ML11339A007

Supplemental Information Request to Adopt Revised Revised Emergency Action Levels

ML11339A007
Person / Time
Site:	Calvert Cliffs
Issue date:	12/01/2011
From:	Fick M Constellation Energy Group, Calvert Cliffs, EDF Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Material Safety and Safeguards
References
Download: ML11339A007 (29)

Text

Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 CENG.

a joint venture of o Cons0eLai#n Energy 1eF 400DF CALVERT CLIFFS NUCLEAR POWER PLANT December 1, 2011 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant; Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Independent Spent Fuel Storage Installation; Docket No. 72-8 Supplemental Information Re: Request to Adopt Revised Emergency Action Levels

REFERENCES:

(a) Letter from Mr. M. J. Fick (CCNPP) to Document Control Desk (NRC), dated February 1, 2011, Emergency Action Level Changes (b) Phone call with Mr. D. A. Johnson (NRC) and Mr. M. J. Fick, et al (CCNPP),

dated November 17, 2011.

(c) Letter from Mr. M. J. Fick (CCNPP) to Document Control Desk (NRC), dated September 23, 2011, Supplemental Information Re: Request to Adopt Revised Emergency Action Levels In Reference (a), Calvert Cliffs Nuclear Power Plant requested Nuclear Regulatory Commission (NRC) approval for the adoption of revised Emergency Action Levels (EALs) for use at Calvert Cliffs Nuclear Power Plant in accordance with 10 CFR Part 50, Appendix E. The revised EALs are based on Nuclear Energy Institute (NEI) 99-01, Revision 5. In Reference (b), several changes to the EAL Technical Bases submitted in Reference (c) were agreed upon. This supplement provides a copy of the affected EAL Technical Bases pages (strike out version) in Attachment (1). A clean copy of the affected EAL Technical Bases pages is also provided [Attachment (2)]. These pages supersede the same clean copy pages of the EAL Technical Bases provided in Reference (c).

1u

Document Control Desk December 1, 2011 Page 2 Should you have questions regarding this matter, please contact me at (410) 495-5216 or Mr. Douglas E. Lauver at (410) 495-5219.

Very truly yours, Director-Emergency Preparedness MJF/PSF/bjd Attachments: (1) EAL Technical Bases pages (strike out version)

(2) EAL Technical Bases pages cc: [w/o Attachmentsl D. V. Pickett, NRC Resident Inspector, NRC W. M. Dean, NRC S. Gray, DNR

ATTACHMENT (1)

EAL TECHNICAL BASES PAGES (STRIKE OUT VERSION)

Calvert Cliffs Nuclear Power Plant, LLC December 1, 2011

CALVERT CLIFFS NUCLEAR POWER PLANT TECHNICAL PROCEDURE EMERGENCY RESPONSE PLAN IMPLEMENTING PROCEDURES ERPIP-XXX EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT REVISION 0 [RAI 11128/111]

Safety-Related X Non-Safety-Related REFERRAL USE Periodically refer to procedure during use Effective Date:

Writer:

Pninted Name and Signature Date Reviewer:

Printed Name and Signature Date Director - EP:

Printed Name and Signature Date POSRC Mtg, #:

Printed Namne and Signature Date Aoroved:

Printed Name and Signature Date

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 170 of 304 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Hazardous Gas Initiating Condition: Access to a Vital Area is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of operable equipment required to maintain safe operations or safely shutdown the reactor EAL:

HA3.1 Alert Access to ANY of the following areas ANY Table H 1 area is prohibited due to toxic, corrosive, asphyxiant or flammable gases whi, h jeopardize .peration of ANY SAFETY RELATED STRUCTURE1, SYST , RC PONENT (Note 5):

" Control Room

" 45' West Electrical Penetration Rooms S69' Electrical Penetration Rooms

" ECOS Pump Rooms

" Charging Pump Rooms Note 5: If the equipment in the stated area was already inoperable. or out of service, before the event occurred, then EAL HLA3.1 should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event TabWeH-I -Sale Shutdown AreaS

" Contakinment

" Auxiliary Build4n

• 1NOC DG 8udkings

" RIAIT Rooms

" CRT No. I

-FOST No. 21

~-uxlir;Feed Pump Rooms Mode Applicability:

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 171 of 304 All Basis:

Generic Gases in a Vital Area can affect the ability to safely operate or safely shutdown the reactor.

The fact that SCBA may be worn does not eliminate the need to declare the event.

Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere poses an immediate threat to life and health or an immediate threat of severe exposure to gases.

This could be based upon documented analysis, indication of personal ill effects from exposure, or operating experience with the hazards.

If ;9 6s4e ed at the Wime th a un.afS CA....trAf... 09..t in thA Affectd ARe Irf the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as itwill have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels.

Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

An uncontrolled release of flammable gasses within a facility structure has the potential to affect safe operation of the plant by limiting either operator or equipment operations due to the potential for ignition and resulting equipment damagelpersonnel injury. Flammable gasses, such as hydrogen and acetylene, are routinely used to maintain plant systems (hydrogen) or to repair equipment/components (acetylene - used in welding). This EAL assumes concentrations of flammable gasses which can ignite/support combustion.

Escalation of this emergency classification level, if appropriate, will be based on EALs in Category S, Category F or Category R.

Plant-Specific

--- Locations designated in the EAL are those areas that are required for Cold Shutdown that cannot be completed from the Control Room.TableH-1 Safe Shutdown Afea&4iG4de al-la-s-1A-,a- Strutue and structures containing Class! 4m qife tan systems-needed4or, safe-shutdown-

-f .aza.dous gas o a a Table 1r c acce but the-equipment 6retaiequsredt*logbe- peFable OF.. wno-bee-h rredtoe- a-bereae a.

reestab" he- (e.g., fanS are Vont."iotin #h- area). th~ELshoukl notbe-declared,

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 172 of 304

-Do~n:itions, Safety-Related- t tea -opet (as defined n-TOGFRSO-2 Those st.. cture*

... ystem& nents that are relied upon to remam-unctional during and following design. .. en. to.s .e: .. .

0) Thn nQmy-of-4he nerOFto coolant P~s*" uu4y (2) T he raoaigl..t tosu down me reacto and mwmaw~a ki on asae-#Awt Genitoni4

(~4Gapabiiý. to pevel 8 A' aGziaents which coula CCNPP Basis Reference(s):

ai~i4~2Plant Pfperty and B3uildings 1-

2. FSAR Se* A.2 Glasse.. of StNu*twre..Systems an~~ment 31_. NEI 99-01 HA3

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 224 of 304 Category: S - System Malfunction Subcategory: 5 - Instrumentation Initiating Condition: Unplanned loss of safety system annunciation or indication in the Control Room for >_15 min.

EAL:

SUS.I Unusual Event UNPLANNED loss of greater than approximately 75% of safety system annunciation or indication on Control Room panels for >_15 min. (Note 4)

Note 4: The ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Basis:

Generic This EAL is intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment.

Recognition of the availability of computer based indication equipment is considered.

"Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions.

It is further recognized that plant design provides redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status.

This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10CFR 5172 If the shutdown is not in compliance with the Technical Specification action, the UE is based on EAL SU4.1.

Annunciators or indicators for this EAL include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.).

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 225 of 304 Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

This UE will be escalated to an Alert based on a concurrent loss of compensatory indications or if a significant transient is in progress during the loss of annunciation or indication.

Plant-Specific The Control Room Panels that house safety related annunciators are listed in the table b helowC.:ro .... .... . ...... ........ . . . . ..... ..... . ............... .. . ..... . . . . ..... .

below:

Unit 1 Unit 2 1C04 2C04 1C05 2C05 1C06 2C06 1C07 2C07 1C08 2C08 1C09 2Q09 i1iC 2C10 1C13 2C13 1C18A 1C19_

1C18B 1 C20 1C19C 1C20A 1C22 1C20B 1l24B 1C22 1C26 1C24B 1C33 1C26 1034 1C33 1C34 Definitions:

Unplanned A parameter change or an event, the reasons for which may be known or unknown, that is not the result of an intended evolution or expected plant response to a transient

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 226 of 304 CCNPP Basis Reference(s):

1. UFSAR Sections 7.6 and 7.7

2. AOP-7J Loss of 120 Volt Vital AC or 125 Volt Vital DC Power

3. UFSAR 7.5.5

4. OI-50A Plant Computer

5. CNG-OP-1.01-2003 Alarm Response and Control

6. NEI 99-01 SU3

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 227 of 304 Category: S - System Malfunction Subcategory: 5 - Instrumentation Initiating Condition: Unplanned loss of safety system annunciation or indication in the Control Room with either (1) a significant transient in progress, or (2) compensatory indicators are unavailable EAL:

SA5.1 Alert UNPLANNED loss of greater than approximately 75% of safety system annunciation or indication on Control Room panels for _>15 min. (Note 4)

AND EITHER:

A significant transient is in progress, Table S-2 OR Compensatory indications are unavailable (Plant Computer, SPDS)

Note 4 The ED shotild not wad until the applicable time has elapsed, but should declare ft event as soon as 4 is determined that the condition has exceeded, or will likely exceed, the applicable time Table S-2 Significant Transients

• Automatic turbine runback > 25% thermal power

• Electric load rejection > 25% full electrical load

• Reactor trip

• Safety Injection actuation Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Basis:

Generic This EAL is intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a significant transient.

"Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Manager be tasked with making a judgment

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 228 of 304 decision as to whether additional personnel are required to provide increased monitoring of system operation.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status.

This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. Ifthe shutdown is not in compliance with the Technical Specification action, the UE is based on EAL SU4.1.

Annunciators or indicators for this EAL include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.).

"Compensatory indications" in this context includes computer based information such as Plant Process Computer and SPDS.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor the transient in progress due to a concurrent loss of compensatory indications with a significant transient in progress during the loss of annunciation or indication.

Plant-Specific Plant Process Computer and SPDS are considered compensatory indication.

Significant transients are listed in Table S-2.

The Control Room Panels that house safety related annunciators are listed in the table below:

Unit 1 Unit 2 1C04 2C04 1Q05 2005 1 C06 2C06 1C07 2Q07 1C08 2008 1C_..9 2009 C100 2C10

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 229 of 304 1C13 2C13 1C18A 1C19C lC18B 1C20 1C19C 1C20A 1C22 1C20B 1C24B 1C22 1 C26 1C248 1C33 1C26 1C34 1C33 1C34 Definitions:

Unplanned A parameter change or an event, the reasons for which may be known or unknown, that is not the result of an intended evolution or expected plant response to a transient.

CCNPP Basis Reference(s):

1. UFSAR Sections 7.6 and 7.7

2. AOP-7J Loss of 120 Volt Vital AC or 125 Volt Vital DC Power

3. UFSAR 7.5.5

4.01-50A Plant Computer

5. CNG-OP-1 .01-2003 Alarm Response and Control

6. NEI 99-01 SA4

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 230 of 304 Category: S - System Malfunction Subcategory: 5 - Instrumentation Initiating Condition: Inability to monitor a significant transient in progress EAL:

SS5.1 Site Area Emergency Loss of greater than approximately 75% of safety system annunciation or indication on Control Room panels for > 15 min. (Note 4)

AND A significant transient is in progress, Table S-2 AND Compensatory indications are unavailable (Plant Computer, SPDS)

Note 4: The ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the oondition has exceeded, or will likely exceed, the applicable time Table S-2 Significant Transients

" Automatic turbine runback > 25% thermal power

• Electric load rejection > 25% full electrical load

• Reactor trip

• Safety Injection actuation Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Basis:

Generic This EAL is intended to recognize the threat to plant safety associated with the complete loss of capability of the Control Room staff to monitor plant response to a significant transient.

'Planned" and "unplanned" actions are not differentiated since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Manager be tasked with making a judgment

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAIl]

TECHNICAL BASES DOCUMENT Page 231 of 304 decision as to whether additional personnel are required to provide increased monitoring of system operation.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status.

This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the NOUE is based on EAL SU4.1 A Site Area Emergency is considered to exist if the Control Room staff cannot monitor safety functions needed for protection of the public while a significant transient is in progress.

Annunciators for this EAL are limited to include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g. area, process, and/or effluent rad monitors, etc.)

Indications needed to monitor safety functions necessary for protection of the public include Control Room indications, computer generated indications and dedicated annunciation capability.

"Compensatory indications" in this context includes computer based information such as Plant Process Computer and SPDS.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Plant-Specific Plant computer and SPDS are considered compensatory indication.

Significant transients are listed in Table S-2.

The Control Room Panels that house safety related annunciators are listed in the table below:

Unit 1 Unit 2 1C04 2C04 1C05 2C05 1C06 2C06 1lC07 2007 1C08 2C08 1C09 2C09

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAIl]

TECHNICAL BASES DOCUMENT Page 232 of 304 10 ClC 2C10 1C13 2C13 1C18A 1C19C 1C18B 1C20 lC19_C 1C20A 1Q22 1020B IC24B C122 lC26 1C24B 1C33 1 C26 1C34 1C33 1C34 CCNPP Basis Reference(s):

1. UFSAR Sections 7.6 and 7.7

2. AOP-7J Loss of 120 Volt Vital AC or 125 Volt Vital DC Power

3. UFSAR 7.5.5

4. OI-50A Plant Computer

5. CNG-OP-1.01-2003 Alarm Response and Control

6. NEI 99-01 SS6

ATTACHMENT (2)

EAL TECHNICAL BASES PAGES Calvert Cliffs Nuclear Power Plant, LLC December 1, 2011

CALVERT CLIFFS NUCLEAR POWER PLANT TECHNICAL PROCEDURE EMERGENCY RESPONSE PLAN IMPLEMENTING PROCEDURES ERPIP-XXX EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT REVISION 0 [RAI 11/28/11]

Safety-Related X Non-Safety-Related REFERRAL USE Periodically refer to procedure during use Effective Date:

Writer:

Printed Name and Signature Date Reviewer:

Printed Name and Signature Date Director - EP:

Printed Name and Signature Date POSRC Mtq. #:

Printed Name and Signature Date Approved:

Printed Name and Signature Date

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 170 of 303 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Hazardous Gas Initiating Condition: Access to a Vital Area is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of operable equipment required to maintain safe operations or safely shutdown the reactor EAL:

HA3.1 Alert Access to ANY of the following areas is prohibited due to toxic, corrosive, asphyxiant or flammable gases (Note 5):

" Control Room

" 45' West Electrical Penetration Rooms

" 69' Electrical Penetration Rooms

" ECCS Pump Rooms

" Charging Pump Rooms Note 5: Ifthe equipment in the stated area was already inoperable, or out of service, before the event occurred, then EAL HA3.1 should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.

Mode Applicability:

All Basis:

Generic Gases in a Vital Area can affect the ability to safely operate or safely shutdown the reactor.

The fact that SCBA may be wom does not eliminate the need to declare the event.

Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere poses an immediate threat to life and health or an immediate threat of severe exposure to gases.

This could be based upon documented analysis, indication of personal ill effects from exposure, or operating experience with the hazards.

Ifthe equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 171 of 303 An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels.

Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

An uncontrolled release of flammable gasses within a facility structure has the potential to affect safe operation of the plant by limiting either operator or equipment operations due to the potential for ignition and resulting equipment damage/personnel injury. Flammable gasses, such as hydrogen and acetylene, are routinely used to maintain plant systems (hydrogen) or to repair equipment/components (acetylene - used in welding). This EAL assumes concentrations of flammable gasses which can ignite/support combustion.

Escalation of this emergency classification level, if appropriate, will be based on EALs in Category S, Category F or Category R.

Plant-Specific Locations designated in the EAL are those areas that are required for Cold Shutdown that cannot be completed from the Control Room.

CCNPP Basis Reference(s):

1. NEI 99-01 HA3

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 223 of 303 Category: S - System Malfunction Subcategory: 5 - Instrumentation Initiating Condition: Unplanned loss of safety system annunciation or indication in the Control Room for > 15 min.

EAL:

SU5.1 Unusual Event UNPLANNED loss of greater than approximately 75% of safety system annunciation or indication on Control Room panels for _ 15 min. (Note 4)

Note 4: The ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Basis:

Generic This EAL is intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment.

Recognition of the availability of computer based indication equipment is considered.

"Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions.

It is further recognized that plant design provides redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status.

This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72- Ifthe shutdown is not in compliance with the Technical Specification action, the UE is based on EAL SU4.1.

Annunciators or indicators for this EAL include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.).

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 224 of 303 Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

This UE will be escalated to an Alert based on a concurrent loss of compensatory indications or if a significant transient is in progress during the loss of annunciation or indication.

Plant-Specific The Control Room Panels that house safety related annunciators are listed in the table below:

Unit I Unit 2 1C04 2C04 1C05 2C05 1C06 2C06 1C07 2C07 1C08 2C08 1C09 2C09 iC1o 2C10 1C13 2C13 1C18A 1C19C 1C18B 1C20 1C19C 1C20A 1C22 1C20B 1C24B 1C22 1C26 1C24B 1C33 1C26 1C34 1C33 1C34 Definitions:

Unplanned A parameter change or an event, the reasons for which may be known or unknown, that is not the result of an intended evolution or expected plant response to a transient.

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 225 of 303 CCNPP Basis Reference(s):

1. UFSAR Sections 7.6 and 7.7

2. AOP-7J Loss of 120 Volt Vital AC or 125 Volt Vital DC Power

3. UFSAR 7.5.5

4. OI-50A Plant Computer

5. CNG-OP-1.01-2003 Alarm Response and Control

6. NEI 99-01 SU3

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 226 of 303 Category: S - System Malfunction Subcategory: 5- Instrumentation Initiating Condition: Unplanned loss of safety system annunciation or indication in the Control Room with either (1) a significant transient in progress, or (2) compensatory indicators are unavailable EAL:

SA5.1 Alert UNPLANNED loss of greater than approximately 75% of safety system annunciation or indication on Control Room panels for Ž_15 min. (Note 4)

AND EITHER:

A significant transient is in progress, Table S-2 OR Compensatory indications are unavailable (Plant Computer, SPDS)

Note 4: The ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time Table S-2 Significant Transients

• Automatic turbine runback > 25% thermal power

• Electric load rejection > 25% full electrical load

• Reactor trip

• Safety Injection actuation Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Basis:

Generic This EAL is intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a significant transient.

"Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost' but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Manager be tasked with making a judgment

ERPIP-XXX EMERGENCY ACTION LEVEL Revision [RAI]

TECHNICAL BASES DOCUMENT Page 227 of 303 decision as to whether additional personnel are required to provide increased monitoring of system operation.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status.

This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the UE is based on EAL SU4.1.

Annunciators or indicators for this EAL include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.).

"Compensatory indications" in this context includes computer based information such as Plant Process Computer and SPDS.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor the transient in progress due to a concurrent loss of compensatory indications with a significant transient in progress during the loss of annunciation or indication.

Plant-Specific Plant Process Computer and SPDS are considered compensatory indication.

Significant transients are listed in Table S-2.

The Control Room Panels that house safety related annunciators are listed in the table below:

Unit 1 Unit 2 1C04 2C04 1C05 2C05 1C06 2C06 1C07 2C07 lC08 2C08 1C09 2C09 IC10 2C10

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TECHNICAL BASES DOCUMENT Page 228 of 303 1C13 2C13 IC18A 1C19C lC18B 1C20 IC19C 1C20A 1C22 IC20B 1C24B 1C22 1C26 1C24B 1C33 1C26 1C34 1C33 1C34 Definitions:

Unplanned A parameter change or an event, the reasons for which may be known or unknown, that is not the result of an intended evolution or expected plant response to a transient.

CCNPP Basis Reference(s):

1. UFSAR Sections 7.6 and 7.7

2. AOP-7J Loss of 120 Volt Vital AC or 125 Volt Vital DC Power

3. UFSAR 7.5.5

4. OI-50A Plant Computer

5. CNG-OP-1.01-2003 Alarm Response and Control

6. NEI 99-01 SA4

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TECHNICAL BASES DOCUMENT Page 229 of 303 Category: S - System Malfunction Subcategory: 5 - Instrumentation Initiating Condition: Inability to monitor a significant transient in progress EAL:

SS5.1 Site Area Emergency Loss of greater than approximately 75% of safety system annunciation or indication on Control Room panels for > 15 min. (Note 4)

AND A significant transient is in progress, Table S-2 AND Compensatory indications are unavailable (Plant Computer, SPDS)

Note 4: The ED should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time Table S-2 Significant Transients

• Automatic turbine runback > 25% thermal power

• Electric load rejection > 25% full electrical load

• Reactor trip

• Safety Injection actuation Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Basis:

Generic This EAL is intended to recognize the threat to plant safety associated with the complete loss of capability of the Control Room staff to monitor plant response to a significant transient, "Planned" and "unplanned" actions are not differentiated since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Manager be tasked with making a judgment

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TECHNICAL BASES DOCUMENT Page 230 of 303 decision as to whether additional personnel are required to provide increased monitoring of system operation.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status.

This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. Ifthe shutdown is not in compliance with the Technical Specification action, the NOUE is based on EAL SU4.1 A Site Area Emergency is considered to exist if the Control Room staff cannot monitor safety functions needed for protection of the public while a significant transient is in progress.

Annunciators for this EAL are limited to include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g. area, process, and/or effluent rad monitors, etc.)

Indications needed to monitor safety functions necessary for protection of the public include Control Room indications, computer generated indications and dedicated annunciation capability.

"Compensatory indications" in this context includes computer based information such as Plant Process Computer and SPDS.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Plant-Specific Plant computer and SPDS are considered compensatory indication.

Significant transients are listed in Table S-2.

The Control Room Panels that house safety related annunciators are listed in the table below:

Unit 1 Unit 2 1C04 2C04 1C05 2C05 1C06 2C06 1C07 2C07 1C08 2C08 1C09 2C09

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TECHNICAL BASES DOCUMENT Page 231 of 303 IClo 2C10 1C13 2C13 IC18A 1C19C lC18B 1C20 lC19C 1C20A 1C22 1C20B lC24B 1C22 1C26 1C24B IC33 1C26 IC34 1C33 1C34 CCNPP Basis Reference(s):

1. UFSAR Sections 7.6 and 7.7

2. AOP-7J Loss of 120 Volt Vital AC or 125 Volt Vital DC Power

3. UFSAR 7.5.5

4. OI-50A Plant Computer

5. CNG-OP-1.01-2003 Alarm Response and Control

6. NEI 99-01 SS6