
{{Adams
| number = ML18212A231
| number = ML18212A227
| issue date = 07/26/2018
| issue date = 07/26/2018
| title = Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. (Pa
| title = Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. (Pa
| author name =  
| author name = Curtland D
| author affiliation = NextEra Energy Duane Arnold, LLC
| author affiliation = NextEra Energy Duane Arnold, LLC
| addressee name =  
| addressee name =  
| addressee affiliation = NRC/NRO
| addressee affiliation = NRC/Document Control Desk, NRC/NRO
| docket = 05000331
| docket = 05000331
| license number = DPR-049
| license number = DPR-049
| contact person =  
| contact person =  
| case reference number = NG-18-0090
| case reference number = NG-18-0090
| document type = Response to Request for Additional Information (RAI)
| document type = Letter type:NG, Response to Request for Additional Information (RAI)
| page count = 125
| page count = 13
}}
}}


=Text=
=Text=
{{#Wiki_filter:NEI 99 QI (RevisioA
{{#Wiki_filter:NEXTeraM ENERGY~ DUANE ARNOLD July 26, 2018 NG-18-0090 10 CFR 50.90 10 CFR 50, Appendix E U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Duane Arnold Energy Center Docket No. 50-331 Renewed Facility Operating License No. DPR-49 Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors"  
: 6) }>Joye me er 2Q 12 10 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS 17 9 
}>ffil 99 QI (RevisioR e) November 2012 Tal>le H 1: Reeognition CategoFY "H" Initiating Condition MatFix UNUSUAL EVENT HUl Confirmed SECURITY CONDITION or Op. A1edes: All HU2 Seismic e 1 ,rent greater than OBE Op. A1edes: All HUJ Hazardous e¥eflt Op. A1edes: All HU4 FIRE potentially degrading the level of safety of the plant. Op. },1edes: All ALERT HAl HOSTILE ACTION within the OWNER CO~ffROLLED AREA or airborne attack threat *within 30 minutes. Op. },fades: All HA5 Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdo 1 Nn. Op. ,\1edes: All Hf...(i Control Room evacuation resulting in transfer of plant control to alternate locations.
Op. ,\1edes: All SITE AREA EMERGENCY HSl HOSTILE ACTION within the PROTECTED AREA. Op. A1edes: All HS(i Inability to control a key safety function from outside the Control Room. Op. },1edes: All 180 I GENERAL EMERGENCY HGl HOSTILE ACTION resulting in loss of physical control of the facility.
Op. ,\1edes: All Table intended for use by 1 EAL deYelopers.
: lnelusion in lieensee : doeurnents is not required.
L------------------J UNUSUAL EVENT HU7 Other conditions exist which in the judgment of the Emergency Director 1tvarrant deelaration of a (NO)UE. Op. J,1odes: All ALERT HA7 Other conditions e>,ist which in the judgment of the Emergency Director warrant deelaration ofan Alert. Op. A/odes: All ECL: Notification of Unusual Event SITE AREA EMERGENCY HS7 Other conditions e>,ist which in the judgment of the Emergency Director warrant deelaration of a Site Area Emergency.
Op. A1ode s: All Initiating Condition:
Confirmed SECURITY CONDITION or threat. Operating Mode Applicability:
All Emergency Action Levels: NE! 99 01 (RevisioR
: 6) November 2012 GENERAL EMERGENCY HG7 Other conditions e>,ist which in the judgment of the Emergency Director warrant declaration of a General Emergency.
Op. ,\1odes: All HU1 E xample Emergency Action Levels: (1 or 2 or 3) A SECURJTY CONDITION that does not involve a HOSTILE ACTION as reported by the (site specific security shift supervision).DAEC Security Shift Supervision. Notification of a credible security threat directed at the siteDAEC. A validated notification from the NRC providing information of an aircraft threat. Definitions:
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 S E CURITY CONDITION does not involve a HOSTILE ACTION. HOSTILE ACTION: An act toward DAEC 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 nuclear power plant. -terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area). 181 
}ffil 99 0 I (Re,*isioA 6) }fo 1 remeer 2012 SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including theincluding the ECCS. These systems are classified as safety-related.
Basis: 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 f-73.71 or 10_-CFR--§ 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HAI, HSI and HGl. Timely and accurate communications between DAEC Security Shift Superv i sion 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 personne l and GRGoffsite response organization
: s. 182 NEI 99 QI (RevisieA a) !>foveme er 2012 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}.
183 NEI 99 Q 1 (ReYisioA
*i) l'loYeFAeeF 2Q12 EAL HUI.I references (site specific security shift supervision)DAEC Security Shift Supervision because these are the indi vidua l s trained to co nfirm that a security event i s occurring or has occ urr ed. Training on security event confirmation and classification i s controlled due to the nature of Safeguards and 10 CFR § 2.39 Q inform atio n. EAL HUI.2 addresses the receipt of a credib l e security threat. The credibi lity of the threat is assessed in accordance with Abnormal Operating Procedure (AOP) 914, Security Events. specific procedure). EAL HU 1.3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) wi ll comm unicat e to the li censee i f the threat inv olves an aircraft.
T h e status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat i s performed in accordance w ith (site specific procedure)
Abnormal Operating Procedure (AOP) 914, Security Events . .,. Emergency plans and implementing procedures are public documents; therefore , EALs should do not in corporate Security-sensitive in formation. This includ es information that may be advantageous to a potential adversary , such as the particulars concerning a specific threat or threat l ocat ion. Security-sensitive information should beis contained in non public documents such as the Security Plan. Esca l ation of the emerge n cy class ific ation l eve l wou ld be via IC HA 1. Developer Notes: The (site specific security shift supervision) is the title of the on shift individual responsible for supervision of the on shift security force. The (site specific procedure) is the procedure(s) used by Control Room and/or Security personnel to determine if a security threat is credible, and to validate receipt of aircraft threat information.
Emergency plans and implementing procedures are public documents; therefore, E/\Ls should not incorporate Security sensitive information. This includes information that may be advantageous to a potential adversary , such as the particulars concerning a specific threat or threat location.
Security sensitive information should be contained in non public documents such as the Security Plan. With due consideration given to the above developer note, EALs may contain alpha or numbered references to selected events described in the Security Plan and associated implementing procedures.
Such references should not contain a recognizable description of the event. For example , an EAL may be worded as "Security event #2, #5 or #9 is reported by the (site specific security shift supervision)
." EGL Assignment Attributes:
3 .1.1.A 184 NEI 99 0 I (Re 1 1isioR 6) }io¥ember 2012 ECL: Notification of Unusual Event Initiating Condition:
Seismic event greater than OBE levels. Operating Mode Applicability:
All Exa1Rple Emergency Action Levels: H 2.1 Seismic event greater than Operating Basis Earthquake (OBE) as indicated by+ HU2 --+----receipt of the Amber Operating Basis Earthquake Light and the wailing seismic alarm on IC35. Definitions:
DESIGN BASIS EARTHQUAKE (DBE): A DBE is vibratory ground motion for which certain (generally, safety-related) structures.
systems, and components must be designed to remain functional.
OPERATING BASIS EARTHQUAKE (OBE): 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.
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 t. An earthquake greater than an OBE but less than a Safe ShutdownDesign Basis Ear thquake (SSeDBE)i 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 under sta nd any impacts , this event represents a potential degradation of the level of safety of the plant. Eve nt verification with external sources s hould not be necessary durin g or following an OBE. Ea rthquakes of this magnitude should be readily felt by on-site personnel and recognized as a se ismic event (e.g., typical lateral accelerations are in e>wess of 0.08g). The Shift Manager or E mergenc y Director ma y seek external verification if deemed appropriate ( e.g., a call to the + AR OBE is ¥ibratory grouRd motioR fur whieh those features ofa Ruelear power plaRt Reeessary for eoRtiRued operatioR without uRdue risk to the health aRd safety of the publie will remaiR fuAetioAal.
;! AR SSE is Yibratory grouRd motioR fur whieh eertaiR (geRerally, safety related) struetures , systems , aAd eompoReRts must be desigRed to remaiR fuAetioRal.
185 NEI 99 0 I (Re\*ision
: 6) NoYember 2012 USGS , check internet news so urces , etc.); however , the verification action must not preclude a timely emergency declaration.
OBE events are detected in accordance with AOP 901. The OBE is associated with a peak horizontal acceleration of+/- 0.06g. Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA6 or .£.A.9SA8. De"-1 el0per Netes: This "site specific indication that a seismic event met or exceeded QBE limits" should be based on the indications, alarms and displays of site specific seismic monitoring equipment.
Indications described in the EAL should be limited to those that are immediately available to Control Room personnel and which can be readily assessed. Indications available outside the Control Room and/or 1.vhich require lengthy times to assess (e.g., processing of scratch plates or recorded data) should not be used. The goal is to specify indications that can be assessed within 15 minutes of the actual or suspected seismic event. For sites that do not have readily assessable QBE indications within the Control Room, developers should use the following alternate EAL (or similar 1.vording). (1) a. b. Control Room personnel feel an actual or potential seismic event. The occurrence of a seismic event is confirmed in manner deemed appropriate by the Shift Manager or Emergency Director.
The EAL l .b statement is included to ensure that a declaration does not result from felt vibrations caused by a non seismic source (e.g., a dropped heavy load). The Shift Manager or Emergency Director may seek e><ternal verification if deemed appropriate (e.g., a call to the USGS, check internet nev,rs sources, etc.); howe*,rer, the verification action must not preclude a timely emergency declaration.
It is recognized that this alternate EAL *.vording may cause a site to declare an Unusual Event *while another site , similarly affected but with readily assessable QBE indications in the Control Room, may not. The above alternate
*n<ording may also be used to develop a compensatory EAL for use during periods vrhen a seismic monitoring system capable of detecting an QBE is out of service for maintenance or repair. EGL Assignment Attributes:
3.1.1.A 186 NEI 99 Q 1 (ReYision
: 6) No 1 1ember 2Ql2 HU3 ECL: Notification of Unu s ual Event Initiating Condition:
Hazardous event.&sect; Operating Mode Applicability:
All Emergency Action Levels: Example EmeFgeney Aetion Levels: (1 or 2 or 3 or 4 or 5 or 6) Note: E AL HU3.4 does not apply to routine traffic impediments such as fog , snow , ice , or vehicle breakdown s o r accident s. ~1 !k 2 H~J3.3 H LJ 3.4 A tornado strike within the PROTECTED AREA. Internal room or area floodin g of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode. Movement of personnel within the PROTECT E D AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).
A hazardous event that results in on-site condition s sufficient to prohibit the plant staff from accessing the site via personal vehicles. Definitions:
PROTECTED AREA: The area under continuous access monitoring and control, and armed protection as described in the site Security Plan. 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 systems are classified as safety-related
.A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the EGGS. Systems classified as safety re l ated. Basis: This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant. EAL HU3.1 addresses a tornado striking (touching down) within the Protected Area. E AL HU3.2 addresses floodin g of a building room or area that results in operators isolating power to a SAFETY SYST E M 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 SAF E TY SYSTEM component from its power source ( e.g., a breaker or relay trip). To 187 Jloffil 99 01 (Revision a) Jl,fo,,cember 2012 warrant classification , operability of the affected component must be required by Technical Specifications for the current operating mode. EAL HU3.3 addresses a hazardous materials event orig in ating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA. 188 NEI 99 01 (RevisioR e) NoYeR'leer 2012 EAL HU3.4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.
Examples of such an event include site flooding caused by a hurricane , heavy rains, up-river water releases , dam fai lur e , etc., or an on-site train derailment blocking the access road. This EAL is not intended apply to routine impediments such as fog , snow, ice, or ve hicl e breakdowns or accidents , but rather to more s i gnificant conditions such as the Hurricane Andrew strike on Turkey Point in 1992 , the flooding around the Cooper Stat i on during the Midwest floods of 1993, or the flooding around Ft. Ca lh oun Station in 2011. EAL .H..!LL5 addresses (site specific description). . Escalation of the emergency classification l eve l wou ld be based on I Cs in Recognition Categories AR , F, Sor C. De'i'elepeF Netes: The "Site specific list of natural or technological hazard events" should include other events that may be a precursor to a more significant event or condition , and that are appropriate to the site location and characteristics. Notwithstanding the events specifically included as EALs above , a " Site specific list of natural or technological hazard events" need not include short lived events for which the extent of the damage and the resulting consequences can be determined 1.vithin a relatively short time frame. In these cases , a damage assessment can be performed soon after the event, and the plant staff 1.vill be able to identify potential or actual impacts to plant systems and structures.
This 1.vill enable prompt definition and implementation of compensatory or corrective measures with no appreciable increase in risk to the public. To the e>, tent that a short lived event does cause immediate and significant damage to plant systems and structures, it will be classifiable under the Recognition Category f, S and C ICs and EALs. Events of lesser impact would be e>,pected to cause only small and localized damage. The consequences from these types of events are adequately assessed and addressed in accordance with Technical Specifications.
In addition , the occurrence or effects of the event may be reportable under the requirements of 10 CFR 50.72. EGL Assignment Attributes:
3.1.1.A and 3.1.1.C 189 NEI 99 Q l (RtwisieR e) Ne&#xa5;ember 2012 HU4 ECL: Not ificati on of U nu s u a l Eve nt Initiating Condition:
F I RE potentially degrading the lev el of safety of the plant. Operating Mode Applicability:
All Emergency Action Levels: Example Emergeeey Aetiee Levels: (1 or 2 or 3 or 4) Note~:
* T h e E m ergency Director s hould declar e the Unusual Eventevent promptl y upon determining that the app li ca ble time ha s b ee n exceede d , or will lik e l y b e excee ded. H LJ 4.l a. A FIRE i s NOT ext in guis h ed w ithin 15-minutes of ANY of the follow in g FIRE d e t ectio n indi catio ns: H 4.2 H 4.4
* Report from the field (i.e., visual observation)
* Receipt of multiple (more than 1) fire alarms or indi cat i o n s
* Fie ld verificat ion of a s in g l e fire a l ar m AND b. The FIRE i s l oca ted w ithin ANY of the followingTable H-1 plant rooms or areas+ a. (site specific list of plant rooms or areas) Receipt of a sing l e fire alarm ~with n o other indications of a FIRE j. ---AND b. The FIRE i s l ocate d w ithin ANY of the followingTable H-1 plant roo m s or areas (site specific I ist of plant rooms or areas) ----AND c. The ex i ste nc e of a FIRE is not verified within 3 0-minut es of a larm receipt. A FIRE w ithin the plant or ISFSI [forplemts wit.Li an ISFSI eutside t,l1ep/a,9t Preteeted Afe.at-PROTECTED AREA n ot ext in g ui s h ed within 60-minutes of the initi a l report , alar m or indication.
A FIRE w ithin the pl ant or ISF SI [for plants wit.Li an ISFSI eutside the plant Pfflteeted Afe.at-PROTECTED AREA that requires firefighting s upp ort by an offs it e fire response agency to extinguish.
Table H-1 Fire Areas 190
* I G31 DG and Day Tank Rooms,
* I G21 DG and Day Tank Rooms,
* Battery Rooms,
* Essential Switchgear Rooms,
* Cable Spreading Room
* Torus Room * ~Intake Structure;
* Pumphouse
* Drywell,
* Torus
* NE. NW. SE Corner Rooms,
* HPCI Room,
* RCIC Room,
* RHR Va l ve Room,
* North CRD Area,
* South CRD Area,
* CSTs
* Control Building,
* Remote Shutdown Panel I C388 Area,
* Panel ICSS/56 Area;
* SBGTRoom 191 Jl,ffil 99 g I (ReyisioR e) jl,fo,,cemeer 2('.)12 Definitions:
NEI 99 0 I (ReYisioR
: 6) }fo 1 i8FR88F 20] 2 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: The area under continuous access monitoring and control. and armed protection as described in the site Security Plan. Basis: 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. E AL HU4.1 The intent of the 15-minute duration i s to size the FIRE and to discriminate against small FIRES that are readi l y extinguished (e.g., smoldering waste paper basket). In addit ion to alarms , other indications of a FIRE cou ld 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 ofreceipt of the initial alarm , indication or report. EAL HU4.2 This EAL addresses receipt of a sing l e fire a l arm , 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 a l arm. 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 , additiona l time is allowed to verify the valid it y 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.
192 
~IBI 99 01 (ReYisioA
: 6) ~Jovemeer 20 I 2 If an actual FIRE is verified by a report from the field, then EAL HU4.1 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 HU4.3 In addition to a FIRE addressed by EAL HU4.1 or EAL HU4.2, a FIRE within the plant or ISFSI PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety. This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA. [Sentence for plants with an ISFSI outside the plant Protested i\rea] EAL HU4.4 If a FIRE within the plant or ISFSI [for plants with tm ISFSI eutside the plant PretectedArea]
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 Rand NFPA-805 Criterion 3 of Appendix A to 10 CFR 50 states in part 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
." The Nuclear Safety Goal (" NSG") in NFPA 805, Section 1.3.1 states, "The nuclear safety goal is to provide reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition." When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance because a safe shutdown success path, free of fire damage, must be available to meet the nuclear safety goals, objectives and performance criteria for a fire under any plant operational mode or configuration.
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.
193 J>ffil 99 O 1 (Re,*isioR e) J>fo*yemaer 2012 In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of I-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). Even though DAEC has adopted the alternate approach provided by NFPA-805 in lieu of the deterministic requirements of Appendix R, the 30-minutes to verify a single alarm as used in EAL HU4.2 is considered a reasonable amount of time to determine if an actual FIRE exists without presenting a challenge to the nuclear safety performance criteria.Basis Related Requirements from Appendix R Appendi>l R to 10 CFR 50 , states in part: Criterion 3 of Appendi>, A to this part specifies that "Structures , systems, and components important to safety shall be designed and located to minimize , consistent 1.vith other safety requirements , the probability and effect of fires and e>,plosions." '.&#xa5;hen considering the effects of fire, those systems associated 1.vith achieving and maintaining safe shutdovm 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 shutdovm 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 ,veil 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 wou ld be via IC CA6 or SA-9SA8. De...eloper Notes: The "site specific list of plant rooms or areas" should specify those rooms or areas that contain SAFETY SYSTEM equipment.
As noted in the EALs and Basis section , include the term ISFSI if the site has an ISFSI outside the plant Protected Area. EGL Assignment Attributes:
3 .1.1.A 194 ECL: Notification of Unusual Event NEJ 99 01 (RevisioA
: 6) ~fo*,<emeer 2012 HU-76 Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrant declaration of a fN 0 1 UE. Operating Mode Applicability:
All l Exemple Emergency Action Levels: 1 Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.
No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of SAFETY SYSTEMS safety systems occurs. Definitions:
SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or p l acing it in the cold shutdown condition, i nc l uding the ECCS. These systems are classified as safety-related
.A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdovm condition, including the EGGS. Systems classified as safety re l ated. Basis: This IC addresses unanticipated conditions not addressed explicit l y elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fa ll under the emergency classificat i on level description for a NOUE. 195 NEJ 99 QI (RevisioR
: 6) No 1 t'0FR00F 2()12 HA1 ECL: Alert Initiating Condition:
HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes. Operating Mode Applicability:
All Example Emergency Action Levels.:.: (1 or 2) A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the (site specific security shift supervision)DAEC Security Shift Supervision. A validated notification from NRC of an aircraft attack threat within 30 minutes of the site. Definitions:
HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. HOSTILE ACTION: An act toward DAEC 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 nuclear power plant. 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). OWNER CONTROLL E D AREA: The site property owned by or otherwise under the control of the licensee. PROJECTILE
: An object directed toward a nuclear power plant that could cause concern for its continued operability , reliability , or personnel safety. Basis: This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. Th i s event will require rapid response and assistance due to the possibi l ity 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 DAEC Security Sh i ft Supervision and the Control Room is essentia l for proper c l assification of a security-re l ated 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}.
196 NEI 99 0 I (RevisioA
*i) NoYeFAeer 2012 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 HA I.I is applicable for any HOSTILE ACTION occurring , or that has occurred , in the OWNER CONTROLLED AREA. This includes any action directed against att-the ISFSI that which is located outside the plant PROTECTED AREA. EAL HAI .2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and GRGoffsite response organization s are in a heightened state of readiness.
This EAL is met when the threat-related information has been validated in accordance with fAbnormal Operating Procedure (AOP) 914, Security Events site specific procedure).&sect;.,_
The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.
The status and size of the plane may be provided by NORAD through the NRC. In some cases , it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected , although not certain , that notification by an appropriate Federal agency to the site would clarify this point. In this case , the appropriate federal agency is intended to be NORAD , FBI , FAA or NRC. The emergency declaration , including one based on other ICs/EALs , should not be unduly delayed while awaiting notification by a Federal agency. Emergency plans and implementing procedures are public documents; therefore, EALs should do not incorporate Security-sensitive information.
This includes information that may be advantageous to a potential adversary , such as the particulars concerning a specific threat or threat location.
Security-sensitive information should be ~contained in non public documents such as the Security Plan. Escalation of the emergency classification level would be via IC HS 1. DevelopeF Notes: The (site specific security shift supervision) is the title of the on shift individual responsible for supervision of the on shift security force. Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.
Security sensitive information should be contained in non public documents such as the Security Plan. 197 
~ffil 99 0 I (Re*,isioA e) urth 8 . November 201? .r1ue cons1aeration given to the abo*c e ., -**~hoR>0 :'*'&deg;'""***
te soloote0 ovoAls Bosoribo~
iElet~el';J'er
*.***. EALs "'"'.I ***teio alpha e, imp ementmg proceaures.
Such references h la n e ec~nty Plan ans associates event. For e:irnm I e s ou not contam a re
* bl . ( * . ----p*e , ao -AL fllay be wer0e8 as " S _eeg,,,za
* Elesenptieo efthe site specific security shift supervision)." ecunty event #2 , #5 or #9 is reportea by the See the relates Developer Note . A
* aevelopment of a scheme aefinition for1:h;*~~~~~~BCgefinitions , for guiaance on the ** }>HROLLBD A~ A eCL Assignment Attributes:
3.1.2.D '..:. n. 198 NEI 99 01 (RevisioR e) ?>lovember 2012 HA5 ECL: Alert Initiating Condition:
Gaseous release impeding access to equipment necessary for normal plant operations , cooldo'+'m , or shutdown. Operating Mode Applieal>ility:
All Example Emergeney Aetion Levels: Note: If the equipment in the listed room or area \Vas already inoperable or out of service before the event occurred , then no emergency classification is warranted.
follo'+'i'ing plant rooms or areas: (site specific I ist of plant rooms or areas 1 Nith entry related mode applicability identified) ,t\..l\JD
: b. Entry into the room or area is prohibited or impeded. This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to maintain normal plant operation, or required for a normal plant cooldown and shutdown. This condition represents an actual or potential substantial degradation of the level of safety of the plant. An Alert declaration is warranted if entry into the affected room/area is, or may be , procedurally required during the plant operating mode in effect at the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release. Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis , report of ill effects on personnel, advice from a subject matter ex.pert or operating e>tperience vrith 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 1 Narranted 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 e>rnmple, the plant is in Mode 1 1.vhen the gaseous release occurs , and the procedures used for normal operation , cooldown and shutdown do not require entry into the affected room unti I Mode 4 . 199 
: h. h address the r , measures 'tV ie . ludes compensate. Y , tern testing). . :~:::;:::*;;;n;e~d;a~c~ftp~,'i~t)~
'~ th~a~t;m:;c;;Efir:es:u:p:p:re:s:s:10:n::S)~:s*:::re:c:o:r:dk:e:e:pm:g
* TAe gas ,el ease IS a.:'~~ efa roam a, area (e.g;j is ef!lfl admiaistrot,ve e, erary iaaeeess, , , rea eat,y is req**ff> d "*euld Rel temp . fer wAieA ,eem,a fRe iRSj)eet10as).
f """'Y """'"'* aA "
* The action I rounds or mu I 'ati, '0 or precau I E norma f consen
* naturee.g., I easures are o a . The aeeess eeRtro* '." ede a required aeheA. d . te daagerous levels. aeUJally preveat er ,mp . tAe level ef eKygea iR !lie ~=s:.i eaviroameat. -!~" al,le ef redue1ag . I eiag aiflA aa eae * ., 4.ieA eaa lea e ' R aspAy,<iaat is a ga s *IIJ' ats werk l,y merely d1Sp ** al !~tel ef al'0uad 19 ,S , " n moni)', asphyxia , n below the nor Mest eem eRtmtiea ef e*) ge """" deatla. reduces the cone I
* unconsciousness , or 200 201 NEI 99 O 1 (RevisieR e) },fovemaer 2012 ECL: Alert NEI 99 01 (RevisioR e) ~fo*refReer 2012 HA6HA5 Initiating Condition:
Control Room evacuation resulting in transfer of plant control to alternate locations.
Operating Mode Applicability:
All Example Emergency Action Level s: H 65.1 An event has resulted in plant control being transferred from the Control Room to specific remote shutdo 1 Nn panels and local control stations)the Remote Shutdown Panel (1 C388). Definitions:
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 HS 62_. Developer Notes: The "site specific remote shutdovrn panels and local control stations" are the panels and control stations referenced in plant procedures used to cooldown and shutdown the plant from a location(s) outside the Control Room. EGL Assignment Attributes:
3.1.2.B 202 ECL: Alert NEI 99 01 (Re11ision t'i) ~lo*reff!eer 2012 HA7HA6 Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert. Operating Mode Applicability:
All l E,ample Eme.-geeeyEmergency Action Leve ls: 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. Definitions:
HOSTILE ACTION: An act toward DAEC 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 nuclear power plant. 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 nuclear power plant that could cause concern for its continued operability, reliability, or personnel safety. 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 Alert. 203 ECL: Site Area Emergency Initiating Condition:
HOSTILE ACTION within the PROTECTED AREA. Operating Mode Applicability:
All Example EmergeneyEmergency Action Levels: NEI 99 01 (RevisioR e) ~lovemeer 2012 HS1 S 1.1 A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site specific security shift supervision)DAEC Security Shift Supervision. Definitions:
HOSTIL E ACTION: An act toward DAEC 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 device s 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 nuclear power plant. Non-terrorism-ba s ed EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area). HOST AGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. HOSTIL E FORCE: One or more 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.
PROJECTILE:
An object directed toward a nuclear power plant that could cause concern for its continued operability, reliability, or personnel safety. PROTECTED AREA: The area under continuous acce s s monitoring and control, and armed protection as described in the site Security Plan. Basis: 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 DAEC 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 , Safeguard s Contingency Plan [and Independent Spent Fuel Storage Installation Security Program}.
204 NEI 99 01 (RevisioA
: 6) NoYemeer 2012 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 GRGoffsite response organization 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 atrthe ISFSI PROTECTED AREA which is located outside the plant PROTECTED AREA; such an attack should be assessed using IC HAI. 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 f-73.71 or 10 CFR f-50.72. Emergency plans and implementing procedures are public documents; therefore, EALs should do not incorporate Security-sensitive information.
This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.
Security-sensitive information should beis contained in non public documents such as the Security Plan. Escalation of the emergency classification level would be via IC HGl. Develeper Netes: The (site specific security shift supervision) is the title of the on shift individual responsible for supervision of the on shift security force. Emergency plans and implementing procedures are public documents; therefore , EALs should not incorporate Security sensitive information.
This inc l udes information that may be advantageous to a potential adversary , such as the particulars concerning a specific threat or threat location.
Security sensitive information should be contained in non public documents such as the Security Plan. 'Nith due consideration given to the above developer note , EALs may contain alpha or numbered references to selected ev e nts described in the Security Plan and associated implementing procedures.
Such references should not contain a recognizable description of the event. For e).ample, an EAL may be 1.vorded as " Security event #2 , #5 or #9 is reported by the (site specific security shift supervision)." See the related Developer Note in Appendix B , Definitions , for guidance on the development of a scheme definition for the PROTECTED AREA. EGL i\ssignment Attributes:
3.1.3.D 205 l'JEI 99 QI (Re*,isioR e) }'fo*,emaer 2Q 12 HS6HS5 ECL: Site Area Emergency Initiating Condition:
Inability to control a key safety function from outside the Control Room. Operating Mode Applicability:
All Example Emergency Action Levels: Note: The Emergency Director should declare the Site Area Emergencyevent promptly upon determining that (site specific number the applicable timeof'.20 minutes) has been exceeded , or will likely be exceeded.
: a. b. Definitions:
Basis: An event has resulted in plant control being transferred from the Control Room to (site specific remote shutdown panels and_control stations) the Remote Shutdown Panel (1 C388). AND Control of ANY of the following key safety functions is not reestablished within (site specific number of20 minutes).
* Reactivity control
* Core cooling [PWR] I RPV water level [BWR]
* RCS heat removal 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 g ain control of a key safety function following a transfer of plant control to alternate locations is a precursor to a challenge to one or more fission product barriers within a relatively short period of time. The determination of whether or not "control" is established at the remote safe shutdown location(s)Remote Shutdown Panel (1 C388-islli based on Emergency Director judgment.
The Emergency Director is expected to make a reasonable , informed judgment within (the site specific time for transfer)
~20 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).
AOP 915, " Shutdown Outside Control Room" provides the following CAUTION -" For Control Room evacuation as th e r e sult ofa fir e , transfer of control at panels 1 C388, 1 C389, 1 C390. JC391, JC392and JC392 i s required to be completed within 20 minutes." E scalation of the emergency classification level would be via IC FG I or CG 1. 206 Developer Notes: NEJ 99 01 (ReYisioR
: 6) No1rember 2012 The "site specific remote shutdown panels and local control stations" are the panels and control stations referenced in plant procedures used to eooldown and shutdown the plant from a location(s) outside the Control Room. The "site specific number of minutes" is the time in which plant control must be (or is expected to be) reestablished at an alternate location as described in the site specific fire response analyses.
Absent a basis in the site specific analyses, 15 minutes should be used. Another time period may be used with appropriate basis/justification.
EGL Assignment Attributes:
3.1.3.B 207 ECL: Site Area E m ergency }ffil 99 QI (Re\1 isioR *i) }loyemeer 2012 HS7HS6 Initiating Condition:
Other conditions ex i s t w hi c h in th e judgment of the E mer ge nc y Dir ec tor warrant declaration of a S it e Area Emerge nc y. Operating Mode Applicability:
Al l E .. mple Emergency Action Level s: 1 Other conditions ex i st w hich in the jud gment of the Emerge nc y Dir ector indicat e t ha t events are in progress or hav e occ urr e d which invol ve act ual or lik e l y major failures of plant f un ct ion s n eede d fo r protection of the public or HOSTILE ACTI O N that r es ult s in int ent i o nal d amage or m a lici o u s acts , (1) toward si t e p erso nnel or eq uipm e nt that could l ead to th e lik e l y fai lur e of or , (2) th at prevent effect i ve access to equipme nt needed fo r the protection of the p ubli c. Any releases are not expected to result in expos ur e l eve l s w hich exceed EPA Protective Action Guideline expos ur e l evels b eyo nd the s it e boundar y. Definitions:
HOSTILE ACTION: An act toward DAEC 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 nuclear power plant. terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individual s 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 nuclear power plant that could cause concern for its continued operability, reliability, or personnel safety. Basis: T hi s IC addresses unanti ci pat e d conditions not ad dr esse d explicitly e l sew h ere but that warrant d e claration of an emergency because conditions exist which are believed b y the E mergenc y Director to fall under the e mer ge nc y classification l eve l d esc ription for a Site Area E mer ge ncy. 208 NE! 99 01 (Re\'isioR 6) ~foYemaer 2012 HG1 ECL: General Emergency Initiating Condition:
HOSTILE ACTION resulting in loss of physical control of the facility.
Operating Mode Applicability:
All Example Emergency Action Level s: H 1.1 a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site specific security shift supervision)DAEC Security Shift Supervision. AND b. EITHER of the following has occurred:
: 1. ANY of the following safety functions cannot be controlled or maintained.
* Reactivity control
* Core cooling [PWR] I RPV water level [BWR]
* RCS heat removal OR 2. Damage to spent fuel has occurred or is IMMINENT.
Definitions:
HOSTILE ACTION: An act toward DAEC 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 nuclear power plant. terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area). HOST AGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. HOSTILE FORCE: One or more 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.
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. 209 NEI 99 QI (Re;cisioA a) November 2012 PROJECTILE:
An object directed toward a nuclear power plant that could cause concern for its continued operability, reliability, or personnel safety. PROTECTED AREA: The area under continuous access monitoring and control, and armed protection as described in the site Security Plan. 210 Basis: 211 tffil 99 01 (Re1, 1 isioR fi) tfo1, 1 emeer 2012 NEI 99 C:l 1 (Re,*isioA 6) Novemeer 2C:ll2 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 HOSTIL E 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 the DAEC 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].
E mergency plans and implementing procedures are public documents; therefore, EALs should do not incorporate Security-sensitive information.
This includes information that may be advantageous to a potential adversary , such as the particulars concerning a specific threat or threat location.
Security-sensitive information should beis contained in non public documents such as the Security Plan. 212 Developer Notes: l>ffil 99 Q l (ReYisieA a) l>foi,*ember 2Ql 2 The (site specific security shift supervision) is the title of the on shift individual responsible for supervision of the on shift security force. Emergency plans and implementing procedures are public documents; therefore , EALs should not incorporate Security sensitive information.
This includes information that may be advantageous to a potential adversary , such as the particulars concerning a specific threat or threat location. Security sensitive information should be contained in non public documents such as the Security Plan. With due consideration given to the above developer note , EALs may contain alpha or numbered references to selected events described in the Security Plan and associated implementing procedures. Such references should not contain a recognizable description of the event. For e1rnmple , an EAL may be worded as " Security event #2, #5 or #9 is reported by the (site specific security shift supervision)." 8ee the related Developer Note in Appendix.
B , Definitions , for guidance on the development of a scheme definition for the PROTECTED AREA. EGL Assignment Attributes:
3 .1.4 .D 213 ECL: General Emergency l'>ffil 99 01 (ReYisioR
: 6) NoYember 2012 HG7HG6 Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency.
Operating Mode Applicability:
All 6 E,ae,ple Emergency Action Leve ls: 1 Other conditions exist which in the judgment of the Emerge ncy Director indicate that events are in progress or have occurred which involve actua l or IMMINENT substantial core degradation or melting with potential for l oss of containment integrity or HOSTILE ACTION that results in an actua l loss of physica l 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. Definitions:
HOSTILE ACTION: An act toward DAEC 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 nuclear power plant. 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. 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. PROJECTILE:
An object directed toward a nuclear power plant that could cause concern for its continued operability, reliability, or personnel safety. Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a General Emergency.
214 11 SYSTEM MALFUNCTION ICS/EALS NEI 99 01 (ReYisieR e) }foyemaer 2012 Table S 1: Reeognition Categorv "S" Initiating Condition Matrix UNUSUAL EVENT SUl Loss of all offsite AC power capability to emergency buses for 15 minutes or longer. Op. },fades: 1. 2. 3. 4Pewer Operetien, Stertup , Het St611'lde:y, Hat 8/mtdewl'l SU2 illlPL",1'll>lED loss of Control Room indications for 15 minutes or longer. Op. ,\fades: Pewer Operetien , Stertup , Hat Stemie;*, Hat 8!1utdewnL...l,_
: 3. 4 SUJ Reactor coolant actiYity greater tkan Technical Specification allowable limits. Op. },fades: 1. 2. 3. 4Pewer Operntien, Sf6lrtup, Het Stendh;*, Het Shutdewn SU4 RCS leakage for 15 minutes or longer. Op. }.fades: 1. 2. 3, '/Pewer Operetien , Stertup, Het Stendby , Het Shutdem'l SUS Automatic or manual (trip [PWRJ / scram [BWR]) fails to shutdown the reactor. Op. }.lodes: Pewer OpaGltien}
ALERT SAl Loss of all but one AC power source to emergency buses for 15 minutes or longer. Op. },fades: L...1....J...
1:.Pewer Opeffllien , Stertup , Het Sf6lndby, Het 8!1utdewn SA2 ill~PLA1'Jl>ffiD loss of Control Room indications for 15 minutes or longer witk a significant transient in progress.
Op. Mades: 1. 2. 3. 4 Pewer Operetien , Stertup , Het Stendby , Het Shu1dew1q SAS Automatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor, and subsequent manua l actions taken at the reactor control consoles are not successful in shutting down the reactor. Op. }.{edes: Pewer Operetienl_
2 15 SITE A.REA EMERGENCY SS1 Loss of all offsite and all onsite AC pov,rer to emergency buses for 15 minutes or longer. Op. },fades: 1, 2, 3, 4Pewer Operetien, Stertup, Het Stendb;*, Het Shutdewn SSS Inability to shutdovm the reactor causing a challenge to (core cooling [PWR] I R.0 V water level [BWR]) or RC8 heat removal. Op. }.fades: Pewer Operetienl 1 GENERAL EMERGENCY SGl Prolonged loss of all offsite and all onsite AC power to emergency buses. Op. }.fades: 1, 2. 3, 4Pewer Operetien, Stertup, Het Stendh;*, Het 8!1utdewn
-------------------
: Table intended for use by 1 EAL developers.
: Inclusion in licensee I 0 * . d , ocuments 1s not require . L------------------1 UNUSUAL EVENT SU6 Loss of all onsite or offsite eommunieations eapabilities.
Op. },fades: 1, 2, 3 , 4.Pewer Opereti e n , Stcwtup , Hat St a l'ldhy , Het Slw tde wn SU7 Failure to i s olate eontainment or loss of eontainment pressure eontrol. [PWR] Op. Afade s: 1 , 2 , 3, 1. Pewe,* Operatie,"i , Starh , tp, Het Stendhy , Hat Shi1tdewl'I A,LERT SITE AREA EMERGENCY NEI 99 01 (Re,,*isioR e) },foyemeer 2012 GENER .... L EMERGENCY SS8 Loss of all Vital DC SG8 Loss of all AC and SA9 Ha:mrdous event affeeting a SAFETY SYSTEM needed for the eurrent operating mode. Op. Med es: 1, 2 , 3, 4.Pewer Operatiel'I , Startitp , Hat S:emihy , Hat Shutdewl'1 po 1 Ner for 15 minutes or Op. },fades: 1 , 2, 3, 4Pewer Operetien , Startitp , H e t Standby*, Hat Shutdewl'I 216 Vital DC power souree s for 15 minutes or longer. Op. },1edes: 1, 2, 3, 4Pewer Operetien , St*lrt1,!fJ , Het Stendey , Hat Shutdewn ,-------------------, : Table intended for use b)' I EAL de>,<elopers.
: lnelusion in lieensee I d * . d , oeuments ts not require . 1 L------------------J ECL: Notification of Unusual Event NE! 99 0 I (ReYisioR
: 6) NoYember 2012 SU1 Initiating Condition:
Loss of alt-ALL offsite AC power capability to emergency essential buses for 15_-minutes or longer. Operating Mode Applicability:
Power Operation , Startup , Hot Standby , Hot Shutdown.1..1.,_]_
Example Emergency Action Level s: Note: The E mergency Director should declare the Unusual E~vent promptly upon determining that the applicable time 15 minutes has been exceeded , or will likely be exceeded.
S 1.1 Loss of ALL offsite AC power capability to (site specific emergency buses)1A3 AND 1 A4 buses for 15 minutes or longer. Definitions:
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 essential buses-. .,_ This condition represents a potential reduction in the level of safety of the plant. The intent of this EAL is to declare an Notification of Unusual Event when offsite power has been lost and both of the emergency diesel generators have successfully started and energized their respective 4kv essential bus. For emergency classification purposes , " capability" means that an offsite AC power source(s) is available to the emergency essential 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. E scalation of the emergency classification level would be via IC SAL De*,zeloper Notes: The " site specific emergency buses" are the buses fed by offsite or emergency AC power sources that supply power to the electrical distribution system that powers SAFETY SYSTEMS. There is typically 1 emergency bus per train of SAFETY SYSTEMS. At multi unit stations , the EALs may credit compensatory measures that are proceduralized and can be implemented 1 within 15 minutes. Consider capabilities such as power source cross ties, " s 1.ving" generators , other power sources described in abnormal or emergenC)' operating procedures , etc. Plants that have a proceduralized capability to supply offsite AC power to an 217 NEl 99 QI (ReyisioR
: 6) tlo*,<emeer 2Q 12 affeeted unit via a eross tie to a eompanion unit may eredit this power souree in the EAL provided that the planned eross tie strategy meets the requirements of 10 CFR 50.63. EGL Assignment Attributes:
3.1.1.A 218 ECL: Notification of Unusua l Event NEI 99 QI (Re'iisioA
: 6) No&#xa5;ember 2Q 12 SU2SU3 Initiating Condition:
UNPLANNED l oss of Control Room indications for 15 minutes or longer. Operating Mode Applicability:
Power Operation , Startup , Hot Standby , Hot Shutdown.L..LJ Examf)le Emergency Action Level s: Note: The Emergency Director shou ld declare the Unusual E~ve n t promptly up o n determining that the applicable time 15 minutes h as been exceeded , or w ill l ikely be exceeded.
S 3.1 ++-a.--An UNPLANNED event results in the inability to monitor one or more of the Definitions:
Reactor Power R.0 V '.Vater Level RPV Pressure Primary Containment Pressure Suppression Pool Le 1 rel
* Suppression Pool Temperature Suppression Pool Temperature Table S-1 Safety System Parameters
* Reactor power
* RPV Water Level
* RPV Pressure
* Primary Containment Pressure
* Suppression Pool Level
* Suppression Pool Temperature 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 systems are 219 
}ffil 99 0 I (ReYisioA
: 6) N0Ye1'l'!eer 2012 classified as safety-related.A system required for safe plant operation, cooling dovm the plant and/or placing it in the cold shutdovm condition, including the EGGS. Systems classified as safety related. UNPLANNED: A parameter change or an event that is not I) 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. Basis: This IC addresses the difficulty associated with monitoring normal p l ant 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 one or more 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 , dig i tal and recorder source within the Control Room. 220 NE! 99 0 I (Re,*isioH
: 6) 1-foyemeer 2012 An event involving a los s 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 [PWR] I RPV level [BWR] and RCS heat removal. The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be more significant than simply a reportable condition.
In addition, if all indication so urces for one or more 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 [PWR] / RPV water level [BWR] 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. Esca lation of the emergency classification level would be via IC SA+/-}. De*,releper Netes: In the PWR parameter list column , the "site specific number" should reflect the minimum number of steam generators necessary for plant cooldown and shutdovm. This criterion may also specify whether the level value should be *wide range , narrow range or both , depending upon the monitoring requirements in emergency operating procedures.
Developers may specify either pressurizer or reactor 1 1essel level in the PWR parameter column entry for RCS Le 1 1el. The number , type , location and layout of Control Room indications , and the range of possible failure modes, can challenge the ability of an operator to accurate!)'
determine , within the time period available for emergenC)' classification assessments , if a specific percentage of indications have been lost. The approach used in this EAL facilitates prompt and accurate emergency classification assessment s by focusing on the indications for a selected subset of parameters. By focusing on the availability of the specified parameter values , instead of the sources of those values , the EAL recognizes and accommodates the wide variety of indications in nuclear power plant Control Rooms. Indication types and sources may be analog or digital , safety related or not , primary or alternate , individual meter value or computer group display , etc. /1 , loss of plant annunciators will be evaluated for reportability in accordance
*with 10 CFR 50.72 (and the associated guidance in 1'ruREG 1022), and reported if it significantly impairs the capability to perform emergency assessments.
Compensatory measures for a loss of annunciation can be readily implemented and may include increased monitoring of main control boards and more frequent plant rounds by non licensed operators.
Their alerting function notwithstanding , annunciators do not provide the parameter values or specific component status information used to operate the plant , or process through AOPs or EOPs. Based on these considerations , a loss of annunciation is considered to be adequately addressed by reportability criteria, and therefore not included in this JC and EAL. 221 
~ffil 99 QI (RevisieA
: 6) ~fo>,*emeer 2012 With respect to establishing event severity , the response to a loss of radiation monitoring data (e.g., process or effluent monitor values) is considered to be adequately bounded by the requirements of 10 CPR 50.72 (and associated guidance in NUREG 1022). The reporting of this event 1,vill ensure adequate plant staff and NRG awareness , and drive the establishment of appropriate compensatory measures and corrective actions. In addition , a loss of radiation monitoring data , by itself , is not a precursor to a more significant event. Personnel at sites that have a Failure Modes and Effects Analysis (H,4EA) included within the design basis of a digital I&C system should consider the FMEA information when developing their site specific EALs. Due to changes in the configurations of SAFETY SYSTEMS , including associated instrumentation and indications , during the cold shutdown , refueling , and defueled modes , no analogous IC is included for these modes of operation. EGL Assignment Attributes:
3.1.1.A 222 2 NEI 99 QI (ReYisioR e) Noyemeer 2Q 12 SU3SU4 ECL: Notification of Unusual Event Initiating Condition:
Reactor coolant activity greater than Technical Specification allowable limits. Operating Mode Applicability:
Power Operation , Startup, Hot Standby , Hot Shutdov,mL 2, 3 Example Emergency Action Levels: (1 or 2) (Site specific radiation monitor) reading greater than (site specific value). Pretreatment Off gas System (RM-4104)
Hi-Hi Radiation Alarm. Sample analysis indicates that reactor coolant specific activity is greater than 2.0 &#xb5;Ci/gm dose equivalent 1-131 for 12 hours or longerSample analysis indicates that a reactor coolant activity value is greater than an allowable limit specified in Technical Specifications.,,.,.
Definitions:
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. For EAL SU4.1, RM-4104 Hi-Hi Radiation Alarm has been chosen because it is operationally significant is readily recognizable by the Control Room Operations Staff, and is set at a level corresponding to noble gas release rate, after 30-m i nute delay and decay of 1 Ci/sec. F or EAL SU4.2, coolant samples exceeding the 2.0 &#xb5;Ci/gm dose equivalent l-131concentration require prompt action by DAEC Technical Specifications and are representative of minor fuel cladding degradation.
Escalation of the emergency classification level would be via ICs FAl or the Recognition Category A-R I Cs. DevelepeF Netes: For EAL #1 Enter the radiation monitor(s) that may be used to readily identify 1.vhen RCS activity levels e>rneed Technical Specification allovvable limits. This EAL may be developed using different method s and sites should use existing capabilities to address it (e.g., de;, elopment of new capabilities is not required).
E>rnmples of e>C.isting methods/capabilities include:
* An installed radiation monitor on the letdown system or air ejector.
* A hand held monitor or deployed detector reading with pre calculated conversion values or readily implementable conversion calculation capability.
223 l>ffil 99 O 1 (Re*,isioR e) November 2012 The monitor reading values should eorrespond to an RCS aetivity leve l approximate l y at , Teehnieal Specification allowable limits. If there is no e>dsting method/capability for determining this EAL , then it should not be included.
IC evaluation will be based on EAL #2. For EAL#2 Developers may reword the EAL to include the reactor coolant activity parameter(s) specified in Teehnieal Specifieations and the assoeiated allowable limit(s) (e.g., va l ues for dose equ i valent I 131 and gross activity, time dependent or transient va l ues, ete.). If this approach is selected, all RCS aetivity allowable limits should be ineluded. EGL Assignment Attributes:
3 .1.1.A and 3 .1.1.B 224 NEI 99 Ql (RevisioA
: 6) November 2012 SU4SU5 ECL: Notification of Unusual Event Initiating Condition:
RCS leakage for 15 minutes or longer. Operating Mode Applicability:
Po*.ver Operation , Startup , Hot Standby , Hot Shutdownl..,_Ll Exem13le Emergency Action Levels: (1 or 2 or 3) Note: S 5.1 $2 ~3 The Emergency Director should declare the Unusual E~vent promptl y upon determining that the applicable time 15 minutes has been exceeded, or will likely be exceeded.
RCS unidentified or pressure boundary leakage greater than (site specific Yalue) 10 gpm for 15 minutes or longer. RCS identified leakage greater than (site specific Yalue)25 gpm for 15 minutes or longer. Leakage from the RCS to a location outside containment greater than 25 gpm for 15 minutes or longer. Definitions:
UNISOLABLE:
An open or breached system line that cannot be isolated , remotely or locally. Basis: 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 SUS.I and EAL SU5.2 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 SU5.3 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 generator tube leakage in a PWR) 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 SUS.I uses a lower value that reflects the greater significance of unidentified or pressure boundary l eakage. 225 tJEI 99 Ql (RevisieR C:i) tl0 1 1em0er 2Q 12 The release of mass from the RCS due to the as-designed
/expected operation of a relief valve does not warrant an emergency classification.
For PWRs , an emergency classification would be required if a mass loss is caused by a relief valve that is not functioning as designed/expected (e.g., a relief valve sticks open and the line flo 1 t't' cannot be isolated). For BWRs , 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 E AL. 226 227 ~ffil 99 01 (RevisioR
: 6) ~fo*remeer 2012 NEI 99 Gl (Re,*isioA
: 6) l>fo*,*emeer 2G 12 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 A-R or F. Develof)eF Notes: Ei\L #1 For the site specific leak rate 1 1alue , enter the higher of l O gpm or the Yalue specified in the site's Technical Specifications for this type of leakage. EAL #2 For the site specific leak rate ,,atue, enter the higher of 25 gpm or the value specified in the site's Technical Specifications for this type of leakage. For sites that haYe Technical Specifications that do not specify a leakage type for steam generator tube leakage , developers should include an EAL for tube leakage greater than 25 gpm for 15 minutes or longer. EGL Assignment Attributes:
3.1. l .,", 228 


l>JEI 99 0 I (RevisioA
==References:==
: 6) l>fo\'emeer 2012 SU5SU6 ECL: Notification of Unusual Event Initiating Condition:
: 1. NextEra Energy Duane Arnold, LLC letter NG-17-0235, License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-
Automatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor. Operating Mode Applicability:
Power Operationl,2 Nate: A manual action is any operator action , or set of actions , \Yhich 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.
Exemf)le Emergency Action Levels: (1 or 2) Note: A manual action is any operator action , or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.
SU6.1 a. An automatic (trip [PWR] / scram [B'.VR]) did not shutdown the reactor. S 6.2 AND b. ANY of the following manual actions taken at 1C05 are successful in lowering reactor power below 5% power a.
* Manual Scram Pushbuttons
* Mode Switch to Shutdown
* Alternate Rod Insertion (ARI)A subsequent manual action taken at the reactor control consoles (I C05) is successful in shutting down the reactor. A manual trip ([P'.1/R]
/ scram [B'.1/R])
did not shutdown the reactor. AND b. EITHER of the following: 1. -ANY of the following subsequent manual actions taken at l COS are successful in lowering reactor power below 5% power
* Manual Scram Pushbuttons
* Mode Switch to Shutdown
* Alternate Rod Insertion (ARI)A subsequent manual action taken at the reactor control console (1 C05)s is successful in shutting down the reactor. ---__ OR 230 Definitions:
Basis: NEI 99 0 I (Re*,isioA
: 6) ~lovemeer 2012 2. -A subsequent automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor. This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor~ [PWR] I scram [BWR]) that results in a reactor shutdown , and either a subsequent operator manual action taken at the reactor control consoles or an automatic (trip [PWR] I scram [BWR]) 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. Following the failure on an automatic reactor (trip [PWR] I scram [BWR]), operators will promptly initiate manual actions at the reactor control console s to shutdown the reactor (e.g., initiate a manual reactor (trip [PWR] I scram [BWR])). If these manual actions are successful in shutting dov,rn the reactor , core heat generation willscram quickly fall to a level within the capabilities of the plant's decay heat removal systems. 231 
---------. ------------------~JBI 99 g I (ReYisioA e) November 2012 If an initial manual reactor (trip [PWR] I scram [BWR]) is unsuccessful , operators will promptly take manual action at another location(s) on the reactor control console s to shutdown the reactor (e.g., initiate a manual reactor (trip [PWR] I scram [BWR])) using a different switch). Depending upon several factors, the initial or subsequent effort to manually (trip [PWR] I scram [BW~]) the reactor , or a concurrent plant condition , may lead to the generation of an automatic reactor ftrtp [PWR] I scram [BWR]) signal. If a subsequent manual or automatic (trip [PWR] I scram [BWR]) is successful in shutting down the reactor , core heat generation will quickly fall to a level within the capabilities of

Latest revision as of 13:44, 30 September 2018

Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. (Pa
ML18212A227
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 07/26/2018
From: Dean Curtland
NextEra Energy Duane Arnold
To:
Document Control Desk, Office of New Reactors
References
NG-18-0090
Download: ML18212A227 (13)
v • d • e


Text

NEXTeraM ENERGY~ DUANE ARNOLD July 26, 2018 NG-18-0090 10 CFR 50.90 10 CFR 50, Appendix E U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Duane Arnold Energy Center Docket No. 50-331 Renewed Facility Operating License No. DPR-49 Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors"

References:

1. NextEra Energy Duane Arnold, LLC letter NG-17-0235, License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors" (ML17363A069)
2. NRC E-Mail: Draft request for additional information (RAI) -Duane Arnold Energy Center (DAEC) -LAR TSCR-166, Adoption of EAL Scheme Pursuant to NEI 99-01 -EPID L-2017-LLA-0420.

From Mahesh Chawla, NRC,June 15, 2018 In Reference 1, NextEra Energy Duane Arnold, LLC (NextEra) submitted a license amendment request (LAR) for Duane Arnold Energy Center (DAEC). The proposed change adopts an Emergency Action Level (EAL) scheme pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors." In Reference 2, the NRC staff requested additional information to support its review of the LAR. The Enclosure to this letter provides NextEra's response to the request for additional information (RAI). The following information is provided as attachments to the Enclosure to aid NRC review and approval and replaces the Attachments in their entirety from Reference 1:

  • Attachment 1 -Updated Redline Markup of NEI 99-01 Revision 6 ;4x4~
  • Attachment 2 -Updated Clean Copy of the Proposed DAEC EAL Scheme
  • Attachment 3 -Updated Deviations and Differences Matrix rJ((IL
  • Attachment 4 -Updated Supporting Technical Information
  • Attachment 5 -Updated DAEC EAL Scheme Wallboards NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324 This RAI response does not alter the conclusions in Reference 1 that the changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the changes. No new or revised commitments are included in this letter. If you have any questions or require additional information, please contact J. Michael Davis, Licensing Manager, at 319-851-7032.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 26, 2018 Dean Curtland Site Director NextEra Energy Duane Arnold, LLC Enclosure cc: Regional Administrator, USNRC, Region III, Project Manager, USNRC, Duane Arnold Energy Center Resident Inspector, USNRC, Duane Arnold Energy Center A. Leek (State of Iowa) NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324 ENCLOSURE DUANE ARNOLD ENERGY CENTER NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 Request for Additional Information (RAI), June 15, 2018 EPID L-2017-LLA-0420.

10 pages follow plus Attachments Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-1 Section 4.4 of NE/ 99-01, Revision 6, states that alternative methods for presenting EAL scheme information may be developed for use provided that it contains all the information needed to make a correct emergency classification.

This information includes the Initiating Conditions, Operating Mode Applicability criteria, EALs, and Notes. DAEC provides a Hot Classification Matrix and a Cold Classification Matrix as alternative presentation methods. a. The DAEC EAL alternative method for presenting EAL scheme information does not include the notes as provided in the proposed EAL Technical Basis document.

This could lead to inaccurate or delayed emergency classifications.

Please revise the DAEC Hot and Cold Matrices to include the applicable notes as described in NE/ 99-01, Revision 6, or provide justification for omission.

b. The DAEC EAL alternative method for presenting EAL scheme information is not consistent with the proposed EAL Technical Basis document.

This could lead to inaccurate or delayed emergency classifications.

A partial list of examples of inconsistencies are as follows: (NOTE: These items should not be considered a complete list of potential inconsistencies.)

  • Fuel clad damage assessment corresponding to Containment Barrier Potential Loss 5A provides a value of 5% vice the value of 20% which is provided in the technical basis document.
  • SA1.1 provides *~c power capability to 1A3 and 1A3" vice *~c power capability to 1 A3 and 1 A4 buses."
  • Table E-1 Cask On Contact Dose Rates implies all readings should be taken On Contact vice three feet from the HSM [horizontal storage module].
  • The tables used on the alternate method for presenting EAL scheme information have different layouts and titles than the technical basis document tables. In some cases, there is no corresponding technical basis document table. (see attached table of additional comments)

Please review the DAEC EAL alternative method for presenting EAL scheme information and ensure the method is technically accurate and addresses human factors issues that could impact timely and accurate EAL assessments.

DAEC Response DAEC has revised the wallcharts and Technical Basis Document for better consistency and prevention of EAL assessor confusion (consideration of human factors).

This revision addressed all the listed examples provided in the RAI, as well as other examples observed during a 100% comparison of the I Cs and EALs between the two documents.

The revised documents are provided in the updated versions of Attachments 1, 2, and 5 provided in this letter. 1 Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-2 On Page 17, the proposed DAEC Section 5. 1, "General Considerations," state: As used here, promptly" means at the first available opportunity (e.g., if the Shift Manager is receiving an update from the fire brigade at the 15 minute mark, it is expected that the declaration will occur as the next action after the call ends). The above statement could infer that it is acceptable for the Shift Manager to make the EAL declaration after the 15 minute mark, if the Shift Manager was on the phone or otherwise busy. Guidance in Section IV.H.8 to NSIR!DPR-ISG-01, "Emergency Staff Guidance for Nuclear Power Plants," provides that delays beyond 15 minutes could be . found compliant under the following conditions:

  • The delay was caused by a licensee actively performing another action immediately needed to protect the public health and safety such that a delay in declaration qualitatively represents the lesser risk.
  • The cause of the delay was not reasonably within the licensee's ability to foresee and prevent. Based on the NRG guidance cited above, unless the Shift Manager was performing actions immediately needed to protect public health and safety, it would be reasonable to expect him to obtain the required information needed to make a declaration within 15 minutes of the initiation of the event. Please explain how the Shift Manager/Emergency Director would not potentially infer that it is acceptable to make a declaration greater than 15 minutes from the initial detection of a fire, or revise accordingly to align with NRG guidance.

DAEC Response After further clarifying discussion with the NRC staff during a June 26, 2018 telephone call, DAEC now believes the guidance in Section IV.H.8 to NSIR/DPR-ISG-01 is best suited for use in EAL assessor training where the full context of the guidance can be considered.

Therefore, DAEC has removed the partial clarifying guidance supplied by Section IV.H.8 to NSIR/DPR-ISG-01 and returns proposed Section 5.1 to the wording provided in NEI 99-01 alone. The revised documents are provided in the updated versions of Attachments 1 and 2 provided in this letter. 2 Enclosure to* NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-3 The proposed DAEC EAL RA1.1, RS1.1, and RG1.1 have values for the Offgas Stack radiation monitor that were rounded from 4.45Exx to 4.5Exx and the Turbine Building ventilation radiation monitor setpoint was rounded from 1. 44Exx to 1. OExx. This could result in a difference of approximately 50% for the Turbine building ventilation radiation monitors.

The staff could not determine why apparently different rounding methodologies were used for the Offgas Stack and Turbine Building ventilation radiation monitors.

Please explain the basis used for the apparently different rounding methodologies or revise accordingly.

DAEC Response DAEC has reevaluated the averaging and rounding methodologies used in selection of these thresholds and agrees that too much emphasis was placed on creation of a stepped escalation progression from UE to GE. A more standard method of averaging and rounding has now been employed to determine these threshold values as shown in the revised Table R-1 below: Reactor Building ventilation rad monitor 1.lE+OO uci/cc 1.lE-01 uci/cc 1.lE-02 uci/cc 8.0E-04 uci/cc (Kaman 3/4, 5/6, 7/8) "' Turbine Building ventilation rad monitor 1.4E+OO uci/cc 1.4E-01 uci/cc 1.4E-02 uci/cc 8.0E-04 ucifcc :::, (Kaman 1/2) 0 Q) "' Offgas Stack rad monitor Ctl 4.SE+02 uci/cc 4.SE+Ol uci/cc 2.0E-01 ucifcc \9 (Kaman 9/10) 4.5E+03 uci/cc LLRPSF rad monitor 1.4E-Ol uci/cc 1.4E-02 uci/cc 1.2E-03 uci/cc (Kaman 12) GSW rad monitor 1.7E+04 cps 1.5E+03 cps (RIS-4767)

"'C :::, RHRSW & ESW rad monitor 1.2E+04 cps 8.4E+02 cps C" (RM-1997)

RHRSW & ESW Rupture Disc rad monitor 1.8E+04 cps 1.0E+03 cps (RM-4268)

The revised threshold values are provided in the updated versions of Attachments 1, 2, 3, 4, and 5 provided in this letter. 3 Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-4 NE/ 99-01, Revision 6, EAL CU1 is intended to result in the declaration of a Notification of Unusual Event (Unusual Event) if there is an unplanned loss of reactor pressure vessel (RPV) inventory that results in a RPV level below a minimum operating level required by the governing procedure for greater than 15 minutes. DAEC proposes to use this threshold value only when RPV level is below the RPV flange. Please explain what unique DAEC conditions require this deviation from proposed guidance for CU1. 1 or revise accordingly.

DAEC Response After further clarifying discussion with the NRC staff during a June 26, 2018 telephone call, DAEC has reevaluated the proposed site-specific implementation of CU1 .1 and proposes to return to the standard language provided in NEI 99-01 of: "UNPLANNED loss of reactor coolant results in RPV level less than a required lower limit for 15 minutes or longer." The revised documents are provided in the updated versions of Attachments 1, 2, 3, and 5 provided in this letter. 4 Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-5 The proposed DAEC EALs CU4. SS2.1, and SG2.1.b use 105 VDC for the threshold value. However, the Developer's Notes for these threshold values provides at least a 15 minute margin for a minimum DC voltage. The DAEC basis for the threshold value states that the inverter has an auto trip at 105 VDC decreasing.

As such, this threshold value would provide no margin. Please explain why the DAEC threshold values for CU4 and SS2. 1 and SG2. 1.b were not developed above the inverter auto trip setpoint to allow for with a 15 minute margin, or revise accordingly.

DAEC Response Duane Arnold has two Class 1 E 125 VDC station batteries (1 D1 and 1 D2). The Class 1 E station batteries have a capacity of 1200 ampere-hours at an 8-hour discharge rate to 1. 75 V per cell. Bus voltage of 105 VDC decreasing was chosen as the SS2 and SG2 loss of Vital DC power threshold due to this value being operationally significant and easy for operators to recognize since the 125V DC SYSTEM 1 TROUBLE, 125V DC CHARGER 1D12 TROUBLE, and 125V DC CHARGER 1D120 TROUBLE annunciators (Div 1) or 125V DC SYSTEM 2 TROUBLE and 125V DC CHARGER 1 D22 TROUBLE annunciators (Div 2) will activate at this minimum system design voltage. Due to differences in bus loading, these Division 1 and Division 2 subsystems are not expected to reach the minimum bus voltage necessary for adequate operation of SAFETY SYSTEM equipment simultaneously.

Therefore, operator response to the loss of one 125 VDC bus would provide adequate (>15 minute) margin as provided by the EAL Developer Note to focus operator attention on the potential EAL threshold.

Additionally, operator follow-up actions are provided in Abnormal Operating Procedure AOP-302.1, LOSS OF 125 VDC POWER, to reference EPIP 1.1 for EAL assessment for conditions that would only occur once battery voltage reaches 105 VDC (see annunciators listed above). The revised source reference is provided iri the updated version of Attachment 4 provided in this letter. 5 Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-6 The proposed EALs CA6 and SAB are intended to result in the declaration of an Alert classification if a hazardous event resulted in degraded performance to one train of a safety system, with either visible damage to or degraded performance of a second train of safety equipment.

The proposed DAEC EALs CA6 and SAB include the following threshold value that that does not appear to be consistent with the overall intent for these EALs: "Loss of the safety function of a single train SAFETY SYSTEM." It was not apparent where such that a single support system issue would compromise public health and safety during a radiological event. As such, please explain which single safety systems would result in compromising public health and safety during a radiological event if they were compromised, or revise accordingly.

As provided, DAEC EALs CA6 and SAB are neither consistent with NE/ 99-01, Revision 6, nor with the guidance provided by EPFAQ 2016-02, "Clarification of Equipment Damage as a Result of a Hazardous Event" (ADAMS Accession No. ML 17195A299).

Please explain what specific design DAEC features preclude using the guidance provided by EPFAQ 2016-02, or revise accordingly to preclude a possible unwarranted event classification.

DAEC Response Using the clarifying guidance provided in draft EALFAQ 2018-04, DAEC has removed the proposed threshold value for single train safety systems that is not consistent with the overall intent for these EALs. DAEC has added the clarifying language provided in this draft EALFAQ to the Basis for proposed EALs CA6 and SA8 as an aid to the plant operators to promote a consistent conclusion in evaluation of these EALs. With the exception of one additional clarifying Basis paragraph as provided by EALFAQ 2018-04, these EALs are now consistent with the guidance provided by EPFAQ 2016-02. The revised documents are provided in the updated versions of Attachments 1, 2, 3, 4, and 5 provided in this letter. 6 Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-7 The proposed DAEC EAL threshold values forCS1.3.b and CG1.2.b include "Erratic source range indication" as a core uncover[y]

indication.

This indication is typically applicable to pressurized water (PWR) reactors and not boiling water reactors (BWR). Please justify using a threshold value that is typically applicable to a PWR for DAEC, which is a BWR, or revise accordingly.

DAEC Response DAEC agrees that use of this indication of potential core uncovery is unreliable for BWR designs and has removed it from the listing of potential indications in DAEC proposed EALs CS1 and CG1. The revised documents are provided in the updated versions of Attachments 1, 2, 3, and 5 provided in this letter. 7 Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-8 The proposed DAEC EAL threshold values for fission product barrier degradation, based on containment radiation monitors, do not appear appropriate.

Considering that the Fuel Clad Loss threshold value should correspond to 2% to 5% clad_ damage, and the Containment Barrier Potential Loss threshold value should be 20% (as provided by NE/ 99-01, Revision 6), it would be reasonable for the radiation values to be different by a factor of 4 to 10. However, the value for the Containment Barrier Loss drywe/1 radiation monitor reading is 25 times higher than the Primary Containment Loss radiation monitor reading, while the corresponding Torus Radiation Monitor reading for a Containment Barrier Potential Loss is 2. 5 times the Fuel Clad Barrier Loss threshold value. Additionally, it appears the Fuel Clad Barrier Loss was developed based on an intact RCS, which is not consistent with the guidance provided by NE/ 99-01, Revision 6, or the DAEC Technical Basis for the Torus Radiation Monitor Containment Loss threshold value, which is based on a loss of RCS inventory.

Please verify that the Fuel Clad Barrier threshold values for the Drywe/1 and Torus radiation monitors are based on a loss of the RCS with between approximately 2% and 5% clad damage and that the Containment Barrier Potential Loss radiation monitors are based on approximately 20% clad damage, or revise accordingly.

DAEC Response After further clarifying discussion with the NRC staff during a June 26, 2018 telephone call, DAEC has updated the proposed Fuel Clad Loss radiation monitor threshold value to reflect a value based on a loss of the RCS with between approximately 2% and 5% clad damage (Loss 4.A). The proposed radiation monitor threshold values for Drywell and Torus Containment Barrier Potential Loss are now both 2.5 times the Fuel Clad Barrier Loss threshold value. Additionally, the standardized threshold for RCS Activity due to Fuel Clad Loss (Loss 1.A) has been added to the Fission Product Barrier Matrix to provide an alternate method of assessing this barrier if coolant samples results are available.

Both changes are consistent with the guidance provided by NEI 99-01, Revision 6. The revised documents are provided in the updated versions of Attachments 1, 2, 3, 4, and 5 provided in this letter. 8 Enclosure to NG-1 S-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-9 The proposed DAEC EAL HU3 includes threshold values that do not appear to be consistent with the overall intent of EAL HU3 to address hazardous events, including a threshold value for high river level and a River Water Supply (RWS) pit low level alarm. Considering that internal room or area flooding is specifically addressed by HU3.2, the threshold value for river level appears redundant.

Additionally, a high river level alone may, or may not, involve internal room or area flooding.

Although a RWS pit low level alarm may be the result of a hazardous event, the RWS pit low level condition does not appear to represent an actual hazardous event. Please verify whether a high river level or a river water supply pit low level alarm should be considered as hazardous events, or revise accordingly.

DAEC Response DAEC agrees that the proposed thresholds for high river level and a River Water Supply (RWS) pit low level alarm are not consistent with the overall intent of EAL HU3 and these examples have been removed. Additionally, the same conditions were listed as example hazardous events in EAL SAS. DAEC has determined that these conditions are adequately covered by the existing standardized examples provided in NEI 99-01, Revision 6, and has removed the high river level and a River Water Supply (RWS) pit low level alarm conditions from EAL SUS as redundant to the other examples provided.

The revised documents are provided in the updated versions of Attachments 1, 2, 3, 4, and 5 provided in this letter. 9 Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-10 The proposed DAEC EAL HU4.2 is intended to provide licensees thirty (30) minutes to validate whether or not a single fire alarm is valid. BWRs typically inert the Drywe/1 and Torus when at power. DAEC EAL HU4.2 does not appear to have a note or other statement that indicates that an Unusual Event should not be declared if the Drywe/1 and Torus are inerted. Please verify that there is a need to declare DAEC EAL HU4 for containment if the DAEC Drywe/1 and Torus are inerted, or revise accordingly.

DAEC Response Due to the absence of fire alarms within the Drywell and Torus, DAEC is not susceptible to false fire alarms in those areas and the accompanying potential for an erroneous NOUE declaration using EAL HU4.2. These areas do remain listed on the Table H-1 fire areas for use in the evaluation of EAL HU4.1 in the event of a fire report from the field during those times that the Drywell and Torus are not inerted and can be accessed by plant personnel.

No changes were made the proposed EAL HU4. 10

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