ML14164A055

Attachment 2, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1001, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 2A, and 2B, Cover Through Page Bw 3-80

ML14164A055
Person / Time
Site:	Braidwood
Issue date:	05/30/2014
From:	Exelon Generation Co
To:	NRC/FSME, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML14164A053	List: ML14164A054 ML14164A055 ML14164A056 ML14164A058 ML14164A060 ML14164A061 ML14164A062 ML14164A063 ML14164A064 ML14164A065 ML14164A066 ML14164A067 ML14164A068 ML14164A069 ML14164A071 ML14164A073 ML14164A076 ML14164A079 NEI 99-01, Braidwood, Units 1 and 2, Attachment 2, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1001, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 2A, and 2B, Cover Through Pa NEI 99-01, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3A, 3B, Cover - by 3-74 NEI 99-01, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3B, 3C, by 3-75 - by 3-157 NEI 99-01, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4A and 4B, Cover - Cl 3-73 NEI 99-01, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4B and 4C, Cl 3-74 - Cl 3-151 NEI 99-01, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5A and 5B, Cover - Dr 3-76 NEI 99-01, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5B and 5C, Dr 3-77 - Dr 3-160 NEI 99-01, LaSalle, Units 1 & 3, Attachment 6, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1005, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 6A and 6B, Cover - LS 3-74 NEI 99-01, License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. RA-14-032, Attachment 10: Discussion of Revision to the Radiological Emergency Plan Annex for Quad Cities Nuclear Power Station, Page QC 3-69 Through End RA-14-032, Attachment 11: Discussion of Revision to the Radiological Emergency Plan Annex for Three Mile Island Nuclear Station, Page TMI 3-80 Through End RA-14-032, Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. Cover Through Page LGS 3-69 RA-14-032, Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. LGS 3-70 Page LGS 3-155 RA-14-032, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station, Page Ocgs 3-76 Through End RA-14-032, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station. Cover Through Page Ocgs 3-75 RA-14-032, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Cover Through Page PBAPS 3-76 RA-14-032, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Page PBAPS 3-77 Through End RA-14-032, Braidwood, Units 1 and 2, Attachment 2, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1001, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 2A, and 2B, Cover Through Pa RA-14-032, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3A, 3B, Cover - by 3-74 RA-14-032, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3B, 3C, by 3-75 - by 3-157 RA-14-032, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4A and 4B, Cover - Cl 3-73 RA-14-032, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4B and 4C, Cl 3-74 - Cl 3-151 RA-14-032, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5A and 5B, Cover - Dr 3-76 RA-14-032, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5B and 5C, Dr 3-77 - Dr 3-160 RA-14-032, LaSalle, Units 1 & 3, Attachment 6, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1005, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 6A and 6B, Cover - LS 3-74 RA-14-032, License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. RS-14-115, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Page PBAPS 3-77 Through End TMI-14-046, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station, Page Ocgs 3-76 Through End
References
NEI 99-01, Rev 6, RA-14-032, RS-14-115, TMI-14-046 EP-AA-1001
Download: ML14164A055 (148)

Text

ATTACHMENT 2 DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FOR BRAIDWOOD STATION EP-AA-1001 Enclosures 0 0 0 Enclosure 2A -EAL Comparison Matrix Document Enclosure 2B -EAL Red-Line Basis Document Enclosure 2C -EAL Basis Document NEI 99-01 REVISION 6 DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS ATTACHMENT 2 DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FOR BRAIDWOOD STATION Exelon Generation, 0 NEI 99-01 Rev 6 Proposed EAL Justification AGI Initiating Condition

-GENERAL EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5.000 mrem thyroid CDE.Operating Mode Applicability:

Ail Example Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the General Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

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

RGI Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1.000 mRem TEDE or 5,000 mRem thyroid CDE.Operating Mode Applicability:

1,2.3.4,5,6,D Emergency Action Levels (EAL): Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PRO3W) > 3.87 E+09 pCilsec for > 15 minutes (as determined from Unit 1 &2 PF430 or PPDS -Total Noble Gas Release Rate).OR 2. Dose assessment Using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 1000 mRem TEDE OR[Ii No Change E Difference

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

2) Added the following to bullet #3 Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 lx17 procedure matrix used by the SM.3.b. > 5000 mRem CDE Thyroid OR Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >1000 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.

Page I of 66 NEI 99-01 Rev 6 Proposed EAL Justification AS1 Initiating Condition

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

All Example Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the General Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

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

RS1 Initiating Condition:

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

1,2.3.4.5,6,D Emergency Action Levels (EAL): Notes:* The Emergency Director should declare the event promptly upon detennining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path. then the effluent monitor reading is no longer valid for classification purposes.The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

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

> 3.87 E+8 pCiisec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS -Total Noble Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 100 mRem TEDE OR b. > 500 mRem CDE Thyroid OR 3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >100 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.

[] No Change [31 Difference 1-1 Deviation 1) Listed site-specific monitors and Threshold values to ensure timely classification.

2) Added the following to bullet t3" Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established.

If trie effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 1x1 7 procedure matrix used by the SM.Page 2 of 66 NEt 99-01 Rev 6 1 Proposed EAL I Justification AA1 Initiating Condition

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

Alt Example Emergency Action Levels: (1 or 2 or 3)Note: " The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes." If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

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

RAI Initiating Condition:

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

1,2.3.4.5,6, D Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path.then the effluent monitor reading is no longer valid for classification purposes.The pre-calculaled effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

The sum of readings on the Unit I and 2 Aux BLDG Vent WRGMs (1/2 RE-PR03O)

> 3.87 E+07 iCi/sec for > 15 minutes (as determined from Unit I & 2 PF430 or PPDS -Total Nobel Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 10 mRem TEDE OR b. > 50 mRem CDE Thyroid OR 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary a. 10 mRem TEDE for 60 minutes of exposure OR b. 50 mRem CDE Thyroid for 60 minutes of exposure OR 4. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates > 10 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.

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

2) Added the following to bullet #3 -Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 1x17 procedure matix used by the SM.3) Calculations were performed, in accordance with (lAW) guidance provided in NEI 99-01 revision 6 EAL AA1, to determine the effluent monitor response for a radioactive liquid release and a WGOT release via the normal site release pathway.The release would contain activity equivalent to provide 10mrem TEDE or 50mrem thyroid CDE at the site boundary.

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

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

All Example Emergency Action Levels: (1 or 2 or 3)Note: " The Emergency Director should declare the Alert promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes." If the effluent flow past an effluent monitor is known to have stopped.indicating that the release path is isolated, the effluent monitor reading is no longer valid for classification purposes.1. Reading on ANY effluent radiation monitor greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer.(site-specific monitor list and threshold values corresponding to 2 times the controlling document limits)2. Reading on ANY effluent radiation monitor greater than 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.3. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times (site-specific effluent release controlling document limits) for 60 minutes or longer.RU1 Initiating Condition:

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

1,2.3,4. 5, 6, D Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.1. Reading on any of the following effluent monitors > 2 times alarm setpoint established by a current radioactive release discharge permit for Z 60 minutes.0PR01 J, Liquid Radwaste Effluent Monitor O 0PR90J, Liquid Radwaste Effluent Monitor OPR02J, Gas Decay Tank Effluent Monitor OPR1OJ. Station Blowdown Monitor 1/2 PR01J, Containment Purge Effluent Monitor* Discharge Permit specified monitor OR 2. The sum of readings on the Unit 1 and 2 Aux Bldg Vent WRGMs (1/2 RE-PRO3W) > 4.42 E+05 pCi/sec for ý 60 minutes (as determined from Unit 1& 2 PF430 or PPDS -Total Noble Gas Release Rate).OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of Z 60 minutes.[- No Change E Difference

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

2) Added the following to bullet #3" Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 1x1 7 procedure matrix used by tne SM.Page 4 ol 66 NEI 99-01 Rev 6 1Proposed EAL ] Justification AG2 Initiating Condition

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

AMl Example Emergency Action Levels: NOTES: The Emergency Director should declare the General Emergency promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded 1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.RG2[II No Change E Difference 1i] Deviation 1) EAL not used in accordance with the discussion in Section 1.4. NRC Order EA-12-051, it is recommended that this EAL be implemented when the enhancea spent fuel pool level instrumentation is available for use. The completion of the enhanced SFP level indicators and need for the inclusion of this EAL is being tracked in accordance with Exelon Generation Company. LLC's Initial Status Reporl to March 12. 2012 Commission Order Mooifying Licenses with Regard for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dazed October 25.2012.Page 5 ol'66 NEI 99-01 Rev 6 Proposed EAL Justification Abz2 RS2 Initiating Condition

-SITE AREA EMERGENCY Spent fuel pool level cannot be restored to at least (site-specific Level 3 description)

Operating Mode Applicability:

All Example Emergency Action Levels: 1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 description)

D-- No Change E Difference

[] Deviation 1) EAL not used in accordance with the discussion in Section 1.4, NRC Order EA-12-051, it is recommended that this EAL be implemented when the enhanced spent fuel pool level instrumentation is available for use. The completion of the enhanced SFP level indicators and need for the inclusion of this EAL is being tracked in accordance with Exelon Generation Company, LLC's Initial Status Report to March 12, 2012 Commission Order Modifying Licenses with Regard for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated October 25,2012.Page 6 otf66 NEI 99-01 Rev 6 1 Proposed EAL Justification AAZ Initiating Condition

-ALERT Significant lowering of water level above, or damage to, irradiated fuel-Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3)1. Uncovery of irradiated fuel in the REFUELING PATHWAY.2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY of the following radiation monitors: (site-specific listing of radiation monitors, and the associated readings, setpoints and/or alarms)3. Lowering of spent fuel pool level to (site-specific Level 2 value).RA2 Initiating Condition:

Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:

1. 2, 3, 4, 5, 6.D Emergency Action Levels (EAL): 1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R1 Radiation Monitor reading >1000 mRemlhr Table R1 Fuel Handling Incident Radiation Monitors" Fuel Building Fuel Handling Incident Monitor ORE-AR055" Fuel Building Fuel Handling Incident Monitor ORE-AR056" Containment Fuel Handling Incident Monitor 12RE-AR011" Containment Fuel Handling Incident Monitor 1/2RE-AR012

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

2) EAL #3 not used in accordance with the discussion in Section 1.4, NRC Order EA-12-051.

it is recommended that this EAL be implemented when the ennanced spent fuel pool level instrumentation is available for use. The completion of the enhanced SFP level indicalors and need for the inclusion of this EAL is being tracked in accordance with Exelon Generation Company, LLC's Initial Status Report to March 12, 2012 Commission Order Modifying Licenses with Regard for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated October 25,2012.Page 7 of 66 NEI 99-01 Rev 6 ] Proposed EAL [Justification Initiating Condition:

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

All AU2 Example Emergency Action Levels: 1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following: (site-specific level indications).

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

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

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

• Refueling Cavity water level <23 ft above the Reactor Flange (< 423 ft. indicated level)OR* Spent Fuel Pool water level < 23 ft. above the fuel (<422 ft 9 in indicated level)OR* Indication or report of a drop in water level in the REFUELING PATHWAY.AND b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitor in Table R1.E No Change 1"- Difference 1 Deviation 1 ) Listed site-specific level indication and monitors to ensure timely classification.

Table R1 Fuel Handling Incident Radiation Monitors* Fuel Building Fuel Handling Incident Monitor ORE-AR055* Fuel Building Fuel Handling Incident Monitor ORE-AR056* Containment Fuel Handling Incident Monitor 112RE-AR01 1* Containment Fuel Handling Incident Monitor 1/2RE-AR012 Page 8 of 66 NEI 99-01 Rev 6 j Proposed EAL I Justification AA3 Initiating Condition

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

All Example Emergency Action Levels: (1 or 2)Note: If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted 1. Dose rate greater than 15 mR/hr in ANY of the following areas:* Control Room* Central Alarm Station* (other site-specific areas/rooms)

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

RA3 Initiating Condition:

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

1,2, 3, 4, 5, 6,D Emergency Action Levels (EAL): Note: If the equipment in the room or area listed in Table R3 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted 1. Dose rate greater than 15 mR/hr in ANY of the following areas: E No Change Dence Dell 1) Listed site specific plant rooms and areas with identified mode applicability to ensure timely classification.

Table R2 Areas Requiring Continuous Occupancy* Main Control Room- 1/2RE-AR010" Central Alarm Station -(by survey)OR 2. An UNPLANNED event results in radiation levels that prohibit or significantly impede access to any of the following plant rooms or areas: Table R3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Auxiliary Building*

Mode 4, 5, and 6*Areas required to establish shutdown cooling Page 9 of 66 NEI 99-01 Rev 6 Proposed EAL [Justification SU3 Initiating Condition:

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

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

RU3 Initiating Condition:

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

1,2,3,4 Emergency Action Levels (EAL): 1. Gross Failed Fuel Monitor 1i2RE-PRO06 indicating 1-135 concentration

> 5 pCI/cc.OR 2. Sample analysis indicates that: a. Dose Equivalent 1-131 specific coolant activity > 60.0 pCilgm.OR b. Dose Equivalent XE-133 specific coolant activity > 603.0 pCi/gm.H No Change W Difference 1 Deviation 1) Listed site-specific monitor and threshold value to ensure timely classification.

2) Listed this system category EAL in the radiological category EAL section to maintain consistency with current and previous revisions of Exelon EALs. This will ensure a timely classification since the threshold values are more aligned with the radiological category vice system category.Page 10 of 66 NEI 99-01 rev 6 Fission Product Barrier Matrix FGI Loss of any two barriers AND Loss or Potential Loss of third barrier. 1,2,3,4 FSI Loss or Potential Loss of ANY two barriers.

1,2,3,4 FAI ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 1,2,3,4 FC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Category Loss Potential Loss Loss Potential Loss Loss Potential Loss 2. The capacity of one charging pump in 1. An automatic or manual SI actuation the normal mode is exceeded due to is required by EITHER of the EITHER of the following:

RCS or S Core Coolng CSF-Orange Path following:

a. UNISOLABLE RCS leakage 1 conditions exist OR A leaking or RUPTURED SG isNone Tube Leakage a. UNISOLABLE RCS leakage b. SG tube leakage. FAULTED outside of containment.

OROR b. SG tube RUPTURE. O 3. RCS Integrity CFS-Red Path conditions exist 1. Core Cooling CSF-Red Path 2. Core Cooling CSF-Orange Path 2.Iaeut odtoseitodlton eis.Nn Heat Sink CSF-Red Path conditions Core Cooling CSF-Red Path conditions Heat Removal te Heat Sink CSF-Red Path conditions None.None exist.AND Functional Restoration

3. Heat Sink CSF-Red Path conditions exist. Procedures not effective in < 15 minutes.exist.1. Containment radiation monitor 3.RCS Activity/ (AR020(21))

reading > 1.95E+03 Containment radiation monitor R/hr. Containment radiation monitor (ARO20(21))

Containment None (AR020(21))

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

a. UNPLANNED lowering in 3. Containment CSF- Red Path conditions containment pressure or rise in exist.radiation monitor readings outside OR of containment in the Emergency

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

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

OR Bypass OR 5. a. Containment pressure >20 psig.b. UNISOLABLE pathway from AND containment to the environment exists. b. Less than one full train of OR containment Spray is operating per design for >15 minutes.2 Indication of RCS leakage outside of containment S. Eergncy .Ay Condition in the opinion ofth 5. Emergency A directo that A. Any Condition in the opinion of the A. ANY Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the Director ency Director that Emergency Director that indicates Emergency Director that indicates Loss Emergency Director that indicates Emergency Director that indicates Loss Emergency Director that indicates Potential Judgment indicates Loss of the Fuel Clad Potential Loss of the Fuel Clad Barrier. of the RCS Barrier. Potential Loss of the RCS Barrer. of the Containment Barrier. Loss of the Containment Barrier.Jugmn Barrier.II Page 11 of 66 Proposed Fission Product Barrier Matrix I _ _ _ _ _ _ _ Barrier Matrix Hot Matrix FGI Loss of any two barriers AND Loss or Potential Loss of third barrier.[ g[l] I FSI Loss or Potential Loss of ANY two barriers.[flgE[ I FAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS fLIMB~* ., ~ ~ ~~ ~ ~~~~~ ~ ~~~~~~~~ ... :. ... ..... ........ .. ... .. .....:: ........ : FC -Fuel Clad RC -Reactor Coolant System CT -Contalnment Sub-Category Lose Potential Loss Lose Potential Loss Loss Potential Loss 2. The capacity of one charging pump in the normal mode is exceeded due to EITHER of the following:

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

Core-Cooling CSF- Orange Path OR A leaking or RUPTURED Oc is FAULTED Non 1 RCS or SG Tube None conditions exist. a. UNISOLABLE RCS leakage Leakage b. SG tube RUPTURE..

outside of containment.

OR OR b. SG tube RUPTURE.3. RCS Integrity CFS -Red path conditions exist.2. Core-Cooling CSF- Orange Path conditions exist. Core Cooling CSF-Red Path conditions exist 2. Inadequate Heat 1. Core-Cooling CSF -Red Path OR None Heat Sink CSF -Red Path conditions exist. None AND Functional Restoration Procedures not Removal3.

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

reading s 1.95E+03 R/hr. Containment radiation monitor (AR020(21))

Containment radiation monitorNAR02St21te Radiation

/ RCS OR None reading > 25 R/hr. reading > 4.40E+03 R/hr.Activity 2. Coolant activity as sampled>300pCi/gm Dose Equivalent 1-131 1. Containment isolation is required and EITHER of Ihe following:

3. Containment CSF -Red path conditions

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

4. Hydrogen concentration in Containment

_ 5%.Directors judgment indicate a loss OR 4. Containment None None of containment integrity.

Integrity or Bypass None None OR 5. a. Containment pressure > 20 pslg.AND b. UNISOLABLE pathway from containment to the environment

b. Less than one full train of Containment exists. Spray is operating per design for_015 minutes.OR 2. Indication of RCS leakage outside of containment

1. Any Condition in the opinion of the 2. Any Condition in the opinion of the 1. Any Condition in the opinion of the 2. Any Condition in the opinion of the 1. Any Condition in the opinion of the 2. Any Condition in the opinion of the Emergency S. Emergency Enmergency Director that indicates Loss Emergency Director that indicates Emergency Director that indicates Loss of Emergency Director that indicates Potential Emergency Director that indicates Loss of Director that indicates Potential Loss of the Director Judgment of the Fuel Clad Barrier. Potential Loss of the Fuel Clad Barrier. the RCS Barrier. Loss of the RCS Barrier. the Containment Barrier. Containment Barrier.Page 12 of66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier Ed Category:

Fuel Clad BarrierC No Change Diffrnce Deviation RCS or SG tube leakage RCS or SG tube leakage 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

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

Fission Product Barrier (FPB) Threshold:

Potential Loss Potential Lose A. RCS/reactor vessel level less than (site-specific level). 1. Core-Cooling CSF -Orange Path conditions exist.Page 13 of 66 NEI 99-01 Rev 6 FC2 Category:

Fuel Clad Barrier Inadequate Heat Removal Operating Mode Applicability:

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

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

Proposed EAL Justification FC2 Category:

Fuel Clad Barrier RCS Activity Operating Mode Applicability:

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

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

Page 14 of 66 NEI es-ci Rev 6 Proposed EAL Justification NEI 99-01 Rev 6 Proposed EAL Justification i -i FC3 Category:

Fuel Clad Barrier Containment Radiation

/ RCS Activity Operating Mode Applicability:

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

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

Fuel Clad Barrier Containment Radiation

/ RCS Activity Operating Mode Applicability:

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

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

reading > 1.95E+03 R/hr.OR 2. Coolant activity as sampled > 300pCilgm Dose Equivalent 1-131.E No Change 1: Difference 1 Deviation 1) Listed site-specific monitor and threshold value to ensure timely classification.

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

Fuel Clad Barrier FC6 Category:

Fuel Clad Barrier FC5 No Change Difference Deviation Emergency Director Judgment Emergency Director Judgment Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

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

2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier. Loss of the Fuel Clad Barrier.Page 16 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Rdl Rdl m- moCag -- Difrne m -m eito Category:

Reactor Coolant System Barrier Category:

Reactor Coolant System Barrier I E No Change [:] Derec Deviation RCS or SG Tube Leakage RCS or SG Tube Leakage 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. An automatic or manual ECCS (SI) actuation is required by EITHER of the 1. An automatic or manual SI actuation is required by EITHER of the following:

following:

a. UNISOLABLE RCS leakage 1. UNISOLABLE RCS leakage OR OR 2. SG tube RUPTURE. b. SG tube RUPTURE.Potential Loss Potential Loss A. Operation of a standby charging (makeup) pump is required by EITHER of the 2. The capacity of one charging pump in the normal charging mode is exceeded following:

due to EITHER of the following:

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

3. RCS integrity CSF -Red path conditions exist.Page 17 of 66 NEI 99-01 Rev 6 Proposed EAL Justification RC2 RC2 No Change [--]Differenice Deviation Category:

Reactor Coolant System Barrier Category:

Reactor Coolant System Barrier Nev Inadequate Heat Removal Inadequate Heat Removal 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Potential Loss Potential Loss A. Inadequate RCS heat removal capability via steam generators as indicated by Heat Sink CSF -Red Path conditions exist.(site-specific indications).

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

Reactor Coolant System Barrier RC3 Category:

Reactor Coolant System Barrier RC3 [ No Change Difference Deviation Containment Radiation

/ RCS Activity RCS Leak Rate 1) Listed site-specific systems and threshold values to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Containment radiation monitor reading greater than (site-specific value). Containment radiation monitor (AR020(21))

reading > 26 R/hr.Page 19 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC6 Category:

Reactor Coolant System Barrier RC5 No Change Diffrce Deviation Emergency Director Judgment Emergency director Judgment Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. ANY Condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier. the RCS Barrier.Potential Loss Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier. 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Page 20 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CTI Category:

Containment Barrier CTI E No Change Difference Deviation RCS or SG Tube Leakage RCS or SG Tube Leakage 1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

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

A leaking or RUPTURED SG is FAULTED outside of containment.

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

Containment Barrier CT2 Category:

Containment Barrier CT2 [ No Change Difference Deviation Inadequate Heat Removal Inadequate Heat Removal 1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

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

Core-Cooling CSF Red Path conditions exist AND Functional Restoration AND procedures not effective in < 15 minutes 2. Restoration procedure not effective within 15 minutes.Page 22 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT3 Category:

Containment BarrierCT3 No Change []Diffeence Deviation Containment Radiation

/ RCS Activity Containment Radiation I RCS Activity 1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Potential Loss Potential Loss A. Containment radiation monitor reading greater than (site-specific value). Containment radiation monitor (AR020(21))

reading > 4.40E+03 R/hr.Page 23 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT4 Category:

Containment Barrier CT4 E No Change Difference Deviation Containment Integrity or Bypass Containment Integrity or Bypass 1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

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

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

monitor readings outside of containment in the Emergency Director 1. Containment integrity has been lost based on Emergency Director judgment indicate a loss of containment integrity.

judgment.

OR OR 2. UNISOLABLE pathway from the containment to the environment exists. b. UNISOLABLE pathway from containment to the environment exists.OR OR B. Indications of RCS leakage outside of containment.

2. Indication of RCS leakage outside of containment Potential Loss Potential Loss A. Containment pressure greater than (site-specific value) 3. Containment CSF -Red path conditions exist.OR OR B. Explosive mixture exists inside containment

4. Hydrogen concentration in Containment_>

5%.OR OR C. 1. Containment pressure greater than (site-specific pressure setpoint)AND 5. a. Containment pressure > 20 psig.2. Less than one full train of (site-specific system or equipment) is operating AND per design for 15 minutes or longer. b. Less than one full train of Containment Spray is operating per design for _>15 minutes.Page 24 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT6 Category:

Containment Barrier C" No Chage Difference Deviation Emergency director Judgment Emergency Director Judgment Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

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

2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier. Loss of the Containment Barrier.Page 25 of 66 0 NEI 99-01 Rev 6 :: ]1Proposed EAL Justification SG1 Initiating Condition:

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

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

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

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

1,2,3,4 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to unit ESF buses.AND 2. Failure of DG IA(2A) and DG 1B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3 EITHER of the following: " Restoration of at least one unit ESF bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely.OR" Core Cooling CFS -Red Path conditions exist No Change D Difference FIDeviation

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

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

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

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.MS1 Initiating Condition:

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

1,2,3,4 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to unit ESF buses.AND 2. Failure of DG 1A(2A) and DG 1B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3. Failure to restore power to at lease one unit ESF bus in < 15 minutes from the time of loss of both offsite and onsite AC power.No Change FIDifference FIDeviation

1) Listed site specific equipment to ensure timely classification.

Page 27 of 66 NEI 99-01 Rev 6 J Proposed EAL 1 Justification SA1 Initiating Condition:

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

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

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

1,2,3,4 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. AC power capability to unit ESF buses reduced to only one of the following power sources for_> 15 minutes.* Affected unit SAT 142-1(242-1)

• Affected unit SAT 142-2(242-2)

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

Page 28 of 66 NEI 99-01 Rev 6 1 Proposed EAL TJustification Sul Initiating Condition:

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

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.Loss of ALL offsite AC power capability to (site-specific emergency buses) for 15 minutes or longer MU1 Initiating Condition:

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

1,2,3,4 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Loss of ALL offsite AC power capability to unit ESF buses for > 15 minutes M No Change FIDifference

[IDeviation

1) Listed site specific equipment to ensure timely classification.

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

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

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the General Emergency promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded..Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses) for 15 minutes or longer.AND Indicated voltage is less than (site-specific bus voltage value) on ALL (site-specific vital DC buses) for 15 minutes or longer.MG2 Initiating Condition:

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

1,2.3,4 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to unit ESF buses.AND 2. Failure of DG 1A(2A) and DG 1B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3. Voltage is < 108 VDC on unit 125 VDC battery buses 111(211) and 112(212).AND 4. All AC and Vital DC power sources have been lost for > 15 minutes.D No Change M Difference FIDeviation

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

2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.Page 30 of 66 NEI 99-01 Rev 6 Proposed EAL Justification S511 Initiating Condition:

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

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.Indicated voltage is less than (site-specific bus voltage value) on ALL Vital DC buses for 15 minutes or longer.MS2 Initiating Condition:

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

1,2,3,4 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Voltage is < 108 VDC on unit 125 VDC battery buses 111(211) and 112(212) for >15 minutes.D- No Change I Difference 1 Deviation 1) Listed site specific equipment and site specific value to ensure timely classification.

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

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

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

AND c. EITHER of the following conditions exist: 1. (Site-specific indication of an inability to adequately remove heat from the core)OR 2. (Site-specific indication of an inability to adequately remove heat from the RCS)MS3 Initiating Condition:

Inability to shutdown the reactor causing a challenge to core cooling or RCS heat removal.Operating Mode Applicability:

1,2 Emergency Action Levels (EAL): 1. Automatic or Manual Trip did not shutdown the reactor as indicated by Reactor Power >5%.AND 2. ALL manual actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power >5%.AND 3. EITHER of the following conditions exist: a. Core Cooling CSF-RED Path conditions exist.OR b. Heat Sink CSF-RED Path conditions exist.D No Change M Difference 1-] Deviation 1) Listed site specific indications to ensure timely classification.

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

ALERT Automatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:

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

1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown the reactor.AND b. Manual action taken at the reactor control consoles are not successful in shutting down the reactor.MA3 Initiating Condition:

Automatic or manual trip fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:

1,2 Emergency Action Levels (EAL): Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. Automatic or manual Trip did not shutdown the reactor as indicated by Reactor Power > 5%.AND 2. Manual actions taken at the Main Control Board are not successful in shutting down the reactor as indicated by Reactor Power > 5%.Hý No Change FIDifference FIDeviation 1 ) Listed site specific indications to ensure timely classification.

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

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

Power Operation Example Emergency Action Levels: (1 or 2)Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. a. An automatic (trip [PVVR] / scram [BWR]) did not shutdown the reactor.AND b. A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.2. a. A manual trip ([PWR] / scram [BWR]) did not shutdown the reactor.AND b. EITHER of the following:

1. A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.OR 2. A subsequent automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor.MU3 Initiating Condition:

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

H No Change WIDifference 1 Deviation 1) Listed site specific indications to ensure timely classification.

2) Mode 2 included in operating mode applicability as per developer notes.1,2 Emergency Action Levels (EAL): Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. a. Automatic Trip did not shutdown the reactor as indicated by Reactor Power> 5%.AND b. Subsequent manual action taken at the Main Control Board is successful in shutting down the reactor.OR 2. a. Manual Trip did not shutdown the reactor as indicated by Reactor Power> 5%.AND b. EITHER of the following:

1. Subsequent manual action taken at the Main Control Board is successful in shutting down the reactor.OR 2. Subsequent Automatic Trip is successful in shutting down the reactor.Page 34 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA2 Initiating Condition:

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

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Alert promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.[see table below][BWR parameter list] [PWR parameter list]Reactor Power Reactor Power RPV Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In Core/Core Exit Temperature Suppression Pool Level Levels in at least (site specific number)steam generators Steam Generator Auxiliary or Suppression PEmergency Feed Water Flow AND b. Any of the following transient events in progress.Automatic or Manual runback greater than 25% thermal reactor power* Electrical load rejection greater than 25% full electrical load* Reactor Scram [BWR] / trip [PWR]* ECCS (SI) actuation* Thermal power oscillations greater than 10% [BWR]MA4 Initiating Condition:

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

1,2,3,4 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. a An UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 16 minutes.M No Change FIDifference FIDeviation

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

Table Mi -Control Room Parameters

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

• Narrow Range level in at least one Steam Generator* Steam generator Auxiliary Feed Water Flow AND b. Any Table M2 transient in progress.Table M2 -Significant Transients

• Automatic Turbine Runback >25% thermal reactor power* Electrical Load Rejection

>25% full electrical load* Reactor Trip* Safety Injection Actuation Page 35 of 66 0 NEI 99-01 Rev 6 Proposed EAL Justification SU2 Initiating Condition:

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

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.[see table below][ BWR parameter list] [PWR parameter list]Reactor Power Reactor Power RPV Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In Core/Core Exit Temperature Levels in at least (site specific Suppression Pool Level number) steam generators Steam Generator Auxiliary or Suppression Pool Temperature Emergency Feed Water Flow MU4 Initiating Condition:

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

1,2,3,4 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.An UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes.Wq No Change FIDifference FIDeviation

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

Table M1 -Control Room Parameters

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

• Narrow Range level in at least one Steam Generator* Steam generator Auxiliary Feed Water Flow Page 36 of 66 NEI 99-01 Rev 6 Proposed EAL Justification NEI 99-01 Rev 6 Proposed ML Justification SA9 Initiating Condition:

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

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

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

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

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

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

• Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* Other events with similar hazard characteristics as determined by the Shift Manager AND 2. EITHER of the following:

a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.OR b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.H No Change -Difference

-Deviation 1) No additional site specific hazard noted 2) Changed the word "needed" to "required" in the IC and to "required by Technical Specification" in the EAL, to be consistent with terminology used by operators and minimize confusion.

Page 37 of 66 NEI 99-01 Rev 6 1 Proposed EAL ] Justification SU4 Initiating Condition:

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

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

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

1,2,3,4 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage > 10 gpm for> 15 minutes OR 2. RCS identified leakage >25 gpm for > 15 minutes OR 3. Leakage from the RCS to a location outside containment

>25 gpm for> 15 minutes M No Change 1 Difference FIDeviation

1) Listed site specific values to ensure timely classification.

Page 38 of 66 NEI199-01 Rev 6 Proposed EAL Justification NEI~~~~~~~~-

990 e rpsd A utfcto SU6 Initiating Condition:

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

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

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

1,2,3,4 Emergency Action Levels (EAL): 1. Loss of ALL Table M3 Onsite communications capability affecting the ability to perform routine operations.

OR 2. Loss of ALL Table M3 Offsite communication capability affecting the ability to perform offsite notifications.

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

Table M3 -Communications Capability System Onsite Offsite NRC Radios X Plant page X Plant Telephone System X Commercial Telephones X X X NARS X ENS X X HPN X X Satellite phones X X M No Change F Difference FIDeviation

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

Page 39 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU7 Initiating Condition:

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

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

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

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

1,2,3,4 Emergency Action Levels (EAL): I a. Failure of containment to isolate when required by an actuation signal.AND b. ANY required penetration remains open > 15 minutes of the actuation signal.OR 2. a. Containment pressure a 20 psig.AND b. Less than one full train of Containment Spray is operating per design for> 15 minutes.F- No Change W] Difference FIDeviation

1) Listed site specific indications to ensure timely classification.

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

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

Cold Shutdown, Refueling, Defueled Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.CAI Initiating Condition:

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

5,6, D Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL off-site AC power to unit ESF buses.AND 2. Failure of DG 1A(2A) and DG 1 B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3. Failure to restore power to at least one unit ESF bus in < 15 minutes from the time of loss of both offsite and onsite AC power.E No Change 1 Difference 1 Deviation 1) Listed site specific equipment to ensure timely classification.

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

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

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

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

5,6, D Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. AC power capability to unit ESF buses reduced to only one of the following power sources for > 15 minutes.* Affected unit SAT 142-1(242-1)

• Affected unit SAT 142-2(242-2)

• Emergency Diesel Generator DG 1A(2A)* Emergency Diesel Generator DG 11B(2B)* Unit crosstie breakers AND 2. Any additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.No Change 1 Difference

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

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

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

Cold Shutdown, Refueling Example Emergency Action Levels: 1. a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

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

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

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

5,6 Emergency Action Levels (EAL): 1. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

• Internal or external flooding event* High winds or tomado strike" FIRE" EXPLOSION* Other events with similar hazard characteristics as determined by the Shift Manager AND 2. EITHER of the following:

a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.OR b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.H: No Change E Difference Deviation 1) No additional site specific hazard noted 2) Changed the word "needed" to "required" in the IC and to "required by Technical Specification" in the EAL, to be consistent with terminology used by operators and minimize confusion.

Page 43 of 66 NEI 99-01 Rev 6 [Proposed EAL IJustification CU4 Initiating Condition:

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

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

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

5, 6 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Voltage is < 108 VDC on required unit 125 VDC battery buses 111(211) and 112(212) for > 15 minutes.D ] No Change E Difference 1 Deviation 1) Listed site specific voltage and equipment to ensure timely classification.

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

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

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

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

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

OR 2. Loss of ALL Table C1 Offsite communication capability affecting the ability to perform offsite notifications.

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

No Change 1 1 Difference 1 Deviation 1) Listed site specific communications methods to ensure timely classification Table Cl -Communications Capability System Onsite Offsite NRC Radios X Plant page X Plant Telephone System X Commercial Telephones X X X NARS X ENS X X HPN X X Satellite phones X X Page 45 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CA3 Initiating Condition:

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

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

[PWR])CA5 Initiating Condition:

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

5, 6 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature

> 200 0 F due to loss of decay heat removal for > Table C2 duration.OR 2. UNPLANNED RCS pressure rise > 10 psig as a result of temperature rise due to loss of decay heat removal. (This EAL does not apply during water- solid plant conditions.)

[H No Change E Difference

[: Deviation 1) Listed site specific Technical Specification cold shutdown temperature limit to ensure timely classification.

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

3) Added wording relating the temp and press rise to a loss of decay heat removal capability as per the developer notes for PWR's Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up Duration Status Intact (but not RCS Reduced Not Applicable 60 minutes*Inventory

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

Table C2 -RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up Duration Status Intact Not Applicable 60 minutes*Not Intact Established 20 minutes*OR Reduced Inventory Not Established 0 minutes (<397 ft.)If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not applicable.

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

UNUSUAL EVENT UNPLANNED increase in RCS temperature.

Operating Mode Applicability:

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

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

UNPLANNED rise in RCS temperature.

Operating Mode Applicability:

5,6 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature

> 200*F due to loss of decay heat removal.OR 2. Loss of the following for > 15 minutes.* ALL RCS temperature indications AND* ALL RPV level indications D: No Change f Difference 1 Deviation 1) Listed site specific Technical Specification cold shutdown temperature limit to ensure timely classification.

2) Changed the word increase to rise in the initiating condition to be consistent with operations language and training.Page 47 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification CGI Initiating Condition:

GENERAL EMERGENCY Loss of (reactor vessel/RCS

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

Operating Mode Applicability:

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

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

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

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

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

AND c. ANY indication from the Containment Challenge Table).CG6 Initiating Condition:

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

Operating Mode Applicability:

5,6 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. a. RVLIS indicates 0% Plenum for > 30 minutes.OR Reactor Vessel Refueling Level Indicators LT-046 and LT-049 < 392 ft. el. for> 30 minutes.AND b. ANY Containment Challenge Indication (Table C4)OR H No Change W Difference 1 Deviation 1) Listed site specific values for level, developer notes indicate the level to be approximately Top of Active Fuel. The rain indicated level of the transmitters LT-046 and 049 is 392 ft el. A level of 392 ft el along with RVLIS indicating 0%is being used as the lowest readable level. And allows for an escalation from CS6.2) Listed site specific levels, radiation monitors, and sumps and tanks to ensure timely classification.

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

4) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.2.3.Reactor vessel level unknown for > 30 minutes.AND Core uncovery is indicated by ANY of the foflowing:

a. Table C3 indications.

OR b. Erratic Source Range Neutron Monitor indication.

OR c. 1/2 RE-AR011 or 1/2 RE-AR12 Containment Fuel Handling Incident radiation monitors> 3000 mR/hr.AND 4. Any Containment Challenge Indication (Table C4)Table C3 Indications of RCS Leakage Table: Containment Challenge Table* CONTAINMENT CLOSURE not established*" (Explosive mixture) exists inside containment

• UNPLANNED increase in containment pressure* Secondary containment radiation monitor reading above (site-specific value) [BWR]* if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.* UNPLANNED Containment Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED Tank level rise** UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.

Table C4 -Containment Challenge Indications

• Hydrogen Concentration in Containment

> 5%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established

• if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.Page 48 of 66 NEI 99-01 Rev 6 { Proposed EAL j Justification CS1 Initiating Condition:

SITE AREA EMERGENCY Loss of (reactor vessel/RCS

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

Operating Mode Applicability:

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

AND b. (Reactor vessel/RCS

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

AND b. (Reactor vesselfRCS

[P14'R] or RPV [BWR]) level less than (site-specific level).3. a. (Reactor vessel/RCS

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

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

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

CS6 Initiating Condition:

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

Operating Mode Applicability:

5,6 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. With CONTAINMENT CLOSURE established EITHER: a. RVLIS indicates 0% Plenum OR b. Reactor Vessel Refueling Level Indicators LT-046 and LT-049 <392 ff el.OR 2. With CONTAINMENT CLOSURE not established EITHER: a. RVLIS_< 15% Plenum.OR b. Reactor Vessel Refueling Level Indicators LT-046 and LT-049 <393 ft. el.OR 3. a. Reactor vessel level unknown for >30 minutes.AND b. Core uncovery is indicated by any of the following:

• Table C3 indications.

OR* Erratic Source Range Neutron Monitor indication.

OR* 1/2 RE-AR01 I or 1/2 RE-AR12 Containment Fuel Handling Incident radiation monitors > 3000 mR/hr.Table C3 Indications of RCS Leakage* UNPLANNED Containment Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED Tank (rad waste) level rise** UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.

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

4) Listed site specific sumps and tanks to ensure timely classification

5) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.Page 49 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CAI Initiating Condition:

ALERT Loss of (reactor vessel/RCS

[P4R] or RPV [BWR]) inventory Operating Mode Applicability:

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

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

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

[PWR] or RPV [BWR]) inventory.

CA6 Initiating Condition:

Loss of reactor vessel / RCS inventory Operating Mode Applicability:

5, 6 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. a. Loss of reactor vessel / RCS inventory as indicated RVLIS < 37%Plenum.OR b. Loss of reactor vessel / RSC inventory as indicated by LT-046 and LT-049 < 393.4 ft. al.OR 2. a. Reactor vessel / RCS level unknown for > 15 minutes.AND b. Loss of reactor vessel / RCS inventory per Table C3 indications.

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

The developer notes indicate the levels to correspond to the level required to support RHR pump operation, lAW BwOA PRI-10 (LOSS OF RH COOLING) RCS levels of > 37%or 393.4' on LT-046 and LT -049 as necessary to maintain RH pumps operating at reduced inventory conditions.

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

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

3) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.Table C3 Indications of RCS Leakage* UNPLANNED Containment Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED Tank (rad waste) level rise** UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventorv.

Page 50 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Cul Initiating Condition:

UNUSUAL EVENT UNPLANNED loss of (reactor vessel/RCS

[PWRI or RPV [BWR]) inventory for 15 minutes or longer.Operating Mode Applicability:

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

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

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

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

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

5, 6 Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED loss of reactor coolant results in the inability to restore and maintain reactor vessel / RCS level to> procedurally established lower limit for >15 minutes.OR 2. a. Reactor vessel / RCS level unknown.AND b. Loss of reactor vessel / RCS inventory per Table C3 indications.

D No Change E Difference 1 Deviation 1) Listed site specific sumps and tanks to ensure timely classification.

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

3) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.Table C3 Indications of RCS Leakage" UNPLANNED Containment Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise*" UNPLANNED Tank (rad waste) level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.

Page 51 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HG1 HG1 Initiating Condition:

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

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

AND b. EITHER of the following:

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

• Reactivity control Core cooling [PlWtR / RPV water level [BIAR]* RCS heat removal OR 2. Damage to spent fuel has occurred or is IMMINENT Initiating Condition:

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

1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL): 1. A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.AND 2. a. ANY Table H1 safety function cannot be controlled or maintained.

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

Table H1 -Safety Functions* Reactivity Control (ability to shutdown the reactor and keep it shutdown)* Core Cooling (ability to cool the core)* RCS Heat Removal (ability to maintain a heatsink)Page 52 of 66 0 NEI 99-01 Rev 6 1 Proposed EAL Justification HS1 Initiating Condition:

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

HS1 Initiating Condition:

HOSTILE ACTION within the Protected Area.Operating Mode Applicability:

1,2, 3, 4,5, 6, D Emergency Action Levels (EAL): A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.M No Change [IDifference 1 Deviation 1) List site security shift supervision as Security Force.All Example Emergency Action Levels: A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-security shift supervision).

Page 53 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HA1 Initiating Condition:

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

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

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

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

1,2,3,4,5,6.

D Emergency Action Levels (EAL): 1. A validated notification from NRC of an aircraft attack threat < 30 minutes from the site.OR 2. Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.M No Change D Difference

[IDeviation

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

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

HU1 All Example Emergency Action Levels: (1 or 2 or 3)1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the (site-specific security shift supervision).

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

Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:

1,2,3,4,5,6, D Emergency Action Levels (EAL): 1. Notification of a credible security threat directed at the site as determined per SY-AA-101-1 32, Security Assessment and Response to Unusual Activities.

OR 2. A validated notification from the NRC providing information of an aircraft threat.OR 3. Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.H No Change FIDifference FIDeviation

1) List site security shift supervision as Security Force.2) Further described credible security threat through listing a site specific procedure.

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

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

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

2. Control of ANY of the following key safety functions is not reestablished within (site-specific number of minutes).Reactivity control* Core cooling [PWR] / RPV water level [BI/]RCS heat removal HS2 Initiating Condition:

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

1,2, 3, 4, 5,6, D Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per 1/2BwOA PRI-5, Control Room Inaccessibility.

AND 2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.F No Change W Difference FD eviation 1) EAL uses the site specific Control Room evacuation procedure to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedure the Control Room would enter should such an event occur, this allows for greater clarity as to when this EAL would apply than if each panel and station used in alternate shutdown were to be listed, 2) Added descriptors to better explain each safety function and allow for a timely classification.

3) Changed "An event" to" A Control Room evacuation" to remove confusion if partial plant control was transferred to outside the control room with the control room still manned, due to testing or equipment failure.Table H1 -Safety Functions* Reactivity Control (ability to shutdown the reactor and keep it shutdown)* Core Cooling (ability to cool the core)RCS Heat Removal (ability to maintain a heatsink)Page 56 of 66 NEI 99-01 Rev 6 1Proposed EAL Justification HA6 HA2 Initiating Condition:

ALERT Initiating Condition:

F No Change M Difference FIDeviation Control Room evacuation resulting in transfer of plant control to alternate locations.

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

Operating Mode Applicability:

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

Operating Mode Applicability:

1,2,34,5.,6, D Emergency Action Levels (EAL): A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per 1i2BwOA PRI-5, Control Room Inaccessibility.

1) EAL uses the site specific Control Room evacuation procedure to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedure the Control Room would enter should such an event occur, this allows for greater clarity as to when this EAL would apply than if each panel and station used in alternate shutdown were to be listed, 2) Changed "An event" to" A Control Room evacuation" to remove confusion if partial plant control was transferred to outside the control room with the control room still manned, due to testing or equipment failure.Page 57 of 66 NEI 99-01 Rev 6 Proposed EAL jJustification HU4 HU3 Initiating Condition:

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

Initiating Condition:

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

H No Change -- Difference FIDeviation

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

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

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

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

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

4. A FIRE within the plant or ISFSI [for plants with an ISFS1 outside the plant Protected Area] PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

1, 2, 3,4, 5, 6, D Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.a. A FIRE in any Table H2 area is not extinguished in <15-minutes of ANY of the following FIRE detection indications:

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

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

• Field verification of a single fire alarm Table H2 -Vital Areas* Containment

• Auxiliary Building* Fuel Handling Building* Main Steam Tunnels* RWST's* Condensate Storage Tanks* Lake Screen House OR 2. a. Receipt of a single fire alarm in any Table H2 area (i.e., no other indications of a FIRE).AND b. The existence of a FIRE is not verified in <30-minutes of alarm receipt.OR 3. A FIRE within the plant PROTECTED AREA not extinguished in<60-minutes of the initial report, alarm or indication.

OR 4. A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

Page 58 of 66 NEI 99-01 Rev 6 Initiating Condition:

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

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

Seismic event greater than OBE levels.Operating Mode Applicability:

1,2,3,4,5,6, D Emergency Action Levels (EAL): Seismic event > Operating Basis Earthquake (OBE) as indicated by seismic check at panel OPA02J.F1 No Change -Difference FIDeviation

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

Page 59 of 66 0 NEI 99-01 Rev 6 HA5 Initiating Condition:

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

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

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

AND b. Entry into the room or area is prohibited or impeded.Proposed EAL Justification HA5 Initiating Condition:

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

1,2,3,4,5,6, D Emergency Action Levels (EAL): Note: If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.

1. Release of a toxic, corrosive, asphyxiant or flammable gas in a Table H3 area.Table H3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Auxiliary Building*

Mode 4, 5, and 6 I Areas required to establish shutdown cooling AND 2. Entry into the room or area is prohibited or impeded.M No Change FIDifference FIDeviation

1) Listed plant specific rooms and areas with entry related mode applicability to ensure timely classification.

Page 60 of 66 NEI 99-01 Rev 6 j Proposed EAL I Justification HU3 HUB Initiating Condition:

UNUSUAL EVENT Hazardous Event Initiating Condition:

Operating Mode Applicability:

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

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

1, 2, 3, 4, 5,6, D Emergency Action Levels (EAL): Note: EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

1. Tornado strike within the PROTECTED AREA.OR 2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating mode.OR 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).OR 4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.F No Change M Difference FIDeviation

1) No site specific list of natural or technological hazard events was noted.2) Changed the word "needed" to "required by Technical Specifications" in the EAL to be consistent with terminology used by operators and minimize confusion.

Page 61 of 66 NEI 99-01 Rev 6 Proposed EAL [Justification HG7 Initiating Condition:

GENERAL EMERGENCY Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency.

Operating Mode Applicability:

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

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area.HG7 Initiating Condition:

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

Operating Mode Applicability:

1,2, 3,4, 5,6, D Emergency Action Levels (EAL): Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area..M No Change F Difference 1 Deviation Page 62 of 66 NEI 99-01 Rev 6 J Proposed EAL Justification HS7 HS7 Initiating Condition:

SITE AREA EMERGENCY Initiating Condition:

IV] No Change 1 Difference FIDeviation Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency.

Operating Mode Applicability:

All Example Emergency Action Levels: Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or: (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency.

Operating Mode Applicability:

1, 2, 3,4, 5, 6, D Emergency Action Levels (EAL): Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Page 63 of 66 NEI 99-01 Rev 6 1Proposed EAL IJustification HA7 HA7 Initiating Condition:

ALERT Initiating Condition:

FH No Change 1 Difference FIDeviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert. declaration of an Alert.Operating Mode Applicability:

All Example Emergency Action Levels: Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Operating Mode Applicability:

1,2,3,4,5,6, D Emergency Action Levels (EAL): Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Page 64 of 66 NEI 99-01 Rev 6 1Proposed EAL [Justification HU7 Initiating Condition:

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

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

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.HU7 Initiating Condition:

W No Change F-1 Difference FIDeviation Other conditions existing which in the judgment of the Emergency director warrant declaration of an UNUSUAL EVENT.Operating Mode Applicability:

1,2, 3,4, 5, 6, D Emergency Action Levels (EAL): Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.Page 65 of 66 NEI 99-01 Rev 6 Proposed EAL Justification E-HU1 E-HU1 Initiating Condition:

UNUSUAL EVENT Initiating Condition:

[-j No Change i- Difference 1 Deviation Damage to a loaded cask CONFINEMENT BOUNDARY.

Damage to a loaded cask CONFINEMENT BOUNDARY.

1) Listed 2x the site specific cask specific allowable radiation level as per the Certificate of Compliance No. 1014 Appendix A Section 5.7 Operating Mode Applicability:

Operating Mode Applicability:

All 1,2, 3, 4,5,6, D Example Emergency Action Levels: Emergency Action Levels (EAL): Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on- Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specific contact radiation reading: technical specification allowable radiation level) on the surface of the spent fuel cask. > > 40 mrfhr (gamma + neutron) on the top of the spent fuel cask OR* > 220 mrfhr (gamma + neutron) on the side of the spent fuel cask, excluding inlet and outlet ducts.Page 66 of 66 Braidwood Annex Exelon Nuclear Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARGI Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRfem TEDE or 5000 mRfem thyroid CDE.Operating Mode Applicability:

1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.*-.The Emnergency Director should declaro the General Em:Fergency event promnptly upon determineing that the applicable time has been exrcded, Or Will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

(1) Reading on ANY of the folloWIng radiation monitorS greater than the reading shown for 15 minutes or longer: (site specifc moniAtor list and threshold values)1. The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PR030)

>3.87 E+09 uCilsec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS-Total Noble Gas Release Rate).OR 2. Dose assessment Using actual meteorology indicates doses at or beyond (site-specific dose re.eptor point) the site boundary of EITHER: a. > 1000 mRem TEDE OR b. > 5000 mRem CDE Thyroid Month 20XX BW 3-1 EP-AA-1001 (Revision XX)

Exelan NUC102r Braidwood Annex Eeo ula RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS OR Field SUr~ey results-6 ind-ic-ato-EITHER of the Wol~wing at OF beyond (site specific dose receptor poin~t): Closed windonw donsse r-ates groater than 1,000 mR'~hr expected to continue for 60- minutos- Or longor.Analyses of field- suroey samples indicate thyroid CDE greator than 5000 mromm for onA hour o f inhnlation.

3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >1000 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.

Basis: This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases.

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

The TEDE dose is set at the EPA PAG of 1000 mRfem while the 5000 mRfem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Classific~ation based on effluenit monitor readings assumes that. a release path to th envionmnt as established.

If the effluent flow past an effluent monitor is known to have stopped due to actions, to- isolate the releas-e path, then the effluent monGitor reading is no!onger valid for classifcation purposes,.

Basis Reference(s):

1 .NEI 99-01 Rev 6, AGI 2. EP-EAL-0601 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Braidwood Station Month 20XX BW 3-2 EP-AA-1001 (Revision XX)

RraidwnnrI Annexv Exelnn Nucleiar RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 3. EP-AA-1 12-500 Emergency Environmental Monitoring Month 20XX BW 3-3 EP-AA-1001 (Revision XX) 12rftir&A#arr1 Annawv I=vg=ltn km. erl-,hr Rr~iI~j,,~jiI A uiini~~ ~U U~d ~ F~I US I~4~ ~ U *URd~*~~*RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARSI Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 100 mRrem TEDE or 500 mRfem thyroid CDE.Operating Mode Applicability:

1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): Notes:*The Emergency D)irector should declare the Site Arca EmcrgeneRy e'.eot promptly upon determning that the appli1abic time has been eXcoeded, Or Will likely be exGeeded*--The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

-" If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

(1) Reading on ANY of the followA.ing radiation monitors g.eato. than the reading shown for 15 ImlinuteAS or longer: (ciate rWoocific moenitor list and threshold Yalwee)(2) Dose assessment using actbu-al metteorology ind~icateAs; do9ses greater than 100 mrom TrEDE Or 50 M.eM thyroid O-DrE at or beyond (site specific dose recepto (3) Field surwey results inedic-ate EITHER of the fomllowing at or beyond (site pepific*Closed vindow dose retes greater- than 100 mnR'hr expeeted to conftinue for- 60 mninutes or- engef7*Analyses of field surfvey samples indicate thyroid CODE greater- than 500 mrcmn for- one hour- of inhalation.

Month 20XX BW 3-4 EP-AA-1001 (Revision XX)

Rraidwnnd Annex Exelon Nucla~r RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS 1. The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PR030)

>3.87 E+08 uCilsec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS-Total Noble Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boun of EITHER: a. > 100 mRem TEDE OR b. > 500 mRem CDE Thyroid OR 3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >100 mR/hr are expected to continue for > 60 minutes.OR Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.

Basis: This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).It includes both monitored and un-monitored releases.

Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1000 mRfem while the 500 mRiem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Clasifcatonbased on effluent monitor readings assumes that- a release path to the eR~iroAnmnt_

is established.

'if the effluent flow past an effluent mon~ito kis kon to have stopped duo to actions toilat the reloase path, then the effluent moitor reading iS no longer valid forcasiicto purposes.Month 20XX BW 3-5 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Escalation of the emergency classification level would be via IC RAG1.BasisReference(s):

1. NEI 99-01 Rev 6, AS1 2. EP-EAL-0601 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Braidwood Station 3. EP-AA-112-500 Emergency Environmental Monitoring Month 20XX BW 3-6 EP-AA-1001 (Revision XX)

Rraidwnnd Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARAI Initiating Condition:

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

1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): Notes: e The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded." .The Emergency Director should decl'are the Alert event promnptly upon determining that the applicable time has been excccded, or Will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

(1) Reading on ANY of thn following radiation monitors greater than the reading shown for 15 mrlinutes-Or logAer:.(2) Dose assessment using actub-al meteoroloGgy indiates doses greater than 10 mr~em TEDE or 59 thyrid ODE at Or beyond (site specific_ rere8ptor Po0int).(3) Analysis&

of a liquid effluent sample idctsa cne~netration or releas'e rate that would Fresult in doses greater than 10 rnrom TED IE Or 50- m.F8m thyroid ODE= at or beyond (si-te specific dose receptor point) for onme hour of exposre.(4) Field survey re-sults indicGate EITHER of the following at Or beyond (site specific dove r eptorvpoint):

Month 20XX BW 3-7 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS t'll - _ --J ... ... .-. ...3+ --^- t 1--T)/, ...-., ..4:. .I" -£ 3 --.A 0 AQA AA- a WAA Aqka V-A+Pq V"14+"r. CM M-K FOU aafa ta PAR+ n44@ r. M AtReq Qr-v..jL,.. .......l _ger, I -1-------------1 --2 1-%1r'?.r..naivses 31 nela ~ur.~v ~amDic~ in~ucnie rnvroia ~1~'i ~reaier inun ~u miem ior one h1ur of iIhaateo n.d 1. The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PR030)> 3.87 E+07 uCilsec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS -Total Noble Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 10 mRem TEDE OR b. > 50 mRem CDE Thyroid OR 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mRem TEDE or 50 mRem CDE thyroid at or beyond the site boundary for 60 minutes of exposure.OR 4. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates > 10 mR/hr are expected to continue for a 60 minutes.OR b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.

Month 20XX BW 3-8 EP-AA-1001 (Revision XX) rnidwnnd AnnoyNiJcIAar Rr~idnnrl nn~vExelnon NucleIaIr RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS Basis: This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1000 mRrem while the 50 mRrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Clsifctinbased onF effluwent-mocnitonr read-ingS aSGneumo that. a release path to the enVirnMent oi, established.

If the e-fflun o pA t I an effluent-m is known to have stopped due to ac~tions to isolate the release path, then the effluent monAitor reading is no longer valid for clartsification purposes.-

Escalation of the emergency classification level would be via IC RAS1.Basis Reference(s):

1. NEI 99-01 Rev 6, AAI 2. ODCM Section 12.3 Liquid Effluents 3. EP-EAL-0601 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Braidwood Station 4. EP-EAL-0618 Rev. 0, Braidwood Criteria for Choosing Radiological Liquid Effluents EAL Threshold Values 5. 0BwlS RETS 2.1-1, Digital Channel Operational Test of OPR01J 6. 0BwISR 11.A.3-002, Rev 001 Channel Operation Test of Liquid Radwaste Effluent Radiation Monitor 0PR01J 7. EP-EAL-0623 Rev. 0, Braidwood Criteria for Choosing Radiological Gaseous Effluents EAL Threshold Values for Waste Gas Decay Tanks Month 20XX BW 3-9 EP-AA-1001 (Revision XX)

Rmirlwnnd Annay F::yalnn N, lahnr Rr2irlwnnrl Annav Fva~dnn NmIf~I~2r RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARUM Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM (site-speGifG effluent release controlling docum.ent) limits for 60 minutes or longer.Operating Mode Applicability:

1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): Notes: e The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.determwining that 650 mlinutes has been exc.eded, Or Will likely be ex.eeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.(1) Rending on ANY effluont radiation monitor greater than 2 times the (rite specific effluent release controlling documnent) limits for 60 minutes Or longer: (cite cpccific monitor list and threshold values corresponding to 2 times the docue-I,- (2) Reading on ANy- effluent radiaton monitor greater than 2 times the a larm setpoint established by a current radioactivie discharge permit for 0 mo 0 inutes.(3) Sample analySis for a gaSeous or liqu-id- releAase-indicrateAs a concentration or re-loaso rate greater than 22 timese the (site spec9ific-efflluent release controlling documenAt) li.mi;ts fo-r 60C mimnu-tesAor-lOn ger.1. Reading on any of the following effluent monitors > 2 times alarm setpoint established by a current radioactive release discharge permit for 2: 60 minutes." OPR01J, Liquid Radwaste Effluent Monitor" OPR90J, Liquid Radwaste Effluent Monitor" OPR02J, Gas Decay Tank Effluent Monitor" OPR10J, Station Blowdown Monitor Month 20XX BW 3-10 EP-AA-1001 (Revision XX) miduunnel Annoy I::valnn ",A~anir Rr~irwr~r~rI A nn~v Fva~Inn NI.uI~2r RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS" 1/2PR01J, Containment Purge Effluent Monitor" Discharge Permit specified monitor OR 2. The sum of readings on the Unit 1 and 2 Aux Bldg Vent WRGMs (1/2 RE-PR030)> 4.42 E+05 uCilsec for > 60 minutes (as determined from Unit I & 2 PF430 or PPDS -Total Noble Gas Release Rate).OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of > 60 minutes.Basis: This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release).

It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment.

Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases.

The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

based On efflUeRt monitor readings assumes that a release path to the enVironment is established.

'if the effluent flow past an effluent monGitor is known to-have stopped due to-actfions to isolate the release path, then the effluent monitor roading is sno longer valid foFr class~fiatien purposes.Releases should not be prorated or averaged.

For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.EAL #1 Basis: F=Al-#-# This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).Month 20XX BW 3-11 EP-AA-1001 (Revision XX)

Rrmiriumpel Anngav IP:valnn kiiil-,,ar RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS The effluent monitors listed are those normally used for planned discharges.

If a discharge is performed using a different flowpath or effluent monitor other than those listed (e.g., a portable or temporary effluent monitor), then the declaration criteria will be based on the monitor specified in the Discharge Permit.EAL #2 Basis: E.A.L #-1 This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous e-l4iquid-effluent pathways.EAL #3 Basis: RAL #3 This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).Escalation of the emergency classification level would be via IC RAA1.Basis Reference(s):

1. NEI 99-01 Rev 6, AU 2. UFSAR Section 11.5.2.3 3. ODCM Section 12.3 Liquid Effluents 4. EP-EAL-0601 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Braidwood Station 5. 0BwSR 11 .A.3-002, Rev 001 Channel Operation Test of Liquid Radwaste Effluent Radiation Monitor OPR01J Month 20XX BW 3-12 EP-AA-1001 (Revision XX)

Rraidwond Annex Exelon Nuclear Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA2 Initiating Condition:

Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:

1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): (1) Un eo:e, ; Of irradiated fuel in the REFUELING PATHWAAY.('\I i' n 4 a A*r~t I+,A f~ 1~ r ota i1+*r% njt-rI' .U ,%~ M ~ ~~-; ,fr, rvsm +kf fui 'i. .*,fS~ ~55-SS S ~ tV~S S t l ind-ic-ated -by ANY of the following radiation monAitors: (site specific isrting Of radiation monitors, and the associated Feadings, 6etpOints and/or alarm6)(3) Lowering of spent fuel pool level to (site specific Level 2 value). [See 1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R1 Radiation Monitor reading >1000 mRemlhr Table R1 Fuel Handling Incident Radiation Monitors" Fuel Building Fuel Handling Incident Monitor ORE-AR055" Fuel Building Fuel Handling Incident Monitor ORE-AR056* Containment Fuel Handling Incident Monitor 1/2RE-AR01 1" Containment Fuel Handling Incident Monitor 1/2RE-AR012 Month 20XX BW 3-13 EP-AA-1001 (Revision XX)

Rraidwood Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS Basis: REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.IMMINENT:

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

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

This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly., or a gn nt lowerQ"" i"ng of water .i.i pent fuel p9ol (,Se, Developer

'o.. s). These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment.

As such, they represent an actual or potential substantial degradation of the level of safety of the plant.This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1.Escalation of the emergency would be based on either Recognition Category A or C ICs.EAL #1 Basis: F=AL- #1 This EAL escalates from RAU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters.

Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations.

While an area radiation monitor could detect aa iGFIeaserise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered.

To the degree possible, readings should be considered in combination with other available indications of inventory loss.A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.Month 20XX BW 3-14 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS EAL #2 Basis: This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly.

A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).

Escalation of the emergency would be based on either Recognition Category RA-or C ICs.EAL= .#3 Spent fuel po'l level At thi Iau -iA w,,,ithin the lower And of the level range necessary to preVent iRgnifiant.

dnrote consequences~r from direct gamm~a Fadiati~on to perSOnnel performingq operations in t~he ':icinity of the spent fuel pool. Thin coend-ito rflectGAs.

a sign~ifcant les of .pet fuel pool water inventery and thus it is also a precursor to lss of the ability, to adequately Goo! the irradiated fu~el asse-mblesA stor-ed 4n the pol 1=b~!tt0 .3 ... 0"H-101'9 3 Deve~opr-Notes)... ... .............

\ .......Basis Reference(s):

1. NEI 99-01 Rev 6, AA2 2. UFSAR 11.5.2.2.6, 11.5.2.2.7, 15.7.4, Table 12.3-3 3. Technical Specification Table 3.3-6-1 4. 1/2BwOA REFUEL-1 Fuel Handling Emergency 5.6.1I/2BwOA REFUEL-2 Refueling Cavity or Spent Fuel Pool Level Loss TRM 3.9.a, Refueling Operations, Decay Time 7. BwAR 1-1-A2, 2-1-A2, CNMT DRAIN LEAK DETECT FLOW HIGH alarm Month 20XX BW 3-15 EP-AA-1001 (Revision XX)

Rmidwnnel Annoy Rr~irwnnrlAnnAYExeIon NuceIanr RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARU2 Initiating Condition:

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

1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): (I) a. ,U^NPLANNED water level dro.p in the REFUELING PATHWAY as indicated by ANY of the folloing:i (site specific levelI indications).

b .UNPLANNED i; area radiation level- as, indi.atd by ANY of the following radiation monitors.(Site -pecif;icst of area radiation monitor)1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following: " Refueling Cavity water level < 23 ft. above the Reactor Flange (< 423 ft.indicated level).OR" Spent Fuel Pool water level < 23 ft. above the fuel (< 422 ft. 9 in.indicated level).OR" Indication or report of a drop in water level in the REFUELING PATHWAY.AND b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R1.Table R1 -Fuel Handling Incident Radiation Monitors" Fuel Building Fuel Handling Incident Monitor ORE-AR055" Fuel Building Fuel Handling Incident Monitor ORE-AR056" Containment Fuel Handling Incident Monitor 1/2RE-AR01 1" Containment Fuel Handling Incident Monitor 1/2RE-AR012 Month 20XX BW 3-16 EP-AA-1001 (Revision XX)

Rrnirlwnnrl Annoy P::v,mlenn khme-laahr RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS UNPLANNED:

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

The cause of the parameter change or event may be known or unknown.REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.This IC addresses a deerease-loss in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.A water level deGrease-loss will be primarily determined by indications from available level instrumentation.

Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available) or from any other temporarily installed monitoring instrumentation.

A significant drop in the water level may also cause ao i*,Geaserise in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered.

For example, a refueling bridge area radiation monitor reading may iPeaeerise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly.

Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RAA2.Basis Reference(s):

1. NEI 99-01 Rev 6, AU2 2. Technical Specifications 3.7.14 3. UFSAR 11.5.2.2.6, 11.5.2.2.7, 15.7.4, Table 12.3-3 4. 1/2BwOA REFUEL-1 Fuel Handling Emergency 5. 1/2BwOA REFUEL-2 Refueling Cavity or Spent Fuel Pool Level Loss 6. 1/2BwOSR 0.1-6 Unit One(Two) Mode 6 Shiftly and Daily Operating Surveillance

7. BwOP RH-8 Filling the Reactor Cavity for Refueling 8. BwOP RH-9 Pump Down of the Reactor Cavity to the RWSTs 9. BwOP RC-4 Reactor Coolant System Drain 10. BwAR 1-6-C3 REFUELING CAVITY LVL HIGH LOW Month 20XX BW 3-17 EP-AA-1001 (Revision XX)

Brairlwnnd Annex Exelon Nucla~r RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 11. BwAR 1-1-Cl SPENT FUEL PIT LEVEL HIGH LOW Month 20XX BW 3-18 EP-AA-1001 (Revision XX)

Prairlwnrri Annoy P:valnn RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARA3 I Initiating Condition:

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

1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): Note: If the equipment in the listed-room or area listed in Table R3 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted HN' r+ r+r k , m krr kVrfk dI~ am r eas,-r~*/

W --~ * ~ .-SS I W IVIIVllII IV HI VHVI" Cntrol Room" Central Alarmn Statio I 614 A\n uNi L'AINrE event resulis in Faaito 16ei Mant WRoDi!i or impoac acccessto% I Iýýt& ^f+ký rlýr%+ ^r ftrmft&-(sitA AsAPcific list of nlant rooms or AreAA With entry related mode annliabilibf

.... .. ir-- --------------... .. ..... ...... ...r,-.... jr 1. Dose rate g-eater--thaR>

15 mR/hr in ANY of the following Table R2 areas: Table R2 Areas Requiring Continuous Occupancy* Main Control Room -1/2RE-AR010" Central Alarm Station -(by survey)OR Month 20XX BW 3-19 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to any of the following Table R3 plant rooms or areas: Table R3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Auxiliary Building*

Mode 4, 5 and 6*Areas required to establish shutdown cooling Basis: UNPLANNED:

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

The cause of the parameter change or event may be known or unknown.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedurelmaintain n.ormal plant operation, Or to prform --a normal plant cooldown and shutdown.

As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the increased radiation levels and determine if another IC may be applicable.

Table R3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown.

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

Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including the Control Room.For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the elevated radiation levels preclude the ability to place shutdown cooling in serviceat the time Of the elevated radiation le e. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding beyond that required by procedure, requiring use of non-routine protective equipment, requesting an Month 20XX BW 3-20 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS extension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation ii=,aserise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.* The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category RA, C or F ICs.Basis Reference(s):

1. NEI 99-01 Rev 6, AA3 2. UFSAR Chapter 3.02, UFSAR Table 3.2-1 Month 20XX BW 3-21 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS SRU3 Initiating Condition:

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

1,2,3,4 Emergency Action Level (EAL): (1) (Site specific radiation monitor) reading greater than (site specific value)-.(2) Sample analysis indicats that a reacr... coo..lant activity value is greater than an allowable limit spocified in Tec-hnical Specifications.

1. Gross Failed Fuel Monitor 1/2RE-PRO06 indicating 1-135 concentration

> 5 uCilcc.OR 2. Sample analysis indicates that: a. Dose Equivalent 1-131 specific coolant activity > 60.0 uCi/gm.OR b. Dose Equivalent XE-1 33 specific coolant activity > 603.0 uCilgm.Basis: This IC addresses a reactor coolant activity value that exceeds an allowable limit specified in Technical Specifications.

This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant.Conditions that cause the specified monitor to alarm that are not related to fuel clad degradation should not result in the declaration of an Unusual Event.This EAL addresses site-specific radiation monitor readings that provide indication of a degradation of fuel clad integrity.

An Unusual Event is only warranted when actual fuel clad damage is the cause of the elevated coolant sample activity (as determined by laboratory confirmation).

Fuel clad damage should be assumed to be the cause of elevated Reactor Coolant activity unless another cause is known.Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category RA ICs.Month 20XX BW 3-22 EP-AA-1001 (Revision XX)

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

1. NEI 99-01 Rev 6, SU3 2. Technical Specifications 3.4.16 3. 1/2BwOA PRI-4, High Reactor Coolant Activity Unit 1/2 4. PWR Letdown Rad Monitor Setpoint Calculation for Degraded Fuel Indication Month 20XX BW 3-23 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FG1 initiating Condition:

Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL): Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis: Fuel Cladding, RCS and Containment comprise the fission product barriers.At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX BW 3-24 EP-AA-1001 (Revision XX)

I=xAInn N r Br~aidwnnrI Annex~ ExeIon Nuclehar RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FS1 Initiating Condition:

Loss or Potential Loss of ANY two barriers.Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL): Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis: Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX BW 3-25 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nucla~r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FA1 Initiating Condition:

ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL)-Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis: Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Alert classification level, Fuel Cladding and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability.

Note that the loss or potential loss of Containment barrier in combination with loss or potential loss of either Fuel Cladding or RCS barrier results in declaration of a Site Area Emergency under EAL FS1.Basis Reference(s):

" 1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX BW 3-26 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC1 Initiating Condition:

RCS or SG Tube Leakage Operating Mode Applicability:

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

POTENTIAL LOSS.; .,-I, ,-Cor.

PCaIth conditionstol

-Vex!it;.Core Cooling CFSCSF-Orange Path conditions exist Basis: There is no Loss threshold associated with RCS or SG Tube Leakage.Potential Loss Threshold Basis Core Cooling -ORANGE indicates subcooling has been lost and that some clad damage may occur.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 2. 1/2BwFR-C.2 Response to Degraded Core Cooling Month 20XX BW 3-27 EP-AA-1001 (Revision XX) roirJuvr%~4 Anngkv i::nlonn Nnnlmha~r r~ iI~nu~j~rI A ii nay Fyc Inn Mm.vIa~r~. n.~ ~ S-'*I EU Efl ....... flu uu.RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 Initiating Condition:

Inadequate Heat Removal Operating Mode Applicability:

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

LOSS A. Coro Exit TheFrmocouple readings greater than (site specific temAperature value)1. Core-Cooling CSF- Red Path conditions exist.Potential Loss A 1' ra.r a.A.4 *karr~ne%

.* ni L aei nnn n c n rgnq+4 r 4k ' rk ig~a ep. i *~mf n , ta niamtran im ij ai fltL LUUUI

• IUU U --- -----B3. inadequate RCS heat remeyal capability via steam generators as indicsated by (site specific niaGn)2. Core Cooling CSF-Orange Path conditions exist.OR 3. Heat Sink CSF- Red Path conditions exist.Basis: Loss Threshold

1. 1 Basis Less-2Le This leadiindicates temperatures within the core are sufficient to cause significant superheating of reactor coolant.Core Cooling -RED indicates significant superheating and core uncovery and is considered to indicate loss of the Fuel Clad Barrier.Potential Loss Threshold

1. 2 Basis PeteRntial 2.A This leadkVg1ndicates temperatures within the core are sufficient to allow the onset of heat-induced cladding damage.Core Cooling -ORANGE indicates subcooling has been lost and that some clad damage may occur.Potential Loss Threshold

1. 3 Basis Potential Loss 2.This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier. The Heat Sink Critical Safety Month 20XX BW 3-28 EP-AA-1001 (Revision XX)

PrýirluutwA Annav IFwalnn knelolar Rrhnwu~,4 A nn~v Fv.inn M..s1a2r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Function Red path condition exists if narrow range levels in all steam generators (S/Gs)are less than or equal to 10% -Unit 1 (31% adverse containment) and 14% -Unit 2 (34% adverse containment) and total feedwater flow to all S/Gs is less than or equal to 500 gpm. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators by reducing total feed flow to less than 500 gpm; during these conditions, classification using threshold is not warranted.

Meeting this threshold results in a Site Area Emergency because this threshold is identical to RCS Barrier RC 2 Potential Loss threshold 2-A; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and RCS pressure to the point where mass will be lost from the system.Heat Sink -RED when heat sink is required indicates the ultimate heat sink function is under extreme challenge.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 2. 1/2BwFR-C.1 Response to Inadequate Core Cooling 3. 1/2BwFR-C.2 Response to Degraded Core Cooling 4. 1/2BwST-3 Heat Sink Month 20XX BW 3-29 EP-AA-1001 (Revision XX)

A r~ imiiuu^~ An.iuiv I:,vn-Inn kNm-la~r~E U5~I ~ I~~E II U~*~ ~ .~RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC3 Initiating Condition:

Containment Radiation

/ RCS Activity Operating Mode Applicability:

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

LOSS 1A. Containment radiation monitor reading greater than (site ;pecific value)(AR020(21))

reading > 1.95E+03 R/hr.OR 29. (Site Gpecific indications that reactor coolanAt aciiy cgeate~r than 300_U~i/flm doeo equiValent 1 131) Coolant activity as sampled > 300uCilgm Dose Equivalent 1-131 Basis: Loss Threshold

1. 1 Basis Les&s&A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals 300giCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.The radiation monitor reading in this threshold is higher than that specified for RCS Barrier RC3 Loss Tthreshold

&A since it indicates a loss of both the Fuel Clad Barrier and the RCS Barrier. Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.

Loss Threshold

1. 2 Basis LG&4.4 *This threshold indicates that RCS radioactivity concentration is greater than 300 jiCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete.

Nonetheless, a sample-related threshold is included as a backup to other indications Month 20XX BW 3-30 EP-AA-1001 (Revision XX)

Braidwond Annex Exelon Nuclea~r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION There is no Potential Loss threshold associated with RCS Activity / Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 2. S&L calculation BB-ER-02, Rev 0 3. Core Damage Assessment Methodology (CDAM)Month 20XX BW 3-31 EP-AA-1001 (Revision XX)

Prnirluunewi Annmv 1=vgsJrn khor-lAmar Rr~irI~.,i~r.,I A nn~v FvMr~n kIu.r~Ia~r 5 ~ s~. EU ES S** *RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC56 Initiating Condition:

Emergency Director Judgment.Operating Mode Applicability:

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

LOSS 1A. Any condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.POTENTIAL LOSS 2A. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.Basis: Loss Threshold

1. 1 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold

1. 2 Basis Potential Loss-".This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX BW 3-32 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RCI Initiating Condition:

RCS or SG Tube Leakage Operating Mode Applicability:

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

LOSSAautomatic or manual EGGS-(SI) actuation is required by EITHER of the following:

a4. UNISOLABLE RCS leakage OR b2. Steam Generator tube RUPTURE.POTENTIAL LOSS R.-2. The capacity of one charging pump in the normal charging mode is exceeded due to EITHER of the following:

Ope.atin of a sta-dby charging (makeup) pump required by EITHER of the feIllemng a4. UNISOLABLE RCS leakage OR b2. Steam Generator tube-eakage tube RUPTURE.I OR I.-1 Al- -I -I- -I-. rr~~F ~ir*~f~rm~*r'1

.*F* -~-.-~...-

w. ** *-** '-..- -I-VI ~.-. ..- ~. ......... ...... ... .. .... .....-.....-. ....r, -SE m 3. RCS Integrity CSF- Red Path eR" conditions metexist.Month 20XX BW 3-33 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Basis: UNISOLABLE:

An open or breached system line that cannot be isolated, remotely or locally.RUPTURE(D):

The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

Loss Threshold

1. 1 Basis This threshold is based on an UNISOLABLE RCS leak of sufficient size to require an automatic or manual actuation of the Emergency Core Cooling System (ECCS). This condition clearly represents a loss of the RCS Barrier.This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location -inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

A steam generator with primary-to-secondary leakage of sufficient magnitude to require a safety injection is considered to be RUPTURED.

If a RUPTURED steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier CT1 Loss threshold l-.A-will also be met.Potential Loss Threshold

1. 2 Basis Lo I .A This threshold is based on an UNISOLABLE RCS leak that results in the inability to maintain pressurizer level within specified limits by operation of a normally used charging (makeup) pump, but an ECCS (SI) actuation has not occurred.

The threshold is met when an operating procedure, or operating crew supervision, directs that a standby charging (makeup) pump be placed in service to restore and maintain pressurizer level.This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location -inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

Month 20XX BW 3-34 EP-AA-1001 (Revision XX)

I=xelon Rrsaidwnnd Annex Exelon ucle~ar RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier CT1 Loss Tthreshold 4-.Awill also be met.Potont.-l Ioe , 1,.B Potential Loss Threshold

1. 3 Basis This condition indicates an extreme challenge to the integrity of the RCS pressure boundary due to pressurized thermal shock -a transient that causes rapid RCS cooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized).

RCS Integrity

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

1. NEI 99-01 Rev 6, Table 9-F-3 2. 1/2BwST-4 Integrity 3. 1/2BwEP-3 Steam Generator Tube Rupture Month 20XX BW 3-35 EP-AA-1001 (Revision XX) rnidwnnd Annoy FyAInn N.nln=ar Rr2 ilwnnl Ann~Y xpinn Nucleamr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC2 Initiating Condition:

Inadequate Heat Removal Operating Mode Applicability:

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

POTENTIAL LOSS A. Inadequate RCS heat removal capabilit' via steam generatos as by (Site specific indications)

Heat Sink CSF- Red Path eptf conditions existmet.Basis: There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold Basis Potential Lows 2A Heat Sink -RED when heat sink is required indicates the ultimate heat sink function is under extreme challenge.

This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier. The Heat Sink Critical Safety Function Red path condition exists if narrow range levels in all steam generators (S/Gs) are less than or equal to 10% -Unit 1 (31% adverse containment) and 14% -Unit 2 (34%adverse containment) and total feedwater flow to all S/Gs is less than or equal to 500 gpm. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators by reducing total feed flow to less than 500 gpm; during these conditions, classification using threshold is not warranted.

Meeting this threshold results in a Site Area Emergency because this threshold is identical to Fuel Clad Barrier FC2 Potential Loss threshold 2-.9#3; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and IiPGFeaserise RCS pressure to the point where mass will be lost from the system.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 2. 1/2BwST-3 Heat Sink Month 20XX BW 3-36 EP-AA-1001 (Revision XX)

Rraidwnnd Anne~x Exelon NuclIear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC3 Initiating Condition:

Containment Radiation

/ RCS Activity Operating Mode Applicability:

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

LOSS A. Containment radiation monitor reading g.e. ter than (AR020(21))

reading > 25 R/hr.(site specific Value).Basis: Loss Threshold Basis The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier FC3 Loss Tthreshold

1. 13-.A since it indicates a loss of the RCS Barrier only.There is no Potential Loss threshold associated with RCS Activity / Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 2. Core Damage Assessment Methodology (CDAM)Month 20XX BW 3-37 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC56 Initiating Condition:

Emergency Director Judgment.Operating Mode Applicability:

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

LOSS 1A. Any condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.POTENTIAL LOSS 28. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Basis: Loss Threshold

1. 1 Basis LOess-6G This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is lost.Potential Loss Threshold

1. 2 Basis PItcntial Lss -6 .This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX BW 3-38 EP-AA-1001 (Revision XX) r!miAwerr1 Annov Fvalnn Nn :-la_=r Rr~iMr,,~r A nnav Fv~Inn M.ir~I~r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT1 Initiating Condition:

RCS or SG Tube Leakage Operating Mode Applicability:

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

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

Basis: RUPTURE(D):

The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

Loss Threshoý, 'Rasis Lgoss-4.AL This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAULTED outside of containment.

The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the thresholds for RCS Barrier RC1 Potential Loss Threshold 2.b 4-A and Loss Threshold 1 .b-A, respectively.

This condition represents a bypass of the containment barrier.FAULTED is a defined term within the NEI 99-01 methodology; this determination is not necessarily dependent upon entry into, or diagnostic steps within, an EOP. For example, if the pressure in a steam generator is decreasing uncontrollably

[part of the FAULTED definition]

and the faulted steam generator isolation procedure is not entered because EOP user rules are dictating implementation of another procedure to address a higher priority condition, the steam generator is still considered FAULTED for emergency classification purposes.The FAULTED criterion establishes an appropriate lower bound on the size of a steam release that may require an emergency classification.

Steam releases of this size are readily observable with normal Control Room indications.

The lower bound for this aspect of the containment barrier is analogous to the lower bound criteria specified in IC RSU3 for the fuel clad barrier (i.e., RCS activity values) and IC MSU64 for the RCS barrier (i.e., RCS leak rate values).This threshold also applies to prolonged steam releases necessitated by operational considerations such as the forced steaming of a leaking or RUPTURED steam generator directly to atmosphere to cooldown the plant, or to drive an auxiliary (emergency) feed water pump. These types of conditions will result in a significant and Month 20XX BW 3-39 EP-AA-1001 (Revision XX) rft!AuufoA Annwv F::n-len khielanr Rr~ ik.uf~,I A miaw Fvn inn IJmiiIa~r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION sustained release of radioactive steam to the environment (and are thus similar to a FAULTED condition).

The inability to isolate the steam flow without an adverse effect on plant cooldown meets the intent of a loss of containment.

Steam releases associated with the expected operation of a SG power operated relief valve or safety relief valve do not meet the intent of this threshold.

Such releases may occur intermittently for a short period of time following a reactor trip as operators process through emergency operating procedures to bring the plant to a stable condition and prepare to initiate a plant cooldown.

Steam releases associated with the unexpected operation of a valve (e.g., a stuck-open safety valve) do meet this threshold.

Following an SG tube leak or rupture, there may be minor radiological releases through a secondary-side system component (e.g., air ejectors, glad seal exhausters, valve packing, etc.). These types of releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category RA ICs.The emergency classification levels resulting from primary-to-secondary leakage, with or without a steam release from the FAULTED SG, are summarized below.Affected SG is FAULTED Outside of Containment?

Primary-to-Secondary Yes No Leak Rate Less than or equal to 25 No classification No classification gpm (Or other value per SU4 Developer Notes), Greater than 25 gpm (of Unusual Event per Unusual Event per other value per SU4 SU4MU6 SU4MU6 DevelepeF N~ets)The capacity of one charging pump in the normal charging mode is Site Area Emergency Alert per FA1 exceeded Ree per FS1A ope~~atiepe Ffastnb charging (makeup) pump (RCS Barrier Potential Loss)Requires an automatic or Site Area Emergency Alert per FA1 manual EGGS (Sl) actuation per FS1 (RCS Barrier Loss)Month 20XX BW 3-40 EP-AA-1001 (Revision XX)

Braidwood Annex Exellon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION There is no Potential Loss threshold associated with RCS or SG Tube Leakage.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 2. I/2BwEP-3 Steam Generator Tube Rupture 3. 1/2BwEP-0 Reactor Trip or Safety Injection Unit 1/2 Month 20XX BW 3-41 EP-AA-1001 (Revision XX)

~rniIwanrw A nnov IFyalnn RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT2 Initiating Condition:

Inadequate Heat Removal Operating Mode Applicability:

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

POTENTIAL LOSS A. 1. (Site sepoific criter-iR for enAtry into core cooling restoration prOcedurc)

AND 2. Retoration prcedure nt ie minutes.Core-Cooling CSF- Red Path conditions exist AND Functional Restoration procedures not effective in < 15 minutes.Basis: IMMINENT:

The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold Basis Poetcnial Ls' 2A This condition represents an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure. For this condition to occur, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. If implementation of a procedure(s) to restore adequate core cooling is not effective (successful) within 15 minutes, it is assumed that the event trajectory will likely lead to core melting and a subsequent challenge of the Containment Barrier.The restoration procedure is considered "effective" if core exit thermocouple readings are decreasing and/or if reactor vessel level is increasing.

Whether or not the procedure(s) will be effective should be apparent within 15 minutes. The Emergency Director should escalate the emergency classification level as soon as it is determined that the procedure(s) will not be effective.

Severe accident analyses (e.g., NUREG-1 150) have concluded that function restoration procedures can arrest core degradation in a significant fraction of core damage scenarios, and that the likelihood of containment failure is very small in these events.Given this, it is appropriate to provide 15 minutes beyond the required entry point to determine if procedural actions can reverse the core melt sequence.Month 20XX BW 3-42 EP-AA-1001 (Revision XX)

Rrmielwennr4 A nnoyr Fx-iminn Nly-lo-yr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):-

.. .. _ ... .. .-..-1. NEI 99-01 Rev 6, Table 9-F-3 2. 1/2BwFR-C.1 Response to Inadequate Core Cooling 3. I/2BwST-2 Core Cooling Month 20XX BW 3-43 EP-AA-1001 (Revision XX)

Rrnidwnnrl A nnay Exeinn Nne-h-ar RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 Initiating Condition:

Containment Radiation

/ RCS Activity Operating Mode Applicability:

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

POTENTIAL LOSS AX Containment radiation monitor reading greater than (AR020(21))

reading > 4.40E+03 R/hr.(rcite specific value).Basis: There is no Loss threshold associated with RCS Activity / Containment Radiation.

Potential Loss Threshold Basis Potential Loss 3BA The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that 20% of the fuel cladding has failed.This level of fuel clad failure is well above that used to determine the analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds.

NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately 20%in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the emergency classification level to a General Emergency.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 2. Core Damage Assessment Methodology (CDAM)Month 20XX BW 3-44 EP-AA-1001 (Revision XX)

Rrmir1mwo%#%A Anngv IFvglnn hint-loar~ruIwn~r~,4 A nn~v Fvgi inn Mmmr~I~2r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 Initiating Condition:

Containment Integrity or Bypass Operating Mode Applicability:

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

LOSS 1A. Containment isolation is required AND EITHER of the following:

a4. UNPLANNED deGIease-lowering in containment pressure or rise in radiation monitor readings outside of containment in the Emergency Directors judgment that indicate a loss of containment integrity.

OR b2-. UNISOLABLE pathway from containment to the environment exists.OR 28. Indication of RCS leakage outside of containment POTENTIAL LOSS 3A. Containment CSF Red Path ey conditions metexist OR 41.. Explosive .ni....e exists in.ide "'tainment.

Hydrogen Concentration in Containment

> 5%.OR 5G. a4-. Containment pressure greater than (site epecifc prFe...ure .etp..-t;*

20 psig AND b2-. Less than one full train of (site specific sy;tem or "c....e÷\Containment Spray is operating per design for >15 minutesI .Basis: FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

UNISOLABLE:

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

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

The cause of the parameter change or event may be known or unknown.LossThreshold

1. 1 Basis: Less-4" Month 20XX BW 3-45 EP-AA-1001 (Revision XX) rimirluv~%A Annmir I=vgslnn Mid"Aanr A nhtaw Fv~Inn IJ..wIc~r~. eu~ ~ 5-~5 Ii E~S~ ~st~ .... .U -~RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION These thresholds address a situation where containment isolation is required and one of two conditions exists as discussed below. Users are reminded that there may be accident and release conditions that simultaneously meet both loss thresholds 1 .a4.A-.and 1.b4,A4.1 .a4-A-A -Containment integrity has been lost, i.e., the actual containment atmospheric leak rate likely exceeds that associated with allowable leakage (or sometimes referred to as design leakage).

Following the release of RCS mass into containment, containment pressure will fluctuate based on a variety of factors; a loss of containment integrity condition may (or may not) be accompanied by a noticeable drop in containment pressure.

Recognizing the inherent difficulties in determining a containment leak rate during accident conditions, it is expected that the Emergency Director will assess this threshold using judgment, and with due consideration given to current plant conditions, and available operational and radiological data (e.g., containment pressure, readings on radiation monitors outside containment, operating status of containment pressure control equipment, etc.).Refer to the middle piping run of Figure 9-F-4. Two simplified examples are provided.One is leakage from a penetration and the other is leakage from an in-service system valve. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure.Another example would be a loss or potential loss of the RCS barrier, and the simultaneous occurrence of two FAULTED locations on a steam generator where one fault is located inside containment (e.g., on a steam or feedwater line) and the other outside of containment.

In this case, the associated steam line provides a pathway for the containment atmosphere to escape to an area outside the containment.

Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design)containment leakage through various penetrations or system components.

These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category RA ICs.1.b4A-2 -Conditions are such that there is an UNISOLABLE pathway for the migration of radioactive material from the containment atmosphere to the environment.

As used here, the term "environment" includes the atmosphere of a room or area, outside the containment, that may, in turn, communicate with the outside-the-plant atmosphere (e.g., through discharge of a ventilation system or atmospheric leakage).

Depending upon a variety of factors, this condition may or may not be accompanied by a noticeable drop in containment pressure.Refer to the top piping run of Figure 9-F-4. In this simplified example, the inboard and outboard isolation valves remained open after a containment isolation was required (i.e., containment isolation was not successful).

There is now an UNISOLABLE pathway from the containment to the environment.

Month 20XX BW 3-46 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION The existence of a filter is not considered in the threshold assessment.

Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.Leakage between two interfacing liquid systems, by itself, does not meet this threshold.

Refer to the bottom piping run of Figure 9-F-4. In this simplified example, leakage in an RCP seal cooler is allowing radioactive material to enter the Auxiliary Building.

The radioactivity would be detected by the Process Monitor. If there is no leakage from the closed water cooling system to the Auxiliary Building, then no threshold has been met.If the pump or system piping developed a leak that allowed steam/water to enter the Auxiliary Building, then loss threshold 24-.B would be met. Depending upon radiation monitor locations and sensitivities, this leakage could be detected by any of the four monitors depicted in the figure and cause threshold 1.a4.A to be met as well.Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design)containment leakage through various penetrations or system components.

Minor releases may also occur if a containment isolation valve(s) fails to close but the containment atmosphere escapes to a closed system. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category RA ICs.The status of the containment barrier during an event involving steam generator tube leakage is assessed using Containment Barrier CT1 Loss Threshold4-A.

Loss Threshold

1. 2 Basis: Loss,-413 Containment sump, temperature, pressure and/or radiation levels will kioFeaserise if reactor coolant mass is leaking into the containment.

If these parameters have not increased, then the reactor coolant mass may be leaking outside of containment (i.e., a containment bypass sequence).

klr-easeRises in sump, temperature, pressure, flow and/or radiation level readings outside of the containment may indicate that the RCS mass is being lost outside of containment.

Unexpected elevated readings and alarms on radiation monitors with detectors outside containment should be corroborated with other available indications to confirm that the source is a loss of RCS mass outside of containment.

If the fuel clad barrier has not been lost, radiation monitor readings outside of containment may not iFieaserise significantly; however, other unexpected changes in sump levels, area temperatures or pressures, flow rates, etc. should be sufficient to determine if RCS mass is being lost outside of the containment.

Refer to the middle piping run of Figure 9-F-4. In this simplified example, a leak has occurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building.Month 20XX BW 3-47 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause loss threshold 1 .a4-A-. to be met as well.To ensure proper escalation of the emergency classification, the RCS leakage outside of containment must be related to the mass loss that is causing the RCS Barrier RC1 Loss Threshold 1.a and/or Potential Loss threshold 2.al-1A to be met.Potential Loss Threshold

1. 3 Basiso A I .Containment CSF RED path indicates an extreme challenge to the safety function derived from appropriate instrument readings and/or sampling results, and thus represents a potential loss of containment.

If containment pressure exceeds the design pressure, there exists a potential to lose the Containment Barrier. To reach this level, there must be an inadequate core cooling condition for an extended period of time; therefore, the RCS and Fuel Clad barriers would already be lost. Thus, this threshold is a discriminator between a Site Area Emergency and General Emergency since there is now a potential to lose the third barrier.Potential Loss Threshold

1. 4 Basis Potential Los&-4-.B The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity.

It therefore represents a potential loss of the Containment Barrier.Potential Loss Threshold

1. 5 Basis Potontial LocsI4e.-This threshold describes a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible.

This threshold represents a potential loss of containment in that containment heat removal/depressurization systems (e.g., containment sprays, ice condenser fans, etc., but not including containment venting strategies) are either lost or performing in a degraded manner Month 20XX BW 3-48 EP-AA-1001 (Revision XX)

Braidwood Annex Braidwod AnnxEFYAon NucleIar RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):

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

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

BRW-99-0017-1

4. Technical Specifications B 3.6.6, Containment Spray and Cooling Systems 5. 1I/2BwST-5 Containment

6. 1I/2BwFR-Z.1 Response to High Containment Pressure Month 20XX BW 3-49 EP-AA-1001 (Revision XX)

Rrjir1wnm1LAnnaY FYP-Inmh.M1ijr-Iaar RECOGNITI06TEGORY FISSION PRODUCT BARRIER DEGRADATION Figure 9-F-4: PWR Containment Integrity or Bypass Examples oo,. ~ 4.Ar1.b -Effluent:Airborne release*Effluent~l Inside afrom pathway Cntine Auxiliary Building tVent ...Containment

---

enreraeeao Damper leakage-..* .*.i .... ...t r Open valve Open valve Pump-System Damper 4-A4. -Penetration reasfom Sealv CAirborne i_,Monitor.

Open valve Open valve 'l2-RC* 4A-1-1.a -'-lekg Intefac leakag ...as leakage: Inerac lakge.

CNMT K ~ ~~~penetration .Prcsi i~~~Monitor , --- --Cooling Water Open valve Open valve Pump System RCP Sea[Cooling Month 20XX BW 3-50 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT56 Initiating Condition:

Emergency Director Judgment.Operating Mode Applicability:

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

LOSS 1A. Any condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.POTENTIAL LOSS 2B. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Basis: Loss Threshold

1. 1 Basis Less-"A This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is lost.Potential Loss Threshold

1. 2 Basis=ntial 6.A This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1 .NEI 99-01 Rev 6, Table 9-F-3 Month 20XX BW 3-51 EP-AA-1001 (Revision XX)

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~E E~IWW~~~A 5'~U II ~ S~*~*R * ~RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSGI Initiating Condition:

Prolonged loss of all Off-site and all On-Site AC power to emergency bujeesbuses.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded..The Em:Fergency Director should declare the General E~mergency promptly upon determining that (site specifc hourS) has been exceeded, Or Will likely be eXGeeded.1-a. Loss of ALL offsite and- A.L' -nsito AC power to (site specific. buses)unit ESF buses.AND 2. Failure of DG 1A(2A) and DG 11B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3b. EITHER of the following:

a. Restoration of at least one ESF bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is notless than (site specif.c hour.) is not likely.OR b. Core Cooling CSF -Red Path conditions exist (Site spei;fic indiratin of an inabilit' to adequately remove heat from the cre)'Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a prolonged loss of all power sources to AC emergency buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring Month 20XX BW 3-52 EP-AA-1001 (Revision XX) i~lanr~l Rrirlwnnrl AnnaY vnnMurI2 RECOGNITION CATEGORY SYSTEM MALFUNCTIONS electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A prolonged loss of these buses will lead to a loss of ono Or moreany fission product barriers.

In addition, fission product barrier monitoring capabilities may be degraded under these conditions.

The EAL should require declaration of a General Emergency prior to meeting the thresholds for IC FG1. This will allow additional time for implementation of offsite protective actions.Escalation of the emergency classification from Site Area Emergency will occur if it is projected that power cannot be restored to at least one AC emergency bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and event trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers.The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation.

Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public.The emergency buses of the affected unit can be powered from the unaffected unit through the crosstie breakers.

Unit crosstie is considered an adequate source of offsite power when evaluating this EAL.The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.Basis Reference(s):

1. NEI 99-01 Rev 6, SG1 2. 20E-0-4001 Station One Line Diagram 3. UFSAR 8.3.1 4. 1/2BwOA ELEC-3 Loss Of 4KV ESF Bus 5. I/2BwOA ELEC-4 Loss Of Offsite Power Unit 1/2 6. I/2BwCA-0.0 Loss Of All AC Power Unit 1/2 7. I/2BwCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/2 8. 1/2BwCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/2 9. 1/2BwCA-0.3 Response To Opposite Unit Loss Of All AC Power 10. BwOP AP-37 Unit Two SAT Crosstie To Unit One ESF Bus 11. BwOP AP-38, Unit One SAT Crosstie To Unit Two ESF Bus 12. Safety Evaluations of the Byron Station and Braidwood Station Responses to the Station Blackout (SBO) Rule (TAC NOS. 68522, 68523 AND 68515, 68516)Month 20XX BW 3-53 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS

13. 1/2BwST-2 Core Cooling 14. 1/2BwFR-C.1 Response to Inadequate Core Cooling 15. 1/2BwFR-C.2 Response to Degraded Core Cooling Month 20XX BW 3-54 EP-AA-1001 (Revision XX)

Nuclear Rraidwnnd Annex Exeoln Nulearil RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS1 Initiating Condition:

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

1,2,3,4 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded..The Emergency Director should declare the Site Area Emergency promptly upon determininig that 15 mninutes has been exreeded, or will likely be exceeded.1. Loss of ALL offsite and ALL AC Power to (site specifc busc.)unit ESF buses for 15 minutes '"or long.AND 2. Failure of DG 1A(2A) and DG 11B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3. Failure to restore power to at least one unit ESF bus in < 15 minutes from the time of loss of both offsite and onsite AC power Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. In addition, fission product barrier monitoring capabilities may be degraded under these conditions.

This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.The emergency buses of the affected unit can be powered from the unaffected unit through the crosstie breakers.

Unit crosstie is considered an adequate source of offsite power when evaluating this EAL.Month 20XX BW 3-55 EP-AA-1001 (Revision XX)

C2 -%;Axjksr%#%A Anngv I:Y,-Inn N,,l,-lanr I nv~arnM jI~RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation of the emergency classification level would be via ICs RAG1, FG1 or MSGI.Basis Reference(s):

1. NEI 99-01 Rev 6, SS1 2. 20E-0-4001 Station One Line Diagram 3. UFSAR 8.3.1 4. 1/2BwOA ELEC-3 Loss Of 4KV ESF Bus 5. 1/2BwOA ELEC-4 Loss Of Offsite Power Unit 1/2 6. 1/2BwCA-0.0 Loss Of All AC Power Unit 1/2 7. 1/2BwCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/2 8. I/2BwCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/2 9. I/2BwCA-0.3 Response To Opposite Unit Loss Of All AC Power 10. BwOP AP-37 Unit Two SAT Crosstie To Unit One ESF Bus 11. BwOP AP-38, Unit One SAT Crosstie To Unit Two ESF Bus 12. Safety Evaluations of the Byron Station and Braidwood Station Responses to the Station Blackout (SBO) Rule (TAC NOS. 68522, 68523 AND 68515, 68516)Month 20XX BW 3-56 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSAlI Initiating Condition:

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

1,2,3,4 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded..T-he Emergencay DiFrctor should decl!are the Aleot promptly upon determ~ining that1 minutes has been exeeded, Or Will likely be ., 1. AC power capability to unit ESF buses reduced to only one of the following power sources for > 15 minutes.* Affected unit SAT 142-1(242-1)

• Affected unit SAT 142-2(242-2)

• Emergency Diesel Generator DG 1A(2A)* Emergency Diesel Generator DG 11B(2B)* Unit crosstie breakers a. AG power capability to (site specific mergeFency buses) is reduced to a single.poWer source for 15 m~inutes Or longer.AND 2b. Any additional single power source failure will result in a loss of ALLa# AC power to SAFETY SYSTEMS.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.

This IC provides an escalation path from IC MgUI.An "AC power source" is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.Month 20XX BW 3-57 EP-AA-1001 (Revision XX)

Rmidwnnel Annoy I=yAInn NunlAar Rr~iewnnrlA nnExFYAon Nuledazr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS" A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator)." A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from the unit main generator." A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.Escalation of the emergency classification level would be via IC MSS1.Basis Reference(s):

1. NEI 99-01 Rev 6, SA1 2. 20E-0-4001 Station One Line Diagram 3. UFSAR 8.3.1 4. 1/2BwOA ELEC-3 Loss Of 4KV ESF Bus 5. 1/2BwOA ELEC-4 Loss Of Offsite Power Unit 1/2 6. 1/2BwCA-0.0 Loss Of All AC Power Unit 1/2 7. 1/2BwCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/2 8. I/2BwCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/2 9. 1/2BwCA-0.3 Response To Opposite Unit Loss Of All AC Power 10. BwOP AP-37 Unit Two SAT Crosstie To Unit One ESF Bus 11. BwOP AP-38, Unit One SAT Crosstie To Unit Two ESF Bus 12. Safety Evaluations of the Byron Station and Braidwood Station Responses to the Station Blackout (SBO) Rule (TAC NOS. 68522, 68523 AND 68515, 68516)Month 20XX BW 3-58 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSUl Initiating Condition:

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

1,2,3,4 Emergency Action Level (EAL):-Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.The EmF.ergency DireGtor should declare the Unusua! Event promptl upon deter~mining that 15 minutes has been eXcooded, Or Will likely be exc-eeded 4--.Loss of ALL offsite AC power capability to unit ESF buses (cite Specific emF"ereny buIee,)-for

> 15 minutes OF IGRge .Basis: This IC addresses a prolonged loss of offsite power. The loss of offsite power sources renders the plant more vulnerable to a complete loss of power to AC emergency buses.This condition represents a potential reduction in the level of safety of the plant.For emergency classification purposes, "capability" means that an offsite AC power source(s) is available to the emergency buses, whether or not the buses are powered from it. (e.g. unit cross-tie breakers)The emergency buses of the affected unit can be powered from the unaffected unit through the crosstie breakers.

Unit crosstie is considered an adequate source of offsite power when evaluating this EAL.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power.Escalation of the emergency classification level would be via IC MsAI.Basis Reference(s):

1. NEI 99-01 Rev 6, SU1 2. 20E-0-4001 Station One Line Diagram 3. UFSAR 8.3.1 4. 1/2BwOA ELEC-3 Loss Of 4KV ESF Bus 5. 1/2BwOA ELEC-4 Loss Of Offsite Power Unit 1/2 6. I/2BwCA-0.0 Loss Of All AC Power Unit 1/2 7. 1/2BwCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/2 8. 1/2BwCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/2 9. I/2BwCA-0.3 Response To Opposite Unit Loss Of All AC Power Month 20XX BW 3-59 EP-AA-1001 (Revision XX)

Primirlim,^~1 Annimv I=v,-In~n N.r-l--mr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS

10. BwOP AP-37 Unit Two SAT Crosstie To Unit One ESF Bus 11. BwOP AP-38, Unit One SAT Crosstie To Unit Two ESF Bus Month 20XX BW 3-60 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSG281 Initiating Condition:

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

1,2,3,4 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.The

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a' v 1. Loss of ALL offsite AC power to unit ESF buses.AND 2. Failure of DG 1A(2A) and DG 11B(2B) emergency diesel generators to supply power to unit ESF buses.AND 3. Voltage is < 108 VDC on unit 125 VDC battery buses 111(211) and 112(212).AND 4. ALL AC and Vital DC power sources have been lost for > 15 minutes.1. a. Lose nof A.LL aand A.LL ,ensitte AC poWer to (Site Sp...fic em.ergenc bUSe,) for 45 m inutes oFr lGRger.AND b IndAic-atesid wltage is less than (rite spe-i;f bus voltage value) on ALL (site specifics Vital PG bussosbuses) for 15 minutes or longer.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

Month 20XX BW 3-61 EP-AA-1001 (Revision XX) 0r!miAuuttA Anngrv F::vgAlnn lM, nr~l~RraI~*,rhj~rI A nai~v Fvt&Ir~n khurI~ar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A loss of Vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both AC and DC power will lead to multiple challenges to fission product barriers.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. The 15-minute emergency declaration clock begins at the point when beth-all EAL conditions thFerholds are met.Basis Reference(s):

1. NEI 99-01 Rev 6, SG8 2. UFSAR 8.3.2.1.1 3. 20E-0-4001 Station One Line Diagram 4. BwAR 1/2-21-E10, 125V DC PNL 111/113(211/213)

VOLT LOW 5. 1/2BwOA ELEC 1 Loss of DC Bus UNIT 1/2 6. BwAR 1/2-22-E10, 125V DC PNL 112/114 (212/214)

VOLT LOW 7. UFSAR 8.3.1 8. 1/2BwOA ELEC-3 Loss Of 4KV ESF Bus 9. 1/2BwOA ELEC-4 Loss Of Offsite Power Unit 1/2 10. 1/2BwCA-0.0 Loss Of All AC Power Unit 1/2 11. 1/2BwCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/2 12. 1/2BwCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/2 13. 1/2BwCA-0.3 Response To Opposite Unit Loss Of All AC Power 14. BwOP AP-37 Unit Two SAT Crosstie To Unit One ESF Bus 15. BwOP AP-38, Unit One SAT Crosstie To Unit Two ESF Bus 16. Safety Evaluations of the Byron Station and Braidwood Station Responses to the Station Blackout (SBO) Rule (TAC NOS. 68522, 68523 AND 68515, 68516)17. 1/2BwST-2 Core Cooling 18. 1/2BwFR-C.1 Response to Inadequate Core Cooling 19. 1/2BwFR-C.2 Response to Degraded Core Cooling Month 20XX BW 3-62 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS28 Initiating Condition:

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

1,2,3,4 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.T-he Emnergency Director should decl-arme the Si*teA Area Emorgoncy prom~ptly upon doterminingA that 1 5 mninutes has boen oxcaeeded, Or Will likely be exceeded.

Voltage is < 108 VDC loss than (Site .pecific bur" ...ltage value) on unit 125 VDC battery buses 111(211) and 112(212)ALL (site specific Vital D, bIusesbuses) for >15 minutes-er-OeF&.

Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a loss of Vital DC power which compromises the ability to monitor and control SAFETY SYSTEMS. In modes above Cold Shutdown, this condition involves a major failure of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation of the emergency classification level would be via ICs RAG1, FG1 or MSG38.Basis Reference(s):

1. NEI 99-01 Rev 6, SS8 2. UFSAR 8.3.2.1.1 3. 20E-0-4001 Station One Line Diagram 4. BwAR 1/2-21-E10, 125V DC PNL 111/113(211/213)

VOLT LOW 5. 1/2BwOA ELEC 1 Loss of DC Bus UNIT 1/2 6. BwAR 1/2-22-E10, 125V DC PNL 112/114 (212/214)

VOLT LOW Month 20XX BW 3-63 EP-AA-1001 (Revision XX)

Braidwood Annex Exellon Nuclear Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS361 Initiating Condition:

Inability to shutdown the reactor causing a challenge to core cooling or RCS heat removal.Operating Mode Applicability:

1,2 Emergency Action Level (EAL): 1. Automatic or Manual Ttrip did not shutdown the reactor as indicated by Reactor Power > 5%.AND 2. ALLA4 manual actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 5%.AND 3. EITHER of the following conditions exist: a. Core Cooling CSF-RED Path conditions exist.(Sito Specific, idton -t an inability to adequately Femove he-at- fromn the core)OR b. Heat Sink CSF-RED Path conditions exist.(Sit.

specific ;indi6c,;tn of an ieabi.ity to adequately romoc heat. from the R.S)Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, all subsequent operator manual actions, both inside and outside the Control Room including driving in control rods and boron injectionall subsequenAt operator to manually sh, Atdin the are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.

If Core Cooling CSF Red Path or Heat Sink CSF Red Path conditions exist prior to a successful reactor shutdown (i.e. < 5% reactor power) then entry is required.The Heat Sink Critical Safety Function Red path condition exists if narrow range levels in all steam generators (S/Gs) are less than or equal to 10% -Unit 1 (31% adverse containment) and 14% -Unit 2 (34% adverse containment) and total feedwater flow to Month 20XX BW 3-64 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS all S/Gs is less than or equal to 500 gpm. If total feed flow is less than 500 gpm due to procedurally directed operator actions then this condition does not apply.In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs.

This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor.A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.Escalation of the emergency classification level would be via IC RAG1 or FG1.Basis Reference~s):

1. NEI 99-01 Rev 6, SS5 2. 1/2BwST-1 Subcriticality

3. 1/2BwST-2 Core Cooling 4. 1/2BwST-3 Heat Sink 5. 1/2BwFR-S.1 Response to Nuclear Power Generation/ATWS

6. 1/2BwFR-H.1 Response to Loss of Secondary Heat Sink 7. 1/2BwFR C.1 Response to Inadequate Core Cooling 8. 1/2BwOSR 0.1-1,2,3 Unit One(Two) Modes 1, 2, And 3 Shiftly and Daily Operating Surveillance Month 20XX BW 3-65 EP-AA-1001 (Revision XX)

Brnidwnod Annex Exemlnn Nnelarlmr Braidwood Annex RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA35 Initiating Condition:

Automatic or manual trip fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:

1,2 Emergency Action Level (EAL): Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. Ao-aAutomatic or manual Ttrip did not shutdown the reactor as indicated by Reactor Power > 5%.AND 2. Manual actions taken at the reactor cntrol- consolecMain Control Board are not successful in shutting down the reactor as indicated by Reactor Power > 5%.Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and subsequent operator manual actions taken at the reactor control consoles to shutdown the reactor are also unsuccessful.

This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the reactor control consoles since this event entails a significant failure of the RPS.A manual action at the Main Control Board reactor control conscloc is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip. This action does not include manually driving in control rods or implementation of boron injection strategies.

If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the reactor control consoles (e.g., locally opening breakers).

Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the reactor control cncnoloMain Control Board".The plant response to the failure of an automatic or manual reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged enough to cause a challenge to the core cooling or RCS heat removal safety functions, the emergency Month 20XX BW 3-66 EP-AA-1001 (Revision XX) mrirdwnnr4 A nnoy Ivp~lnn Nne-~lonr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS classification level will escalate to a Site Area Emergency via IC MSS36. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC M9S35 or FS1, an Alert declaration is appropriate for this event.It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL are included to ensure a timely emergency declaration.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.Basis Reference(s):

1. NEI 99-01 Rev 6, SA5 2. 1/2BwST-1 Subcriticality

3. 1/2BwFR-S.1 Response to Nuclear Power Generation/ATWS

4. 1/2BwOSR 0.1-1,2,3 Unit One(Two) Modes 1, 2, And 3 Shiftly and Daily Operating Surveillance Month 20XX BW 3-67 EP-AA-1001 (Revision XX)

RrairlwnnrI A nnoyN,,-laJr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU35i Initiating Condition:

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

1,2 Emergency Action Level (EAL): Note: A manual action is any operator action, or set of actions, which causes the i control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1.a. AA-aAutomatic Ttrip did not shutdown the reactor as indicated by Reactor Power > 5%.AND b. A-sSubsequent manual action taken at the reactor control Control Board is successful in shutting down the reactor.-eenselesMain OR 2.a. A-mManual Ttrip did not shutdown the reactor as indicated by Reactor Power > 5%.AND b. EITHER of the following:

1. A-sSubsequent manual action taken at the cotrol Control Board is successful in shutting down the reactor.roensaleMain OR 2. A-sSubsequent autematic Automatic Ttrip is successful in shutting down the reactor.Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic trip is successful in shutting Month 20XX BW 3-68 EP-AA-1001 (Revision XX)

I:xAInn NlmlAar Rrairwnnd Annex Exelnn Nucnlear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.EAL #1 Basis Following the failure on an automatic reactor trip, operators will promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor trip). If these manual actions are successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems.EAL #2 Basis If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the Main Control Boardroactor conAto-l concolo to shutdown the reactor (e.g., initiate a manual reactor trip using a different switch).Depending upon several factors, the initial or subsequent effort to manually trip the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor trip signal. If a subsequent manual or automatic trip is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems.A manual action at the Main Control Boardroa.tOr contr-l is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip). This action does not include manually driving in control rods or implementation of boron injection strategies.

Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the Main Control Boardr.a.tO.

contr-ol consoloc.The plant response to the failure of an automatic or manual reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the Main Control BoardreactOr .cntrol conG col are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC MSA36. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC MSA35 or FAI, an Unusual Event declaration is appropriate for this event.A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.Should a reactor trip signal be generated as a result of plant work (e.g., RPS setpoint testing), the following classification guidance should be applied.* If the signal generated as a result of plant work causes a plant transient that creates a real condition that should have included an automatic reactor trip and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.

Month 20XX BW 3-69 EP-AA-1001 (Revision XX)

Braidwood Annex Exellon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS

• If the signal generated as a result of plant work does not cause a plant transient but should have generated an RPS trip signal and the trip failure is determined through other means (e.g., assessment of test results), then this IC and the EALs are not applicable and no classification is warranted.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU5 2. 1/2BwST-1 Subcriticality

3. 1/2BwFR-S.1 Response to Nuclear Power Generation/ATWS

4. 1/2BwOSR 0.1-1,2,3 Unit One(Two) Modes 1, 2, And 3 Shiftly and Daily Operating Surveillance Month 20XX BW 3-70 EP-AA-1001 (Revision XX)

Rraidwnnd Annex Exelon Nuc~lear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA432 Initiating Condition:

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

1,2,3,4 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.The Emcrgency DirFe.tr should decGar, Alert prom.ptly upon that 15 mninutes has, been eXceeded, Or Will likely be exceeded-.

1. a. AR-UNPLANNED event results in the inability to monitor ne r mer-eANY Table Mlef parameters from within the Control Room for >15 minutes er--enge .[see tablebelow

[ PVV.R parameter

!i*t]Table M1 -Control Room Parameters R Reactor Power RC-S -L-evl o PZR Level" RCS Pressure RCS Pressure In Core/Core Exit Temperature

• Narrow Range level in at least one In CrGe!CrFe Exit Steam Generator Temper-atuf Steam generator Auxiliary Feed I eelsin atlat(ite specificWtrFo n u m b e r s te a m g e n e ra t o r ...__" W a te r F lo w Steam Generator Auxiliary Or Em~ergency Feed WaterFlow" AND b. Any Table M2e--the-fAeIig transient events in progress." Automatic or Manual runback greater than 25% t~hermFal reactor power" Electrical load rejection greater than 25% full electrical load..---a.-F4Fip" ECCS; 1211 acta-tionn Month 20XX BW 3-71 EP-AA-1001 (Revision XX)

Rraidwood Annex Exelon Nuclear Braidwond Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Table M2 -Significant Transients

• Automatic Turbine Runback >25% thermal reactor power* Electrical Load Rejection

>25% full electrical load" Reactor Trip* Safety Injection Actuation Basis: UNPLANNED:

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

The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fission product barrier challenge is reduced. It thus represents a potential substantial degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for one9 Omor-eany of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s).

For example, the reactor power level cannot be determined from any analog, computer point, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)to determine if an NRC event report is required.

The event would be reported if it significantly impaired the capability to perform emergency assessments.

In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine one Or mereany of these parameters from within the Control Month 20XX BW 3-72 EP-AA-1001 (Revision XX)

Brsaidwond Annex ExeIon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Room is considered to be more significant than simply a reportable condition.

In addition, if all indication sources for eo-e r-moeany of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation of the emergency classification level would be via ICs FS1 or IC RASI.Basis Reference(s):

1. NEI 99-01 Rev 6, SA2 Month 20XX BW 3-73 EP-AA-1001 (Revision XX) raidwnvd Annex Exelon Nucea.r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU42 I Initiating Condition:

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

1,2,3,4 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.The Rmarpna e. Mlrr ,sd r h-1a.m ,I 4 rpn prrp *kn I In. ar ,,2 1 m t,,n* nrp Il, , mt f 1 1[ r'n............ .... UI IUU V 11 y 11IJAA uU UIT II1r~lynn

[r.-]T in flrri .ITu L ri--t;- .uur. uvteeuu.u.

u .-.n ira~ro! m u.. u OAL..u U.u.that IV a ll minutes HasV beeVRl ex~we d , Vl *will Ulkel~y be Ve VVedVed.a- AA-UNPLANNED event results in the inability to monitor onoe moFm ANY Table M1 parameters from within the Control Room for > 15 minutes.Table M1 -Control Room Parameters" Reactor Power" PZR Level* RCS Pressure" In Core/Core Exit Temperature

• Narrow Range level in at least one Steam Generator" Steam generator Auxiliary Feed Water Flow 1. of the foallo.in.

..arameters fm.ro. within the Control Room. fr 15 Finute, OF ]eRgef-l .....2. -r. 3. .PW.RP ...M..4. Re-acter-Pewcr- 6. Reactor Power V Water- Level 5-1 RGS L-ee 10.-RP-V Pr-essuire

11. RCS Pr-essuf 42. l~imaIy 13. in Cor-e/Corce Contolinmen Exit Tcmpcraturc

14. Suppression Pool 15. Levels in at least Leve (stpeeie 16. Supprcssion Pool 1-7. Sbteatm GCcncrtor Temperaur Au~ilf~yf Eme~gen~ey el_at__ Fow Month 20XX BW 3-74 EP-AA-1001 (Revision XX) midwnnei Annoy l::vplnn Nrlanl_ r Rr2irlwnnrl A nn~v Fva~Inn Nfur~IAnr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis: UNPLANNED:

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

The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. This condition is a precursor to a more significant event and represents a potential degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for oRe OrFmor-eany of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s).

For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)to determine if an NRC event report is required.

The event would be reported if it significantly impaired the capability to perform emergency assessments.

In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine One OrF mreeany of these parameters from within the Control Room is considered to be more significant than simply a reportable condition.

In addition, if all indication sources for ne OFr mereany of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation of the emergency classification level would be via IC MSA42.Basis Reference(s):

1. NEI 99-01 Rev 6, SU2 Month 20XX BW 3-75 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA59 Initiating Condition:

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

1,2,3,4 Emergency Action Level (EAL): (-14) 1. a- The occurrence of ANY of the following hazardous events: " Seismic event (earthquake)" Internal or external flooding event" High winds or tornado strike" FIRE" EXPLOSION* (site specific hazards)* Other events with similar hazard characteristics as determined by the Shift Manager AND 2.b-. EITHER of the following:

a.4- Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM nieeded-required by Technical Specifications for the current operating mode.OR b.2- The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure n-eededrequired by Technical Specifications for the current operating mode.Basis: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.EXPLOSION:

A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization.

A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion.

Such events may require a post-event inspection to determine if the attributes of an explosion are present.Month 20XX BW 3-76 EP-AA-1001 (Revision XX) midwnnel Annoy EYPlnn N~rnlp_:r Rr2irlwnnrl A nn~v Fwa~Inn N.ir~Iu~aar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis.

The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, needed-required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL I h I#2.a addresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in seWieeoperation since indications for it will be readily available.

The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train. -EAL 1.b.2#2.b addresses damage to a SAFETY SYSTEM component that is required to be operable by Technical Specifications for the current operating mode, and is not in sewioeloperation or readily apparent through indications alone, er-as well as damage to a structure containing SAFETY SYSTEM components.

Operators will make this determination based on the totality of available event and damage report information.

This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC FS1 or RAS1.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):

1. NEI 99-01, Rev 6 SA9 Month 20XX BW 3-77 EP-AA-1001 (Revision XX) rftiAuurrr1 Annav P:=alnn Nn hnr~l~~r~iiI~nhI%6IrI A .inav Fvn inn kIiurIn~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU641 Initiating Condition:

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

1,2,3,4 Emergency Action Level (EAL):-Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

Tho Emergency Direo should dec.lare the Unusual EVent upon determniRng that 15 minutes has been exceeded, Fr will likely be exceeded.1. RCS unidentified or pressure boundary leakage geateF-than

> 10 gpm for > 15 minutes. (site specific value) for 15 minutes or 'onger.OR 2. RCS identified leakage geatei-thap,>25 gpm for_> 15 minutes.(site specific v.'alue)for 15 minutes, or longer.OR 3. Leakage from the RCS to a location outside containment

>25 gpm for > 15 minutes.greater than 25 gpmn forF 15 minutes Or longer.Basis: UNISOLABLE:

An open or breached system line that cannot be isolated, remotely or locally.This IC addresses RCS leakage which may be a precursor to a more significant event.In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant.EAL #1 and EAL #2 Basis These EALs are focused on a loss of mass from the RCS due to "unidentified leakage","pressure boundary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications).

EAL #3 Basis This EAL addresses a RCS mass loss caused by an UNISOLABLE leak through an interfacing system.Month 20XX BW 3-78 EP-AA-1001 (Revision XX)

Braidwood Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS These EALs thus apply to leakage into the containment, a secondary-side system (e.g., steam generator tube leakage) or a location outside of containment.

The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications.

Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation).

EAL #1 uses a lower value that reflects the greater significance of unidentified or pressure boundary leakage.The release of mass from the RCS due to the as-designed/expected operation of a relief valve does not warrant an emergency classification.

An emergency classification would be required if a mass loss is caused by a relief valve that is not functioning as designed/expected (e.g., a relief valve sticks open and the line flow cannot be isolated).

The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible.Escalation of the emergency classification level would be via ICs of Recognition Category RA or F.Basis Reference(s):

1. NEI 99-01 Rev 6, SU4 2. Technical Specifications 3.4.13 & 3.4.14 3. UFSAR 6.2, 5.24 4. 1/2BwOSR 3.4.13.1 Unit One(Two) Reactor Coolant System Water Inventory Balance Surveillance

5. LCOAR -RCS Leakage Detection Instrumentation

-Tech Spec LCO 3.4.15 6. LCOAR -RCS Operational Leakage -Tech Spec LCO 3.4.13 7. 1/2BwOA PRI-1 Excessive Primary Leakage Unit 1/2 8. 1/2BwOSR 0.1-4 Unit One(Two) Modes 4 Shiftly and Daily Operating Surveillance

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

10. 1/2BwOS XCB-R1 UO and UI MCR Meter Color Banding Month 20XX BW 3-79 EP-AA-1001 (Revision XX) roiduunnd Annoy IFvolnn Ninloar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU761 Initiating Condition:

Loss of all On-site or Off-site communications capabilities.

Operating Mode Applicability:

1,2,3,4 Emergency Action Level (EAL): 1. Loss of ALL Table M3 Onsite communications capability affecting the ability to perform routine operations.

OR 2. Loss of ALL Table M3 Offsite communication capability affecting the ability to perform offsite notifications.

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

Table M3 -Communications Capability System Onsite Offsite NRC Radios X Plant page X Plant Telephone X System Commercial X X X Telephones NARS X ENS X X HPN X X Satellite phones X X 1. Loer of ALL of the following I nsite o n I Ition methoIe: (sitc -pecific lict of co-lmmunica 0 t 0-nms nethod 2. Losseof ALL of the feellemwing ORO communications s) mnethods-Month 20XX BW 3-80 EP-AA-1001 (Revision XX)