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{{#Wiki_filter:Enclosure 2 to 0CAN031801 Proposed EAL Technical Basis Document (Markup) to 0CAN031801 Page 1 of 255 Table of Contents Section                                                                                                                          Page
 
==1.0  INTRODUCTION==
.................................................................................................................2 2.0  DISCUSSION ......................................................................................................................2 2.1  Background ................................................................................................................2 2.2  Fission Product Barriers .............................................................................................3 2.3  Fission Product Barrier Classification Criteria ............................................................3 2.4  EAL Organization .......................................................................................................4 2.5  Technical Basis Information .......................................................................................5 2.6  Operations Mode Applicability....................................................................................7 3.0  GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS ..........................................8 3.1  General Considerations .............................................................................................8 3.2  Classification Methodology ......................................................................................10
 
==4.0  REFERENCES==
..................................................................................................................13 4.1  Developmental .........................................................................................................13 4.2  Implementing............................................................................................................13 5.0  DEFINITIONS, ACRONYMS & ABBREVIATIONS ...........................................................13 5.1  Definitions (ref. 4.1.1 except as noted) ....................................................................13 5.2  Abbreviations/Acronyms ..........................................................................................18 6.0  ANO-TO-NEI 99-01 Rev. 6 EAL CROSS-REFERENCE ..................................................22 7.0  ATTACHMENTS ...............................................................................................................24 7.1  Attachment 1, Emergency Action Level Technical Bases ........................................24 Category A - Abnormal Rad Levels / Rad Effluents ................................................25 Category C - Cold Shutdown / Refueling System Malfunction ................................70 Category E - Independent Spent Fuel Storage Installation (ISFSI) .......................109 Category F - Fission Product Barrier Degradation ................................................112 Table 1[2]F-1, Fission Product Barrier Threshold Matrix & Bases ...119 Category H - Hazards and Other Conditions Affecting Plant Safety .....................164 Category S - System Malfunction ..........................................................................210 7.2  Attachment 2, Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases .....................................................253 to 0CAN031801 Page 2 of 255
 
==1.0      INTRODUCTION==
 
This document provides an explanation and rationale for each Emergency Action Level (EAL) included in the EAL Upgrade Project for Arkansas Nuclear One (ANO). It should be used to facilitate review of the ANO EALs and provide historical documentation for future reference.
Decision-makers responsible for implementation of 1903.010, Emergency Action Level Classification, may use this document as a technical reference in support of EAL interpretation.
This information may assist the Emergency Director in making classifications, particularly those involving judgment or multiple events. The basis information may also be useful in training and for explaining event classifications to off-site officials.
The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases when conditions are present and have been recognized. Use of this document for assistance is not intended to delay the emergency classification.
Because the information in a basis document can affect emergency classification decision-making (e.g., the Emergency Director refers to it during an event), the NRC staff expects that changes to the basis document will be evaluated in accordance with the provisions of 10 CFR 50.54(q).
2.0      DISCUSSION 2.1      Background EALs are the plant-specific indications, conditions or instrument readings that are utilized to classify emergency conditions defined in the ANO Emergency Plan.
In 1992, the NRC endorsed NUMARC/NESP-007 Methodology for Development of Emergency Action Levels as an alternative to NUREG-0654 EAL guidance.
NEI 99-01 (NUMARC/NESP-007) Revisions 4 and 5 were subsequently issued for industry implementation. Enhancements over earlier revisions included:
Consolidating the system malfunction initiating conditions and example emergency action levels which address conditions that may be postulated to occur during plant shutdown conditions.
Initiating conditions and example emergency action levels that fully address conditions that may be postulated to occur at permanently Defueled Stations and Independent Spent Fuel Storage Installations (ISFSIs).
Simplifying the fission product barrier EAL threshold for a Site Area Emergency.
Subsequently, Revision 6 of NEI 99-01 has been issued which incorporates resolutions to numerous implementation issues including the NRC EAL Frequently Asked Questions (FAQs).
Using NEI 99-01 Revision 6, "Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, November 2012 (ref. 4.1.1), ANO conducted an EAL implementation upgrade project that produced the EALs discussed herein.
to 0CAN031801 Page 3 of 255 2.2    Fission Product Barriers Fission product barrier thresholds represent threats to the defense in depth design concept that precludes the release of radioactive fission products to the environment. This concept relies on multiple physical barriers, any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment.
Many of the EALs derived from the NEI methodology are fission product barrier threshold based. That is, the conditions that define the EALs are based upon thresholds that represent the loss or potential loss of one or more of the three fission product barriers. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. A Loss threshold means the barrier no longer assures containment of radioactive materials.
A Potential Loss threshold implies a greater probability of barrier loss and reduced certainty of maintaining the barrier.
The primary fission product barriers are:
A. Fuel Clad Barrier (FCB): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.
B. Reactor Coolant System Barrier (RCB): The Reactor Coolant System Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.
C. Containment Barrier (CNB): The Containment Barrier includes the Reactor Building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the Reactor Building up to and including the outermost secondary side isolation valve.
Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency.
2.3    Fission Product Barrier Classification Criteria The following criteria are the bases for event classification related to fission product barrier loss or potential loss:
Alert:
Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency:
Loss or potential loss of any two barriers General Emergency:
Loss of any two barriers and loss or potential loss of the third barrier to 0CAN031801 Page 4 of 255 2.4      EAL Organization The ANO EAL scheme includes the following features:
Division of the EAL set into three broad groups:
o  EALs applicable under any plant operating modes - This group would be reviewed by the EAL-user any time emergency classification is considered.
o  EALs applicable only under hot operating modes - This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby, Startup, or Power Operation mode.
o  EALs applicable only under cold operating modes - This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refueling or Defueled mode.
The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency.
Within each group, assignment of EALs to categories and subcategories:
Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. The ANO EAL categories are aligned to and represent the NEI 99-01, Recognition Categories. Subcategories are used in the ANO scheme as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The ANO EAL categories and subcategories are listed below.
The primary tool for determining the emergency classification level is the EAL Classification Matrix. The user of the EAL Classification Matrix may (but is not required to) consult the EAL technical bases in order to obtain additional information concerning the EALs under classification consideration. The user should consult Section 3.0 and Attachment 1 of this document for such information.
to 0CAN031801 Page 5 of 255 EAL Groups, Categories and Subcategories EAL Group/Category                            EAL Subcategory Any Operating Mode:
A - Abnormal Rad Levels / Rad Effluent      1 - Radiological Effluent 2 - Irradiated Fuel Event 3 - Area Radiation Levels H - Hazards and Other Conditions Affecting  1 - Security Plant Safety                            2 - Seismic Event 3 - Natural or Technological Hazard 4 - Fire 5 - Hazardous Gas 6 - Control Room Evacuation 7 - Emergency Director Judgment E - Independent Spent Fuel Storage          1 - Confinement Boundary Installation (ISFSI)
Hot Conditions:
S - System Malfunction                      1 - Loss of Essential AC Power 2 - Loss of Vital DC Power 3 - Loss of Control Room Indications 4 - RCS Activity 5 - RCS Leakage 6 - RPS Failure 7 - Loss of Communications 8 - Containment Failure 9 - Hazardous Event Affecting Safety Systems F - Fission Product Barrier Degradation    None Cold Conditions:
C - Cold Shutdown / Refueling System        1 - RCS Level Malfunction                            2 - Loss of Essential AC Power 3 - RCS Temperature 4 - Loss of Vital DC Power 5 - Loss of Communications 6 - Hazardous Event Affecting Safety Systems 2.5      Technical Bases Information EAL technical bases are provided in Attachment 1 for each EAL according to EAL group (Any, Hot, Cold), EAL category (A, C, E, F, H and S) and EAL subcategory. A summary explanation of each category and subcategory is given at the beginning of the technical bases discussions of the EALs included in the category. For each EAL, the following information is provided:
to 0CAN031801 Page 6 of 255 Category Letter & Title Subcategory Number & Title Initiating Condition (IC)
Site-specific description of the generic IC given in NEI 99-01 Rev. 6.
EAL Identifier (enclosed in rectangle)
Each EAL is assigned a unique identifier to support accurate communication of the emergency classification to onsite and offsite personnel. Four characters define each EAL identifier:
: 1. First character (letter): Corresponds to the EAL category as described above (A, C, E, F, H or S)
: 2. Second character (letter): The emergency classification (G, S, A or U)
G = General Emergency S = Site Area Emergency A = Alert U = Unusual Event
: 3. Third character (number): Subcategory number within the given category. Subcategories are sequentially numbered beginning with the number one (1). If a category does not have a subcategory, this character is assigned the number one (1).
: 4. Fourth character (number): The numerical sequence of the EAL within the EAL subcategory. If the subcategory has only one EAL, it is given the number one (1).
Classification (enclosed in rectangle):
Unusual Event (U), Alert (A), Site Area Emergency (S) or General Emergency (G)
EAL (enclosed in rectangle)
Exact wording of the EAL as it appears in the EAL Classification Matrix. If an ANO Unit 2 EAL threshold value differs from Unit 1, the Unit 2 threshold is enclosed in brackets. For example, in the EAL threshold RVLMS Levels 1 through 8 indicate DRY [RVLMS Levels 1 through 5 indicate DRY], RVLMS Levels 1 through 5 indicate DRY apply only to Unit 2.
Mode Applicability One or more of the following plant operating conditions comprise the mode to which each EAL is applicable: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling, DEF - Defueled, or All. (See Section 2.6 for operating mode definitions).
to 0CAN031801 Page 7 of 255 Definitions:
If the EAL wording contains a defined term, the definition of the term is included in this section. These definitions can also be found in Section 5.1.
Basis:
An EAL basis section that provides ANO-relevant information concerning the EAL as well as a description of the rationale for the EAL as provided in NEI 99-01 Rev. 6.
Reference(s):
Source documentation from which the EAL is derived.
2.6      Operating Mode Applicability Unit 1 (ref. 4.1.6):
1      Power Operation Keff  0.99, reactor power > 5%
2      Startup Keff  0.99, reactor power  5%
3      Hot Standby Keff < 0.99, reactor coolant temperature  280&deg;F 4      Hot Shutdown Keff < 0.99, reactor coolant temperature 280&deg;F > Tavg > 200&deg;F and all reactor vessel head closure bolts fully tensioned 5      Cold Shutdown Keff < 0.99, reactor coolant temperature  200&deg;F and all reactor vessel head closure bolts fully tensioned 6      Refueling One or more reactor vessel head closure bolts less than fully tensioned DEF    Defueled All fuel assemblies have been removed from Containment and placed in the spent fuel pool.
to 0CAN031801 Page 8 of 255 Unit 2 (ref. 4.1.6):
1      Power Operation Keff  0.99, reactor power > 5%, average coolant temperature  300&deg;F 2      Startup Keff  0.99, reactor power  5%, average coolant temperature  300&deg;F 3      Hot Standby Keff < 0.99, average coolant temperature  300&deg;F 4      Hot Shutdown Keff < 0.99, average coolant temperature 300&deg;F > Tavg > 200&deg;F 5      Cold Shutdown Keff < 0.99, average coolant temperature  200&deg;F 6      Refueling Keff  0.95, average coolant temperature  140&deg;F, reactor vessel head unbolted or removed, and fuel in the vessel.
DEF    Defueled All fuel assemblies have been removed from Containment and placed in the spent fuel pool.
The plant operating mode that exists at the time that the event occurs (prior to any protective system or operator action being initiated in response to the condition) should be compared to the mode applicability of the EALs. If a lower or higher plant operating mode is reached before the emergency classification is made, the declaration shall be based on the mode that existed at the time the event occurred.
3.0    GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 3.1    General Considerations When making an emergency classification, the Emergency Director must consider all information having a bearing on the proper assessment of an Initiating Condition (IC). This includes the Emergency Action Level (EAL) plus the associated Operating Mode Applicability, Notes, and the informing basis information. In the Recognition Category F matrices, EALs are based on loss or potential loss of Fission Product Barrier Thresholds.
EAL matrices should be read from left to right, from General Emergency to Unusual Event, and top to bottom. Declaration decisions should be independently verified before declaration is made except when gaining this verification would exceed the 15 minute declaration requirement. Place keeping should be used on all EAL matrices.
to 0CAN031801 Page 9 of 255 3.1.1      Classification Timeliness NRC regulations require the licensee to establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and to promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. The NRC staff has provided guidance on implementing this requirement in NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants" (ref. 4.1.8).
3.1.2      Valid Indications All emergency classification assessments shall be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicators operability, the conditions existence, or the reports accuracy. For example, verification could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by plant personnel.
An indication, report, or condition is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
3.1.3      Imminent Conditions For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the Emergency Director 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. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary.
3.1.4      Planned vs. Unplanned Events A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that: 1) the activity proceeds as planned, and 2) the plant remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain or modify a system or component. In these cases, the controls associated with the planning, preparation and execution of the work will ensure that compliance is maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10 CFR 50.72 (ref. 4.1.4).
3.1.5      Classification Based on Analysis The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., dose assessments, chemistry sampling, RCS leak rate calculation, etc.). For these EALs, the EAL wording or the to 0CAN031801 Page 10 of 255 associated basis discussion will identify the necessary analysis. In these cases, the 15-minute declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available). The NRC expects licensees to establish the capability to initiate and complete EAL-related analyses within a reasonable period of time (e.g., maintain the necessary expertise on-shift).
3.1.6      Emergency Director Judgment While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 EAL scheme provides the Emergency Director with the ability to classify events and conditions based upon judgment using EALs that are consistent with the Emergency Classification Level (ECL) definitions (refer to Category H). The Emergency Director will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.
A similar provision is incorporated in the Fission Product Barrier Tables; judgment may be used to determine the status of a fission product barrier.
3.2      Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e., the relevant plant indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL must be consistent with the related Operating Mode Applicability and Notes. If an EAL has been met or exceeded, the associated IC is likewise met, the emergency classification process clock starts, and the ECL must be declared in accordance with plant procedures no later than fifteen minutes after the process clock started.
When assessing an EAL that specifies a time duration for the off-normal condition, the clock for the EAL time duration runs concurrently with the emergency classification process clock.
For a full discussion of this timing requirement, refer to NSIR/DPR-ISG-01 (ref. 4.1.8).
3.2.1      Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared. For example:
If an Alert EAL and a Site Area Emergency EAL are met, whether at one unit or at two units, a Site Area Emergency should be declared.
There is no additive effect from multiple EALs meeting the same ECL. For example:
If two Alert EALs are met, whether at one unit or at two units, an Alert should be declared.
Related guidance concerning classification of rapidly escalating events or conditions is provided in Regulatory Issue Summary (RIS) 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events (ref. 4.1.2).
to 0CAN031801 Page 11 of 255 3.2.2      Consideration of Mode Changes During Classification The mode in effect at the time that an event or condition occurred, and prior to any plant or operator response, is the mode that determines whether or not an IC is applicable. If an event or condition occurs, and results in a mode change before the emergency is declared, the emergency classification level is still based on the mode that existed at the time that the event or condition was initiated (and not when it was declared). Once a different mode is reached, any new event or condition, not related to the original event or condition, requiring emergency classification should be evaluated against the ICs and EALs applicable to the operating mode at the time of the new event or condition.
For events that occur in Cold Shutdown or Refueling, escalation is via EALs that are applicable in the Cold Shutdown or Refueling modes, even if Hot Shutdown (or a higher mode) is entered during the subsequent plant response. In particular, the fission product barrier EALs are applicable only to events that initiate in the Hot Shutdown mode or higher.
3.2.3      Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Director must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Emergency Director, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all emergency classification levels, this approach is particularly important at the higher emergency classification levels since it provides additional time for implementation of protective measures.
3.2.4      Emergency Classification Level Upgrading and Termination An ECL may be terminated when the event or condition that meets the classified IC and EAL no longer exists, and other site-specific termination requirements are met.
As noted above, guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02 (ref. 4.1.2).
3.2.5      Classification of Short-Lived Events Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration. Examples of such events include an earthquake or a failure of the reactor protection system to automatically trip the reactor followed by a successful manual trip.
3.2.6      Classification of Transient Conditions Many of the ICs and/or EALs employ time-based criteria. These criteria will require that the IC/EAL conditions be present for a defined period of time before an emergency declaration is warranted. In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes). The following guidance should be applied to the classification of these conditions.
to 0CAN031801 Page 12 of 255 EAL momentarily met during expected plant response - In instances in which an EAL is briefly met during an expected (normal) plant response, an emergency declaration is not warranted provided that associated systems and components are operating as expected, and operator actions are performed in accordance with procedures.
EAL momentarily met but the condition is corrected prior to an emergency declaration - If an operator takes prompt manual action to address a condition, and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required. For illustrative purposes, consider the following example:
An ATWS occurs and the high pressure ECCS systems fail to automatically start. The plant enters an inadequate core cooling condition (a potential loss of both the Fuel Clad and RCS Barriers). If an operator manually starts a high pressure ECCS system in accordance with an EOP step and clears the inadequate core cooling condition prior to an emergency declaration, then the classification should be based on the ATWS only.
It is important to stress that the 15-minute emergency classification assessment period (process clock) is not a grace period during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event. Emergency classification assessments must be deliberate and timely, with no undue delays. The provision discussed above addresses only those rapidly evolving situations when an operator is able to take a successful corrective action prior to the Emergency Director completing the review and steps necessary to make the emergency declaration. This provision is included to ensure that any public protective actions resulting from the emergency classification are truly warranted by the plant conditions.
3.2.7      After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery. This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.
In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022 (ref. 4.1.3) is applicable. Specifically, the event should be reported to the NRC in accordance with 10 CFR &sect; 50.72 (ref. 4.1.4) within one hour of the discovery of the undeclared event or condition. The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.
3.2.8      Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022 (ref. 4.1.3).
to 0CAN031801 Page 13 of 255
 
==4.0    REFERENCES==
 
4.1    Developmental 4.1.1      NEI 99-01 Revision 6, Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, ADAMS Accession Number ML12326A805 4.1.2      RIS 2007-02 Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2, 2007.
4.1.3      NUREG-1022 Event Reporting Guidelines: 10CFR50.72 and 50.73 4.1.4      10 &sect; CFR 50.72 Immediate Notification Requirements for Operating Nuclear Power Reactors 4.1.5      10 &sect; CFR 50.73 License Event Report System 4.1.6      Unit 1[2] Technical Specifications Table 1.1-1[1.1], Modes[Operational Modes]
4.1.7      Arkansas Nuclear One Offsite Dose Calculation Manual (ODCM) 4.1.8      NSIR/DPR-ISG-01 Interim Staff Guidance, Emergency Planning for Nuclear Power Plants 4.1.9      Arkansas Nuclear One Emergency Plan 4.1.10    1015.008 Unit 2 SDC Control 4.2    Implementing 4.2.1      1903.010 Emergency Action Level Classification 4.2.2      NEI 99-01 Rev. 6 to ANO EAL Comparison Matrix 4.2.3      ANO EAL Matrix 5.0    DEFINITIONS, ACRONYMS & ABBREVIATIONS 5.1    Definitions (ref. 4.1.1 except as noted)
Selected terms used in Initiating Condition, Emergency Action Level statements and EAL bases are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.
Alert 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.
to 0CAN031801 Page 14 of 255 Confinement Boundary The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).
Containment Closure The procedurally defined actions taken to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown existing plant conditions (ref. 4.1.10).
As applied to ANO, Containment Closure must be capable of being set within 30 minutes.
Containment Closure is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
Emergency Action Level (EAL)
A pre-determined, site-specific, observable threshold for an INITIATING CONDITION that, when met or exceeded, places the plant in a given emergency classification level.
Emergency Classification Level (ECL)
One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:
Notification of Unusual Event (NOUE)
Alert Site Area Emergency (SAE)
General Emergency (GE)
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 require a post-event inspection to determine if the attributes of an explosion are present.
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.
to 0CAN031801 Page 15 of 255 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.
Fission Product Barrier Threshold A pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier.
Flooding A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.
General Emergency 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 PAG exposure levels offsite for more than the immediate site area.
Hostage A person(s) held as leverage against the station to ensure that demands will be met by the station.
Hostile Action An act toward a NPP ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPPANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).
Hostile Force One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
Imminent The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.
to 0CAN031801 Page 16 of 255 Impede(d)
Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
Independent Spent Fuel Storage Installation (ISFSI)
A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.
Initiating Condition (IC)
An event or condition that aligns with the definition of one of the four emergency classification levels by virtue of the potential or actual effects or consequences.
Normal Levels As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.
Owner Controlled Area (OCA)
For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line. Access to this area is controlled by the SOCA Personnel Access Control Point (ref. 4.1.9).
Projectile An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.
Protected Area An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled (ref. 4.1.9).
RCS Intact The RCS should be considered intact when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams).
Refueling Pathway All the cavities, tubes, canals and pools through which irradiated fuel may be moved, but not including the reactor vessel.
to 0CAN031801 Page 17 of 255 Ruptured The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).
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 (as defined in 10CFR50.2):
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Security Condition Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A Security Condition does not involve a HOSTILE ACTION.
Site Area Emergency 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 PAG exposure levels beyond the SITE BOUNDARY.
Site Boundary That boundary defined by a 1046 meter (0.65 mile) radius around the plant (ref. 4.1.7).
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.
to 0CAN031801 Page 18 of 255 Unusual Event Events are in progress or have occurred which indicate a potential degradation in 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.
Valid An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
Visible Damage Damage to a SAFETY SYSTEM train 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 SAFETY SYSTEM train.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.
5.2        Abbreviations/Acronyms
&deg;F .................................................................................................................... Degrees Fahrenheit
&deg;......................................................................................................................................... Degrees AC ..................................................................................................................... Alternating Current ANO ............................................................................................................ Arkansas Nuclear One AOP .............................................................................................. Abnormal Operating Procedure ATWS.................................................................................... Anticipated Transient Without Scram BMS ................................................................................................... Boron Management System BWST................................................................................................ Borated Water Storage Tank CDE ................................................................................................... Committed Dose Equivalent CET .......................................................................................................... Core Exit Thermocouple CFR................................................................................................... Code of Federal Regulations CIAS.................................................................................. Containment Isolation Actuation Signal CMT, CNTMT, CTMT ..................................................................................................Containment CNB ................................................................................................................ Containment Barrier DBA............................................................................................................. Design Basis Accident DBE......................................................................................................... Design Basis Earthquake to 0CAN031801 Page 19 of 255 DC .............................................................................................................................Direct Current DEF ...................................................................................................................................Defueled D/G....................................................................................................................... Diesel Generator DHR .............................................................................................................. Decay Heat Removal DROPS ............................................................ Diverse Reactor Overpressure Protection System DSC ............................................................................................................. Dry Shielded Canister DSS............................................................................................................ Diverse Scram System EAL .......................................................................................................... Emergency Action Level ECCS ......................................................................................... Emergency Core Cooling System ECL ............................................................................................... Emergency Classification Level DEF ...................................................................................................................................Defueled ENS............................................................................................... Emergency Notification System EOF................................................................................................ Emergency Operations Facility EOP ........................................................................................... Emergency Operating Procedure EPA ............................................................................................ Environmental Protection Agency ERG ............................................................................................ Emergency Response Guideline EPIP ............................................................................. Emergency Plan Implementing Procedure ESAS ........................................................................... Engineered Safeguards Actuation System ESF ...................................................................................................... Engineered Safety Feature ESFAS .................................................................. Engineered Safety Features Actuation System FAA ............................................................................................... Federal Aviation Administration FBI ................................................................................................ Federal Bureau of Investigation FCB ...................................................................................................................... Fuel Clad Barrier FEMA ............................................................................ Federal Emergency Management Agency GE ................................................................................................................... General Emergency HPI ............................................................................................................. High Pressure Injection IC ...................................................................................................................... Initiating Condition IPEEE ............................. Individual Plant Examination of External Events (Generic Letter 88-20)
ISFSI ......................................................................... Independent Spent Fuel Storage Installation Keff ...................................................................................... Effective Neutron Multiplication Factor LCO................................................................................................Limiting Condition of Operation LER .............................................................................................................Licensee Event Report LOCA ...................................................................................................... Loss of Coolant Accident LRW ....................................................................................................................Liquid Rad Waste to 0CAN031801 Page 20 of 255 LTOP............................................................................................ Low Temperature Overpressure LWR ................................................................................................................ Light Water Reactor MCC .............................................................................................................. Motor Control Center MPC ................................................ Maximum Permissible Concentration/Multi-Purpose Canister mR, mRem, mrem, mREM ............................................................ milli-Roentgen Equivalent Man MSL...................................................................................................................... Main Steam Line MTS ................................................................................................................ Margin to Saturation MW.................................................................................................................................. Megawatt NDTT ...................................................................................... Nil Ductility Transition Temperature NEI ............................................................................................................Nuclear Energy Institute NEIC ................................................................................ National Earthquake Information Center NESP ................................................................................ National Environmental Studies Project NORAD ................................................................ North American Aerospace Defense Command NOT .............................................................................................. Normal Operating Temperature (NO)UE ............................................................................................. Notification of Unusual Event NPP................................................................................................................ Nuclear Power Plant NRC ............................................................................................ Nuclear Regulatory Commission NSSS ............................................................................................. Nuclear Steam Supply System OBE ................................................................................................... Operating Basis Earthquake OCA ........................................................................................................... Owner Controlled Area ODCM ........................................................................................ Off-site Dose Calculation Manual ORO ............................................................................................... Offsite Response Organization PA ........................................................................................................................... Protected Area PAG ..................................................................................................... Protective Action Guideline PRA/PSA .................................. Probabilistic Risk Assessment / Probabilistic Safety Assessment P-T .............................................................................................................. Pressure-Temperature PTS ..................................................................................................... Pressurized Thermal Shock PWR..................................................................................................... Pressurized Water Reactor PSIG ............................................................................................ Pounds per Square Inch Gauge R ..................................................................................................................................... Roentgen RB .........................................................................................................................Reactor Building RCC ......................................................................................................... Reactor Control Console RCB ............................................................................................. Reactor Coolant System Barrier RCP ............................................................................................................ Reactor Coolant Pump to 0CAN031801 Page 21 of 255 RCS ......................................................................................................... Reactor Coolant System Rem, rem, REM ..................................................................................... Roentgen Equivalent Man Rep CET ....................................................................... Representative Core Exit Thermocouples RETS ...................................................................... Radiological Effluent Technical Specifications RPS...................................................................................................... Reactor Protection System RV ...........................................................................................................................Reactor Vessel RVLMS........................................................................... Reactor Vessel Level Monitoring System RWT ............................................................................................................. Refueling Water Tank SAR.............................................................................................................Safety Analysis Report SBO ...................................................................................................................... Station Blackout SCBA ................................................................................... Self-Contained Breathing Apparatus SDC ................................................................................................................... Shutdown Cooling SOCA ........................................................................................... Security Owner Controlled Area SG ....................................................................................................................... Steam Generator SI............................................................................................................................ Safety Injection SPDS ........................................................................................ Safety Parameter Display System SPING ..................................................................................... Super Particulate Iodine Noble Gas SRO ......................................................................................................... Senior Reactor Operator TEDE ............................................................................................ Total Effective Dose Equivalent TOAF ................................................................................................................. Top of Active Fuel TSC ........................................................................................................ Technical Support Center USGS .......................................................................................... United States Geological Survey VBS ............................................................................................................ Vehicle Barrier System to 0CAN031801 Page 22 of 255 6.0    ANO-TO-NEI 99-01 REV. 6 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of an ANO EAL within the NEI 99-01 IC/EAL identification scheme. Further information regarding the development of the ANO EALs based on the NEI guidance can be found in the EAL Comparison Matrix.
ANO                    NEI 99-01 Rev. 6 EAL              IC            Example EAL AU1.1            AU1                  1, 2 AU1.2            AU1                  3 AU2.1            AU2                  1 AA1.1            AA1                  1 AA1.2            AA1                  2 AA1.3            AA1                  3 AA1.4            AA1                  4 AA2.1            AA2                  1 AA2.2            AA2                  2 AA2.3            AA2                  3 AA3.1            AA3                  1 AA3.2            AA3                  2 AS1.1            AS1                  1 AS1.2            AS1                  2 AS1.3            AS1                  3 AS2.1            AS2                  1 AG1.1            AG1                  1 AG1.2            AG1                  2 AG1.3            AG1                  3 AG2.1            AG2                  1 CU1.1            CU1                  1 CU1.2            CU1                  2 CU2.1            CU2                  1 CU3.1            CU3                  1 CU3.2            CU3                  2 CU4.1            CU4                  1 to 0CAN031801 Page 23 of 255 ANO      NEI 99-01 Rev. 6 EAL  IC        Example EAL CU5.1 CU5            1, 2, 3 CA1.1 CA1              1 CA1.2 CA1              2 CA2.1 CA2              1 CA3.1 CA3            1, 2 CA6.1 CA6              1 CS1.1 CS1              1 CS1.2 CS1              2 CS1.3 CS1              3 CG1.1 CG1              1 CG1.2 CG1              2 EU1.1 EU1              1 FA1.1 FA1              1 FS1.1 FS1              1 FG1.1 FG1              1 HU1.1 HU1            1, 2, 3 HU2.1 HU2              1 HU3.1 HU3              1 HU3.2 HU3              2 HU3.3 HU3              3 HU3.4 HU3              4 HU4.1 HU4              1 HU4.2 HU4              2 HU4.3 HU4              3 HU4.4 HU4              4 HU7.1 HU7              1 HA1.1 HA1            1, 2 HA5.1 HA5              1 HA6.1 HA6              1 HA7.1 HA7              1 HS1.1 HS1              1 to 0CAN031801 Page 24 of 255 ANO                NEI 99-01 Rev. 6 EAL          IC          Example EAL HS6.1          HS6                  1 HS7.1          HS7                  1 HG7.1          HG7                  1 SU1.1          SU1                  1 SU3.1          SU2                  1 SU4.1          SU3                  1 SU4.2          SU3                  2 SU5.1          SU4              1, 2, 3 SU6.1          SU5                  1 SU6.2          SU5                  2 SU7.1          SU6              1, 2, 3 SU8.1          SU7                1, 2 SA1.1        SA1                  1 SA3.1        SA2                  1 SA6.1        SA5                  1 SA9.1        SA9                  1 SS1.1        SS1                  1 SS2.1        SS8                  1 SS6.1        SS5                  1 SG1.1          SG1                  1 SG1.2          SG8                  1 7.0  ATTACHMENTS 7.1  Attachment 1, Emergency Action Level Technical Bases 7.2  Attachment 2, Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases to 0CAN031801 Page 25 of 255 Attachment 1 - Emergency Action Level Technical Bases Category A - Abnormal Rad Levels / Rad Effluent EAL Group:        ANY (EALs in this category are applicable to any plant condition, hot or cold.)
Many EALs are based on actual or potential degradation of fission product barriers because of the elevated potential for offsite radioactivity release. Degradation of fission product barriers though is not always apparent via non-radiological symptoms. Therefore, direct indication of elevated radiological effluents or area radiation levels are appropriate symptoms for emergency classification.
At lower levels, abnormal radioactivity releases may be indicative of a failure of containment systems or precursors to more significant releases. At higher release rates, offsite radiological conditions may result which require offsite protective actions. Elevated area radiation levels in plant may also be indicative of the failure of containment systems or preclude access to plant vital equipment necessary to ensure plant safety.
Events of this category pertain to the following subcategories:
: 1. Radiological Effluent Direct indication of effluent radiation monitoring systems provides a rapid assessment mechanism to determine releases in excess of classifiable limits. Projected offsite doses, actual offsite field measurements or measured release rates via sampling indicate doses or dose rates above classifiable limits.
: 2. Irradiated Fuel Event Conditions indicative of a loss of adequate shielding or damage to irradiated fuel may preclude access to vital plant areas or result in radiological releases that warrant emergency classification.
: 3. Area Radiation Levels Sustained general area radiation levels which may preclude access to areas requiring continuous occupancy also warrant emergency classification.
to 0CAN031801 Page 26 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                          A - Abnormal Rad Levels / Rad Effluent Subcategory:                      1 - Radiological Effluent Initiating Condition:              Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:
AU1.1            Unusual Event Reading on any Table 1[2]A-1 effluent radiation monitor > column "UE" for  60 min.
(Notes 1, 2, 3)
Note 1:        The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:        If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Note 3:        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.
Table 1A-1        Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE                SAE              Alert              UE RX-9820 Containment Purge                4.15E+01 Ci/cc    4.15E+00 &#xb5;Ci/cc    4.15E-01 &#xb5;Ci/cc  1.21E-03 &#xb5;Ci/cc (SPING 1)
RX-9825 Radwaste Area                    2.67E+01 Ci/cc    2.67E+00 &#xb5;Ci/cc    2.67E-01 &#xb5;Ci/cc  4.94E-04 &#xb5;Ci/cc Gaseous (SPING 2)
RX-9830 Fuel Handling Area              6.20E+02 Ci/cc    6.20E+01 &#xb5;Ci/cc    6.20E+00 &#xb5;Ci/cc  5.44E-04 &#xb5;Ci/cc (SPING 3)
Emergency            RX-9835 6.55E+02 Ci/cc    6.55E+01 &#xb5;Ci/cc    6.55E+00 &#xb5;Ci/cc  1.21E-02 &#xb5;Ci/cc Penetration Room    (SPING 4)
Liquid Liquid Radwaste      RE-4642          ----              ----              ----        2.46E+05 cpm to 0CAN031801 Page 27 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1        Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE              SAE              Alert              UE 2RX-9820 Containment Purge                1.88E+01 Ci/cc  1.88E+00 &#xb5;Ci/cc  1.88E-01 &#xb5;Ci/cc  5.48E-04 &#xb5;Ci/cc (SPING 5) 2RX-9825 Radwaste Area                    2.35E+01 Ci/cc  2.35E+00 &#xb5;Ci/cc  2.35E-01 &#xb5;Ci/cc  4.35E-04 &#xb5;Ci/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area              6.86E+02 Ci/cc  6.86E+01 &#xb5;Ci/cc  6.86E+00 &#xb5;Ci/cc  6.04E-04 &#xb5;Ci/cc (SPING 7)
Emergency            2RX-9835 5.88E+02 Ci/cc  5.88E+01 &#xb5;Ci/cc  5.88E+00 &#xb5;Ci/cc  1.09E-02 &#xb5;Ci/cc Penetration Room    (SPING 8)
BMS Liquid 2RE-2330          ----              ----              ----        2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423          ----              ----              ----        2.45E+05 cpm Waste Discharge Mode Applicability:
All Definition(s):
VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
Basis:
This IC addresses a potential decrease reduction 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.
to 0CAN031801 Page 28 of 255 Attachment 1 - Emergency Action Level Technical Bases 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.
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.
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 - This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways .
EAL #2 - This EAL addressesas well as radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit.
This EAL will Such releases are typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).
EAL #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 AA1.
Reference(s):
: 1. OP-1604.051 Eberline Radiation Monitor System
: 2. Offsite Dose Calculation Manual
: 3. EP-CALC-ANO-1701 Radiological Effluent EAL Values
: 4. NEI 99-01 AU1 to 0CAN031801 Page 29 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                1 - Radiological Effluent Initiating Condition:        Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:
AU1.2      Unusual Event Sample analysis for a gaseous or liquid release indicates a concentration or release rate 2 x ODCM limits for  60 min. (Notes 1, 2)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:  If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Mode Applicability:
All Definition(s):
None Basis:
This IC addresses a potential decrease reduction 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.
to 0CAN031801 Page 30 of 255 Attachment 1 - Emergency Action Level Technical Bases 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.
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 - This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways.
EAL #2 - 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).
EAL #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 AA1.
Reference(s):
: 1. Offsite Dose Calculation Manual
: 2. NEI 99-01 AU1 to 0CAN031801 Page 31 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                          A - Abnormal Rad Levels / Rad Effluent Subcategory:                      1 - Radiological Effluent Initiating Condition:              Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:
AA1.1            Alert Reading on any Table 1[2]A-1 effluent radiation monitor > column "ALERT" for  15 min.
(Notes 1, 2, 3, 4)
Note 1:        The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:        If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Note 3:        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.
Note 4          The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
Table 1A-1        Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE                SAE              Alert              UE RX-9820 Containment Purge                4.15E+01 Ci/cc    4.15E+00 &#xb5;Ci/cc    4.15E-01 &#xb5;Ci/cc  1.21E-03 &#xb5;Ci/cc (SPING 1)
RX-9825 Radwaste Area                    2.67E+01 Ci/cc    2.67E+00 &#xb5;Ci/cc    2.67E-01 &#xb5;Ci/cc  4.94E-04 &#xb5;Ci/cc Gaseous (SPING 2)
RX-9830 Fuel Handling Area              6.20E+02 Ci/cc    6.20E+01 &#xb5;Ci/cc    6.20E+00 &#xb5;Ci/cc  5.44E-04 &#xb5;Ci/cc (SPING 3)
Emergency            RX-9835 6.55E+02 Ci/cc    6.55E+01 &#xb5;Ci/cc    6.55E+00 &#xb5;Ci/cc  1.21E-02 &#xb5;Ci/cc Penetration Room    (SPING 4)
Liquid Liquid Radwaste      RE-4642          ----              ----              ----        2.46E+05 cpm to 0CAN031801 Page 32 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1        Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE              SAE              Alert              UE 2RX-9820 Containment Purge                1.88E+01 Ci/cc  1.88E+00 &#xb5;Ci/cc  1.88E-01 &#xb5;Ci/cc  5.48E-04 &#xb5;Ci/cc (SPING 5) 2RX-9825 Radwaste Area                    2.35E+01 Ci/cc  2.35E+00 &#xb5;Ci/cc  2.35E-01 &#xb5;Ci/cc  4.35E-04 &#xb5;Ci/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area              6.86E+02 Ci/cc  6.86E+01 &#xb5;Ci/cc  6.86E+00 &#xb5;Ci/cc  6.04E-04 &#xb5;Ci/cc (SPING 7)
Emergency            2RX-9835 5.88E+02 Ci/cc  5.88E+01 &#xb5;Ci/cc  5.88E+00 &#xb5;Ci/cc  1.09E-02 &#xb5;Ci/cc Penetration Room    (SPING 8)
BMS Liquid 2RE-2330          ----              ----              ----        2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423          ----              ----              ----        2.45E+05 cpm Waste Discharge Mode Applicability:
All Definition(s):
VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
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.
to 0CAN031801 Page 33 of 255 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
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.
Escalation of the emergency classification level would be via IC AS1.
Reference(s):
: 1. OP-1604.051 Eberline Radiation Monitor System
: 2. EP-CALC-ANO-1701 Radiological Effluent EAL Values
: 3. NEI 99-01 AA1 to 0CAN031801 Page 34 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  A - Abnormal Rad Levels / Rad Effluent Subcategory:                1 - Radiological Effluent Initiating Condition:      Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:
AA1.2      Alert Dose assessment using actual meteorology indicates doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY. (Note 4)
Note 4:  The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
Mode Applicability:
All Definition(s):
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.
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 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
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.
to 0CAN031801 Page 35 of 255 Attachment 1 - Emergency Action Level Technical Bases Escalation of the emergency classification level would be via IC AS1.
Reference(s):
: 1. OP-1904.002 Offsite Dose Projections
: 2. NEI 99-01 AA1 to 0CAN031801 Page 36 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                1 - Radiological Effluent Initiating Condition:        Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:
AA1.3      Alert Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY for 60 min. of exposure. (Notes 1, 2)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:  If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Mode Applicability:
All Definition(s):
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.
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 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
to 0CAN031801 Page 37 of 255 Attachment 1 - Emergency Action Level Technical Bases 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 EAL is assessed per the ODCM (ref. 2).
Escalation of the emergency classification level would be via IC AS1.
Reference(s):
: 1. OP-1904.002 Offsite Dose Projections
: 2. Offsite Dose Calculation Manual
: 3. NEI 99-01 AA1 to 0CAN031801 Page 38 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                  1 - Radiological Effluent Initiating Condition:        Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:
AA1.4        Alert Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:
Closed window dose rates > 10 mR/hr expected to continue for  60 min.
Analyses of field survey samples indicate thyroid CDE > 50 mrem for 60 min. of inhalation.
(Notes 1, 2)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:    If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Mode Applicability:
All Definition(s):
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.
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.
to 0CAN031801 Page 39 of 255 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
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.
Escalation of the emergency classification level would be via IC AS1.
Reference(s):
: 1. OP-1905.002 Offsite Emergency Monitoring
: 2. NEI 99-01 AA1 to 0CAN031801 Page 40 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                          A - Abnormal Rad Levels / Rad Effluent Subcategory:                      1 - Radiological Effluent Initiating Condition:              Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:
AS1.1            Site Area Emergency Reading on any Table A-1 effluent radiation monitor > column "SAE" for  15 min.
(Notes 1, 2, 3, 4)
Note 1:        The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:        If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Note 3:        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.
Note 4:        The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
Table 1A-1        Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE                SAE              Alert              UE RX-9820 Containment Purge                4.15E+01 Ci/cc    4.15E+00 &#xb5;Ci/cc    4.15E-01 &#xb5;Ci/cc  1.21E-03 &#xb5;Ci/cc (SPING 1)
RX-9825 Radwaste Area                    2.67E+01 Ci/cc    2.67E+00 &#xb5;Ci/cc    2.67E-01 &#xb5;Ci/cc  4.94E-04 &#xb5;Ci/cc Gaseous (SPING 2)
RX-9830 Fuel Handling Area              6.20E+02 Ci/cc    6.20E+01 &#xb5;Ci/cc    6.20E+00 &#xb5;Ci/cc  5.44E-04 &#xb5;Ci/cc (SPING 3)
Emergency            RX-9835 6.55E+02 Ci/cc    6.55E+01 &#xb5;Ci/cc    6.55E+00 &#xb5;Ci/cc  1.21E-02 &#xb5;Ci/cc Penetration Room    (SPING 4)
Liquid Liquid Radwaste      RE-4642          ----              ----              ----        2.46E+05 cpm to 0CAN031801 Page 41 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1        Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE              SAE              Alert              UE 2RX-9820 Containment Purge                1.88E+01 Ci/cc  1.88E+00 &#xb5;Ci/cc  1.88E-01 &#xb5;Ci/cc  5.48E-04 &#xb5;Ci/cc (SPING 5) 2RX-9825 Radwaste Area                    2.35E+01 Ci/cc  2.35E+00 &#xb5;Ci/cc  2.35E-01 &#xb5;Ci/cc  4.35E-04 &#xb5;Ci/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area              6.86E+02 Ci/cc  6.86E+01 &#xb5;Ci/cc  6.86E+00 &#xb5;Ci/cc  6.04E-04 &#xb5;Ci/cc (SPING 7)
Emergency            2RX-9835 5.88E+02 Ci/cc  5.88E+01 &#xb5;Ci/cc  5.88E+00 &#xb5;Ci/cc  1.09E-02 &#xb5;Ci/cc Penetration Room    (SPING 8)
BMS Liquid 2RE-2330          ----              ----              ----        2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423          ----              ----              ----        2.45E+05 cpm Waste Discharge Mode Applicability:
All Definition(s):
VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
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.
to 0CAN031801 Page 42 of 255 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
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.
Escalation of the emergency classification level would be via IC AG1.
Reference(s):
: 1. OP-1604.051 Eberline Radiation Monitor System
: 2. EP-CALC-ANO-1701 Radiological Effluent EAL Values
: 3. NEI 99-01 AS1 to 0CAN031801 Page 43 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                1 - Radiological Effluent Initiating Condition:        Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:
AS1.2      Site Area Emergency Dose assessment using actual meteorology indicates doses > 100 mrem TEDE or 500 mrem thyroid CDE at or beyond the SITE BOUNDARY. (Note 4)
Note 4    The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
Mode Applicability:
All Definition(s):
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant).
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 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
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.
Escalation of the emergency classification level would be via IC AG1.
to 0CAN031801 Page 44 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. OP-1904.002 Offsite Dose Projections
: 2. NEI 99-01 AS1 to 0CAN031801 Page 45 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                  1 - Radiological Effluent Initiating Condition:        Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:
AS1.3        Site Area Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:
Closed window dose rates > 100 mR/hr expected to continue for  60 min.
Analyses of field survey samples indicate thyroid CDE > 500 mrem for 60 min. of inhalation.
(Notes 1, 2)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:    If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Mode Applicability:
All Definition(s):
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.
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 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
to 0CAN031801 Page 46 of 255 Attachment 1 - Emergency Action Level Technical Bases 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.
Escalation of the emergency classification level would be via IC AG1.
Reference(s):
: 1. OP-1905.002 Offsite Emergency Monitoring
: 2. NEI 99-01 AS1 to 0CAN031801 Page 47 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                          A - Abnormal Rad Levels / Rad Effluent Subcategory:                      1 - Radiological Effluent Initiating Condition:              Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:
AG1.1            General Emergency Reading on any Table A-1 effluent radiation monitor > column "GE" for  15 min.
(Notes 1, 2, 3, 4)
Note 1:        The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:        If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Note 3:        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.
Note 4:        The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
Table 1A-1        Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE                SAE              Alert              UE RX-9820 Containment Purge                4.15E+01 Ci/cc    4.15E+00 &#xb5;Ci/cc    4.15E-01 &#xb5;Ci/cc  1.21E-03 &#xb5;Ci/cc (SPING 1)
RX-9825 Radwaste Area                    2.67E+01 Ci/cc    2.67E+00 &#xb5;Ci/cc    2.67E-01 &#xb5;Ci/cc  4.94E-04 &#xb5;Ci/cc Gaseous (SPING 2)
RX-9830 Fuel Handling Area              6.20E+02 Ci/cc    6.20E+01 &#xb5;Ci/cc    6.20E+00 &#xb5;Ci/cc  5.44E-04 &#xb5;Ci/cc (SPING 3)
Emergency            RX-9835 6.55E+02 Ci/cc    6.55E+01 &#xb5;Ci/cc    6.55E+00 &#xb5;Ci/cc  1.21E-02 &#xb5;Ci/cc Penetration Room    (SPING 4)
Liquid Liquid Radwaste      RE-4642          ----              ----              ----        2.46E+05 cpm to 0CAN031801 Page 48 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1        Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE              SAE              Alert              UE 2RX-9820 Containment Purge                1.88E+01 Ci/cc  1.88E+00 &#xb5;Ci/cc  1.88E-01 &#xb5;Ci/cc  5.48E-04 &#xb5;Ci/cc (SPING 5) 2RX-9825 Radwaste Area                    2.35E+01 Ci/cc  2.35E+00 &#xb5;Ci/cc  2.35E-01 &#xb5;Ci/cc  4.35E-04 &#xb5;Ci/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area              6.86E+02 Ci/cc  6.86E+01 &#xb5;Ci/cc  6.86E+00 &#xb5;Ci/cc  6.04E-04 &#xb5;Ci/cc (SPING 7)
Emergency            2RX-9835 5.88E+02 Ci/cc  5.88E+01 &#xb5;Ci/cc  5.88E+00 &#xb5;Ci/cc  1.09E-02 &#xb5;Ci/cc Penetration Room    (SPING 8)
BMS Liquid 2RE-2330          ----              ----              ----        2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423          ----              ----              ----        2.45E+05 cpm Waste Discharge Mode Applicability:
All Definition(s):
VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
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.
to 0CAN031801 Page 49 of 255 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
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.
Reference(s):
: 1. OP-1604.051 Eberline Radiation Monitor System
: 2. EP-CALC-ANO-1701 Radiological Effluent EAL Values
: 3. NEI 99-01 AG1 to 0CAN031801 Page 50 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                1 - Radiological Effluent Initiating Condition:        Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:
AG1.2      General Emergency Dose assessment using actual meteorology indicates doses > 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)
Note 4    The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
Mode Applicability:
All Definition(s):
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant).
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 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
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.
to 0CAN031801 Page 51 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. OP-1904.002 Offsite Dose Projections
: 2. NEI 99-01 AG1 to 0CAN031801 Page 52 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                1 - Radiological Effluent Initiating Condition:        Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:
AG1.3      General Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:
Closed window dose rates > 1,000 mR/hr expected to continue for  60 min.
Analyses of field survey samples indicate thyroid CDE > 5,000 mrem for 60 min. of inhalation (Notes 1, 2)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:  If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Mode Applicability:
All Definition(s):
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.
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 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
to 0CAN031801 Page 53 of 255 Attachment 1 - Emergency Action Level Technical Bases 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.
Reference(s):
: 1. OP-1905.002 Offsite Emergency Monitoring
: 2. NEI 99-01 AG1 to 0CAN031801 Page 54 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                A - Abnormal Rad Levels / Rad Effluent Subcategory:              2 - Irradiated Fuel Event Initiating Condition:    UNPLANNED loss of water level above irradiated fuel EAL:
AU2.1      Unusual Event UNPLANNED water level drop in the REFUELING PATHWAY as indicated by low water level alarm, visual observation, or BWST[RWT] level drop due to makeup demands AND UNPLANNED rise in corresponding area radiation levels as indicated by any of the following radiation monitors:
Unit 1 o  RE-8009 Spent Fuel Area o  RE-8017 Fuel Handling Area Unit 2 o  2RE-8914 Spent Fuel Area o  2RE-8915 Spent Fuel Area o  2RE-8916 Spent Fuel Area o  2RE-8912 Containment Incore Instrumentation Mode Applicability:
All Definition(s):
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, but not including the reactor vessel.
to 0CAN031801 Page 55 of 255 Attachment 1 - Emergency Action Level Technical Bases Basis:
This IC addresses a decrease drop 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 decrease drop 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). A significant drop in the water level may also cause an increase a rise in the radiation levels of adjacent areas that can be detected by monitors in those locations.
The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may increase rise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.
A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.
Escalation of the emergency classification level would be via IC AA2.
Reference(s):
: 1. OP-1203.050 Unit 1 Spent Fuel Pool Emergencies
: 2. OP-2203.002 Spent Fuel Pool Emergencies
: 3. 1SAR 11.2.5 Area Radiation Monitoring Systems Table 11-15 Area Radiation Monitors
: 4. 2SAR 12.1.4 Area Radiation Monitoring System
: 5. NEI 99-01 AU2 to 0CAN031801 Page 56 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                2 - Irradiated Fuel Event Initiating Condition:        Significant lowering of water level above, or damage to, irradiated fuel EAL:
AA2.1      Alert IMMINENT uncovery of irradiated fuel in the REFUELING PATHWAY.
Mode Applicability:
All Definition(s):
CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).
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.
REFUELING PATHWAY - All the cavities, tubes, canals and pools through which irradiated fuel may be moved, but not including the reactor vessel.
Basis:
This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel poolREFUELING PATHWAY (see Developer Notes). 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 to 0CAN031801 Page 57 of 255 Attachment 1 - Emergency Action Level Technical Bases This EAL escalates from AU2 AU2.1 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 an increasea rise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss.
A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance with Recognition Category C during the Cold Shutdown and Refueling modes.
EAL #2 This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).
EAL #3 Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.
Escalation of the emergency classification level would be via ICs AS1 AS1or AS2 (see AS2 Developer Notes).
Reference(s):
: 1. NEI 99-01 AA2 to 0CAN031801 Page 58 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                A - Abnormal Rad Levels / Rad Effluent Subcategory:              2 - Irradiated Fuel Event Initiating Condition:    Significant lowering of water level above, or damage to, irradiated fuel EAL:
AA2.2      Alert Damage to irradiated fuel resulting in a release of radioactivity AND High alarm on any Table 1[2]A-2 radiation monitor.
Table 1A-2      Unit 1 Fuel Damage Radiation Monitors RE-8009 Spent Fuel Area RE-8017 Fuel Handling RE-8060 Containment High Range Radiation Monitors RE-8061 Containment High Range Radiation Monitors RX-9820 (SPING 1) Containment Purge RX-9825 (SPING 2) Radwaste Area RX-9830 (SPING 3) Fuel Handling Area Table 2A-2      Unit 2 Fuel Damage Radiation Monitors 2RE-8905 Containment Equipment Hatch Area 2RE-8909 Containment Personnel Access Area 2RE-8912 Containment Incore Inst.
2RE-8914 Spent Fuel Area 2RE-8915 Spent Fuel Area 2RE-8916 Spent Fuel Area 2RE-8925-1 Containment High Range Radiation Monitors 2RE-8925-2 Containment High Range Radiation Monitors 2RX-9820 (SPING 5) Containment Purge 2RX-9825 (SPING 6) Radwaste Area 2RX-9830 (SPING 7) Fuel Handling Area to 0CAN031801 Page 59 of 255 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:
All Definition(s):
CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).
VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
Basis:
This IC EAL addresses events that have caused imminent or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool (see Developer Notes). 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 EAL 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.
EAL #This EAL escalates from AU2 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 an increase 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.
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 to 0CAN031801 Page 60 of 255 Attachment 1 - Emergency Action Level Technical Bases considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident). EAL #3Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.
Escalation of the emergency classification level would be via ICs AS1 or AS2 (see AS2 Developer Notes).
Reference(s):
: 1. OP-1203.050 Unit 1 Spent Fuel Pool Emergencies
: 2. OP-1305.001 Radiation Monitoring System Check and Test
: 3. OP-2203.002 Spent Fuel Pool Emergencies
: 4. OP-1604.051 Eberline Radiation Monitoring System
: 5. OP-2304.133 Containment High Range Radiation Monitor Calibration
: 6. Offsite Dose Calculation Manual
: 7. NEI 99-01 AA2 to 0CAN031801 Page 61 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                2 - Irradiated Fuel Event Initiating Condition:        Significant lowering of water level above, or damage to, irradiated fuel EAL:
AA2.3      Alert Lowering of spent fuel pool level to 387.0 ft. [389.5 ft.] (Alarm 2) on LIT-2020-3(4)
[2LIT-2020-1(2)]
Mode Applicability:
All Definition(s):
None Basis:
This IC EAL addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool (see Developer Notes). 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
#This EAL escalates from AU2 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 an increase 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.
to 0CAN031801 Page 62 of 255 Attachment 1 - Emergency Action Level Technical Bases 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.
This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).
EAL #3Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.
Escalation of the emergency classification level would be via ICs AS1 or AS2 (see AS2 Developer Notes).
Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).
Reference(s):
: 1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0
: 2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0
: 3. NEI 99-01 AA2 to 0CAN031801 Page 63 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                2 - Irradiated Fuel Event Initiating Condition:        Spent fuel pool level at the top of the fuel racks EAL:
AS2.1      Site Area Emergency Lowering of spent fuel pool level to 377.0 ft. [379.5 ft.] (Alarm 3) on LIT-2020-3(4)
[2LIT-2020-1(2)]
Mode Applicability:
All Definition(s):
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.
Basis:
This IC EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to IMMINENT fuel damage. This condition entails major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.
It is recognized that this IC would likely not be met until well after another Site Area Emergency IC was met; however, it is included to provide classification diversity.
Escalation of the emergency classification level would be via IC AG1 or AG2A.
Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).
Reference(s):
: 1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0
: 2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0
: 3. NEI 99-01 AS2 to 0CAN031801 Page 64 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                2 - Irradiated Fuel Event Initiating Condition:        Spent fuel pool level cannot be restored to at least the top of the fuel racks for 60 minutes or longer EAL:
AG2.1      General Emergency Spent fuel pool level cannot be restored to at least 377.0 ft. [379.5 ft.] (Alarm 3) on LIT-2020-3(4) [2LIT-2020-1(2)] for  60 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
All Definition(s):
None Basis:
This IC EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment.
It is recognized that this IC would likely not be met until well after another General Emergency IC was met; however, it is included to provide classification diversity.
Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).
Reference(s):
: 1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0
: 2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0
: 3. NEI 99-01 AG2 to 0CAN031801 Page 65 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  A - Abnormal Rad Levels / Rad Effluent Subcategory:                3 - Area Radiation Levels Initiating Condition:      Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:
AA3.1    Alert Dose rate > 15 mR/hr in EITHER of the following areas:
Control Room Central Alarm Station (by survey)
Mode Applicability:
All Definition(s):
IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
Basis:
Areas that meet this threshold include the Control Room (CR) and the Central Alarm Station (CAS). The Control Room envelope (Unit 1 and Unit 2) is monitored for excessive radiation by five detectors. These radiation detectors are RE-8001, 2RE-8001A, 2RE-8001B, 2RE-8750-1A, and 2RE-8750-1B (ref. 1). The CAS is included in this EAL because of its importance to permitting access to areas required to assure safe plant operations. There are no permanently installed area radiation monitors in CAS that may be used to assess this EAL threshold.
Therefore, this threshold is evaluated using local radiation survey for this area.
This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or IMPEDE personnel from performing actions necessary to maintain normal plant operation, or to perform 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 rise in radiation levels and determine if another IC may be applicable. For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the elevated radiation levels. 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 to 0CAN031801 Page 66 of 255 Attachment 1 - Emergency Action Level Technical Bases affected room/area (e.g., installing temporary shielding, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).
An emergency declaration is not warranted if any of the following conditions apply.
The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation increase 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 A, C or F ICs.
Reference(s):
: 1. STM 1-62 Radiation Monitoring
: 2. NEI 99-01 AA3 to 0CAN031801 Page 67 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                3 - Area Radiation Levels Initiating Condition:        Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:
AA3.2      Alert An UNPLANNED event results in radiation levels that prohibit or IMPEDE access to any Table 1[2]A-3 room or area (Note 5)
Note 5:  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.
Table 1A-3        Unit 1 Safe Operation & Shutdown Rooms/Areas Room/Area                            Mode A-4 Switchgear Room                                            3, 4 Upper North Electrical Penetration Room                        3, 4 Lower South Electrical Equipment Room                          3, 4 Table 2A-3        Unit 2 Safe Operation & Shutdown Rooms/Areas Room/Area                            Mode Aux Building 317 Emergency Core Cooling Rooms                  3, 4 Aux Building 317 Tendon Gallery Access                        3, 4 Aux Building 335 Charging Pumps / MCC 2B-52                    3, 4 Aux Building 354 MCC 2B-62 Area                                3, 4 Emergency Diesel Generator Corridor                            3, 4 Lower South Piping Penetration Room                            3, 4 Aux Building 386 Containment Hatch                            3, 4 to 0CAN031801 Page 68 of 255 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:
3 - Hot Standby, 4 - Hot Shutdown Definition(s):
IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
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.
Basis:
This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or IMPEDE personnel from performing actions necessary to maintain normal plant operation, or to perform 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 rise in radiation levels and determine if another IC may be applicable.
For EAL #2 AA3.2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the elevated radiation levels. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased higher 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, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).
An emergency declaration is not warranted if any of the following conditions apply:
The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation increase rise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 43.
The increased higher 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.
to 0CAN031801 Page 69 of 255 Attachment 1 - Emergency Action Level Technical Bases Escalation of the emergency classification level would be via Recognition Category A, C or F ICs.
If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact beyond that already allowed by Technical Specifications at the time of the event.
The list of plant rooms or areas with entry-related mode applicability identified specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations) are not included. In addition, the list specifies the plant mode(s) during which entry would be required for each room or area (ref. 1).
EAL AA3.2 mode applicability has been limited to the mode limitations of Table 1[2]A-3 (Modes 3 and 4 only).
Reference(s):
: 1. Attachment 2 Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases
: 2. NEI 99-01 AA3 to 0CAN031801 Page 70 of 255 Attachment 1 - Emergency Action Level Technical Bases Category C - Cold Shutdown / Refueling System Malfunction EAL Group:        Cold Conditions (RCS temperature  200&deg;F); EALs in this category are applicable only in one or more cold operating modes.
Category C EALs are directly associated with cold shutdown or refueling system safety functions. Given the variability of plant configurations (e.g., systems out-of-service for maintenance, containment open, reduced AC power redundancy, time since shutdown) during these periods, the consequences of any given initiating event can vary greatly. For example, a loss of decay heat removal capability that occurs at the end of an extended outage has less significance than a similar loss occurring during the first week after shutdown. Compounding these events is the likelihood that instrumentation necessary for assessment may also be inoperable. The cold shutdown and refueling system malfunction EALs are based on performance capability to the extent possible with consideration given to RCS integrity, CONTAINMENT CLOSURE, and fuel clad integrity for the applicable operating modes (5 - Cold Shutdown, 6 - Refueling, DEF - Defueled).
The events of this category pertain to the following subcategories:
: 1. RCS Level RCS water level is directly related to the status of adequate core cooling and, therefore, fuel clad integrity.
: 2. Loss of Vital AC Power Loss of vital plant electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite power sources for 4.16 KV vital buses.
: 3. RCS Temperature Uncontrolled or inadvertent temperature or pressure rises are indicative of a potential loss of safety functions.
: 4. Loss of Vital DC Power Loss of emergency plant electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of power to or degraded voltage on the 125V DC vital buses.
: 5. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.
: 6. Hazardous Event Affecting Safety Systems Certain hazardous natural and technological events may result in VISIBLE DAMAGE to or degraded performance of safety systems warranting classification.
to 0CAN031801 Page 71 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                1 - RCS Level Initiating Condition:        UNPLANNED loss of RCS inventory EAL:
CU1.1      Unusual Event UNPLANNED loss of reactor coolant results in RCS water level less than a required lower limit for  15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
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.
Basis:
This IC EAL addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor (reactor vessel/RCS
[PWR] or RPV [BWR]) level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.
Refueling evolutions that decreaselower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level decreasinglowering below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.
This EAL #1 recognizes that the minimum required (reactor vessel/RCS [PWR] or RPV [BWR])
level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.
to 0CAN031801 Page 72 of 255 Attachment 1 - Emergency Action Level Technical Bases The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.
EAL #2 addresses a condition where all means to determine (reactor vessel/RCS [PWR] or RPV [BWR]) level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).
Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.
Reference(s):
: 1. OP-1015.002 Decay Heat Removal and LTOP System
: 2. OP-1015.008 Unit 2 SDC Control
: 3. NEI 99-01 CU1 to 0CAN031801 Page 73 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                C - Cold Shutdown / Refueling System Malfunction Subcategory:              1 - RCS Level Initiating Condition:    UNPLANNED loss of RCS inventory EAL:
CU1.2      Unusual Event RCS level cannot be monitored AND EITHER UNPLANNED rise in any Table 1[2]C-1 sump/tank level due to loss of RCS inventory Visual observation of UNISOLABLE RCS leakage Table 1C-1    Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank Table 2C-1    Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)
Holdup Tank Aux. Building Sump Quench Tank Mode Applicability:
5 - Cold Shutdown, 6 - Refueling to 0CAN031801 Page 74 of 255 Attachment 1 - Emergency Action Level Technical Bases Definition(s):
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.
Basis:
This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor (reactor vessel/RCS [PWR]
or RPV [BWR]) level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.
Refueling evolutions that decrease lower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level decreasing lowering below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.
EAL #1 recognizes that the minimum required (reactor vessel/RCS [PWR] or RPV [BWR]) level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.
The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.
This EAL #2 addresses a condition where all means to determine (reactor vessel/RCS [PWR] or RPV [BWR]) level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels (Table C-1). Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).
Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.
Reference(s):
: 1. OP-1203.039 Excess RCS Leakage
: 2. OP-2203.016 Excess RCS Leakage
: 3. NEI 99-01 CU1 to 0CAN031801 Page 75 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                1 - RCS Level Initiating Condition:        Significant Loss of RCS inventory EAL:
CA1.1      Alert Loss of RCS inventory as indicated by EITHER:
RVLMS Levels 1 through 8 [1 through 5] indicate DRY Reactor vessel level 368.5 ft. (LT-1195/LT-1196) [0 in. (L4791/L4792)] (bottom of hot leg)
Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
None Basis:
This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.
For this EAL #1, a lowering of RPV water level below (site-specific level) ft the specified level indicates that operator actions have not been successful in restoring and maintaining RCS (reactor vessel/RCS [PWR] or RPV [BWR]) water level. The heat-up rate of the coolant will increase rise as the available water inventory is reduced. A continuing decrease drop in water level will lead to core uncovery.
Although related, this EAL #1 is concerned with the loss of RPV inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Decay Heat Removal suction point). An increase rise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA3.
For EAL #2, the inability to monitor (reactor vessel/RCS [PWR] or RPV [BWR]) level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).
to 0CAN031801 Page 76 of 255 Attachment 1 - Emergency Action Level Technical Bases The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS1 If RCS the (reactor vessel/RCS [PWR] or RPV [BWR]) inventory water level continues to lower, then escalation to Site Area Emergency would be via IC CS1.
The bottom of the RCS hot leg penetration into the reactor vessel is approximately RLVMS Level 8 (Unit 1) or RVLMS Level 5 (Unit 2). However, RVLMS may not be available in the cold shutdown modes. Redundant means of level indication is provided in these modes and included in this EAL. The bottom of the RCS hot leg penetration into the reactor vessel is 368 ft., 0 in. (Unit 1) or 369 ft., 1.5 in. (Unit 2). Below this level, reactor vessel level indication may be lost and loss of suction to decay heat removal systems will occur (ref. 1, 2, 3). Where redundant means of level indication cannot read below this level, the lowest indication that can be read on scale is used for this EAL. The inability to restore and maintain level after reaching this setpoint would be indicative of a failure of the RCS barrier.
Reference(s):
: 1. OP-1105.008 Inadequate Core Cooling Monitor and Display
: 2. OP-2105.003 Reactor Vessel Level Monitoring System Operations
: 3. Calculation No. 90-E-0116-01 ANO-2 EOP Setpoint Basis Document, Setpoints R.3 and R.9
: 4. NEI 99-01 CA1 to 0CAN031801 Page 77 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  C - Cold Shutdown / Refueling System Malfunction Subcategory:                1 - RCS Level Initiating Condition:      Significant Loss of RCS inventory EAL:
CA1.2      Alert RCS level cannot be monitored for  15 min. (Note 1)
AND EITHER UNPLANNED rise in any Table 1[2]C-1 Sump / Tank level due to a loss of RCS inventory Visual observation of UNISOLABLE RCS leakage Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1C-1      Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank Table 2C-1      Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)
Holdup Tank Aux. Building Sump Quench Tank to 0CAN031801 Page 78 of 255 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
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.
Basis:
This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.
For EAL #1, a lowering of water level below (site-specific level) indicates that operator actions have not been successful in restoring and maintaining (reactor vessel/RCS [PWR] or RPV
[BWR]) water level. The heat-up rate of the coolant will increase as the available water inventory is reduced. A continuing decrease in water level will lead to core uncovery.
Although related, EAL #1 is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). An increase in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA3.
For this EAL #2, the inability to monitor RCS (reactor vessel/RCS [PWR] or RPV [BWR]) level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).
The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS1.
If the (reactor vessel/RCS [PWR] or RPV [BWR]) inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS1.
Reference(s):
: 1. OP-1203.039 Excess RCS Leakage
: 2. OP-2203.016 Excess RCS Leakage
: 3. NEI 99-01 CA1 to 0CAN031801 Page 79 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                1 - RCS Level Initiating Condition:        Loss of RCS inventory affecting core decay heat removal capability EAL:
CS1.1      Site Area Emergency CONTAINMENT CLOSURE not established AND RVLMS Levels 1 through 9 [1 through 6] indicate DRY Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
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.
Basis:
This IC addresses a significant and prolonged loss of (reactor vessel/RCS [PWR] or RPV
[BWR]) inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.
Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.
Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.
The difference in the specified RCS/reactor vessel levels of EALs 1.b and 2.b reflect the fact to 0CAN031801 Page 80 of 255 Attachment 1 - Emergency Action Level Technical Bases that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.
In EAL 3.a, the 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.
The inability to monitor (reactor vessel/RCS [PWR] or RPV [BWR]) level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).
Thisese EALs addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
Escalation of the emergency classification level would be via IC CG1 or AG1.
Reference(s):
: 1. OP-1105.008 Inadequate Core Cooling Monitor and Display
: 2. OP-2105.003 Reactor Vessel Level Monitoring System Operations
: 3. NEI 99-01 CS1 to 0CAN031801 Page 81 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  C - Cold Shutdown / Refueling System Malfunction Subcategory:                1 - RCS Level Initiating Condition:      Loss of RCS inventory affecting core decay heat removal capability EAL:
CS1.2      Site Area Emergency
[RVLMS Levels 1 through 7 indicate DRY OR]
RCS level cannot be monitored for  30 min. (Note 1)
AND Core uncovery is indicated by any of the following:
UNPLANNED rise in any Table 1[2]C-1 sump/tank level of sufficient magnitude to indicate core uncovery Containment high range radiation monitor RE-8060/8061 [2RE-8925-1/8925-2] reading
          > 10 R/hr Erratic Source Range Monitor indication Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1C-1      Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank to 0CAN031801 Page 82 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2C-1    Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)
Holdup Tank Aux. Building Sump Quench Tank Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
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.
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.
Basis:
When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.
Level 7 DRY on this system is an indication of core uncovery.
This IC addresses a significant and prolonged loss of (reactor vessel/RCS RCS [PWR] or RPV
[BWR]) inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.
to 0CAN031801 Page 83 of 255 Attachment 1 - Emergency Action Level Technical Bases Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.
Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.
The difference in the specified RCS/reactor vessel levels of EALs 1.b and 2.b CS1.1 and CS1.2 reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.
In EAL 3.a, Tthe 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.
The inability to monitor (reactor vessel/RCS [PWR] or RPV [BWR]) level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).
These This EALs addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
Containment High Range Radiation Monitors RE-8060/8061 [2RE-8925-1/8925-2] are the site-specific radiation monitors that would be indicative of possible core uncovery in the Refueling mode. The dose rate due to core shine when the top of the core becomes uncovered should result in dose rates > 10 R/hr.
Escalation of the emergency classification level would be via IC CG1 or AG1.
Reference(s):
: 1. OP-1203.039 Excess RCS Leakage
: 2. OP-2203.016 Excess RCS Leakage
: 3. OP-2105.003 Reactor Vessel Level Monitoring System Operations
: 4. 1SAR Table 7-11
: 5. 2SAR 12.1.4.2
: 6. NEI 99-01 CS1 to 0CAN031801 Page 84 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                  1 - RCS Level Initiating Condition:        Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL:
CG1.1        General Emergency - UNIT 2 ONLY RVLMS Levels 1 through 7 indicate DRY AND Any Containment Challenge indication, Table 2C-2 Note 6:    If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required.
Table 1[2]C-2 Containment Challenge Indications CONTAINMENT CLOSURE not established (Note 6)
Containment hydrogen concentration > 3%
UNPLANNED rise in containment pressure Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
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.
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.
to 0CAN031801 Page 85 of 255 Attachment 1 - Emergency Action Level Technical Bases Basis:
When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.
Level 7 DRY on this system is an indication of core uncovery.
This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.
Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.
With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.
The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.
In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.
In EAL 2.b, tThe 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.
The inability to monitor (reactor vessel/RCS [PWR] or RPV [BWR]) level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).
to 0CAN031801 Page 86 of 255 Attachment 1 - Emergency Action Level Technical Bases This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
Reference(s):
: 1. OP-1203.039 Excess RCS Leakage
: 2. OP-2203.016 Excess RCS Leakage
: 3. OP-2105.003 Reactor Vessel Level Monitoring System Operations
: 4. 1SAR Table 7-11
: 5. 2SAR 12.1.4.2
: 6. Unit 1 SAMG Figure III-1B
: 7. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart
: 8. NEI 99-01 CG1 to 0CAN031801 Page 87 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  C - Cold Shutdown / Refueling System Malfunction Subcategory:                1 - RCS Level Initiating Condition:      Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL:
CG1.2      General Emergency RCS level cannot be monitored for  30 min. (Note 1)
AND Core uncovery is indicated by any of the following:
UNPLANNED rise in any Table 1[2]C-1 sump/tank level of sufficient magnitude to indicate core uncovery Containment High Range Radiation Monitor RE-8060/8061 [2RE-8925-1/8925-2]
reading > 10 R/hr Erratic Source Range Monitor indication AND Any Containment Challenge indication, Table 1[2]C-2 Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 6:  If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required.
Table 1C-1      Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank to 0CAN031801 Page 88 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2C-1    Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)
Holdup Tank Aux. Building Sump Quench Tank Table 1[2]C-2 Containment Challenge Indications CONTAINMENT CLOSURE not established (Note 6)
Containment hydrogen concentration > 3%
UNPLANNED rise in containment pressure Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
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.
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.
to 0CAN031801 Page 89 of 255 Attachment 1 - Emergency Action Level Technical Bases Basis:
When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.
Level 7 DRY on this system is an indication of core uncovery.
This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.
Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.
With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.
The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.
In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.
In EAL 2.b, tThe 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.
The inability to monitor (reactor vessel/RCS [PWR] or RPV [BWR]) level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).
to 0CAN031801 Page 90 of 255 Attachment 1 - Emergency Action Level Technical Bases Containment High Range Radiation Monitor RE-8060/8061 [2RE-8925-1/8925-2] are the site-specific radiation monitors that would be indicative of possible core uncovery in the Refueling mode. The dose rate due to core shine when the top of the core becomes uncovered should result in dose rates > 10 R/hr.
This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
Reference(s):
: 1. OP-1203.039 Excess RCS Leakage
: 2. OP-2203.016 Excess RCS Leakage
: 3. OP-2105.003 Reactor Vessel Level Monitoring System Operations
: 4. 1SAR Table 7-11
: 5. 2SAR 12.1.4.2
: 6. Unit 1 SAMG Figure III-1B
: 7. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart
: 8. NEI 99-01 CG1 to 0CAN031801 Page 91 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                2 - Loss of Vital AC Power Initiating Condition:        Loss of all but one AC power source to vital buses for 15 minutes or longer EAL:
CU2.1      Unusual Event AC power capability, Table 1[2]C-3, to vital 4.16 KV buses A3 [2A3] and A4 [2A4] reduced to a single power source for  15 min. (Note 1)
AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1C-3 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)
Onsite DG1 DG2 AAC Gen to 0CAN031801 Page 92 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2C-3 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)
Onsite 2DG1 2DG2 AAC Gen Mode Applicability:
5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):
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 (as defined in 10 CFR 50.2):
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.
When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the increased greater time available to restore another power source to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.
to 0CAN031801 Page 93 of 255 Attachment 1 - Emergency Action Level Technical Bases An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to a vital bus. Some examples of this condition are presented below.
A loss of all offsite power with a concurrent failure of all but one emergency vital power source (e.g., an onsite diesel generator).
A loss of all offsite power and loss of all emergency vital power sources (e.g., onsite diesel generators) with a single train of emergency vital buses being back-fed from the unit main generator.
A loss of emergency vital power sources (e.g., onsite diesel generators) with a single train of emergency vital buses being back-fed from an offsite power source.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.
The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA2.
This EAL is the cold condition equivalent of the hot condition EAL SA1.1.
Reference(s):
: 1. 1SAR Figure 8-1 Station Single Line Diagram
: 2. OP-1202.007 Degraded Power
: 3. OP-1202.008 Blackout
: 4. OP-2104.037 Alternate AC Diesel Generator Operations
: 5. 2SAR Figure 8.3-1 Station Single Line Diagram
: 6. OP-2202.007 Loss of Off-Site Power
: 7. OP-2202.008 Station Blackout
: 8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
: 9. NEI 99-01 CU2 to 0CAN031801 Page 94 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                  2 - Loss of Vital AC Power Initiating Condition:        Loss of all offsite and all onsite AC power to vital buses for 15 minutes or longer EAL:
CA2.1      Alert Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3 [2A3] and A4 [2A4] for 15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):
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 (as defined in 10 CFR 50.2):
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
Although the AAC may be considered available, it will not prevent declaration of this EAL unless it is powering a vital bus within the 15-minute time period of the EAL.
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.
Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in to 0CAN031801 Page 95 of 255 Attachment 1 - Emergency Action Level Technical Bases accordance with abnormal or emergency operating procedures, or beyond design basis accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems.
When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased greater time available to restore an emergency vital bus to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.
Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.
Escalation of the emergency classification level would be via IC CS1 or AS1.
This EAL is the cold condition equivalent of the hot condition EAL SS1.1.
Reference(s):
: 1. 1SAR Figure 8-1 Station Single Line Diagram
: 2. OP-1202.007 Degraded Power
: 3. OP-1202.008 Blackout
: 4. OP-2104.037 Alternate AC Diesel Generator Operations
: 5. 2SAR Figure 8.3-1 Station Single Line Diagram
: 6. OP-2202.007 Loss of Off-Site Power
: 7. OP-2202.008 Station Blackout
: 8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
: 9. NEI 99-01 CU2 to 0CAN031801 Page 96 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  C - Cold Shutdown / Refueling System Malfunction Subcategory:              3 - RCS Temperature Initiating Condition:      UNPLANNED rise in RCS temperature EAL:
CU3.1      Unusual Event UNPLANNED rise in RCS temperature to > 200&deg;F due to loss of decay heat removal capability Mode Applicability:
5 - Cold Shutdown, 6 - Refueling&deg; Definition(s):
CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
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.
Basis:
This IC addresses an UNPLANNED increase rise in RCS temperature above the Technical Specification cold shutdown temperature limit or the inability to determine RCS temperature and level,and represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to IC EAL CA3.1.
A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.
EAL #1This EALThis EAL involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.
to 0CAN031801 Page 97 of 255 Attachment 1 - Emergency Action Level Technical Bases During an outage, the level in the reactor vessel will normally be maintained at or above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at loweredreduced inventory may result in a rapid increase rise in reactor coolant temperature depending on the time after shutdown.
EAL #2 reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.
Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria.
Reference(s):
: 1. Unit 1 and Unit 2 Technical Specifications Table 1.1-1
: 2. NEI 99-01 CU3 to 0CAN031801 Page 98 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  C - Cold Shutdown / Refueling System Malfunction Subcategory:                3 - RCS Temperature Initiating Condition:      UNPLANNED rise in RCS temperature EAL:
CU3.2      Unusual Event Loss of all RCS temperature and RCS level indication for  15 min. (Note 1)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
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.
Basis:
This IC EALEAL addresses an UNPLANNED increase in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level, andand represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to IC EAL CA3.1.
A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.
EAL #1 involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be to 0CAN031801 Page 99 of 255 Attachment 1 - Emergency Action Level Technical Bases maintained below the cold shutdown temperature limit specified in Technical Specifications.
During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.
During an outage, the level in the reactor vessel will normally be maintained above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at reduced inventory may result in a rapid increase in reactor coolant temperature depending on the time after shutdown.
EAL #2This EAL reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.
Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria.
Reference(s):
: 1. NEI 99-01 CU3 to 0CAN031801 Page 100 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                  3 - RCS Temperature Initiating Condition:        Inability to maintain plant in cold shutdown EAL:
CA3.1        Alert UNPLANNED rise in RCS temperature to > 200&deg;F for > Table 1[2]C-4 duration (Note 1)
OR UNPLANNED RCS pressure rise > 10 psig due to a loss of RCS cooling (this EAL does not apply during water-solid plant conditions)
Note 1:    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 is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1[2]C-4    RCS Heat-up Duration Thresholds CONTAINMENT RCS Status                                                    Heat-up Duration CLOSURE Status Intact (but not lowered inventory)                    N/A                      60 min.*
Not intact                                      established                  20 min.*
OR lowered inventory                            not established                    0 min.
* If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.
Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
to 0CAN031801 Page 101 of 255 Attachment 1 - Emergency Action Level Technical Bases As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
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.
Basis:
In the absence of reliable RCS temperature indication caused by the loss of decay heat removal capability, classification should be based on the RCS pressure rise criteria when the RCS is intact in Mode 5 or based on time to boil data when in Mode 6 or the RCS is not intact in Mode 5.
This IC EAL addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant.
A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.
The RCS Heat-up Duration Thresholds table addresses an increasea rise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact, or RCS inventory is reduced (e.g., lowered inventory operationmid-loop operation in PWRs). The 20-minute criterion was included to allow time for operator action to address the temperature increaserise.
The RCS Heat-up Duration Thresholds table also addresses an increasea rise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release.
The 60-minute time frame should allow sufficient time to address the temperature increase rise without a substantial degradation in plant safety.
Finally, in the case where there is an increase rise in RCS temperature, the RCS is not intact or is at loweredreduced inventory [PWR], and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) the evaporated reactor coolant may be released directly into the containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel.
EAL #2The RCS pressure rise threshold provides a pressure-based indication of RCS heat-up in the absence of RCS temperature monitoring capability.
Escalation of the emergency classification level would be via IC CS1 or AS1.
Reference(s):
: 1. Unit 1 and Unit 2 Technical Specifications Table 1.1-1
: 2. NEI 99-01 CA3 to 0CAN031801 Page 102 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                4 - Loss of Vital DC Power Initiating Condition:        Loss of Vital DC power for 15 minutes or longer EAL:
CU4.1      Unusual Event Indicated voltage is < 105 VDC on vital 125 VDC buses for  15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC.
This IC addresses a loss of vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions increase raise the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant.
to 0CAN031801 Page 103 of 255 Attachment 1 - Emergency Action Level Technical Bases As used in this EAL, required means the vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment. For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification.
Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.
Depending upon the event, escalation of the emergency classification level would be via IC CA1 or CA3, or an IC in Recognition Category A.
This EAL is the cold condition equivalent of the hot condition EAL SS2.1.
Reference(s):
: 1. 1SAR 8.3.2.1.1 Batteries
: 2. 2SAR 8.3.2.1.1 Batteries
: 3. NEI 99-01 CU4 to 0CAN031801 Page 104 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  C - Cold Shutdown / Refueling System Malfunction Subcategory:                5 - Loss of Communications Initiating Condition:      Loss of all onsite or offsite communications capabilities EAL:
CU5.1      Unusual Event Loss of all Table 1[2]C-5 onsite communication methods OR Loss of all Table 1[2]C-5 State and local agency communication methods OR Loss of all Table 1[2]C-5 NRC communication methods Table 1[2]C-5          Communication Methods System                        Onsite    ORO        NRC Station radio system                                  X ANO plant phone system                                X Gaitronics                                            X Telephone Systems:
Commercial Microwave                                                  X        X Satellite VOIP INFORM Notification System                                      X Emergency Notification System (ENS)                                        X Mode Applicability:
5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):
None to 0CAN031801 Page 105 of 255 Attachment 1 - Emergency Action Level Technical Bases Basis:
This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to State and local agenciesOROs and the NRC.
This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).
EAL #1The first EAL condition addresses a total loss of the communications methods used in support of routine plant operations.
EAL #2The second EAL condition addresses a total loss of the communications methods used to notify all State and local agenciesOROs of an emergency declaration. The State and local agenciesOROs referred to here are the Arkansas Department of Health, Arkansas Department of Emergency Management, Pope, Yell, Johnson, and Logan County offsite agencies (see Developer Notes).
EAL #3The third EAL addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.
This EAL is the cold condition equivalent of the hot condition EAL SU7.1.
Reference(s):
: 1. OP-1903.062 Communications System Operating Procedure
: 2. NEI 99-01 CU5 to 0CAN031801 Page 106 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                6 - Hazardous Event Affecting Safety Systems Initiating Condition:        Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode EAL:
CA6.1      Alert The occurrence of any Table 1[2]C-6 hazardous event AND Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode AND EITHER:
Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)
Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted.
Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.
Table 1[2]C-6    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 to 0CAN031801 Page 107 of 255 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
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 require a post-event inspection to determine if the attributes of an explosion are present.
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.
FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
VISIBLE DAMAGE - Damage to a SAFETY SYSTEM train 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 SAFETY SYSTEM train.
Basis:
This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS needed for the current operating mode. In order to provide the appropriate context for consideration of an ALERT classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues. Note that this second SAFETY SYSTEM to 0CAN031801 Page 108 of 255 Attachment 1 - Emergency Action Level Technical Bases train is from the same SAFETY SYSTEM that has indications of degraded performance; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events.
Indications of degraded performance addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.
VISIBLE DAMAGE addresses damage to a SAFETY SYSTEM train that is not in service/operation and that potentially could cause performance issues. 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.
This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.
This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, needed 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.
EAL 1.b.1 addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.
EAL 1.b.2 addresses damage to a SAFETY SYSTEM component that is not in service/operation or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.
Escalation of the emergency classification level would be via IC CS1 or AS1.
This EAL is the cold condition equivalent of the hot condition EAL SA9.1.
Reference(s):
: 1. EP FAQ 2016-002
: 2. NEI 99-01 CA6 to 0CAN031801 Page 109 of 255 Attachment 1 - Emergency Action Level Technical Bases Category E - Independent Spent Fuel Storage Installation (ISFSI)
EAL Group:        ANY (EALs in this category are applicable to any plant condition, hot or cold.)
An independent spent fuel storage installation (ISFSI) is a complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. A significant amount of the radioactive material contained within a canister must escape its packaging and enter the biosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel.
An Unusual Event is declared on the basis of the occurrence of an event of sufficient magnitude that a loaded cask CONFINEMENT BOUNDARY is damaged or violated.
The ANO ISFSI is located wholly within the plant PROTECTED AREA. Therefore any security event related to the ISFSI is classified under Category H1 security event related EALs.
to 0CAN031801 Page 110 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  E - ISFSI Subcategory:              Confinement Boundary Initiating Condition:      Damage to a loaded cask CONFINEMENT BOUNDARY EAL:
EU1.1      Unusual Event Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading on the surface of a loaded spent fuel cask (VSC-24 VCC or HI-STORM overpack) > any Table 1[2]-E-1 value Table 1[2]E-1 ISFSI Dose Rates VSC-24 VCC                                  HI-STORM 200 mrem/hr on the sides              60 mrem/hr (gamma + neutron) on the top or outlet vent 400 mrem/hr on the top 600 mrem/hr (gamma + neutron on 700 mrem/hr at the air inlet the side of the side of the overpack 200 mrem/hr at the air outlet          (excluding inlet and outlet ducts)
Mode Applicability:
All Definition(s):
CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).
INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) - A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.
Basis:
This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the to 0CAN031801 Page 111 of 255 Attachment 1 - Emergency Action Level Technical Bases creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.
The existence of damage is determined by radiological survey. The specified EAL threshold values correspond to 2 times the cask technical specification values (ref. 1, 2). The technical specification (licensing bases document) multiple of 2 times, which is also used in Recognition Category A IC AU1, is used here to distinguish between non-emergency and emergency conditions. The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the on-contact dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.
Security-related events for ISFSIs are covered under ICs HU1 and HA1.
Reference(s):
: 1. Certificate of Compliance Appendix A Technical Specifications for the HI-STORM 100 Cask System Section 5.7.4
: 2. VSC-24 Storage Cask Final Safety Analysis Report Section 1.2.4 Maximum External Surface Dose Rate
: 3. NEI 99-01 E-HU1 to 0CAN031801 Page 112 of 255 Attachment 1 - Emergency Action Level Technical Bases Category F - Fission Product Barrier Degradation EAL Group:        Hot Conditions (RCS temperature > 200&deg;F); EALs in this category are applicable only in one or more hot operating modes.
EALs in this category represent threats to the defense in depth design concept that precludes the release of highly radioactive fission products to the environment. This concept relies on multiple physical barriers any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment. The primary fission product barriers are:
A. Fuel Clad Barrier (FCB): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.
B. Reactor Coolant System Barrier (RCB): The RCS Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.
C. Containment Barrier (CNB): The Containment Barrier includes the Reactor Building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the Reactor Building up to and including the outermost secondary side isolation valve.
Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency.
The EALs in this category require evaluation of the loss and potential loss thresholds listed in the fission product barrier matrix of Table F-1. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. Loss means the barrier no longer assures containment of radioactive materials. Potential Loss means integrity of the barrier is threatened and could be lost if conditions continue to degrade. The number of barriers that are lost or potentially lost and the following criteria determine the appropriate emergency classification level:
Alert:
Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency:
Loss or potential loss of any two barriers General Emergency:
Loss of any two barriers and loss or potential loss of third barrier to 0CAN031801 Page 113 of 255 Attachment 1 - Emergency Action Level Technical Bases The logic used for emergency classification based on fission product barrier monitoring should reflect the following considerations:
The Fuel Clad Barrier and the RCS Barrier are weighted more heavily than the Containment Barrier.
Unusual Event ICs associated with RCS and Fuel Clad Barriers are addressed under System Malfunction ICs.
For accident conditions involving a radiological release, evaluation of the fission product barrier thresholds will need to be performed in conjunction with dose assessments to ensure correct and timely escalation of the emergency classification. For example, an evaluation of the fission product barrier thresholds may result in a Site Area Emergency classification while a dose assessment may indicate that an EAL for General Emergency IC AG1 has been exceeded.
The fission product barrier thresholds specified within a scheme reflect plant-specific ANO design and operating characteristics.
As used in this category, the term RCS leakage encompasses not just those types defined in Technical Specifications but also includes the loss of RCS mass to any location - inside the containment, an interfacing system, or outside of the containment.
The release of liquid or steam mass from the RCS due to the as-designed/expected operation of a relief valve is not considered to be RCS leakage.
At the Site Area Emergency level, EAL users should maintain cognizance of how far present conditions are from meeting a threshold that would require a General Emergency declaration. For example, if the Fuel Clad and RCS fission product barriers were both lost, then there should be frequent assessments of containment radioactive inventory and integrity. Alternatively, if both the Fuel Clad and RCS fission product barriers were potentially lost, the Emergency Director would have more assurance that there was no immediate need to escalate to a General Emergency.
to 0CAN031801 Page 114 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    F - Fission Product Barrier Degradation Subcategory:                N/A Initiating Condition:        Any loss or any potential loss of either Fuel Clad or RCS EAL:
FA1.1    Alert Any loss or any potential loss of either Fuel Clad or RCS barrier (Table 1[2]F-1)
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
None Basis:
Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.
At the Alert classification level, Fuel Clad and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Clad 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 Clad or RCS barrier results in declaration of a Site Area Emergency under EAL FS1.1.
Reference(s):
: 1. NEI 99-01 FA1 to 0CAN031801 Page 115 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    F - Fission Product Barrier Degradation Subcategory:                  N/A Initiating Condition:        Loss or potential loss of any two barriers EAL:
FS1.1      Site Area Emergency Loss or potential loss of any two barriers (Table 1[2]F-1)
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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.
Basis:
Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.
At the Site Area Emergency classification level, each barrier is weighted equally. A Site Area Emergency is therefore appropriate for any combination of the following conditions:
One barrier loss and a second barrier loss (i.e., loss - loss)
One barrier loss and a second barrier potential loss (i.e., loss - potential loss)
One barrier potential loss and a second barrier potential loss (i.e., potential loss -
potential loss)
At the Site Area Emergency classification level, the ability to dynamically assess the proximity of present conditions with respect to the threshold for a General Emergency is important. For example, the existence of Fuel Clad and RCS Barrier loss thresholds in addition to offsite dose assessments would require continual assessments of radioactive inventory and Containment integrity in anticipation of reaching a General Emergency classification. Alternatively, if both Fuel Clad and RCS potential loss thresholds existed, the Emergency Director would have greater assurance that escalation to a General Emergency is less IMMINENT.
Reference(s):
: 1. NEI 99-01 FS1 to 0CAN031801 Page 116 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    F - Fission Product Barrier Degradation Subcategory:                N/A Initiating Condition:        Loss of any two barriers and loss or potential loss of third barrier EAL:
FG1.1    General Emergency Loss of any two barriers AND Loss or potential loss of the third barrier (Table 1[2]F-1)
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
None Basis:
Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.
At the General Emergency classification level each barrier is weighted equally. A General Emergency is therefore appropriate for any combination of the following conditions:
Loss of Fuel Clad, RCS and Containment Barriers Loss of Fuel Clad and RCS Barriers with potential loss of Containment Barrier Loss of RCS and Containment Barriers with potential loss of Fuel Clad Barrier Loss of Fuel Clad and Containment Barriers with potential loss of RCS Barrier Reference(s):
: 1. NEI 99-01 FG1 to 0CAN031801 Page 117 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1 Fission Product Barrier Threshold Matrix & Bases Table 1[2]F-1 lists the threshold conditions that define the Loss and Potential Loss of the three fission product barriers (Fuel Clad, Reactor Coolant System, and Containment). The table is structured so that each of the three barriers occupies adjacent columns. Each fission product barrier column is further divided into two columns; one for Loss thresholds and one for Potential Loss thresholds.
The first column of the table (to the left of the Fuel Clad Loss column) lists the categories (types) of fission product barrier thresholds. The fission product barrier categories are:
A. RCS or S/G Tube Leakage B. Inadequate Heat removal C. Containment Radiation / RCS Activity D. Containment Integrity or Bypass E. Emergency Director Judgment Each category occupies a row in Table 1[2]F-1 thus forming a matrix defined by the categories.
The intersection of each row with each Loss/Potential Loss column forms a cell in which one or more fission product barrier thresholds appear. If NEI 99-01 does not define a threshold for a barrier Loss/Potential Loss, the word None is entered in the cell.
Thresholds are assigned sequential numbers within each barrier column beginning with number one (ex., FCB1, FCB2FCB9).
If a cell in Table 1[2]F-1 contains more than one numbered threshold, each of the numbered thresholds, if exceeded, signifies a Loss or Potential Loss of the barrier. It is not necessary to exceed all of the thresholds in a category before declaring a barrier Loss/Potential Loss.
Subdivision of Table 1[2]F-1 by category facilitates association of plant conditions to the applicable fission product barrier Loss and Potential Loss thresholds. This structure promotes a systematic approach to assessing the classification status of the fission product barriers.
When equipped with knowledge of plant conditions related to the fission product barriers, the EAL-user first scans down the category column of Table 1[2]F-1, locates the likely category and then reads across the fission product barrier Loss and Potential Loss thresholds in that category to determine if a threshold has been exceeded. If a threshold has not been exceeded, the EAL-user proceeds to the next likely category and continues review of the thresholds in the new category.
If the EAL-user determines that any threshold has been exceeded, by definition, the barrier is lost or potentially lost - even if multiple thresholds in the same barrier column are exceeded, only that one barrier is lost or potentially lost. The EAL-user must examine each of the three fission product barriers to determine if other barrier thresholds in the category are lost or potentially lost. For example, if containment radiation is sufficiently high, a Loss of the Fuel to 0CAN031801 Page 118 of 255 Attachment 1 - Emergency Action Level Technical Bases Clad and RCS Barriers and a Potential Loss of the Containment Barrier can occur. Barrier Losses and Potential Losses are then applied to the algorithms given in EALs FG1.1, FS1.1, and FA1.1 to determine the appropriate emergency classification.
In the remainder of this Attachment, the Fuel Clad Barrier threshold bases appear first, followed by the RCS Barrier and finally the Containment Barrier threshold bases. In each barrier, the bases are given according category Loss followed by category Potential Loss beginning with Category A, then B,, E.
to 0CAN031801 Page 119 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1        Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FCB)                              Reactor Coolant System Barrier (RCB)                                              Containment Barrier (CNB)
Category          Loss                Potential Loss                      Loss                          Potential Loss                                Loss                        Potential Loss RCB2 UNISOLABLE RCS leakage or S/G tube leakage > 50[44] gpm excluding normal reductions in RCS inventory (e.g.,
letdown, RCP seal leakoff)
RCB3 RCB1                        Unit 1:    PTS limits apply (RT14)              CNB1 A                                                          An automatic or manual                    AND                                A S/G that is leaking >
FCB1                          ESAS [ESFAS] actuation                                                      50[44] gpm (excluding normal RCS or S/G                                                      required by EITHER:                    RCS pressure and temperature are left None        RVLMS Levels 1 through 9                                                                                    reductions in RCS inventory) or                  None of the NDTT/LTOP limit lines on EOP Tube                          [1 through 7] indicate DRY          UNISOLABLE RCS                  Figure 3 (Note 12)                    that is RUPTURED is also Leakage                                                              leakage Unit 2:    Uncontrolled RCS cooldown (50&deg;F FAULTED outside of S/G tube RUPTURE                                                        containment step change which is below 500&deg;F from NOT)
AND RCS pressure and temperature are to the left of line B (200 degrees MTS),
Standard Attachment 1, P-T Limits (Note 12)
FCB3 CETs > 700&deg;F B                          FCB4                                                      RCB4                                                                            CNB2 RCS heat removal cannot be established using                                    CETs > 1200&deg;F Inadequate  FCB2                RCS heat removal cannot be established using steam                    None            steam generators                                              None                  AND Heat    CETs > 1200&deg;F generators                                                      AND                                                                        Restoration procedures not effective Removal                              AND                                                  HPI [Once Through] cooling initiated                                            within 15 min. (Note 1)
HPI [Once Through] cooling initiated FCB5 Containment High C      Range Radiation RCB5 Monitor RE-8060/8061                                                                                                                                            CNB3 CTMT    [2RE-8925-1/ 8925-2]                                Containment High Range None                                                                  None                                None              Containment High Range Radiation Radiation / > 750 [700] R/hr                                    Radiation Monitor RE-Monitor RE-8060/8061 [2RE-8925-8060/8061 [2RE-8925-RCS    FCB6 1/8925-2] > 40 [50] R/hr 1/8925-2] > 10,000 [12,000] R/hr Activity  Coolant activity
            > 300 Ci/gm dose equivalent I-131 to 0CAN031801 Page 120 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1          Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FCB)                                  Reactor Coolant System Barrier (RCB)                                                  Containment Barrier (CNB)
Category            Loss                Potential Loss                            Loss                            Potential Loss                                  Loss                        Potential Loss CNB4 Containment isolation is        CNB6 required Containment pressure > 73.7 psia AND EITHER:
CNB7 Containment integrity D                                                                                                                                                        has been lost based on  Containment hydrogen concentration Emergency Director      > 3%
CTMT                None                      None                              None                                    None                              judgment                CNB8 Integrity or UNISOLABLE pathway      Containment pressure > 44.7 psia Bypass                                                                                                                                                      from Containment to the  [23.3 psia] with < one full train of environment exists      containment heat removal systems CNB5                            (Note 9) operating per design for 15 min. (Note 1)
Indications of RCS leakage outside of Containment FCB7 E      Any condition in the FCB8                              RCB6                          RCB7                                              CNB9                            CNB10 Any condition in the opinion of    Any condition in the opinion                                                    Any condition in the opinion of Any condition in the opinion of the Emergency    opinion of the        the Emergency Director that        of the Emergency Director Any condition in the opinion of the Emergency the Emergency Director that    Emergency Director that indicates Director  Emergency Director                                                                      Director that indicates potential loss of the RCS indicates potential loss of the    that indicates loss of the RCS                                                  indicates loss of the          potential loss of the Containment that indicates loss of                                                                  barrier Judgment    the Fuel Clad barrier Fuel Clad barrier                  barrier                                                                          Containment barrier            barrier to 0CAN031801 Page 121 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Fuel Clad Category:              A - RCS or S/G Tube Leakage Degradation Threat:    Loss Threshold:
None to 0CAN031801 Page 122 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Fuel Clad Category:                  A - RCS or S/G Tube Leakage Degradation Threat:        Potential Loss Threshold:
FCB1 RVLMS Levels 1 through 9 [1 through 7] indicate DRY Definition(s):
None Basis:
This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage.
There is no Fuel Clad Barrier Loss threshold associated with RCS or S/G Tube Leakage.
Reference(s):
: 1. ULD-1-SYS-24 Unit 1 Inadequate Core Cooling System
: 2. Calculation 84-EQ-0080-02 Loop Error Analysis for Reactor Vessel Level Monitoring System
: 3. ULD-2-SYS-24 Unit 2 Inadequate Core Cooling Monitoring System
: 4. Calculation 90-E-0116-01 Unit 2 EOP Setpoint Document, Setpoint R.3
: 5. NEI 99-01 RCS or SG Tube Leakage Potential Loss 1.A to 0CAN031801 Page 123 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Fuel Clad Category:                B - Inadequate Heat Removal Degradation Threat:      Loss Threshold:
FCB2 CETs > 1200&deg;F Definition(s):
None Basis:
This reading indicates temperatures within the core are sufficient to cause significant superheating of reactor coolant.
Reference(s):
: 1. NEI 99-01 Inadequate Heat Removal Loss 2.A to 0CAN031801 Page 124 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Fuel Clad Category:                  B - Inadequate Heat Removal Degradation Threat:        Potential Loss Threshold:
FCB3 CETs > 700&deg;F Definition(s):
None Basis:
This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage.
Reference(s):
: 1. NEI 99-01 Inadequate Heat Removal Potential Loss 2.A to 0CAN031801 Page 125 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Fuel Clad Category:                  B - Inadequate Heat Removal Degradation Threat:        Potential Loss Threshold:
FCB4 RCS heat removal cannot be established using steam generators AND HPI [Once Through] cooling initiated Definition(s):
None Basis:
This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using this threshold is not warranted.
In combination with Potential Loss RCB4, meeting this threshold results in a Site Area Emergency.
Reference(s):
: 1. OP-1202.004 Overheating
: 2. OP-1202.013 Figure 4, Core Exit Thermocouple for Inadequate Core Cooling
: 3. OP-2202.006 Loss of Feedwater
: 4. OP-2202.009 Functional Recovery, Safety Function Status Check 5
: 5. NEI 99-01 Inadequate Heat Removal Potential Loss 2.B to 0CAN031801 Page 126 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Fuel Clad Category:                  C - CTMT Radiation / RCS Activity Degradation Threat:        Loss Threshold:
FCB5 Containment High Range Radiation Monitor RE-8060/8061 [2RE-8925-1/8925-2]
> 750 [700] R/hr Definition(s):
None Basis:
The containment radiation monitor reading (768[682] R/hr rounded to 750[700] R/hr for readability) corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals 300 &#xb5;Ci/gm dose equivalent I-131.
Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to 51.49[1.13]an approximate range of 2% to 3% 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 Loss threshold C.1RCB5 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 ECL to a Site Area Emergency.
There is no Potential Loss threshold associated with CTMT Radiation/RCS Activity
/Containment Radiation.
Basis Reference(s):
: 1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values
: 2. NEI 99-01 RCS Activity/Containment Radiation FC Loss 3.A to 0CAN031801 Page 127 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Fuel Clad Category:                  C - CTMT Radiation / RCS Activity Degradation Threat:        Loss Threshold:
FCB6 Coolant activity > 300 Ci/gm dose equivalent I-131 Definition(s):
None Basis:
This threshold indicates that RCS radioactivity concentration is greater than 300 &#xb5;Ci/gm dose equivalent I-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.
It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications.
There is no Potential Loss threshold associated with CTMT Radiation/RCS Activity
/Containment Radiation.
Reference(s):
: 1. NEI 99-01 RCS Activity/Containment Radiation Fuel Clad Loss 3.B to 0CAN031801 Page 128 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Fuel Clad Category:              C - CTMT Radiation / RCS Activity Degradation Threat:    Potential Loss Threshold:
None to 0CAN031801 Page 129 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Fuel Clad Category:              D - CTMT Integrity or Bypass Degradation Threat:    Loss Threshold:
None to 0CAN031801 Page 130 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Fuel Clad Category:              D - CTMT Integrity or Bypass Degradation Threat:    Potential Loss Threshold:
None to 0CAN031801 Page 131 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Fuel Clad Category:                E - Emergency Director Judgment Degradation Threat:      Loss Threshold:
FCB7 Any condition in the opinion of the Emergency Director that indicates loss of the Fuel Clad barrier Definition(s):
None Basis:
This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad barrier is lost.
Reference(s):
: 1. NEI 99-01 Emergency Director Judgment Fuel Clad Loss 6.A to 0CAN031801 Page 132 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Fuel Clad Category:                E - Emergency Director Judgment Degradation Threat:      Potential Loss Threshold:
FCB8 Any condition in the opinion of the Emergency Director that indicates potential loss of the Fuel Clad barrier Definition(s):
None Basis:
This threshold addresses any other factors that are to 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.
Reference(s):
: 1. NEI 99-01 Emergency Director Judgment Potential Fuel Clad Loss 6.A to 0CAN031801 Page 133 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Reactor Coolant System Category:                  A - RCS or S/G Tube Leakage Degradation Threat:        Loss Threshold:
RCB1 An automatic or manual ESAS [ESFAS] actuation required by EITHER:
UNISOLABLE RCS leakage S/G tube RUPTURE Definition(s):
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.
RUPTURED - The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).
UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.
Basis:
Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.
This 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 Loss threshold 1.ACNB1 will also be met.
to 0CAN031801 Page 134 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. OP-1202.010 ESAS
: 2. OP-2202.003 Loss of Coolant Accident
: 3. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Loss 1.A to 0CAN031801 Page 135 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Reactor Coolant System Category:                  A - RCS or S/G Tube Leakage Degradation Threat:        Potential Loss Threshold:
RCB2 UNISOLABLE RCS leakage or S/G tube leakage > 50[44] gpm excluding normal reductions in RCS inventory (e.g., letdown, RCP seal leakoff)
Definition(s):
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.
Basis:
Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.
This 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 makeup [charging]
(makeup) pump, but an ECCS (SI)ESAS [ESFAS] actuation has not occurred. The threshold is met when letdown has been isolated and an operating procedure, or operating crew supervision, directs that a standby charging (makeup)makeup [charging] pump be placed in service to restore and maintain pressurizer level.
This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system.
The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.
If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold 1.ACNB1 will also be met.
to 0CAN031801 Page 136 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. 1SAR 9.1 Makeup and Purification System
: 2. 2SAR 9.3.4 Chemical and Volume Control System
: 3. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.A to 0CAN031801 Page 137 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Reactor Coolant System Category:                  A - RCS or S/G Tube Leakage Degradation Threat:        Potential Loss Threshold:
RCB3 Unit 1:
PTS limits apply (RT14)
AND RCS pressure and temperature are left of the NDTT/LTOP limit lines, on EOP Figure 3 (Note 12)
Unit 2:
Uncontrolled RCS cooldown (50&deg;F step change which is below 500&deg;F from NOT)
AND RCS pressure and temperature are to the left of line B (200 degrees MTS), Standard Attachment 1, P-T Limits (Note 12)
Note 12: Once PTS limits are first invoked, if RCS temperature and pressure are not brought within the limits within 15 minutes, this threshold is met and an immediate declaration is warranted. This threshold is met immediately upon exceeding the limits after this initial 15 minute period until PTS limits no longer apply.
Definition(s):
None 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).
to 0CAN031801 Page 138 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. OP-1202.012 Repetitive Task 14 Control RCS Pressure
: 2. OP-1202.013 EOP Figures, Figure 3 RCS Pressure vs Temperature Limits
: 3. OP-1202.011 HPI Cooldown
: 4. Calculation No: 90-E-0116-01 ANO- EOP Setpoint Basis Document OP Setpoint P.2, RCS Pressure-Temperature
: 5. OP-2202.010 Standard Attachments, Attachment 1, P-T Limits
: 6. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.B to 0CAN031801 Page 139 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Reactor Coolant System Category:              B - Inadequate Heat Removal Degradation Threat:    Loss Threshold:
None to 0CAN031801 Page 140 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Reactor Coolant System Category:                  B - Inadequate Heat Removal Degradation Threat:        Potential Loss Threshold:
RCB4 RCS heat removal cannot be established using steam generators AND HPI [Once Through] cooling initiated Definition(s):
None Basis:
This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using this threshold is not warranted.
In combination with Potential Loss FCB4, meeting this threshold results in a Site Area Emergency.
Meeting this threshold results in a Site Area Emergency because this threshold is identical to Fuel Clad Barrier Potential Loss threshold 2.BFCB4; 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 increaseraise RCS pressure to the point where mass will be lost from the system.
There is no RCS barrier Loss threshold associated with Inadequate Heat Removal.
Reference(s):
: 1. OP-1202.004 Overheating
: 2. OP-1202.013 Figure 4, Core Exit Thermocouple for Inadequate Core Cooling
: 3. OP-2202.006 Loss of Feedwater
: 4. OP-2202.009 Functional Recovery, Safety Function Status Check 5
: 5. NEI 99-01 Inadequate Heat Removal RCS Potential Loss 2.B to 0CAN031801 Page 141 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Reactor Coolant System Category:                  C - CTMT Radiation/ RCS Activity Degradation Threat:        Loss Threshold:
RCB5 Containment High Range Radiation Monitor RE-8060/8061 [2RE-8925-1/8925-2] > 40 [50] R/hr Definition(s):
None Basis:
NRC Information Notice 97-045, Supplement 1, identifies the potential for erratic indications from the high range radiation monitors (HRRMs) as a result of thermally induced currents (TIC) which may cause the HRRM to read falsely high (for approximately 15 minutes) on a rapid temperature rise, and fail low intermittently on a rapid temperature fall. Because of this phenomenon, any trends or alarms on the HRRMs should be validated by comparison to the containment low range/area radiation monitors and Air Monitoring Systems trends before actions are taken.
The containment radiation monitor reading (42.8[50.4] R/hr rounded to 40[50] R/hr for readability) 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 Loss threshold 3.AFCB5 since it indicates a loss of the RCS Barrier only.
There is no Potential Loss threshold associated with RCS Activity / ContainmentCTMT Radiation/RCS Activity.
Reference(s):
: 1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values
: 2. NEI 99-01 CMT Radiation / RCS Activity RCS Loss 3.A to 0CAN031801 Page 142 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Reactor Coolant System Category:              B - CTMT Radiation/ RCS Activity Degradation Threat:    Potential Loss Threshold:
None to 0CAN031801 Page 143 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Reactor Coolant System Category:              D - CTMT Integrity or Bypass Degradation Threat:    Loss Threshold:
None to 0CAN031801 Page 144 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Reactor Coolant System Category:              D - CTMT Integrity or Bypass Degradation Threat:    Potential Loss Threshold:
None to 0CAN031801 Page 145 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Reactor Coolant System Category:                E - Emergency Director Judgment Degradation Threat:      Loss Threshold:
RCB6 Any condition in the opinion of the Emergency Director that indicates loss of the RCS barrier Definition(s):
None Basis:
This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is lost.
Reference(s):
: 1. NEI 99-01 Emergency Director Judgment RCS Loss 6.A to 0CAN031801 Page 146 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Reactor Coolant System Category:                E - Emergency Director Judgment Degradation Threat:      Potential Loss Threshold:
RCB7 Any condition in the opinion of the Emergency Director that indicates potential loss of the RCS barrier Definition(s):
None Basis:
This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.
Reference(s):
: 1. NEI 99-01 Emergency Director Judgment RCS Potential Loss 6.A to 0CAN031801 Page 147 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Containment Category:                    A - RCS or S/G Tube Leakage Degradation Threat:          Loss Threshold:
CNB1 A S/G that is leaking > 50[44] gpm (excluding normal reductions in RCS inventory) or that is RUPTURED S/G is also FAULTED outside of containment Definition(s):
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.
RUPTURED - The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).
Basis:
This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAULTED outside of containment. The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the thresholds for RCS Barrier Potential Loss 1.A RCB2 and Loss 1.ARCB1, 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 droppecreasing 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 SU4 for the fuel clad barrier (i.e., RCS activity values) and IC SU5 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 sustained release of radioactive to 0CAN031801 Page 148 of 255 Attachment 1 - Emergency Action Level Technical Bases 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 A ICs.
The emergency classification levelECLs 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?
P-to-S Leak Rate                        Yes                        No Less than or equal to 25 gpm                No classification        No classification Unusual Event per        Unusual Event per Greater than 25 gpm SU4SU5.1                  SU4SU5.1 Greater than 50[44] gpm (RCS            Site Area Emergency per Alert per FA1.1 Barrier Potential Loss)                          FS1.1 Requires an automatic or manual Site Area Emergency per ESAS [ESFAS]ECCS (SIAS)                                                Alert per FA1.1 FS1.1 actuation (RCS Barrier Loss)
There is no Potential Loss threshold associated with RCS or S/G Tube Leakage.
Reference(s):
: 1. NEI 99-01 RCS or SG Tube Leakage Containment Loss 1.A to 0CAN031801 Page 149 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Containment Category:              A - RCS or S/G Tube Leakage Degradation Threat:    Potential Loss Threshold:
None to 0CAN031801 Page 150 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Containment Category:              B - Inadequate Heat Removal Degradation Threat:    Loss Threshold:
None to 0CAN031801 Page 151 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Containment Category:                    B - Inadequate Heat Removal Degradation Threat:          Potential Loss Threshold:
CNB2 CETs > 1200&deg;F AND Restoration procedures not effective within 15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Definition(s):
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.
Basis:
The restoration procedure is considered effective if core exit thermocouple readings are droppdecreasing and/or if reactor vessel level is risincreasing. 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.
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.
Severe accident analyses (e.g., NUREG-1150) 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.
Reference(s):
: 1. NEI 99-01 Inadequate Heat Removal Containment Potential Loss 2.A to 0CAN031801 Page 152 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Containment Category:              C - CTMT Radiation/RCS Activity Degradation Threat:    Loss Threshold:
None to 0CAN031801 Page 153 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Containment Category:                  C - CTMT Radiation/RCS Activity Degradation Threat:        Potential Loss Threshold:
CNB3 Containment High Range Radiation Monitor RE-8060/8061 [2RE-8925-1/8925-2]
> 10,000 [12,000] R/hr Definition(s):
None Basis:
The containment radiation monitor reading (10,300[12,100] R/hr rounded to 10,000[12,000] R/hr for readability) 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 levelECL to a General Emergency.
There is no Loss threshold associated with RCS Activity/ContainmentCTMT Radiation/RCS Activity.
Reference(s):
: 1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values
: 2. NEI 99-01 CTMT Radiation / RCS Activity Containment Potential Loss 3.A to 0CAN031801 Page 154 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Containment Category:                  D - CTMT Integrity or Bypass Degradation Threat:        Loss Threshold:
CNB4 Containment isolation is required AND EITHER:
Containment integrity has been lost based on Emergency Director judgment UNISOLABLE pathway from Containment to the environment exists Definition(s):
UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.
Basis:
Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.
The status of the containment barrier during an event involving steam generator tube leakage is assessed using Loss Threshold 1.ACNB1.
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 bulleted thresholds 4.A.1 and 4.A.2.
4.A.1First Threshold - 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.).
to 0CAN031801 Page 155 of 255 Attachment 1 - Emergency Action Level Technical Bases Refer to the middle piping run of Figure 9-F-41. 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 A ICs.
4.A.2Second Threshold - 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-41. In this simplified example, the inboard and outboard isolation valves remained open after a containment isolation was required (i.e.,
containment isolation was not successful). There is now an UNISOLABLE pathway from the containment to the environment.
The existence of a filter is not considered in the threshold assessment. Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.
Leakage between two interfacing liquid systems, by itself, does not meet this threshold.
Refer to the bottom piping run of Figure 9-F-41. 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 developed a leak that allowed steam/water to enter the Auxiliary Building, then second threshold 4.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 the first threshold 4.A.1 to be met as well.
to 0CAN031801 Page 156 of 255 Attachment 1 - Emergency Action Level Technical Bases Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable 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 an enclosed system.
These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A ICs.
Reference(s):
: 1. NEI 99-01 CTMT Integrity or Bypass Containment Loss 4.A to 0CAN031801 Page 157 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Containment Category:                  D - CTMT Integrity or Bypass Degradation Threat:        Loss Threshold:
CNB5 Indications of RCS leakage outside of Containment Definition(s):
None Basis:
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 Loss RCB1 and/or Potential Loss RCB2 threshold 1.A to be met.
The status of the containment barrier during an event involving steam generator tube leakage is assessed using Containment Loss Threshold CNB1.
Containment sump, temperature, pressure and/or radiation levels will riincrease if reactor coolant mass is leaking into the containment. If these parameters have not risenincreased, then the reactor coolant mass may be leaking outside of containment (i.e., a containment bypass sequence). RiIncreases 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 riincrease 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-41. In this simplified example, a leak has occurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause threshold CNB4 to be met as well.
Reference(s):
: 1. NEI 99-01 CTMT Integrity or Bypass Containment Loss 4.B to 0CAN031801 Page 158 of 255 Attachment 1 - Emergency Action Level Technical Bases Figure 1: Containment Integrity or Bypass Examples nd 2    Threshold - Airborne release from pathway Effluent Inside                Auxiliary              Monitor Reactor                Building Building Damper                                                                          Area Monitor Open valve                Open valve Damper st Penetration                      1 Threshold -
Airborne Airborne Monitor nd Open valve                            Open valve                                          2    Threshold -
st RCS leakage Interface          1 Threshold - Airborne                                                outside AB leakage          release from penetration Process Monitor Closed Cooling Open valve                Open valve                                                  Pump RCP Seal Cooling to 0CAN031801 Page 159 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Containment Category:                  D - CTMT Integrity or Bypass Degradation Threat:        Potential Loss Threshold:
CNB6 Containment pressure > 73.7 psia Definition(s):
None Basis:
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.
Reference(s):
: 1. 1SAR 1.4.43 Criterion 50 - Containment Design Basis
: 2. 2SAR Table 6.2-7 Principle Containment Design Parameters
: 3. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.A to 0CAN031801 Page 160 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Containment Category:                D - CTMT Integrity or Bypass Degradation Threat:      Potential Loss Threshold:
CNB7 Containment hydrogen concentration > 3%
Definition(s):
None Basis:
The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a potential loss of the Containment Barrier.
Reference(s):
: 1. Unit 1 SAMG Figure III-1B
: 2. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart
: 3. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.B to 0CAN031801 Page 161 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                      Containment Category:                      D - CTMT Integrity or Bypass Degradation Threat:            Potential Loss Threshold:
CNB8 Containment pressure > 44.7 psia [23.3 psia] with < one full train of containment heat removal systems (Note 9) operating per design for  15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 9:    One full train of containment heat removal systems consists of one train of RB [Containment]
Spray and one train of RB [Containment] Cooling System.
Definition(s):
None Basis:
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.
Reference(s):
: 1. 1SAR 6.2 Reactor Building Spray System
: 2. 1SAR 6.3 Reactor Building Cooling System
: 3. OP-2202.003 Loss of Coolant Accident
: 4. OP-2202.010 Standard Attachments, Attachment 22
: 5. 2SAR 6.2.2 Containment Heat Removal Systems
: 6. 2SAR 7.3.1.1.11.2 Containment Spray System
: 7. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.C to 0CAN031801 Page 162 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Containment Category:                E - Emergency Director Judgment Degradation Threat:      Loss Threshold:
CNB9 Any condition in the opinion of the Emergency Director that indicates loss of the Containment barrier Definition(s):
None Basis:
This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is lost.
Reference(s):
: 1. NEI 99-01 Emergency Director Judgment Containment Loss 6.A to 0CAN031801 Page 163 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Containment Category:                E - Emergency Director Judgment Degradation Threat:      Potential Loss Threshold:
CNB10 Any condition in the opinion of the Emergency Director that indicates potential loss of the Containment barrier Definition(s):
None Basis:
This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.
Reference(s):
: 1. NEI 99-01 Emergency Director Judgment Containment Potential Loss 6.A to 0CAN031801 Page 164 of 255 Attachment 1 - Emergency Action Level Technical Bases Category H - Hazards and Other Conditions Affecting Plant Safety EAL Group:        ANY (EALs in this category are applicable to any plant condition, hot or cold.)
Hazards are non-plant, system-related events that can directly or indirectly affect plant operation, reactor plant safety or personnel safety.
: 1. Security Unauthorized entry attempts into the PROTECTED AREA, bomb threats, sabotage attempts, and actual security compromises threatening loss of physical control of the plant.
: 2. Seismic Event Natural events such as earthquakes have potential to cause plant structure or equipment damage of sufficient magnitude to threaten personnel or plant safety.
: 3. Natural or Technological Hazard Other natural and non-naturally occurring events that can cause damage to plant facilities include tornados, FLOODING, hazardous material releases and events restricting site access warranting classification.
: 4. Fire FIRES can pose significant hazards to personnel and reactor safety. Appropriate for classification are FIRES within the plant PROTECTED AREA or which may affect operability of equipment needed for safe shutdown.
: 5. Hazardous Gas Toxic, corrosive, asphyxiant or flammable gas leaks can affect normal plant operations or preclude access to plant areas required to safely shutdown the plant.
: 6. Control Room Evacuation Events that are indicative of loss of Control Room habitability. If the Control Room must be evacuated, additional support for monitoring and controlling plant functions is necessary through the emergency response facilities.
: 7. Emergency Director Judgment The EALs defined in other categories specify the predetermined symptoms or events that are indicative of emergency or potential emergency conditions and thus warrant classification.
While these EALs have been developed to address the full spectrum of possible emergency conditions which may warrant classification and subsequent implementation of the Emergency Plan, a provision for classification of emergencies based on operator/management experience and judgment is still necessary. The EALs of this category provide the Emergency Director the latitude to classify emergency conditions consistent with the established classification criteria based upon Emergency Director judgment.
to 0CAN031801 Page 165 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards Subcategory:                1 - Security Initiating Condition:        Confirmed SECURITY CONDITION or threat EAL:
HU1.1      Unusual Event A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by ANO Security Shift Supervision OR Notification of a credible security threat directed at the site OR A validated notification from the NRC providing information of an aircraft threat Mode Applicability:
All Definition(s):
HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.
HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).
OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.
Access to this area is controlled by the SOCA Personnel Access Control Point.
PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.
to 0CAN031801 Page 166 of 255 Attachment 1 - Emergency Action Level Technical Bases PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)    The integrity of the reactor coolant pressure boundary; (2)    The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)    The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
SECURITY CONDITION - Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A security condition does not involve a HOSTILE ACTION.
Basis:
This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, and HS1 and HG1.
Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and Offsite Response Organizations.
Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
The first threshold EAL #1 references the Security Shift Supervision (site-specific security shift supervision)because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR 2.39 information.
The second threshold EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with OP-1203.048 Security Event (site-specific procedure).
to 0CAN031801 Page 167 of 255 Attachment 1 - Emergency Action Level Technical Bases The third threshold EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with 11-S-82-1 Security Contingency Events (ref. 2)(site-specific procedure).
Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).
Escalation of the emergency classification level would be via IC HA1.
Reference(s):
: 1. ANO Security Plan
: 2. OP-1203.048 Security Event
: 3. NEI 99-01 HU1 to 0CAN031801 Page 168 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards Subcategory:                1 - Security Initiating Condition:        HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes EAL:
HA1.1    Alert A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by ANO Security Shift Supervision OR A validated notification from NRC of an aircraft attack threat within 30 min. of the site Mode Applicability:
All Definition(s):
HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.
HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).
HOSTILE FORCE - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.
Access to this area is controlled by the SOCA Personnel Access Control Point.
PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.
to 0CAN031801 Page 169 of 255 Attachment 1 - Emergency Action Level Technical Bases PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
Basis:
This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.
Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.
Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations (OROs), allowing them to be better prepared should it be necessary to consider further actions.
This IC EAL does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.
Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.
The first threshold EAL #1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA.
The second threshold EAL #2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with OP-1203.048 Security Event (ref. 2)(site-specific procedure).
The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRC.
In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The to 0CAN031801 Page 170 of 255 Attachment 1 - Emergency Action Level Technical Bases emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.
Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).
Escalation of the emergency classification level would be via IC HS1.
Reference(s):
: 1. ANO Security Plan
: 2. OP-1203.048 Security Event
: 3. NEI 99-01 HA1 to 0CAN031801 Page 171 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  H - Hazards Subcategory:                1 - Security Initiating Condition:      HOSTILE ACTION within the PROTECTED AREA EAL:
HS1.1    Site Area Emergency A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by ANO Security Shift Supervision Mode Applicability:
All Definition(s):
HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.
HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).
HOSTILE FORCE - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.
Access to this area is controlled by the SOCA Personnel Access Control Point.
PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.
PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
to 0CAN031801 Page 172 of 255 Attachment 1 - Emergency Action Level Technical Bases Basis:
This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment.
Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event (ref. 1, 2).
Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Site Area Emergency declaration will mobilize Offsite Response Organization (ORO) resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.
This IC EAL does not apply to a HOSTILE ACTION directed at an ISFSI Protected Area located outside the PROTECTED AREA; such an attack should be assessed using IC HA1. It also does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.
Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).
Escalation of the emergency classification level would be via IC HG1.
Reference(s):
: 1. ANO Security Plan
: 2. OP-1203.048 Security Event
: 3. NEI 99-01 HS1 to 0CAN031801 Page 173 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                2 - Seismic Event Initiating Condition:      Seismic event greater than OBE levels EAL:
HU2.1      Unusual Event Seismic event > OBE as indicated by annunciation of the 0.10 g acceleration alarm Mode Applicability:
All Definition(s):
None Basis:
This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (OBE). An earthquake greater than an OBE but less than a Safe Shutdown Earthquake (SSE)Design Basis Earthquake (DBE) should have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections). Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety of the plant.
Event verification with external sources should not be necessary during or following an OBE.
Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., lateral accelerations in excess of 0.08g1g). The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA6 or SA9.
Two strong motion triaxial accelerometers, ACS-8001 and ACS-8003, located at the base slab provide alarms to the Unit 1 control room via the seismic network control center, C529-NCC.
One alarm from C529-NCC is triggered when a setpoint of 0.01g has been exceeded. This alarm indicates that an earthquake has occurred and the seismic monitoring system is recording seismic data. Another alarm from C529-NCC is triggered when the pre-determined value of 0.1g, indicating the OBE has been exceeded (ref. 2, 3).
to 0CAN031801 Page 174 of 255 Attachment 1 - Emergency Action Level Technical Bases To avoid inappropriate emergency classification resulting from spurious actuation of the seismic instrumentation or felt motion not attributable to seismic activity, an offsite agency (USGS, National Earthquake Information Center (NEIC)) can confirm that an earthquake has occurred in the area of the plant. Such confirmation should not, however, preclude a timely emergency declaration based on receipt of the OBE alarm. If requested, provide the analyst with the following ANO coordinates: 35&#xba; 18' 36" north latitude, 93&#xba; 13' 53" west longitude (ref. 4).
Alternatively, near real-time seismic activity can be accessed via the NEIC website:
Reference(s):
: 1. 1SAR 2.2.1 Location
: 2. 1SAR 2.7.2 Site Seismic Evaluation
: 3. 1SAR 2.7.6 Time-History Accelerograph
: 4. OP-1203.025 Natural Emergencies
: 5. OP-2203.008 Natural Emergencies
: 6. NEI 99-01 HU2 to 0CAN031801 Page 175 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                3 - Natural or Technological Hazard Initiating Condition:        Hazardous event EAL:
HU3.1      Unusual Event A tornado strike within the PROTECTED AREA Mode Applicability:
All Definition(s):
PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
Basis:
This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.
This EALEAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA.
EAL #2 addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns. Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.
EAL #3 addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.
EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.
Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.
This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.
to 0CAN031801 Page 176 of 255 Attachment 1 - Emergency Action Level Technical Bases EAL #5 addresses (site-specific description).
Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.
If damage is confirmed visually or by other in-plant indications, the event may be escalated to an Alert under EAL CA6.1 or SA9.1.
A tornado striking (touching down) within the PROTECTED AREA warrants declaration of an Unusual Event regardless of the measured wind speed at the meteorological tower. A tornado is defined as a violently rotating column of air in contact with the ground and extending from the base of a thunderstorm.
Reference(s):
: 1. OP-1203.025 Natural Emergencies
: 2. OP-2203.008 Natural Emergencies
: 3. NEI 99-01 HU3 to 0CAN031801 Page 177 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                3 - Natural or Technological Hazard Initiating Condition:        Hazardous event EAL:
HU3.2      Unusual Event 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 Mode Applicability:
All Definition(s):
FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.
EAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA.
This EAL addresses FLOODING of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.
Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To to 0CAN031801 Page 178 of 255 Attachment 1 - Emergency Action Level Technical Bases warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.
EAL #3 addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.
EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.
Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.
This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.
EAL #5 addresses (site-specific description).
Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.
Refer to EAL CA6.1 or SA9.1 for internal FLOODING affecting more than one SAFETY SYSTEM train.
Reference(s):
: 1. OP-1203.025 Natural Emergencies
: 2. OP-2203.008 Natural Emergencies
: 3. NEI 99-01 HU3 to 0CAN031801 Page 179 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                3 - Natural or Technological Hazard Initiating Condition:        Hazardous event EAL:
HU3.3      Unusual Event Movement of personnel within the PROTECTED AREA is IMPEDED due to an event external to the PROTECTED AREA involving hazardous materials (e.g., an offsite chemical spill or toxic gas release)
Mode Applicability:
All Definition(s):
IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
Basis:
This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.
This EAL EAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA.
This EAL addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns. Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.
EAL #3 addresses a hazardous materials event originating at an offsite location outside the PROTECTED AREA and of sufficient magnitude to IMPEDE the movement of personnel within the PROTECTED AREA.
EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.
to 0CAN031801 Page 180 of 255 Attachment 1 - Emergency Action Level Technical Bases Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.
This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.
EAL #5 addresses (site-specific description).
Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.
Reference(s):
: 1. NEI 99-01 HU3 to 0CAN031801 Page 181 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                3 - Natural or Technological Hazard Initiating Condition:        Hazardous event EAL:
HU3.4      Unusual Event A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles (Note 7)
Note 7:  This EAL does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.
Mode Applicability:
All Definition(s):
FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.
Basis:
This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant. EAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA.
This EAL addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns. Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.
EAL #3 addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.
This EAL EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of such an event include site FLOODING caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.
to 0CAN031801 Page 182 of 255 Attachment 1 - Emergency Action Level Technical Bases This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the FLOODING around the Cooper Station during the Midwest floods of 1993, or the FLOODING around Ft. Calhoun Station in 2011.
EAL #5 addresses (site-specific description). Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.
Reference(s):
: 1. NEI 99-01 HU3 to 0CAN031801 Page 183 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                  4 - Fire Initiating Condition:        FIRE potentially degrading the level of safety of the plant EAL:
HU4.1      Unusual Event A FIRE is not extinguished within 15 min. of any of the following FIRE detection indications (Note 1):
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 The FIRE is located within any Table 1[2]H-1 area Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1H-1 Unit 1 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Penthouse/MSIV Room Exceptions:
Boric Acid Mix Tank Room (Chem Add Area), 404 (157-B), EDG Exhaust Fan area on 386 (1-E and 2-E)
Turbine Building All elevations including: Pipechase under ICW Coolers, CRD Pump Pit/T-28 Room/Area under ICW Pumps Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)
Manholes adjacent to Intake Structure (MH-05/MH-06)
Intake Structure (354 and 366)
Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10) to 0CAN031801 Page 184 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2H-1 Unit 2 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Aux Extension Turbine Building All elevations Outside Areas Intake Structure (354 and 366)
Concrete Manhole East, NE of intake (2MH-01)
Concrete Manhole East of Turbine Building next to train bay (2MH-03)
Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)
Mode Applicability:
All Definition(s):
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.
VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
Basis:
This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.
EAL #1 The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.
to 0CAN031801 Page 185 of 255 Attachment 1 - Emergency Action Level Technical Bases Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report. EAL #2 This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.
A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.
If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.
EAL #3 In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.
This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA. [Sentence for plants with an ISFSI outside the plant Protected Area]
EAL #4 If a FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area]
PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish. Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.
Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part:
to 0CAN031801 Page 186 of 255 Attachment 1 - Emergency Action Level Technical Bases Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."
When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.
Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.
In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC EAL CA6.1 or SA9SA9.1.
The 15 minute requirement begins with a credible notification that a FIRE is occurring, or receipt of multiple VALID fire detection system alarms or field validation of a single fire alarm. The alarm is to be validated using available Control Room indications or alarms to prove that it is not spurious, or by reports from the field.
Table 1[2]H-1 Fire Areas are those areas that contain equipment necessary for safe operation and shutdown of the plant (ref. 1, 2).
Reference(s):
: 1. OP-1203.049 Fires in Areas Affecting Safe Shutdown
: 2. OP- 2203.049 Fires in Areas Affecting Safe Shutdown
: 3. NEI 99-01 HU4 to 0CAN031801 Page 187 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                  4 - Fire Initiating Condition:        FIRE potentially degrading the level of safety of the plant EAL:
HU4.2      Unusual Event Receipt of a single fire alarm (i.e., no other indications of a FIRE)
AND The fire alarm is indicating a FIRE within any Table 1[2]H-1 area AND The existence of a FIRE is not verified within 30 min. of alarm receipt (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1H-1 Unit 1 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Penthouse/MSIV Room Exceptions:
Boric Acid Mix Tank Room (Chem Add Area), 404 (157-B), EDG Exhaust Fan area on 386 (1-E and 2-E)
Turbine Building All elevations including: Pipechase under ICW Coolers, CRD Pump Pit/T-28 Room/Area under ICW Pumps Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)
Manholes adjacent to Intake Structure (MH-05/MH-06)
Intake Structure (354 and 366)
Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10) to 0CAN031801 Page 188 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2H-1 Unit 2 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Aux Extension Turbine Building All elevations Outside Areas Intake Structure (354 and 366)
Concrete Manhole East, NE of intake (2MH-01)
Concrete Manhole East of Turbine Building next to train bay (2MH-03)
Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)
Mode Applicability:
All Definition(s):
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.
VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
Basis:
This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.
EAL #1 The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.
to 0CAN031801 Page 189 of 255 Attachment 1 - Emergency Action Level Technical Bases Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report.
EAL #2 This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.
A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.
If an actual FIRE is verified by a report from the field, then HU4.1 EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted. EAL #3 In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.
This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA. [Sentence for plants with an ISFSI outside the plant Protected Area]
EAL #4 Basis-Related Fire Protection Requirements from Appendix R Appendix R to 10 CFR 50, states in part:
Criterion 3 of 10 CFR 50, Appendix A, states, in part:
Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.
In this respect, noncombustible and heat resistant materials are used wherever practical throughout the unit, particularly in locations such as the containment and Control Room. Fire detection and fighting systems of appropriate capacity and capability are provided and designed to minimize the adverse effects of fires on SSCs important to safety. Firefighting systems are to 0CAN031801 Page 190 of 255 Attachment 1 - Emergency Action Level Technical Bases designed to assure that the rupture or inadvertent operation of a fire system does not significantly impair the safety capability of these structures, systems, and components.
When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.
Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.
In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train is employed(G.2.c). As used in HU4.2EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC EAL CA6.1 or SA9SA9.1.
The 30-minute requirement begins upon receipt of a single VALID fire detection system alarm.
The alarm is to be validated using available Control Room indications or alarms to prove that it is not spurious, or by reports from the field. Actual field reports must be made within the 30-minute time limit or a classification must be made. If a fire is verified to be occurring by field report, classification shall be made based on EAL HU4.1, with the 15-minute requirement beginning with the verification of the fire by field report.
Table 1[2]H-1 Fire Areas are those areas that contain equipment necessary for safe operation and shutdown of the plant (ref. 1, 2).
Reference(s):
: 1. OP-1203.049 Fires in Areas Affecting Safe Shutdown
: 2. OP- 2203.049 Fires in Areas Affecting Safe Shutdown
: 3. NEI 99-01 HU4 to 0CAN031801 Page 191 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                4 - Fire Initiating Condition:        FIRE potentially degrading the level of safety of the plant EAL:
HU4.3      Unusual Event A FIRE within the PROTECTED AREA not extinguished within 60 min. of the initial report, alarm or indication (Note 1)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
All Definition(s):
FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.
PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
Basis:
This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.
EAL #1 The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.
Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report.
to 0CAN031801 Page 192 of 255 Attachment 1 - Emergency Action Level Technical Bases EAL #2 This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.
A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.
If an actual FIRE is verified by a report from the field, then HU4.1 EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted. EAL #3 In addition to a FIRE addressed by EAL HU4.1 #1 or HU4.2EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.
This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA. [Sentence for plants with an ISFSI outside the plant Protected Area]
EAL #4 If a FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area]
PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish. Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.
Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part:
Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."
to 0CAN031801 Page 193 of 255 Attachment 1 - Emergency Action Level Technical Bases When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.
Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.
In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC EAL CA6.1 or SA9SA8.1.
Reference(s):
: 1. NEI 99-01 HU4 to 0CAN031801 Page 194 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                4 - Fire Initiating Condition:        FIRE potentially degrading the level of safety of the plant EAL:
HU4.4    Unusual Event A FIRE within the PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish Mode Applicability:
All Definition(s):
FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.
PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
Basis:
This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.
EAL #1 The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.
Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report.
EAL #2 to 0CAN031801 Page 195 of 255 Attachment 1 - Emergency Action Level Technical Bases This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.
A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.
If an actual FIRE is verified by a report from the field, then HU4.1 EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted. EAL #3 In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.
This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA. [Sentence for plants with an ISFSI outside the plant Protected Area]
EAL #4 If a FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area]
PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish. Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.
Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part:
Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."
When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.
Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not to 0CAN031801 Page 196 of 255 Attachment 1 - Emergency Action Level Technical Bases per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.
In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC EAL CA6.1 or SA9SA9.1.
Reference(s):
: 1. NEI 99-01 HU4 to 0CAN031801 Page 197 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                5 - Hazardous Gas Initiating Condition:        Gaseous release IMPEDING access to equipment necessary for normal plant operations, cooldown or shutdown EAL:
HA5.1      Alert Release of a toxic, corrosive, asphyxiant or flammable gas into any Table 1[2]H-2 room or area AND Entry into the room or area is prohibited or IMPEDED (Note 5)
Note 5:  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.
Table 1H-2        Unit 1 Safe Operation & Shutdown Rooms/Areas Room/Area                            Mode A-4 Switchgear Room                                            3, 4 Upper North Electrical Penetration Room                        3, 4 Lower South Electrical Equipment Room                          3, 4 Table 2H-2        Unit 2 Safe Operation & Shutdown Rooms/Areas Room/Area                            Mode Aux Building 317 Emergency Core Cooling Rooms                  3, 4 Aux Building 317 Tendon Gallery Access                        3, 4 Aux Building 335 Charging Pumps / MCC 2B-52                    3, 4 Aux Building 354 MCC 2B-62 Area                                3, 4 Emergency Diesel Generator Corridor                            3, 4 Lower South Piping Penetration Room                            3, 4 Aux Building 386 Containment Hatch                            3, 4 to 0CAN031801 Page 198 of 255 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:
3 - Hot Standby, 4 - Hot Shutdown Definition(s):
IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
Basis:
This IC addresses an event involving a release of a hazardous gas that precludes or IMPEDES access to equipment necessary to maintain normal plant operation, or required for a normal plant cooldown and shutdown. This condition represents an actual or potential substantial degradation of the level of safety of the plant.
An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.
Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Directors judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly IMPEDE procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards.
Access should be considered as IMPEDED if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
An emergency declaration is not warranted if any of the following conditions apply:
The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release). For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.
The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).
The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
to 0CAN031801 Page 199 of 255 Attachment 1 - Emergency Action Level Technical Bases The access control measures are of a conservative or precautionary nature, and would not actually prevent or IMPEDE a required action.
If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact 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.
This EAL does not apply to firefighting activities that generate smoke and that automatically or manually activate a fire suppression system in an area , or to intentional inerting of containment.
(BWR only).
The list of plant rooms or areas with entry-related mode applicability identified specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations) are not included. In addition, the list specifies the plant mode(s) during which entry would be required for each room or area (ref. 1).
Escalation of the emergency classification level would be via Recognition Category A, C or F ICs.
EAL HA5.1 mode applicability has been limited to the mode limitations of Table 1[2]H-2 (Modes 3 and 4 only).
Reference(s):
: 1. Attachment 2 Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases
: 2. NEI 99-01 HA5 to 0CAN031801 Page 200 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  H - Hazards and Other Conditions Affecting Plant Safety Subcategory:              6 - Control Room Evacuation Initiating Condition:      Control Room evacuation resulting in transfer of plant control to alternate locations EAL:
HA6.1      Alert An event has resulted in plant control being transferred from the Control Room to alternate locations Mode Applicability:
All Definition(s):
None Basis:
This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety.
Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations. The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel. Activation of the ERO and emergency response facilities will assist in responding to these challenges.
Transfer of plant control begins when the last licensed operator leaves the Control Room.
Escalation of the emergency classification level would be via IC HS6.
Reference(s):
: 1. OP-1203.002 Alternate Shutdown
: 2. OP- 2203.014 Alternate Shutdown
: 3. NEI 99-01 HA6 to 0CAN031801 Page 201 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                6 - Control Room Evacuation Initiating Condition:      Inability to control a key safety function from outside the Control Room EAL:
HS6.1      Site Area Emergency An event has resulted in plant control being transferred from the Control Room to alternate locations AND Control of any of the following key safety functions is not re-established within 15 min. (Note 1):
Reactivity (Modes 1, 2 and 3 only)
Core cooling RCS heat removal Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling Definition(s):
None Basis:
This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plant control to alternate locations is a precursor to a challenge to one or more fission product barriers within a relatively short period of time.
The determination of whether or not control is established at the remote safe shutdown location(s) is based on Emergency Director judgment. The Emergency Director is expected to make a reasonable, informed judgment within 15 (the site-specific time for transfer) minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).
to 0CAN031801 Page 202 of 255 Attachment 1 - Emergency Action Level Technical Bases Transfer of plant control and the time period to establish control begins when the last licensed operator leaves the Control Room.
Escalation of the emergency classification level would be via IC FG1 or CG1 Reference(s):
: 1. OP-1203.002 Alternate Shutdown
: 2. OP-2203.014 Alternate Shutdown
: 3. NEI 99-01 HS6 to 0CAN031801 Page 203 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                7 - Emergency Director Judgment Initiating Condition:        Other conditions exist that in the judgment of the Emergency Director warrant declaration of a UE EAL:
HU7.1      Unusual Event 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.
Mode Applicability:
All Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an UNUSUAL EVENTNOUE.
Reference(s):
: 1. NEI 99-01 HU7 to 0CAN031801 Page 204 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                7 - Emergency Director Judgment Initiating Condition:        Other conditions exist that in the judgment of the Emergency Director warrant declaration of an ALERT EAL:
HA7.1      Alert 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.
Mode Applicability:
All Definition(s):
HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.
HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).
OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.
Access to this area is controlled by the SOCA Personnel Access Control Point.
PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.
PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
to 0CAN031801 Page 205 of 255 Attachment 1 - Emergency Action Level Technical Bases Basis:
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an ALERT.
Reference(s):
: 1. NEI 99-01 HA7 to 0CAN031801 Page 206 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                7 - Emergency Director Judgment Initiating Condition:        Other conditions exist that in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY EAL:
HS7.1      Site Area Emergency 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.
Mode Applicability:
All Definition(s):
HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.
HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).
OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.
Access to this area is controlled by the SOCA Personnel Access Control Point.
PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.
to 0CAN031801 Page 207 of 255 Attachment 1 - Emergency Action Level Technical Bases PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.
Basis:
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a SITE AREA EMERGENCY.
Reference(s):
: 1. NEI 99-01 HS7 to 0CAN031801 Page 208 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                7 - Emergency Director Judgment Initiating Condition:        Other conditions exist that in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY EAL:
HG7.1      General Emergency Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.
Mode Applicability:
All Definition(s):
HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.
HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).
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.
OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.
Access to this area is controlled by the SOCA Personnel Access Control Point.
PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.
to 0CAN031801 Page 209 of 255 Attachment 1 - Emergency Action Level Technical Bases PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
Basis:
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a GENERAL EMERGENCY.
Reference(s):
: 1. NEI 99-01 HG7 to 0CAN031801 Page 210 of 255 Attachment 1 - Emergency Action Level Technical Bases Category S - System Malfunction EAL Group:      Hot Conditions (RCS temperature > 200&deg;F); EALs in this category are applicable only in one or more hot operating modes.
Numerous system-related equipment failure events that warrant emergency classification have been identified in this category. They may pose actual or potential threats to plant safety.
The events of this category pertain to the following subcategories:
: 1. Loss of Vital AC Power Loss of vital electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite sources for vital 4.16 KV buses.
: 2. Loss of Vital DC Power Loss of emergency electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of vital plant 125V DC power sources.
: 3. Loss of Control Room Indications Certain events that degrade plant operator ability to effectively assess plant conditions within the plant warrant emergency classification. Losses of indicators are in this subcategory.
: 4. RCS Activity During normal operation, reactor coolant fission product activity is very low. Small concentrations of fission products in the coolant are primarily from the fission of tramp uranium in the fuel clad or minor perforations in the clad itself. Any significant rise from these base-line levels (2% - 5% clad failures) is indicative of fuel failures and is covered under the Fission Product Barrier Degradation category. However, lesser amounts of clad damage may result in coolant activity exceeding Technical Specification limits. These fission products will be circulated with the reactor coolant and can be detected by coolant sampling.
: 5. RCS Leakage The reactor vessel provides a volume for the coolant that covers the reactor core. The reactor pressure vessel and associated pressure piping (reactor coolant system) together provide a barrier to limit the release of radioactive material should the reactor fuel clad integrity fail. Excessive RCS leakage greater than Technical Specification limits indicates potential pipe cracks that may propagate to an extent threatening fuel clad, RCS and containment integrity.
to 0CAN031801 Page 211 of 255 Attachment 1 - Emergency Action Level Technical Bases
: 6. RPS Failure This subcategory includes events related to failure of the Reactor Protection System (RPS) to initiate and complete reactor trips. In the plant licensing basis, postulated failures of the RPS to complete a reactor trip comprise a specific set of analyzed events referred to as Anticipated Transient Without Scram (ATWS) events. For EAL classification, however, ATWS is intended to mean any trip failure event that does not achieve reactor shutdown. If RPS actuation fails to assure reactor shutdown, positive control of reactivity is at risk and could cause a threat to fuel clad, RCS and containment integrity.
: 7. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.
: 8. Containment Failure Failure of containment isolation capability (under conditions in which the containment is not currently challenged) warrants emergency classification. Failure of containment pressure control capability also warrants emergency classification.
: 9. Hazardous Event Affecting Safety Systems Various natural and technological events that result in degraded plant safety system performance or significant VISIBLE DAMAGE warrant emergency classification under this subcategory.
to 0CAN031801 Page 212 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                1 - Loss of Vital AC Power Initiating Condition:        Loss of all offsite AC power capability to vital buses for 15 minutes or longer EAL:
SU1.1      Unusual Event Loss of all offsite AC power capability, Table 1[2]S-1, to vital 4.16 KV buses A3 [2A3] and A4 [2A4] for  15 min. (Note 1)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1S-1 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)
Onsite Unit Auxiliary Transformer (main generator via main transformer)
DG1 DG2 AAC Gen to 0CAN031801 Page 213 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2S-1 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)
Onsite Unit Auxiliary Transformer (main generator via main transformer) 2DG1 2DG2 AAC Gen Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
None 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 vital 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 vital buses, whether or not the buses are powered from it.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power.
Escalation of the emergency classification level would be via IC SA1.
Reference(s):
: 1. 1SAR Figure 8-1 Station Single Line Diagram
: 2. OP-1202.007 Degraded Power
: 3. OP-1202.008 Blackout
: 4. OP-2104.037 Alternate AC Diesel Generator Operations to 0CAN031801 Page 214 of 255 Attachment 1 - Emergency Action Level Technical Bases
: 5. 2SAR Figure 8.3-1 Station Single Line Diagram
: 6. OP-2202.007 Loss of Off-Site Power
: 7. OP-2202.008 Station Blackout
: 8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
: 9. NEI 99-01 SU1 to 0CAN031801 Page 215 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                1 - Loss of Vital AC Power Initiating Condition:        Loss of all but one AC power source to vital buses for 15 minutes or longer EAL:
SA1.1      Alert AC power capability, Table 1[2]S-1, to vital 4.16 KV buses A3 [2A3] and A4 [2A4] reduced to a single power source for  15 min. (Note 1)
AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1S-1 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)
Onsite Unit Auxiliary Transformer (main generator via main transformer)
DG1 DG2 AAC Gen to 0CAN031801 Page 216 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2S-1 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)
Onsite Unit Auxiliary Transformer (main generator via main transformer) 2DG1 2DG2 AAC Gen Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
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 SU1.
An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to a emergency vital bus. Some examples of this condition are presented below.
to 0CAN031801 Page 217 of 255 Attachment 1 - Emergency Action Level Technical Bases 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 vital emergency power sources (e.g., onsite diesel generators) with a single train of emergency vital buses being back-fed from the unit main generator.
A loss of vital emergency power sources (e.g., onsite diesel generators) with a single train of vital 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 SS1.
This EAL is the hot condition equivalent of the cold condition EAL CU2.1.
Reference(s):
: 1. 1SAR Figure 8-1 Station Single Line Diagram
: 2. OP-1202.007 Degraded Power
: 3. OP-1202.008 Blackout
: 4. OP-2104.037 Alternate AC Diesel Generator Operations
: 5. 2SAR Figure 8.3-1 Station Single Line Diagram
: 6. OP-2202.007 Loss of Off-Site Power
: 7. OP-2202.008 Station Blackout
: 8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
: 9. NEI 99-01 SA1 to 0CAN031801 Page 218 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                  1 - Loss of Vital AC Power Initiating Condition:        Loss of all offsite power and all onsite AC power to vital buses for 15 minutes or longer EAL:
SS1.1      Site Area Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3 [2A3] and A4 [2A4] for 15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
Although the AAC may be considered available, it will not prevent declaration of this EAL unless it is powering a vital bus within the 15 minute time period of the EAL.
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.
Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or emergency operating procedures, or beyond design basis to 0CAN031801 Page 219 of 255 Attachment 1 - Emergency Action Level Technical Bases accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.
Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.
Escalation of the emergency classification level would be via ICs AG1, FG1 or SG1.
This EAL is the hot condition equivalent of the cold condition EAL CA2.1.
Reference(s):
: 1. 1SAR Figure 8-1 Station Single Line Diagram
: 2. OP-1202.007 Degraded Power
: 3. OP-1202.008 Blackout
: 4. OP-2104.037 Alternate AC Diesel Generator Operations
: 5. 2SAR Figure 8.3-1 Station Single Line Diagram
: 6. OP-2202.007 Loss of Off-Site Power
: 7. OP-2202.008 Station Blackout
: 8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
: 9. NEI 99-01 SS1 to 0CAN031801 Page 220 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                1 - Loss of Vital AC Power Initiating Condition:        Prolonged loss of all offsite and all onsite AC power to vital buses EAL:
SG1.1      General Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3 [2A3] and A4 [2A4]
AND EITHER:
Restoration of at least one vital 4.16 KV bus in < 4 hours is not likely (Note 1)
CETs > 1200&deg;F Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
This IC addresses a prolonged loss of all power sources to AC emergency vital buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or to 0CAN031801 Page 221 of 255 Attachment 1 - Emergency Action Level Technical Bases emergency operating procedures, or beyond design basis accident response guidelines (e.g.,
FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. A prolonged loss of these buses will lead to a loss of one or more 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 vital 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 greater likelihood of challenges to multiple fission product barriers. 4 hours is the site-specific SBO coping analysis time (ref. 4, 5).
The estimate for restoring at least one emergency vital bus should be based on a realistic appraisal of the situation. Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public.
The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.
Reference(s):
: 1. OP-1202.005 Inadequate Core Cooling
: 2. OP-2202.009 Functional Recovery
: 3. OP-2202.011 Lower Mode Functional Recovery
: 4. Unit 1 Calculation 85-E-0072-02 Time from Loss of All AC Power to Loss of Subcooling
: 5. Unit 2 Calculation 85-E-0072-01 Time from Loss of All AC Power to Loss of Subcooling
: 6. 1SAR Figure 8-1 Station Single Line Diagram
: 7. OP-1202.007 Degraded Power
: 8. OP-1202.008 Blackout
: 9. OP-2104.037 Alternate AC Diesel Generator Operations
: 10. 2SAR Figure 8.3-1 Station Single Line Diagram
: 11. OP-2202.007 Loss of Off-Site Power
: 12. OP-2202.008 Station Blackout
: 13. OP-2107.006 Backfeed of Unit Auxiliary Transformer
: 14. NEI 99-01 SG1 to 0CAN031801 Page 222 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                      S - System Malfunction Subcategory:                  1 - Loss of Vital AC Power Initiating Condition:          Loss of all vital AC and vital DC power sources for 15 minutes or longer EAL:
SG1.2        General Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3 [2A3] and A4 [2A4] for 15 min. (Note 1)
AND Indicated voltage is < 105 VDC on D01 [2D01] and D02 [2D02] vital 125 VDC buses for 15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)    The integrity of the reactor coolant pressure boundary; (2)    The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)    The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC (ref. 9, 10).
This IC addresses a concurrent and prolonged loss of both vital AC and Vital DC power. A loss of all vital AC power compromises the performance of all SAFETY SYSTEMS requiring electric to 0CAN031801 Page 223 of 255 Attachment 1 - Emergency Action Level Technical Bases power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or emergency operating procedures, or beyond design basis accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. A loss of vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both vital AC and vital 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 both EAL thresholds are met.
Reference(s):
: 1. 1SAR Figure 8-1 Station Single Line Diagram
: 2. OP-1202.007 Degraded Power
: 3. OP-1202.008 Blackout
: 4. OP-2104.037 Alternate AC Diesel Generator Operations
: 5. 2SAR Figure 8.3-1 Station Single Line Diagram
: 6. OP-2202.007 Loss of Off-Site Power
: 7. OP-2202.008 Station Blackout
: 8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
: 9. 1SAR 8.3.2.1.1 Batteries
: 10. 2SAR 8.3.2.1.1 Batteries
: 11. OP-1203.036 Loss of 125V DC
: 12. OP-2203.037 Loss of 125V DC
: 13. 2SAR Figure 8.3-6 Low Voltage Safety System Power Supplies
: 14. NEI 99-01 SG8 to 0CAN031801 Page 224 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                2 - Loss of Vital DC Power Initiating Condition:        Loss of all vital DC power for 15 minutes or longer EAL:
SS2.1      Site Area Emergency Indicated voltage is < 105 VDC on D01 [2D01] and D02 [2D02] vital 125 VDC buses for 15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC (ref. 2, 3).
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 AG1, FG1 or SG1SG8.
to 0CAN031801 Page 225 of 255 Attachment 1 - Emergency Action Level Technical Bases This EAL is the hot condition equivalent of the cold condition EAL CU4.1.
Reference(s):
: 1. 1SAR Figure 8-1 Station Single Line Diagram
: 2. 1SAR 8.3.2.1.1 Batteries
: 3. 2SAR 8.3.2.1.1 Batteries
: 4. OP-1203.036 Loss of 125V DC
: 5. OP-2203.037 Loss of 125V DC
: 6. 2SAR Figure 8.3-6 Low Voltage Safety System Power Supplies
: 7. NEI 99-01 SS8 to 0CAN031801 Page 226 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                3 - Loss of Control Room Indications Initiating Condition:        UNPLANNED loss of Control Room indications for 15 minutes or longer EAL:
SU3.1      Unusual Event An UNPLANNED event results in the inability to monitor one or more Table 1[2]S-2 parameters from within the Control Room for  15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1[2]S-2 Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one S/G EFW flow to at least one S/G Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
to 0CAN031801 Page 227 of 255 Attachment 1 - Emergency Action Level Technical Bases 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.
Basis:
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 one or more of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.
An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.
This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling [PWR] / RPV level [BWR] and RCS heat removal.
The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level [PWR] / RPV water level [BWR] cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.
Escalation of the emergency classification level would be via IC EAL SA3.1SA2.
Reference(s):
: 1. 1SAR 7.5 Safety-Related Display Instrumentation
: 2. 2SAR 7.5 Safety-Related Display Instrumentation
: 3. NEI 99-01 SU2 to 0CAN031801 Page 228 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                3 - Loss of Control Room Indications Initiating Condition:        UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress EAL:
SA3.1      Alert An UNPLANNED event results in the inability to monitor one or more Table 1[2]S-2 parameters from within the Control Room for  15 min. (Note 1)
AND Any significant transient is in progress, Table 1[2]S-3 Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1[2]S-2 Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one S/G EFW flow to at least one S/G Table 1[2]S-3 Significant Transients Reactor trip Runback > 25% thermal power Electrical load rejection > 25% electrical load Safety injection actuation Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown to 0CAN031801 Page 229 of 255 Attachment 1 - Emergency Action Level Technical Bases Definition(s):
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 (as defined in 10 CFR 50.2):
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
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.
Basis:
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 one or more of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.
An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.
This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling [PWR] / RPV level [BWR] and RCS heat removal.
The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level [PWR] / RPV water level [BWR] cannot be determined from the to 0CAN031801 Page 230 of 255 Attachment 1 - Emergency Action Level Technical Bases 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 AS1.
Reference(s):
: 1. 1SAR 7.1.3 Engineered Safeguards Actuation System
: 2. 2SAR 7.3 Engineered Safety Features Systems
: 3. NEI 99-01 SA2 to 0CAN031801 Page 231 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                4 - RCS Activity Initiating Condition:        RCS activity greater than Technical Specification allowable limits EAL:
SU4.1      Unusual Event Failed Fuel Iodine radiation monitor RI-1237S [2RITS-4806B] > 9.0 E5 cpm Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
None 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.
Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category A ICs.
Unit 1 RE-1237S, Failed Fuel Monitor, is in the letdown system to monitor the letdown line for evidence of fuel damage.
Unit 2 specific activity monitor 2RITS-4806B monitors the Letdown fluid for the presence of Iodine-131.
A monitor reading corresponding to the instantaneous dose equivalent I-131 value of 60 uCi/gm is determined by multiplying by 30 the monitor reading listed in the table in OP-1203.019[OP-2203.020] that represents a projected 2.0 uCi/gm I-131 RCS activity in order to correlate to a Tech Spec instantaneous limit of 60 uCi/gm dose equivalent I-131 for the EAL (ref. 2, 5). This yields values of 3.1E6 cpm for Unit 1 and 3.9E6 cpm for Unit 2. The top of scale of the monitor is 1E6. The EAL value is set at 9.0 E5 cpm for both units which is 90% of the top of the scale.
to 0CAN031801 Page 232 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. 1SAR Table 11-7
: 2. OP-1203-019 High Activity in Reactor Coolant
: 3. Unit 1 Technical Specifications LCO 3.4.12 RCS Specific Activity
: 4. 2SAR 9.3.5 Failed Fuel Detection System
: 5. OP-2203.020 High Activity in RCS
: 6. OP- 2203.012L ANNUNCIATOR 2K12 CORRECTIVE ACTION, A-1
: 7. Unit 2 Technical Specifications LCO 3.4.8 Reactor Coolant System Specific Activity
: 8. NEI 99-01 SU3 to 0CAN031801 Page 233 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  S - System Malfunction Subcategory:                4 - RCS Activity Initiating Condition:      RCS activity greater than Technical Specification allowable limits EAL:
SU4.2      Unusual Event RCS sample activity > 1.0 &#xb5;Ci/gm dose equivalent I-131 for > 48 hours (Note 1)
OR RCS sample activity > 60 &#xb5;Ci/gm dose equivalent I-131 OR RCS sample activity > 2200[3100] &#xb5;Ci/gm dose equivalent Xe-133 for > 48 hours (Note 1)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
None 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.
Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category A ICs.
Reference(s):
: 1. Unit 1 Technical Specifications LCO 3.4.12 RCS Specific Activity
: 2. Unit 2 Technical Specifications LCO 3.4.8 Reactor Coolant System Specific Activity
: 3. NEI 99-01 SU3 to 0CAN031801 Page 234 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  S - System Malfunction Subcategory:                5 - RCS Leakage Initiating Condition:      RCS leakage for 15 minutes or longer EAL:
SU5.1      Unusual Event RCS unidentified or pressure boundary leakage > 10 gpm for  15 min. (Note 1)
OR RCS identified leakage > 25 gpm for  15 min. (Note 1)
OR Reactor coolant leakage to a location outside containment > 25 gpm for  15 min. (Note 1)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.
Basis:
Failure to isolate the leak (from the Control Room or locally) within 15 minutes, or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.
Steam generator tube leakage is identified RCS leakage.
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.
The first and second EAL conditions EAL #1 and EAL #2 are focused on a loss of mass from the RCS due to unidentified leakage", "pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications). The third condition EAL
#3 addresses an RCS mass loss caused by an UNISOLABLE leak through an interfacing to 0CAN031801 Page 235 of 255 Attachment 1 - Emergency Action Level Technical Bases system. These conditions EALs thus apply to leakage into the containment, a secondary-side system (e.g., steam generator tube leakage in a PWR) or a location outside of containment.
The leak rate values for each condition 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). The first condition 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. For PWRs, aAn 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). For BWRs, a stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is not applicable to this EAL.
The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible.
Escalation of the emergency classification level would be via ICs of Recognition Category A or F.
Reference(s):
: 1. Unit 1 and Unit 2 Technical Specifications Section 1.1 Definitions
: 2. NEI 99-01 SU4 to 0CAN031801 Page 236 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                      S - System Malfunction Subcategory:                  6 - RPS Failure Initiating Condition:          Automatic or manual trip fails to shut down the reactor EAL:
SU6.1      Unusual Event An automatic trip did not shut down the reactor as indicated by reactor power > 5% after any RPS setpoint is exceeded AND A subsequent automatic trip or manual trip action taken at the reactor control console (C03
[2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) is successful in shutting down the reactor as indicated by reactor power  5% (Note 8)
Note 8:    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.
Mode Applicability:
1 - Power Operation Definition(s):
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.
Basis:
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor (trip [PWR] / scram [BWR]) that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic (trip [PWR] / scram [BWR])
is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.
In the event that the operator identifies a reactor trip is IMMINENT and initiates a successful manual reactor trip before the automatic trip setpoint is reached, no declaration is required. The successful manual trip of the reactor before it reaches its automatic trip setpoint or reactor trip signals caused by instrumentation channel failures do not lead to a potential fission product barrier loss.
Following the failure onf an automatic reactor (trip[PWR] / scram [BWR]), operators will promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor (trip[PWR] / scram [BWR])). If these manual actions are successful in shutting to 0CAN031801 Page 237 of 255 Attachment 1 - Emergency Action Level Technical Bases down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.
If an initial manual reactor (trip [PWR] / scram [BWR]) is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor (trip[PWR] / scram [BWR])) using a different switch).
Depending upon several factors, the initial or subsequent effort to manually (trip [PWR] / scram
[BWR]) the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor (trip [PWR] / scram [BWR]) signal. If a subsequent manual or automatic (trip [PWR] /
scram [BWR]) is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.
A manual action at the reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor (trip[PWR] / scram [BWR])). This action does not include manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the reactor control consoles.Taking the Reactor Mode Switch to SHUTDOWN is considered to be a manual scram action. [BWR]
The plant response to the failure of an automatic or manual reactor (trip [PWR] / scram [BWR])
will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the reactor control consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC SA5SA6. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC SA5 SA6 or FA1, an Unusual Event declaration is appropriate for this event.
A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
Should a reactor (trip [PWR] / scram [BWR]) 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 results in a condition that should have included an automatic reactor trip [PWR] / scram [BWR]) and the RPS fails to automatically shutdown the reactor, then this IC and associated the EALs are applicable, and should be evaluated.
If the signal generated as a result of plant work does not cause a plant transient and the (trip [PWR] / scram [BWR]) failure is determined through other means (e.g., assessment of test results), then this IC and associated the EALs are not applicable and no classification is warranted.
to 0CAN031801 Page 238 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
: 2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
: 3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
: 4. OP-1202.001 Reactor Trip
: 5. OP-2202.001 Standard Post Trip Actions
: 6. NEI 99-01 SU5 to 0CAN031801 Page 239 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                  6 - RPS Failure Initiating Condition:        Automatic or manual trip fails to shut down the reactor EAL:
SU6.2      Unusual Event A manual trip did not shut down the reactor as indicated by reactor power > 5% after any manual trip action was initiated AND A subsequent automatic trip or manual trip action taken at the reactor control console (C03
[2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) is successful in shutting down the reactor as indicated by reactor power  5% (Note 8)
Note 8:  A manual scram 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.
Mode Applicability:
1 - Power Operation Definition(s):
None Basis:
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor (trip [PWR] / scram [BWR]) that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic (trip [PWR] / scram [BWR])
is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.
This EAL addresses a failure of a manually initiated trip in the absence of having exceeded an automatic RPS trip setpoint and a subsequent automatic or manual trip is successful in shutting down the reactor.
Following the failure on an automatic reactor (trip [PWR] / scram [BWR]), operators will promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor (trip [PWR] / scram [BWR])). 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 plants decay heat removal systems.
to 0CAN031801 Page 240 of 255 Attachment 1 - Emergency Action Level Technical Bases If an initial manual reactor (trip [PWR] / scram [BWR]) is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor (trip [PWR] / scram [BWR])) using a different switch).
Depending upon several factors, the initial or subsequent effort to manually (trip [PWR] / scram
[BWR]) the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor (trip [PWR] / scram [BWR]) signal. If a subsequent manual or automatic (trip [PWR] /
scram [BWR]) is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.
A manual action at the reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor (trip
[PWR] / scram [BWR])). This action does not include manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the reactor control consoles.
Taking the Reactor Mode Switch to SHUTDOWN is considered to be a manual scram action.
[BWR]
The plant response to the failure of an automatic or manual reactor (trip [PWR] / scram [BWR])
will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the reactor control consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC SA5SA6. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC SA5 SA6 or FA1, an Unusual Event declaration is appropriate for this event.
A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
Should a reactor (trip [PWR] / scram [BWR]) 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 results in a condition that should have included an automatic reactor (trip [PWR] / scram [BWR]) and the RPS fails to automatically shutdown the reactor, then this IC and associated the EALs are applicable, and should be evaluated.
If the signal generated as a result of plant work does not cause a plant transient and the (trip [PWR] / scram [BWR]) failure is determined through other means (e.g., assessment of test results), then this IC and associated the EALs are not applicable and no classification is warranted.
to 0CAN031801 Page 241 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
: 2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
: 3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
: 4. OP-1202.001 Reactor Trip
: 5. OP-2202.001 Standard Post Trip Actions
: 6. NEI 99-01 SU5 to 0CAN031801 Page 242 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                      S - System Malfunction Subcategory:                  6 - RPS Failure Initiating Condition:          Automatic or manual trip fails to shut down the reactor and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor EAL:
SA6.1      Alert An automatic or manual trip fails to shut down the reactor as indicated by reactor power > 5%
AND Manual trip actions taken at the reactor control console (C03 [2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) are not successful in shutting down the reactor as indicated by reactor power > 5% (Note 8)
Note 8:    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.
Mode Applicability:
1 - Power Operation Definition(s):
None Basis:
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor (trip [PWR] / scram [BWR]) 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 reactor control console 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
[PWR] / scram [BWR])). 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 to 0CAN031801 Page 243 of 255 Attachment 1 - Emergency Action Level Technical Bases the Control Room, or any location outside the Control Room, are not considered to be at the reactor control consoles.
Taking the Reactor Mode Switch to SHUTDOWN is considered to be a manual scram action.
[BWR]
The plant response to the failure of an automatic or manual reactor (trip [PWR] / scram [BWR])
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 shut down the reactor is prolonged enough to cause a challenge to the core cooling [PWR] / RPV water level [BWR] or RCS RCS heat removal safety functions, the emergency classification level will escalate to a Site Area Emergency via IC SS65. Depending upon plant responses and symptoms, escalation is also possible via IC FS1.
Absent the plant conditions needed to meet either IC SS65 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.
Reference(s):
: 1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
: 2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
: 3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
: 4. OP-1202.001 Reactor Trip
: 5. OP-2202.001 Standard Post Trip Actions
: 6. NEI 99-01 SA5 to 0CAN031801 Page 244 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                6 - RPS Failure Initiating Condition:        Inability to shut down the reactor causing a challenge to core cooling or RCS heat removal EAL:
SS6.1      Site Area Emergency An automatic or manual trip fails to shut down the reactor as indicated by reactor power > 5%
AND All actions to shut down the reactor are not successful as indicated by reactor power > 5%
AND EITHER:
CETs >1200&deg;F RCS heat removal cannot be established using steam generators and HPI [Once Through] cooling initiated.
Mode Applicability:
1 - Power Operation Definition(s):
None Basis:
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor (trip [PWR] / scram [BWR]) that results in a reactor shutdown, all subsequent operator actions to manually shutdown the reactor are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.
In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs. This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shut down 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.
to 0CAN031801 Page 245 of 255 Attachment 1 - Emergency Action Level Technical Bases Escalation of the emergency classification level would be via IC AG1 or FG1.
Reference(s):
: 1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
: 2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
: 3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
: 4. OP-1202.001 Reactor Trip
: 5. OP-2202.001 Standard Post Trip Actions
: 6. OP-1202.004 Overheating
: 7. OP-2202.006 Loss of Feedwater
: 8. OP-1202.013 Figure 1, Saturation and Adequate SCM
: 9. Calculation 90-E-0116-07 Unit 1 EOP Setpoint Document, Setpoint B.19
: 10. OP-2202.009 Functional Recovery
: 11. Calculation 90-E-0116-01 Unit 2 EOP Setpoint Document
: 12. NEI 99-01 SS5 to 0CAN031801 Page 246 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  S - System Malfunction Subcategory:              7 - Loss of Communications Initiating Condition:      Loss of all onsite or offsite communications capabilities EAL:
SU7.1      Unusual Event Loss of all Table 1[2]S-4 onsite communication methods OR Loss of all Table 1[2]S-4 State and local agency communication methods OR Loss of all Table 1[2]S-4 NRC communication methods Table 1[2]S-4    Communication Methods System                          Onsite    State / Local NRC Station radio system                                  X ANO plant phone system                                X Gaitronics                                            X Telephone Systems:
Commercial Microwave                                                      X        X Satellite VOIP INFORM Notification System                                          X Emergency Notification System (ENS)                                          X Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown to 0CAN031801 Page 247 of 255 Attachment 1 - Emergency Action Level Technical Bases Definition(s):
None Basis:
This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to OROs State and local agencies and the NRC.
This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).
EAL #1The first EAL condition addresses a total loss of the communications methods used in support of routine plant operations.
EAL #2The second EAL condition addresses a total loss of the communications methods used to notify all OROs State and local agencies of an emergency declaration. The OROs State and local agencies referred to here are the Arkansas Department of Health, Arkansas Department of Emergency Management, Pope, Yell, Johnson, and Logan County agencies.(see Developer Notes)
EAL #3The third EAL addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.
This EAL is the hot condition equivalent of the cold condition EAL CU5.1.
Reference(s):
: 1. OP-1903.062 Communications System Operating Procedure
: 2. NEI 99-01 SU6 to 0CAN031801 Page 248 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                      S - System Malfunction Subcategory:                  8 - Containment Failure Initiating Condition:          Failure to isolate containment or loss of containment pressure control EAL:
SU8.1      Unusual Event Any penetration is not closed within 15 min. of an ESAS [CIAS] actuation signal OR Containment pressure > 44.7 psia [23.3 psia] with < one full train of containment heat removal systems (Note 9) operating per design for  15 min. (Note 1)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 9:    One full train of containment heat removal systems consists of one train of RB [Containment]
Spray and one train of RB [Containment] Cooling System.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
None Basis:
A penetration is closed for this EAL if either side of the penetration has a closed valve or a check valve is intact (for penetrations that only have one automatic valve and a check valve).
This IC EAL addresses a failure of one or more containment penetrations to automatically isolate (close) when required by an actuation signal. It also addresses an event that results in high containment pressure with a concurrent failure of containment pressure control systems.
Absent challenges to another fission product barrier, either condition represents potential degradation of the level of safety of the plant.
For EAL #1the first condition, the containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); a failure resulting from testing or maintenance does not warrant classification. The determination of containment and penetration status - isolated or not isolated - should be made in accordance with the appropriate criteria contained in the plant AOPs and EOPs. The 15-minute to 0CAN031801 Page 249 of 255 Attachment 1 - Emergency Action Level Technical Bases criterion is included to allow operators time to manually isolate the required penetrations, if possible.
EAL #2The second condition addresses a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. The inability to start the required equipment indicates that containment heat removal/depressurization systems (e.g., containment sprays or ice condenser fans) are either lost or performing in a degraded manner.
This event would escalate to a Site Area Emergency in accordance with IC FS1 if there were a concurrent loss or potential loss of either the Fuel Clad or RCS fission product barriers.
Reference(s):
: 1. OP-1202.010 ESAS
: 2. 1SAR 6.2 Reactor Building Spray System
: 3. 1SAR 6.3 Reactor Building Cooling System
: 4. OP-2202.003 Loss of Coolant Accident
: 5. OP-2202.010 Standard Attachments, Attachment 22
: 6. 2SAR 6.2.2 Containment Heat Removal Systems
: 7. 2SAR 7.3.1.1.11.2 Containment Spray System
: 8. NEI 99-01 SU7 to 0CAN031801 Page 250 of 255 Attachment 1 - Emergency Action Level Technical Bases Category:                  S - System Malfunction Subcategory:                9 - Hazardous Event Affecting Safety Systems Initiating Condition:      Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode EAL:
SA9.1      Alert The occurrence of any Table 1[2]S-5 hazardous event AND Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode AND EITHER:
Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)
Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted.
Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.
Table 1[2]S-5    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 to 0CAN031801 Page 251 of 255 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 require a post-event inspection to determine if the attributes of an explosion are present.
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.
FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
VISIBLE DAMAGE - Damage to a SAFETY SYSTEM train 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 SAFETY SYSTEM train.
Basis:
This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS needed for the current operating mode. In order to provide the appropriate context for consideration of an ALERT classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues.
to 0CAN031801 Page 252 of 255 Attachment 1 - Emergency Action Level Technical Bases Note that this second SAFETY SYSTEM train is from the same SAFETY SYSTEM that has indications of degraded performance; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events.
Indications of degraded performance addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.
VISIBLE DAMAGE addresses damage to a SAFETY SYSTEM train that is not in service/operation and that potentially could cause performance issues. Operators will make a determination of VISIBLE DAMAGE 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. This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.
This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, needed 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.
EAL 1.b.1 addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.
EAL 1.b.2 addresses damage to a SAFETY SYSTEM component that is not in service/operation or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.
Escalation of the emergency classification level would be via IC FS1 or AS1.
This EAL is the hot condition equivalent of the cold condition EAL CA6.1.
Reference(s):
: 1. EP FAQ 2016-002
: 2. NEI 99-01 SA9 to 0CAN031801 Page 253 of 255 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases
 
===Background===
NEI 99-01 Revision 6 ICs AA3 and HA5 prescribe declaration of an Alert based on impeded access to rooms or areas (due to either area radiation levels or hazardous gas concentrations) where equipment necessary for normal plant operations, cooldown or shutdown is located.
These areas are intended to be plant operating mode dependent. Specifically the Developers Notes for AA3 and HA5 states:
The site-specific list of plant rooms or areas with entry-related mode applicability identified should specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Do not include rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations). In addition, the list should specify the plant mode(s) during which entry would be required for each room or area.
The list should 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).
Further, as specified in IC HA5:
The list need not include the Control Room if adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas. Such features may include, but are not limited to, capability to draw air from multiple air intakes at different and separate locations, inner and outer atmospheric boundaries, or the capability to acquire and maintain positive pressure within the Control Room envelope.
to 0CAN031801 Page 254 of 255 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases ANO Table 1[2]A-3 and 1[2]H-2 Bases A review of station operating procedures identified the following mode dependent in-plant actions and associated areas that are required for normal plant operation, cooldown or shutdown:
Unit 1 AREA              MODES              PURPOSE                  REFERENCE Core flood tank valves,          OP-1102.010 A-4 Switchgear Room              3, 4 decay heat removal (DHR)          OP-1104.004 Upper North Electrical 3, 4    DHR alignment                    OP-1104.004 Penetration Room Lower South Electrical 3, 4    DHR alignment                    OP-1104.004 Equipment Room Unit 2 AREA              MODES              PURPOSE                  REFERENCE Aux Building 317 Emergency              Shutdown Cooling (SDC) 3, 4                                      OP-2104.004 Core Cooling Rooms                      venting and alignment Aux Building 317 Tendon 3, 4    SDC alignment                    OP-2104.004 Gallery Access Aux Building 335 Charging              Charging low pressure            OP-2102.010 Pumps / Motor Control Center    3, 4    operation, T-Hot injection (MCC) 2B-52                              valves, and SDC alignment        OP-2104.004 SDC alignment and T-Hot          OP-2102.010 Auxiliary Building 354 3, 4    injection valves at MCC 2B-62 Area                                                            OP-2104.004 MCC 2B-62 Close Safety Injection Tank (SIT) valves and SDC / Low Emergency Diesel Generator 3, 4    Temperature Overpressure          OP-2102.010 Corridor (LTOP) valve alignment at MCC 2B-51 Lower South Piping 3, 4    SDC alignment                      OP-2104.004 Penetration Room Aux Building 386                        Close SIT valves at 3, 4                                      OP-2102.010 Containment Hatch                        MCC 2B-61 Mode 3 is included above for DHR- and SDC-related activities because the procedures begin alignment in Mode 3; however, these actions could be delayed until Mode 4, if necessary. In order to ensure adequate guidance to emergency response personnel, the above areas are added to the EAL in order to provide prompt operator guidance for EAL declaration.
to 0CAN031801 Page 255 of 255 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases Both ANO-1 and ANO-2 Control Room ventilation systems have adequate engineered safety/design features in place to preclude a Control Room evacuation due to the release of a hazardous gas. Therefore the Control Room is not included in this assessment or in Tables 1[2]H-2.
Table 1[2]A-3 & 1[2]H-2 Results Table 1[2]A-3 & 1[2]H-2      Safe Operation & Shutdown Rooms/Areas Unit 1 Room/Area                              Mode Applicability A-4 Switchgear Room                                                            3, 4 Upper North Electrical Penetration Room                                        3, 4 Lower South Electrical Equipment Room                                          3, 4 Unit 2 Room/Area                              Mode Applicability Aux Building 317 Emergency Core Cooling Rooms                                3, 4 Aux Building 317 Tendon Gallery Access                                        3, 4 Aux Building 335 Charging Pumps / MCC 2B-52                                  3, 4 Auxiliary Building 354 MCC 2B-62 Area                                        3, 4 Emergency Diesel Generator Corridor                                            3, 4 Lower South Piping Penetration Room                                            3, 4 Aux Building 386 Containment Hatch                                            3, 4
 
Enclosure 3 to 0CAN031801 Proposed EAL Technical Basis Document (Clean) to 0CAN031801 Page 1 of 240 Table of Contents Section                                                                                                                          Page
 
==1.0  INTRODUCTION==
.................................................................................................................2 2.0  DISCUSSION ......................................................................................................................2 2.1  Background ................................................................................................................2 2.2  Fission Product Barriers .............................................................................................3 2.3  Fission Product Barrier Classification Criteria ............................................................3 2.4  EAL Organization .......................................................................................................4 2.5  Technical Basis Information .......................................................................................5 2.6  Operations Mode Applicability....................................................................................7 3.0  GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS ..........................................8 3.1  General Considerations .............................................................................................8 3.2  Classification Methodology ......................................................................................10
 
==4.0  REFERENCES==
..................................................................................................................13 4.1  Developmental .........................................................................................................13 4.2  Implementing............................................................................................................13 5.0  DEFINITIONS, ACRONYMS & ABBREVIATIONS ...........................................................13 5.1  Definitions (ref. 4.1.1 except as noted) ....................................................................13 5.2  Abbreviations/Acronyms ..........................................................................................18 6.0  ANO-TO-NEI 99-01 Rev. 6 EAL CROSS-REFERENCE ..................................................21 7.0  ATTACHMENTS ...............................................................................................................24 7.1  Attachment 1, Emergency Action Level Technical Bases ........................................24 Category A - Abnormal Rad Levels / Rad Effluents ................................................25 Category C - Cold Shutdown / Refueling System Malfunction ................................65 Category E - Independent Spent Fuel Storage Installation (ISFSI) .......................104 Category F - Fission Product Barrier Degradation ................................................107 Table 1[2]F-1, Fission Product Barrier Threshold Matrix & Bases ...114 Category H - Hazards and Other Conditions Affecting Plant Safety .....................158 Category S - System Malfunction ..........................................................................196 7.2  Attachment 2, Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases .....................................................238 to 0CAN031801 Page 2 of 240
 
==1.0      INTRODUCTION==
 
This document provides an explanation and rationale for each Emergency Action Level (EAL) included in the EAL Upgrade Project for Arkansas Nuclear One (ANO). It should be used to facilitate review of the ANO EALs and provide historical documentation for future reference.
Decision-makers responsible for implementation of 1903.010, Emergency Action Level Classification, may use this document as a technical reference in support of EAL interpretation.
This information may assist the Emergency Director in making classifications, particularly those involving judgment or multiple events. The basis information may also be useful in training and for explaining event classifications to off-site officials.
The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present. Use of this document for assistance is not intended to delay the emergency classification.
Because the information in a basis document can affect emergency classification decision-making (e.g., the Emergency Director refers to it during an event), the NRC staff expects that changes to the basis document will be evaluated in accordance with the provisions of 10 CFR 50.54(q).
2.0      DISCUSSION 2.1      Background EALs are the plant-specific indications, conditions or instrument readings that are utilized to classify emergency conditions defined in the ANO Emergency Plan.
In 1992, the NRC endorsed NUMARC/NESP-007 Methodology for Development of Emergency Action Levels as an alternative to NUREG-0654 EAL guidance.
NEI 99-01 (NUMARC/NESP-007) Revisions 4 and 5 were subsequently issued for industry implementation. Enhancements over earlier revisions included:
Consolidating the system malfunction initiating conditions and example emergency action levels which address conditions that may be postulated to occur during plant shutdown conditions.
Initiating conditions and example emergency action levels that fully address conditions that may be postulated to occur at permanently Defueled Stations and Independent Spent Fuel Storage Installations (ISFSIs).
Simplifying the fission product barrier EAL threshold for a Site Area Emergency.
Subsequently, Revision 6 of NEI 99-01 has been issued which incorporates resolutions to numerous implementation issues including the NRC EAL Frequently Asked Questions (FAQs).
Using NEI 99-01 Revision 6, "Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, November 2012 (ref. 4.1.1), ANO conducted an EAL implementation upgrade project that produced the EALs discussed herein.
to 0CAN031801 Page 3 of 240 2.2    Fission Product Barriers Fission product barrier thresholds represent threats to the defense in depth design concept that precludes the release of radioactive fission products to the environment. This concept relies on multiple physical barriers, any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment.
Many of the EALs derived from the NEI methodology are fission product barrier threshold based. That is, the conditions that define the EALs are based upon thresholds that represent the loss or potential loss of one or more of the three fission product barriers. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. A Loss threshold means the barrier no longer assures containment of radioactive materials.
A Potential Loss threshold implies a greater probability of barrier loss and reduced certainty of maintaining the barrier.
The primary fission product barriers are:
A. Fuel Clad Barrier (FCB): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.
B. Reactor Coolant System Barrier (RCB): The Reactor Coolant System Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.
C. Containment Barrier (CNB): The Containment Barrier includes the Reactor Building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the Reactor Building up to and including the outermost secondary side isolation valve.
Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency.
2.3    Fission Product Barrier Classification Criteria The following criteria are the bases for event classification related to fission product barrier loss or potential loss:
Alert:
Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency:
Loss or potential loss of any two barriers General Emergency:
Loss of any two barriers and loss or potential loss of the third barrier to 0CAN031801 Page 4 of 240 2.4      EAL Organization The ANO EAL scheme includes the following features:
Division of the EAL set into three broad groups:
o  EALs applicable under any plant operating modes - This group would be reviewed by the EAL-user any time emergency classification is considered.
o  EALs applicable only under hot operating modes - This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby, Startup, or Power Operation mode.
o  EALs applicable only under cold operating modes - This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refueling or Defueled mode.
The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency.
Within each group, assignment of EALs to categories and subcategories:
Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. The ANO EAL categories are aligned to and represent the NEI 99-01, Recognition Categories. Subcategories are used in the ANO scheme as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The ANO EAL categories and subcategories are listed below.
The primary tool for determining the emergency classification level is the EAL Classification Matrix. The user of the EAL Classification Matrix may (but is not required to) consult the EAL technical bases in order to obtain additional information concerning the EALs under classification consideration. The user should consult Section 3.0 and Attachment 1 of this document for such information.
to 0CAN031801 Page 5 of 240 EAL Groups, Categories and Subcategories EAL Group/Category                            EAL Subcategory Any Operating Mode:
A - Abnormal Rad Levels / Rad Effluent      1 - Radiological Effluent 2 - Irradiated Fuel Event 3 - Area Radiation Levels H - Hazards and Other Conditions Affecting  1 - Security Plant Safety                            2 - Seismic Event 3 - Natural or Technological Hazard 4 - Fire 5 - Hazardous Gas 6 - Control Room Evacuation 7 - Emergency Director Judgment E - Independent Spent Fuel Storage          1 - Confinement Boundary Installation (ISFSI)
Hot Conditions:
S - System Malfunction                      1 - Loss of Essential AC Power 2 - Loss of Vital DC Power 3 - Loss of Control Room Indications 4 - RCS Activity 5 - RCS Leakage 6 - RPS Failure 7 - Loss of Communications 8 - Containment Failure 9 - Hazardous Event Affecting Safety Systems F - Fission Product Barrier Degradation    None Cold Conditions:
C - Cold Shutdown / Refueling System        1 - RCS Level Malfunction                            2 - Loss of Essential AC Power 3 - RCS Temperature 4 - Loss of Vital DC Power 5 - Loss of Communications 6 - Hazardous Event Affecting Safety Systems 2.5      Technical Bases Information EAL technical bases are provided in Attachment 1 for each EAL according to EAL group (Any, Hot, Cold), EAL category (A, C, E, F, H and S) and EAL subcategory. A summary explanation of each category and subcategory is given at the beginning of the technical bases discussions of the EALs included in the category. For each EAL, the following information is provided:
to 0CAN031801 Page 6 of 240 Category Letter & Title Subcategory Number & Title Initiating Condition (IC)
Site-specific description of the generic IC given in NEI 99-01 Rev. 6.
EAL Identifier (enclosed in rectangle)
Each EAL is assigned a unique identifier to support accurate communication of the emergency classification to onsite and offsite personnel. Four characters define each EAL identifier:
: 1. First character (letter): Corresponds to the EAL category as described above (A, C, E, F, H or S)
: 2. Second character (letter): The emergency classification (G, S, A or U)
G = General Emergency S = Site Area Emergency A = Alert U = Unusual Event
: 3. Third character (number): Subcategory number within the given category. Subcategories are sequentially numbered beginning with the number one (1). If a category does not have a subcategory, this character is assigned the number one (1).
: 4. Fourth character (number): The numerical sequence of the EAL within the EAL subcategory. If the subcategory has only one EAL, it is given the number one (1).
Classification (enclosed in rectangle):
Unusual Event (U), Alert (A), Site Area Emergency (S) or General Emergency (G)
EAL (enclosed in rectangle)
Exact wording of the EAL as it appears in the EAL Classification Matrix. If an ANO Unit 2 EAL threshold value differs from Unit 1, the Unit 2 threshold is enclosed in brackets. For example, in the EAL threshold RVLMS Levels 1 through 8 indicate DRY [RVLMS Levels 1 through 5 indicate DRY], RVLMS Levels 1 through 5 indicate DRY apply only to Unit 2.
Mode Applicability One or more of the following plant operating conditions comprise the mode to which each EAL is applicable: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling, DEF - Defueled, or Any. (See Section 2.6 for operating mode definitions).
to 0CAN031801 Page 7 of 240 Definitions:
If the EAL wording contains a defined term, the definition of the term is included in this section. These definitions can also be found in Section 5.1.
Basis:
An EAL basis section that provides ANO-relevant information concerning the EAL as well as a description of the rationale for the EAL as provided in NEI 99-01 Rev. 6.
Reference(s):
Source documentation from which the EAL is derived.
2.6      Operating Mode Applicability Unit 1 (ref. 4.1.6):
1      Power Operation Keff  0.99, reactor power > 5%
2      Startup Keff  0.99, reactor power  5%
3      Hot Standby Keff < 0.99, reactor coolant temperature  280&deg;F 4      Hot Shutdown Keff < 0.99, reactor coolant temperature 280&deg;F > Tavg > 200&deg;F and all reactor vessel head closure bolts fully tensioned 5      Cold Shutdown Keff < 0.99, reactor coolant temperature  200&deg;F and all reactor vessel head closure bolts fully tensioned 6      Refueling One or more reactor vessel head closure bolts less than fully tensioned DEF    Defueled All fuel assemblies have been removed from Containment and placed in the spent fuel pool.
to 0CAN031801 Page 8 of 240 Unit 2 (ref. 4.1.6):
1      Power Operation Keff  0.99, reactor power > 5%, average coolant temperature  300&deg;F 2      Startup Keff  0.99, reactor power  5%, average coolant temperature  300&deg;F 3      Hot Standby Keff < 0.99, average coolant temperature  300&deg;F 4      Hot Shutdown Keff < 0.99, average coolant temperature 300&deg;F > Tavg > 200&deg;F 5      Cold Shutdown Keff < 0.99, average coolant temperature  200&deg;F 6      Refueling Keff  0.95, average coolant temperature  140&deg;F, reactor vessel head unbolted or removed, and fuel in the vessel.
DEF    Defueled All fuel assemblies have been removed from Containment and placed in the spent fuel pool.
The plant operating mode that exists at the time that the event occurs (prior to any protective system or operator action being initiated in response to the condition) should be compared to the mode applicability of the EALs. If a lower or higher plant operating mode is reached before the emergency classification is made, the declaration shall be based on the mode that existed at the time the event occurred.
3.0    GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 3.1    General Considerations When making an emergency classification, the Emergency Director must consider all information having a bearing on the proper assessment of an Initiating Condition (IC). This includes the Emergency Action Level (EAL) plus the associated Operating Mode Applicability, Notes, and the informing basis information. In the Recognition Category F matrices, EALs are based on loss or potential loss of Fission Product Barrier Thresholds.
EAL matrices shall be read from left to right, from General Emergency to Unusual Event, and top to bottom. Declaration decisions shall be independently verified before declaration is made except when gaining this verification would exceed the 15 minute declaration requirement.
Place keeping shall be used on all EAL matrices.
to 0CAN031801 Page 9 of 240 3.1.1      Classification Timeliness NRC regulations require the licensee to establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and to promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. The NRC staff has provided guidance on implementing this requirement in NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants" (ref. 4.1.8).
3.1.2      Valid Indications All emergency classification assessments shall be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicators operability, the conditions existence, or the reports accuracy. For example, verification could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by plant personnel.
An indication, report, or condition is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
3.1.3      Imminent Conditions For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the Emergency Director 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. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary.
3.1.4      Planned vs. Unplanned Events A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that: 1) the activity proceeds as planned, and 2) the plant remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain or modify a system or component. In these cases, the controls associated with the planning, preparation and execution of the work will ensure that compliance is maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10 CFR 50.72 (ref. 4.1.4).
3.1.5      Classification Based on Analysis The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., dose assessments, chemistry sampling, RCS leak rate calculation, etc.). For these EALs, the EAL wording or the to 0CAN031801 Page 10 of 240 associated basis discussion will identify the necessary analysis. In these cases, the 15-minute declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available). The NRC expects licensees to establish the capability to initiate and complete EAL-related analyses within a reasonable period of time (e.g., maintain the necessary expertise on-shift).
3.1.6      Emergency Director Judgment While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 EAL scheme provides the Emergency Director with the ability to classify events and conditions based upon judgment using EALs that are consistent with the Emergency Classification Level (ECL) definitions (refer to Category H). The Emergency Director will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.
A similar provision is incorporated in the Fission Product Barrier Tables; judgment may be used to determine the status of a fission product barrier.
3.2      Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e., the relevant plant indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL must be consistent with the related Operating Mode Applicability and Notes. If an EAL has been met or exceeded, the associated IC is likewise met, the emergency classification process clock starts, and the ECL must be declared in accordance with plant procedures no later than fifteen minutes after the process clock started.
When assessing an EAL that specifies a time duration for the off-normal condition, the clock for the EAL time duration runs concurrently with the emergency classification process clock.
For a full discussion of this timing requirement, refer to NSIR/DPR-ISG-01 (ref. 4.1.8).
3.2.1      Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared. For example:
If an Alert EAL and a Site Area Emergency EAL are met, whether at one unit or at two units, a Site Area Emergency should be declared.
There is no additive effect from multiple EALs meeting the same ECL. For example:
If two Alert EALs are met, whether at one unit or at two units, an Alert should be declared.
3.2.2      Consideration of Mode Changes During Classification The mode in effect at the time that an event or condition occurred, and prior to any plant or operator response, is the mode that determines whether or not an IC is applicable. If an event or condition occurs, and results in a mode change before the emergency is declared, the emergency classification level is still based on the mode that existed at the time that the event to 0CAN031801 Page 11 of 240 or condition was initiated (and not when it was declared). Once a different mode is reached, any new event or condition, not related to the original event or condition, requiring emergency classification should be evaluated against the ICs and EALs applicable to the operating mode at the time of the new event or condition.
For events that occur in Cold Shutdown or Refueling, escalation is via EALs that are applicable in the Cold Shutdown or Refueling modes, even if Hot Shutdown (or a higher mode) is entered during the subsequent plant response. In particular, the fission product barrier EALs are applicable only to events that initiate in the Hot Shutdown mode or higher.
3.2.3      Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Director must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Emergency Director, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all emergency classification levels, this approach is particularly important at the higher emergency classification levels since it provides additional time for implementation of protective measures.
3.2.4      Emergency Classification Level Upgrading and Termination An ECL may be terminated when the event or condition that meets the classified IC and EAL no longer exists, and other site-specific termination requirements are met.
3.2.5      Classification of Short-Lived Events Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration. Examples of such events include an earthquake or a failure of the reactor protection system to automatically trip the reactor followed by a successful manual trip.
3.2.6      Classification of Transient Conditions Many of the ICs and/or EALs employ time-based criteria. These criteria will require that the IC/EAL conditions be present for a defined period of time before an emergency declaration is warranted. In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes). The following guidance should be applied to the classification of these conditions.
EAL momentarily met during expected plant response - In instances in which an EAL is briefly met during an expected (normal) plant response, an emergency declaration is not warranted provided that associated systems and components are operating as expected, and operator actions are performed in accordance with procedures.
to 0CAN031801 Page 12 of 240 EAL momentarily met but the condition is corrected prior to an emergency declaration - If an operator takes prompt manual action to address a condition, and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required. For illustrative purposes, consider the following example:
An ATWS occurs and the high pressure ECCS systems fail to automatically start. The plant enters an inadequate core cooling condition (a potential loss of both the Fuel Clad and RCS Barriers). If an operator manually starts a high pressure ECCS system in accordance with an EOP step and clears the inadequate core cooling condition prior to an emergency declaration, then the classification should be based on the ATWS only.
It is important to stress that the 15-minute emergency classification assessment period (process clock) is not a grace period during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event. Emergency classification assessments must be deliberate and timely, with no undue delays. The provision discussed above addresses only those rapidly evolving situations when an operator is able to take a successful corrective action prior to the Emergency Director completing the review and steps necessary to make the emergency declaration. This provision is included to ensure that any public protective actions resulting from the emergency classification are truly warranted by the plant conditions.
3.2.7      After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery. This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.
In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022 (ref. 4.1.3) is applicable. Specifically, the event should be reported to the NRC in accordance with 10 CFR &sect; 50.72 (ref. 4.1.4) within one hour of the discovery of the undeclared event or condition. The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.
3.2.8      Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022 (ref. 4.1.3).
to 0CAN031801 Page 13 of 240
 
==4.0    REFERENCES==
 
4.1    Developmental 4.1.1      NEI 99-01 Revision 6, Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, ADAMS Accession Number ML12326A805 4.1.2      RIS 2007-02 Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2, 2007.
4.1.3      NUREG-1022 Event Reporting Guidelines: 10CFR50.72 and 50.73 4.1.4      10 &sect; CFR 50.72 Immediate Notification Requirements for Operating Nuclear Power Reactors 4.1.5      10 &sect; CFR 50.73 License Event Report System 4.1.6      Unit 1[2] Technical Specifications Table 1.1-1[1.1], Modes[Operational Modes]
4.1.7      Arkansas Nuclear One Offsite Dose Calculation Manual (ODCM) 4.1.8      NSIR/DPR-ISG-01 Interim Staff Guidance, Emergency Planning for Nuclear Power Plants 4.1.9      Arkansas Nuclear One Emergency Plan 4.1.10    1015.008 Unit 2 SDC Control 4.2    Implementing 4.2.1      1903.010 Emergency Action Level Classification 4.2.2      NEI 99-01 Rev. 6 to ANO EAL Comparison Matrix 4.2.3      ANO EAL Matrix 5.0    DEFINITIONS, ACRONYMS & ABBREVIATIONS 5.1    Definitions (ref. 4.1.1 except as noted)
Selected terms used in Initiating Condition, Emergency Action Level statements and EAL bases are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.
Alert 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.
to 0CAN031801 Page 14 of 240 Confinement Boundary The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).
Containment Closure The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions (ref. 4.1.10).
As applied to ANO, Containment Closure must be capable of being set within 30 minutes.
Containment Closure is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
Emergency Action Level (EAL)
A pre-determined, site-specific, observable threshold for an INITIATING CONDITION that, when met or exceeded, places the plant in a given emergency classification level.
Emergency Classification Level (ECL)
One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:
Unusual Event (UE)
Alert Site Area Emergency (SAE)
General Emergency (GE)
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 require a post-event inspection to determine if the attributes of an explosion are present.
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.
to 0CAN031801 Page 15 of 240 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.
Fission Product Barrier Threshold A pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier.
Flooding A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.
General Emergency 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 PAG exposure levels offsite for more than the immediate site area.
Hostage A person(s) held as leverage against the station to ensure that demands will be met by the station.
Hostile Action An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).
Hostile Force One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
Imminent The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.
to 0CAN031801 Page 16 of 240 Impede(d)
Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
Independent Spent Fuel Storage Installation (ISFSI)
A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.
Initiating Condition (IC)
An event or condition that aligns with the definition of one of the four emergency classification levels by virtue of the potential or actual effects or consequences.
Owner Controlled Area (OCA)
For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line. Access to this area is controlled by the SOCA Personnel Access Control Point (ref. 4.1.9).
Projectile An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.
Protected Area An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled (ref. 4.1.9).
RCS Intact The RCS should be considered intact when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams).
Refueling Pathway All the cavities, tubes, canals and pools through which irradiated fuel may be moved, but not including the reactor vessel.
Ruptured The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).
to 0CAN031801 Page 17 of 240 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 (as defined in 10 CFR 50.2):
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Security Condition Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A Security Condition does not involve a HOSTILE ACTION.
Site Area Emergency 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 PAG exposure levels beyond the SITE BOUNDARY.
Site Boundary That boundary defined by a 1046 meter (0.65 mile) radius around the plant (ref. 4.1.7).
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.
Unusual Event Events are in progress or have occurred which indicate a potential degradation in 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.
to 0CAN031801 Page 18 of 240 Valid An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
Visible Damage Damage to a SAFETY SYSTEM train 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 SAFETY SYSTEM train.
5.2        Abbreviations/Acronyms
&deg;F .................................................................................................................... Degrees Fahrenheit
&deg;......................................................................................................................................... Degrees AC ..................................................................................................................... Alternating Current ANO ............................................................................................................ Arkansas Nuclear One AOP .............................................................................................. Abnormal Operating Procedure ATWS.................................................................................... Anticipated Transient Without Scram BMS ................................................................................................... Boron Management System BWST................................................................................................ Borated Water Storage Tank CDE ................................................................................................... Committed Dose Equivalent CET .......................................................................................................... Core Exit Thermocouple CFR................................................................................................... Code of Federal Regulations CIAS.................................................................................. Containment Isolation Actuation Signal CMT, CNTMT, CTMT ..................................................................................................Containment CNB ................................................................................................................ Containment Barrier DBA............................................................................................................. Design Basis Accident DBE......................................................................................................... Design Basis Earthquake DC .............................................................................................................................Direct Current DEF ...................................................................................................................................Defueled D/G....................................................................................................................... Diesel Generator DHR .............................................................................................................. Decay Heat Removal DROPS ............................................................ Diverse Reactor Overpressure Protection System DSC ............................................................................................................. Dry Shielded Canister to 0CAN031801 Page 19 of 240 DSS............................................................................................................ Diverse Scram System EAL .......................................................................................................... Emergency Action Level ECCS ......................................................................................... Emergency Core Cooling System ECL ............................................................................................... Emergency Classification Level DEF ...................................................................................................................................Defueled ENS............................................................................................... Emergency Notification System EOF................................................................................................ Emergency Operations Facility EOP ........................................................................................... Emergency Operating Procedure EPA ............................................................................................ Environmental Protection Agency ERG ............................................................................................ Emergency Response Guideline EPIP ............................................................................. Emergency Plan Implementing Procedure ESAS ........................................................................... Engineered Safeguards Actuation System ESF ...................................................................................................... Engineered Safety Feature ESFAS .................................................................. Engineered Safety Features Actuation System FAA ............................................................................................... Federal Aviation Administration FBI ................................................................................................ Federal Bureau of Investigation FCB ...................................................................................................................... Fuel Clad Barrier FEMA ............................................................................ Federal Emergency Management Agency GE ................................................................................................................... General Emergency HPI ............................................................................................................. High Pressure Injection IC ...................................................................................................................... Initiating Condition IPEEE ............................. Individual Plant Examination of External Events (Generic Letter 88-20)
ISFSI ......................................................................... Independent Spent Fuel Storage Installation Keff ...................................................................................... Effective Neutron Multiplication Factor LCO................................................................................................Limiting Condition of Operation LER .............................................................................................................Licensee Event Report LOCA ...................................................................................................... Loss of Coolant Accident LRW ....................................................................................................................Liquid Rad Waste LTOP............................................................................................ Low Temperature Overpressure LWR ................................................................................................................ Light Water Reactor MCC .............................................................................................................. Motor Control Center MPC ................................................ Maximum Permissible Concentration/Multi-Purpose Canister mR, mRem, mrem, mREM ............................................................ milli-Roentgen Equivalent Man MSL...................................................................................................................... Main Steam Line to 0CAN031801 Page 20 of 240 MTS ................................................................................................................ Margin to Saturation MW.................................................................................................................................. Megawatt NDTT ...................................................................................... Nil Ductility Transition Temperature NEI ............................................................................................................Nuclear Energy Institute NEIC ................................................................................ National Earthquake Information Center NESP ................................................................................ National Environmental Studies Project NORAD ................................................................ North American Aerospace Defense Command NOT .............................................................................................. Normal Operating Temperature (NO)UE ............................................................................................. Notification of Unusual Event NPP................................................................................................................ Nuclear Power Plant NRC ............................................................................................ Nuclear Regulatory Commission NSSS ............................................................................................. Nuclear Steam Supply System OBE ................................................................................................... Operating Basis Earthquake OCA ........................................................................................................... Owner Controlled Area ODCM ........................................................................................ Off-site Dose Calculation Manual ORO ............................................................................................... Offsite Response Organization PA ........................................................................................................................... Protected Area PAG ..................................................................................................... Protective Action Guideline PRA/PSA .................................. Probabilistic Risk Assessment / Probabilistic Safety Assessment P-T .............................................................................................................. Pressure-Temperature PTS ..................................................................................................... Pressurized Thermal Shock PWR..................................................................................................... Pressurized Water Reactor PSIG ............................................................................................ Pounds per Square Inch Gauge R ..................................................................................................................................... Roentgen RB .........................................................................................................................Reactor Building RCC ......................................................................................................... Reactor Control Console RCB ............................................................................................. Reactor Coolant System Barrier RCP ............................................................................................................ Reactor Coolant Pump RCS ......................................................................................................... Reactor Coolant System Rem, rem, REM ..................................................................................... Roentgen Equivalent Man Rep CET ....................................................................... Representative Core Exit Thermocouples RETS ...................................................................... Radiological Effluent Technical Specifications RPS...................................................................................................... Reactor Protection System RV ...........................................................................................................................Reactor Vessel to 0CAN031801 Page 21 of 240 RVLMS........................................................................... Reactor Vessel Level Monitoring System RWT ............................................................................................................. Refueling Water Tank SAR.............................................................................................................Safety Analysis Report SBO ...................................................................................................................... Station Blackout SCBA ................................................................................... Self-Contained Breathing Apparatus SDC ................................................................................................................... Shutdown Cooling SOCA ........................................................................................... Security Owner Controlled Area SG ....................................................................................................................... Steam Generator SI............................................................................................................................ Safety Injection SPDS ........................................................................................ Safety Parameter Display System SPING ..................................................................................... Super Particulate Iodine Noble Gas SRO ......................................................................................................... Senior Reactor Operator TEDE ............................................................................................ Total Effective Dose Equivalent TOAF ................................................................................................................. Top of Active Fuel TSC ........................................................................................................ Technical Support Center USGS .......................................................................................... United States Geological Survey VBS ............................................................................................................ Vehicle Barrier System 6.0      ANO-TO-NEI 99-01 REV. 6 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of an ANO EAL within the NEI 99-01 IC/EAL identification scheme. Further information regarding the development of the ANO EALs based on the NEI guidance can be found in the EAL Comparison Matrix.
ANO                              NEI 99-01 Rev. 6 EAL                      IC                  Example EAL AU1.1                    AU1                            1, 2 AU1.2                    AU1                              3 AU2.1                    AU2                              1 AA1.1                    AA1                              1 AA1.2                    AA1                              2 AA1.3                    AA1                              3 AA1.4                    AA1                              4 AA2.1                    AA2                              1 to 0CAN031801 Page 22 of 240 ANO      NEI 99-01 Rev. 6 EAL  IC        Example EAL AA2.2 AA2              2 AA2.3 AA2              3 AA3.1 AA3              1 AA3.2 AA3              2 AS1.1 AS1              1 AS1.2 AS1              2 AS1.3 AS1              3 AS2.1 AS2              1 AG1.1 AG1              1 AG1.2 AG1              2 AG1.3 AG1              3 AG2.1 AG2              1 CU1.1 CU1              1 CU1.2 CU1              2 CU2.1 CU2              1 CU3.1 CU3              1 CU3.2 CU3              2 CU4.1 CU4              1 CU5.1 CU5            1, 2, 3 CA1.1 CA1              1 CA1.2 CA1              2 CA2.1 CA2              1 CA3.1 CA3            1, 2 CA6.1 CA6              1 CS1.1 CS1              1 CS1.2 CS1              2 CS1.3 CS1              3 CG1.1 CG1              1 CG1.2 CG1              2 EU1.1 EU1              1 FA1.1 FA1              1 to 0CAN031801 Page 23 of 240 ANO      NEI 99-01 Rev. 6 EAL  IC        Example EAL FS1.1 FS1              1 FG1.1 FG1              1 HU1.1 HU1            1, 2, 3 HU2.1 HU2              1 HU3.1 HU3              1 HU3.2 HU3              2 HU3.3 HU3              3 HU3.4 HU3              4 HU4.1 HU4              1 HU4.2 HU4              2 HU4.3 HU4              3 HU4.4 HU4              4 HU7.1 HU7              1 HA1.1 HA1            1, 2 HA5.1 HA5              1 HA6.1 HA6              1 HA7.1 HA7              1 HS1.1 HS1              1 HS6.1 HS6              1 HS7.1 HS7              1 HG7.1 HG7              1 SU1.1 SU1              1 SU3.1 SU2              1 SU4.1 SU3              1 SU4.2 SU3              2 SU5.1 SU4            1, 2, 3 SU6.1 SU5              1 SU6.2 SU5              2 SU7.1 SU6            1, 2, 3 SU8.1 SU7            1, 2 SA1.1 SA1              1 to 0CAN031801 Page 24 of 240 ANO                NEI 99-01 Rev. 6 EAL          IC          Example EAL SA3.1        SA2                1 SA6.1        SA5                1 SA9.1        SA9                1 SS1.1        SS1                1 SS2.1        SS8                1 SS6.1        SS5                1 SG1.1          SG1                1 SG1.2          SG8                1 7.0  ATTACHMENTS 7.1  Attachment 1, Emergency Action Level Technical Bases 7.2  Attachment 2, Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases to 0CAN031801 Page 25 of 240 Attachment 1 - Emergency Action Level Technical Bases Category A - Abnormal Rad Levels / Rad Effluent EAL Group:        ANY (EALs in this category are applicable to any plant condition, hot or cold.)
Many EALs are based on actual or potential degradation of fission product barriers because of the elevated potential for offsite radioactivity release. Degradation of fission product barriers though is not always apparent via non-radiological symptoms. Therefore, direct indication of elevated radiological effluents or area radiation levels are appropriate symptoms for emergency classification.
At lower levels, abnormal radioactivity releases may be indicative of a failure of containment systems or precursors to more significant releases. At higher release rates, offsite radiological conditions may result which require offsite protective actions. Elevated area radiation levels in plant may also be indicative of the failure of containment systems or preclude access to plant vital equipment necessary to ensure plant safety.
Events of this category pertain to the following subcategories:
: 1. Radiological Effluent Direct indication of effluent radiation monitoring systems provides a rapid assessment mechanism to determine releases in excess of classifiable limits. Projected offsite doses, actual offsite field measurements or measured release rates via sampling indicate doses or dose rates above classifiable limits.
: 2. Irradiated Fuel Event Conditions indicative of a loss of adequate shielding or damage to irradiated fuel may preclude access to vital plant areas or result in radiological releases that warrant emergency classification.
: 3. Area Radiation Levels Sustained general area radiation levels which may preclude access to areas requiring continuous occupancy also warrant emergency classification.
to 0CAN031801 Page 26 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                          A - Abnormal Rad Levels / Rad Effluent Subcategory:                      1 - Radiological Effluent Initiating Condition:              Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:
AU1.1            Unusual Event Reading on any Table 1[2]A-1 effluent radiation monitor > column "UE" for  60 min.
(Notes 1, 2, 3)
Note 1:        The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:        If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Note 3:        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.
Table 1A-1        Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE                SAE              Alert              UE RX-9820 Containment Purge                4.15E+01 Ci/cc    4.15E+00 &#xb5;Ci/cc    4.15E-01 &#xb5;Ci/cc  1.21E-03 &#xb5;Ci/cc (SPING 1)
RX-9825 Radwaste Area                    2.67E+01 Ci/cc    2.67E+00 &#xb5;Ci/cc    2.67E-01 &#xb5;Ci/cc  4.94E-04 &#xb5;Ci/cc Gaseous (SPING 2)
RX-9830 Fuel Handling Area              6.20E+02 Ci/cc    6.20E+01 &#xb5;Ci/cc    6.20E+00 &#xb5;Ci/cc  5.44E-04 &#xb5;Ci/cc (SPING 3)
Emergency            RX-9835 6.55E+02 Ci/cc    6.55E+01 &#xb5;Ci/cc    6.55E+00 &#xb5;Ci/cc  1.21E-02 &#xb5;Ci/cc Penetration Room    (SPING 4)
Liquid Liquid Radwaste      RE-4642          ----              ----              ----        2.46E+05 cpm to 0CAN031801 Page 27 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1        Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE              SAE              Alert              UE 2RX-9820 Containment Purge                1.88E+01 Ci/cc  1.88E+00 &#xb5;Ci/cc  1.88E-01 &#xb5;Ci/cc  5.48E-04 &#xb5;Ci/cc (SPING 5) 2RX-9825 Radwaste Area                    2.35E+01 Ci/cc  2.35E+00 &#xb5;Ci/cc  2.35E-01 &#xb5;Ci/cc  4.35E-04 &#xb5;Ci/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area              6.86E+02 Ci/cc  6.86E+01 &#xb5;Ci/cc  6.86E+00 &#xb5;Ci/cc  6.04E-04 &#xb5;Ci/cc (SPING 7)
Emergency            2RX-9835 5.88E+02 Ci/cc  5.88E+01 &#xb5;Ci/cc  5.88E+00 &#xb5;Ci/cc  1.09E-02 &#xb5;Ci/cc Penetration Room    (SPING 8)
BMS Liquid 2RE-2330          ----              ----              ----        2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423          ----              ----              ----        2.45E+05 cpm Waste Discharge Mode Applicability:
All Definition(s):
VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
Basis:
This IC addresses a potential reduction 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.
to 0CAN031801 Page 28 of 240 Attachment 1 - Emergency Action Level Technical Bases 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.
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.
Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.
This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways as well as radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit.
Such releases are typically associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).
Escalation of the emergency classification level would be via IC AA1.
Reference(s):
: 1. OP-1604.051 Eberline Radiation Monitor System
: 2. Offsite Dose Calculation Manual
: 3. EP-CALC-ANO-1701 Radiological Effluent EAL Values
: 4. NEI 99-01 AU1 to 0CAN031801 Page 29 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                1 - Radiological Effluent Initiating Condition:        Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:
AU1.2      Unusual Event Sample analysis for a gaseous or liquid release indicates a concentration or release rate 2 x ODCM limits for  60 min. (Notes 1, 2)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:  If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Mode Applicability:
All Definition(s):
None Basis:
This IC addresses a potential reduction 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.
to 0CAN031801 Page 30 of 240 Attachment 1 - Emergency Action Level Technical Bases Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.
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 AA1.
Reference(s):
: 1. Offsite Dose Calculation Manual
: 2. NEI 99-01 AU1 to 0CAN031801 Page 31 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                          A - Abnormal Rad Levels / Rad Effluent Subcategory:                      1 - Radiological Effluent Initiating Condition:              Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:
AA1.1            Alert Reading on any Table 1[2]A-1 effluent radiation monitor > column "ALERT" for  15 min.
(Notes 1, 2, 3, 4)
Note 1:        The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:        If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Note 3:        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.
Note 4          The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
Table 1A-1        Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE                SAE              Alert              UE RX-9820 Containment Purge                4.15E+01 Ci/cc    4.15E+00 &#xb5;Ci/cc    4.15E-01 &#xb5;Ci/cc  1.21E-03 &#xb5;Ci/cc (SPING 1)
RX-9825 Radwaste Area                    2.67E+01 Ci/cc    2.67E+00 &#xb5;Ci/cc    2.67E-01 &#xb5;Ci/cc  4.94E-04 &#xb5;Ci/cc Gaseous (SPING 2)
RX-9830 Fuel Handling Area              6.20E+02 Ci/cc    6.20E+01 &#xb5;Ci/cc    6.20E+00 &#xb5;Ci/cc  5.44E-04 &#xb5;Ci/cc (SPING 3)
Emergency            RX-9835 6.55E+02 Ci/cc    6.55E+01 &#xb5;Ci/cc    6.55E+00 &#xb5;Ci/cc  1.21E-02 &#xb5;Ci/cc Penetration Room    (SPING 4)
Liquid Liquid Radwaste      RE-4642          ----              ----              ----        2.46E+05 cpm to 0CAN031801 Page 32 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1        Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE              SAE              Alert              UE 2RX-9820 Containment Purge                1.88E+01 Ci/cc  1.88E+00 &#xb5;Ci/cc  1.88E-01 &#xb5;Ci/cc  5.48E-04 &#xb5;Ci/cc (SPING 5) 2RX-9825 Radwaste Area                    2.35E+01 Ci/cc  2.35E+00 &#xb5;Ci/cc  2.35E-01 &#xb5;Ci/cc  4.35E-04 &#xb5;Ci/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area              6.86E+02 Ci/cc  6.86E+01 &#xb5;Ci/cc  6.86E+00 &#xb5;Ci/cc  6.04E-04 &#xb5;Ci/cc (SPING 7)
Emergency            2RX-9835 5.88E+02 Ci/cc  5.88E+01 &#xb5;Ci/cc  5.88E+00 &#xb5;Ci/cc  1.09E-02 &#xb5;Ci/cc Penetration Room    (SPING 8)
BMS Liquid 2RE-2330          ----              ----              ----        2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423          ----              ----              ----        2.45E+05 cpm Waste Discharge Mode Applicability:
All Definition(s):
VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
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.
to 0CAN031801 Page 33 of 240 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
Escalation of the emergency classification level would be via IC AS1.
Reference(s):
: 1. OP-1604.051 Eberline Radiation Monitor System
: 2. EP-CALC-ANO-1701 Radiological Effluent EAL Values
: 3. NEI 99-01 AA1 to 0CAN031801 Page 34 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  A - Abnormal Rad Levels / Rad Effluent Subcategory:                1 - Radiological Effluent Initiating Condition:      Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:
AA1.2      Alert Dose assessment using actual meteorology indicates doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)
Note 4:  The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
Mode Applicability:
All Definition(s):
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.
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 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
Escalation of the emergency classification level would be via IC AS1.
Reference(s):
: 1. OP-1904.002 Offsite Dose Projections
: 2. NEI 99-01 AA1 to 0CAN031801 Page 35 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                1 - Radiological Effluent Initiating Condition:        Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:
AA1.3      Alert Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY for 60 min. of exposure (Notes 1, 2)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:  If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Mode Applicability:
All Definition(s):
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.
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 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
This EAL is assessed per the ODCM (ref. 2).
Escalation of the emergency classification level would be via IC AS1.
to 0CAN031801 Page 36 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. OP-1904.002 Offsite Dose Projections
: 2. Offsite Dose Calculation Manual
: 3. NEI 99-01 AA1 to 0CAN031801 Page 37 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                  1 - Radiological Effluent Initiating Condition:        Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:
AA1.4        Alert Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:
Closed window dose rates > 10 mR/hr expected to continue for  60 min.
Analyses of field survey samples indicate thyroid CDE > 50 mrem for 60 min. of inhalation (Notes 1, 2)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:    If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Mode Applicability:
All Definition(s):
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.
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.
to 0CAN031801 Page 38 of 240 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
Escalation of the emergency classification level would be via IC AS1.
Reference(s):
: 1. OP-1905.002 Offsite Emergency Monitoring
: 2. NEI 99-01 AA1 to 0CAN031801 Page 39 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                          A - Abnormal Rad Levels / Rad Effluent Subcategory:                      1 - Radiological Effluent Initiating Condition:              Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:
AS1.1            Site Area Emergency Reading on any Table A-1 effluent radiation monitor > column "SAE" for  15 min.
(Notes 1, 2, 3, 4)
Note 1:        The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:        If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Note 3:        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.
Note 4:        The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
Table 1A-1        Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE                SAE              Alert              UE RX-9820 Containment Purge                4.15E+01 Ci/cc    4.15E+00 &#xb5;Ci/cc    4.15E-01 &#xb5;Ci/cc  1.21E-03 &#xb5;Ci/cc (SPING 1)
RX-9825 Radwaste Area                    2.67E+01 Ci/cc    2.67E+00 &#xb5;Ci/cc    2.67E-01 &#xb5;Ci/cc  4.94E-04 &#xb5;Ci/cc Gaseous (SPING 2)
RX-9830 Fuel Handling Area              6.20E+02 Ci/cc    6.20E+01 &#xb5;Ci/cc    6.20E+00 &#xb5;Ci/cc  5.44E-04 &#xb5;Ci/cc (SPING 3)
Emergency            RX-9835 6.55E+02 Ci/cc    6.55E+01 &#xb5;Ci/cc    6.55E+00 &#xb5;Ci/cc  1.21E-02 &#xb5;Ci/cc Penetration Room    (SPING 4)
Liquid Liquid Radwaste      RE-4642          ----              ----              ----        2.46E+05 cpm to 0CAN031801 Page 40 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1        Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE              SAE              Alert              UE 2RX-9820 Containment Purge                1.88E+01 Ci/cc  1.88E+00 &#xb5;Ci/cc  1.88E-01 &#xb5;Ci/cc  5.48E-04 &#xb5;Ci/cc (SPING 5) 2RX-9825 Radwaste Area                    2.35E+01 Ci/cc  2.35E+00 &#xb5;Ci/cc  2.35E-01 &#xb5;Ci/cc  4.35E-04 &#xb5;Ci/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area              6.86E+02 Ci/cc  6.86E+01 &#xb5;Ci/cc  6.86E+00 &#xb5;Ci/cc  6.04E-04 &#xb5;Ci/cc (SPING 7)
Emergency            2RX-9835 5.88E+02 Ci/cc  5.88E+01 &#xb5;Ci/cc  5.88E+00 &#xb5;Ci/cc  1.09E-02 &#xb5;Ci/cc Penetration Room    (SPING 8)
BMS Liquid 2RE-2330          ----              ----              ----        2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423          ----              ----              ----        2.45E+05 cpm Waste Discharge Mode Applicability:
All Definition(s):
VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
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.
to 0CAN031801 Page 41 of 240 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
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.
Escalation of the emergency classification level would be via IC AG1.
Reference(s):
: 1. OP-1604.051 Eberline Radiation Monitor System
: 2. EP-CALC-ANO-1701 Radiological Effluent EAL Values
: 3. NEI 99-01 AS1 to 0CAN031801 Page 42 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                1 - Radiological Effluent Initiating Condition:        Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:
AS1.2      Site Area Emergency Dose assessment using actual meteorology indicates doses > 100 mrem TEDE or 500 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)
Note 4    The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
Mode Applicability:
All Definition(s):
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant).
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 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
Escalation of the emergency classification level would be via IC AG1.
Reference(s):
: 1. OP-1904.002 Offsite Dose Projections
: 2. NEI 99-01 AS1 to 0CAN031801 Page 43 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                  1 - Radiological Effluent Initiating Condition:        Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:
AS1.3        Site Area Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:
Closed window dose rates > 100 mR/hr expected to continue for  60 min.
Analyses of field survey samples indicate thyroid CDE > 500 mrem for 60 min. of inhalation (Notes 1, 2)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:    If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Mode Applicability:
All Definition(s):
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.
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 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
Escalation of the emergency classification level would be via IC AG1.
to 0CAN031801 Page 44 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. OP-1905.002 Offsite Emergency Monitoring
: 2. NEI 99-01 AS1 to 0CAN031801 Page 45 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                          A - Abnormal Rad Levels / Rad Effluent Subcategory:                      1 - Radiological Effluent Initiating Condition:              Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:
AG1.1            General Emergency Reading on any Table A-1 effluent radiation monitor > column "GE" for  15 min.
(Notes 1, 2, 3, 4)
Note 1:        The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:        If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Note 3:        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.
Note 4:        The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
Table 1A-1        Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE                SAE              Alert              UE RX-9820 Containment Purge                4.15E+01 Ci/cc    4.15E+00 &#xb5;Ci/cc    4.15E-01 &#xb5;Ci/cc  1.21E-03 &#xb5;Ci/cc (SPING 1)
RX-9825 Radwaste Area                    2.67E+01 Ci/cc    2.67E+00 &#xb5;Ci/cc    2.67E-01 &#xb5;Ci/cc  4.94E-04 &#xb5;Ci/cc Gaseous (SPING 2)
RX-9830 Fuel Handling Area              6.20E+02 Ci/cc    6.20E+01 &#xb5;Ci/cc    6.20E+00 &#xb5;Ci/cc  5.44E-04 &#xb5;Ci/cc (SPING 3)
Emergency            RX-9835 6.55E+02 Ci/cc    6.55E+01 &#xb5;Ci/cc    6.55E+00 &#xb5;Ci/cc  1.21E-02 &#xb5;Ci/cc Penetration Room    (SPING 4)
Liquid Liquid Radwaste      RE-4642          ----              ----              ----        2.46E+05 cpm to 0CAN031801 Page 46 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1        Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point        Monitor          GE              SAE              Alert              UE 2RX-9820 Containment Purge                1.88E+01 Ci/cc  1.88E+00 &#xb5;Ci/cc  1.88E-01 &#xb5;Ci/cc  5.48E-04 &#xb5;Ci/cc (SPING 5) 2RX-9825 Radwaste Area                    2.35E+01 Ci/cc  2.35E+00 &#xb5;Ci/cc  2.35E-01 &#xb5;Ci/cc  4.35E-04 &#xb5;Ci/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area              6.86E+02 Ci/cc  6.86E+01 &#xb5;Ci/cc  6.86E+00 &#xb5;Ci/cc  6.04E-04 &#xb5;Ci/cc (SPING 7)
Emergency            2RX-9835 5.88E+02 Ci/cc  5.88E+01 &#xb5;Ci/cc  5.88E+00 &#xb5;Ci/cc  1.09E-02 &#xb5;Ci/cc Penetration Room    (SPING 8)
BMS Liquid 2RE-2330          ----              ----              ----        2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423          ----              ----              ----        2.45E+05 cpm Waste Discharge Mode Applicability:
All Definition(s):
VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
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.
to 0CAN031801 Page 47 of 240 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
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.
Reference(s):
: 1. OP-1604.051 Eberline Radiation Monitor System
: 2. EP-CALC-ANO-1701 Radiological Effluent EAL Values
: 3. NEI 99-01 AG1 to 0CAN031801 Page 48 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  A - Abnormal Rad Levels / Rad Effluent Subcategory:                1 - Radiological Effluent Initiating Condition:      Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:
AG1.2      General Emergency Dose assessment using actual meteorology indicates doses > 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)
Note 4    The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
Mode Applicability:
All Definition(s):
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant).
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 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
Reference(s):
: 1. OP-1904.002 Offsite Dose Projections
: 2. NEI 99-01 AG1 to 0CAN031801 Page 49 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                1 - Radiological Effluent Initiating Condition:        Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:
AG1.3      General Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:
Closed window dose rates > 1,000 mR/hr expected to continue for  60 min.
Analyses of field survey samples indicate thyroid CDE > 5,000 mrem for 60 min. of inhalation (Notes 1, 2)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 2:  If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Mode Applicability:
All Definition(s):
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.
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 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
to 0CAN031801 Page 50 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. OP-1905.002 Offsite Emergency Monitoring
: 2. NEI 99-01 AG1 to 0CAN031801 Page 51 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                A - Abnormal Rad Levels / Rad Effluent Subcategory:              2 - Irradiated Fuel Event Initiating Condition:    UNPLANNED loss of water level above irradiated fuel EAL:
AU2.1      Unusual Event UNPLANNED water level drop in the REFUELING PATHWAY as indicated by low water level alarm, visual observation, or BWST[RWT] level drop due to makeup demands AND UNPLANNED rise in corresponding area radiation levels as indicated by any of the following radiation monitors:
Unit 1 o  RE-8009 Spent Fuel Area o  RE-8017 Fuel Handling Area Unit 2 o  2RE-8914 Spent Fuel Area o  2RE-8915 Spent Fuel Area o  2RE-8916 Spent Fuel Area o  2RE-8912 Containment Incore Instrumentation Mode Applicability:
All Definition(s):
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, but not including the reactor vessel.
to 0CAN031801 Page 52 of 240 Attachment 1 - Emergency Action Level Technical Bases Basis:
This IC addresses a drop 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 drop 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). A significant drop in the water level may also cause a rise in the radiation levels of adjacent areas that can be detected by monitors in those locations.
The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may rise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.
A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.
Escalation of the emergency classification level would be via IC AA2.
Reference(s):
: 1. OP-1203.050 Unit 1 Spent Fuel Pool Emergencies
: 2. OP-2203.002 Spent Fuel Pool Emergencies
: 3. 1SAR 11.2.5 Area Radiation Monitoring Systems Table 11-15 Area Radiation Monitors
: 4. 2SAR 12.1.4 Area Radiation Monitoring System
: 5. NEI 99-01 AU2 to 0CAN031801 Page 53 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                2 - Irradiated Fuel Event Initiating Condition:        Significant lowering of water level above, or damage to, irradiated fuel EAL:
AA2.1      Alert IMMINENT uncovery of irradiated fuel in the REFUELING PATHWAY.
Mode Applicability:
All Definition(s):
CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).
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.
REFUELING PATHWAY - All the cavities, tubes, canals and pools through which irradiated fuel may be moved, but not including the reactor vessel.
Basis:
This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the REFUELING PATHWAY. 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 EU1.
This EAL escalates from AU2.1 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.
to 0CAN031801 Page 54 of 240 Attachment 1 - Emergency Action Level Technical Bases While an area radiation monitor could detect a rise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss.
A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance with Recognition Category C during the Cold Shutdown and Refueling modes.
Escalation of the emergency classification level would be via IC AS1.
Reference(s):
: 1. NEI 99-01 AA2 to 0CAN031801 Page 55 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                A - Abnormal Rad Levels / Rad Effluent Subcategory:              2 - Irradiated Fuel Event Initiating Condition:    Significant lowering of water level above, or damage to, irradiated fuel EAL:
AA2.2      Alert Damage to irradiated fuel resulting in a release of radioactivity AND High alarm on any Table 1[2]A-2 radiation monitor.
Table 1A-2      Unit 1 Fuel Damage Radiation Monitors RE-8009 Spent Fuel Area RE-8017 Fuel Handling RE-8060 Containment High Range Radiation Monitors RE-8061 Containment High Range Radiation Monitors RX-9820 (SPING 1) Containment Purge RX-9825 (SPING 2) Radwaste Area RX-9830 (SPING 3) Fuel Handling Area Table 2A-2      Unit 2 Fuel Damage Radiation Monitors 2RE-8905 Containment Equipment Hatch Area 2RE-8909 Containment Personnel Access Area 2RE-8912 Containment Incore Inst.
2RE-8914 Spent Fuel Area 2RE-8915 Spent Fuel Area 2RE-8916 Spent Fuel Area 2RE-8925-1 Containment High Range Radiation Monitors 2RE-8925-2 Containment High Range Radiation Monitors 2RX-9820 (SPING 5) Containment Purge 2RX-9825 (SPING 6) Radwaste Area 2RX-9830 (SPING 7) Fuel Handling Area to 0CAN031801 Page 56 of 240 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:
All Definition(s):
CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).
VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
Basis:
This EAL addresses events that have caused actual damage to an irradiated fuel assembly.
These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.
This EAL 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 EU1.
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 classification level would be via IC AS1.
Reference(s):
: 1. OP-1203.050 Unit 1 Spent Fuel Pool Emergencies
: 2. OP-1305.001 Radiation Monitoring System Check and Test
: 3. OP-2203.002 Spent Fuel Pool Emergencies
: 4. OP-1604.051 Eberline Radiation Monitoring System
: 5. OP-2304.133 Containment High Range Radiation Monitor Calibration
: 6. Offsite Dose Calculation Manual
: 7. NEI 99-01 AA2 to 0CAN031801 Page 57 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  A - Abnormal Rad Levels / Rad Effluent Subcategory:                2 - Irradiated Fuel Event Initiating Condition:      Significant lowering of water level above, or damage to, irradiated fuel EAL:
AA2.3      Alert Lowering of spent fuel pool level to 387.0 ft.[389.5 ft.] (Alarm 2) on LIT-2020-3(4)
[2LIT-2020-1(2)]
Mode Applicability:
All Definition(s):
None Basis:
This EAL addresses events that have caused a significant lowering of water level within the spent fuel pool. 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.
Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.
Escalation of the emergency classification level would be via IC AS1 or AS2.
Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).
Reference(s):
: 1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0
: 2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0
: 3. NEI 99-01 AA2 to 0CAN031801 Page 58 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                2 - Irradiated Fuel Event Initiating Condition:        Spent fuel pool level at the top of the fuel racks EAL:
AS2.1      Site Area Emergency Lowering of spent fuel pool level to 377.0 ft.[379.5 ft.] (Alarm 3) on LIT-2020-3(4)
[2LIT-2020-1(2)]
Mode Applicability:
All Definition(s):
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.
Basis:
This EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to IMMINENT fuel damage. This condition entails major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.
It is recognized that this IC would likely not be met until well after another Site Area Emergency IC was met; however, it is included to provide classification diversity.
Escalation of the emergency classification level would be via IC AG1 or AG2.
Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).
Reference(s):
: 1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0
: 2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0
: 3. NEI 99-01 AS2 to 0CAN031801 Page 59 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                2 - Irradiated Fuel Event Initiating Condition:        Spent fuel pool level cannot be restored to at least the top of the fuel racks for 60 minutes or longer EAL:
AG2.1      General Emergency Spent fuel pool level cannot be restored to at least 377.0 ft.[379.5 ft.] (Alarm 3) on LIT-2020-3(4)[2LIT-2020-1(2)] for  60 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
All Definition(s):
None Basis:
This EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment.
It is recognized that this IC would likely not be met until well after another General Emergency IC was met; however, it is included to provide classification diversity.
Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).
Reference(s):
: 1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0
: 2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0
: 3. NEI 99-01 AG2 to 0CAN031801 Page 60 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  A - Abnormal Rad Levels / Rad Effluent Subcategory:                3 - Area Radiation Levels Initiating Condition:      Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:
AA3.1    Alert Dose rate > 15 mR/hr in EITHER of the following areas:
Control Room Central Alarm Station (by survey)
Mode Applicability:
All Definition(s):
IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
Basis:
Areas that meet this threshold include the Control Room (CR) and the Central Alarm Station (CAS). The Control Room envelope (Unit 1 and Unit 2) is monitored for excessive radiation by five detectors. These radiation detectors are RE-8001, 2RE-8001A, 2RE-8001B, 2RE-8750-1A, and 2RE-8750-1B (ref. 1). The CAS is included in this EAL because of its importance to permitting access to areas required to assure safe plant operations. There are no permanently installed area radiation monitors in CAS that may be used to assess this EAL threshold.
Therefore, this threshold is evaluated using local radiation survey for this area.
This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or IMPEDE personnel from performing actions necessary to maintain normal plant operation, or to perform 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 rise in radiation levels and determine if another IC may be applicable.
Escalation of the emergency classification level would be via Recognition Category A, C or F ICs.
to 0CAN031801 Page 61 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. STM 1-62 Radiation Monitoring
: 2. NEI 99-01 AA3 to 0CAN031801 Page 62 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    A - Abnormal Rad Levels / Rad Effluent Subcategory:                3 - Area Radiation Levels Initiating Condition:        Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:
AA3.2      Alert An UNPLANNED event results in radiation levels that prohibit or IMPEDE access to any Table 1[2]A-3 room or area (Note 5)
Note 5:  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.
Table 1A-3        Unit 1 Safe Operation & Shutdown Rooms/Areas Room/Area                            Mode A-4 Switchgear Room                                            3, 4 Upper North Electrical Penetration Room                        3, 4 Lower South Electrical Equipment Room                          3, 4 Table 2A-3        Unit 2 Safe Operation & Shutdown Rooms/Areas Room/Area                            Mode Aux Building 317 Emergency Core Cooling Rooms                  3, 4 Aux Building 317 Tendon Gallery Access                        3, 4 Aux Building 335 Charging Pumps / MCC 2B-52                    3, 4 Aux Building 354 MCC 2B-62 Area                                3, 4 Emergency Diesel Generator Corridor                            3, 4 Lower South Piping Penetration Room                            3, 4 Aux Building 386 Containment Hatch                            3, 4 to 0CAN031801 Page 63 of 240 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:
3 - Hot Standby, 4 - Hot Shutdown Definition(s):
IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
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.
Basis:
This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or IMPEDE personnel from performing actions necessary to maintain normal plant operation, or to perform 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 rise in radiation levels and determine if another IC may be applicable.
For AA3.2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the elevated radiation levels. The emergency classification is not contingent upon whether entry is actually necessary at the time of the higher 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, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).
An emergency declaration is not warranted if any of the following conditions apply:
The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation rise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 3.
The higher 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 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 A, C or F ICs.
to 0CAN031801 Page 64 of 240 Attachment 1 - Emergency Action Level Technical Bases If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact beyond that already allowed by Technical Specifications at the time of the event.
The list of plant rooms or areas with entry-related mode applicability identified specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations) are not included. In addition, the list specifies the plant mode(s) during which entry would be required for each room or area (ref. 1).
EAL AA3.2 mode applicability has been limited to the mode limitations of Table 1[2]A-3 (Modes 3 and 4 only).
Reference(s):
: 1. Attachment 2 Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases
: 2. NEI 99-01 AA3 to 0CAN031801 Page 65 of 240 Attachment 1 - Emergency Action Level Technical Bases Category C - Cold Shutdown / Refueling System Malfunction EAL Group:        Cold Conditions (RCS temperature  200&deg;F); EALs in this category are applicable only in one or more cold operating modes.
Category C EALs are directly associated with cold shutdown or refueling system safety functions. Given the variability of plant configurations (e.g., systems out-of-service for maintenance, containment open, reduced AC power redundancy, time since shutdown) during these periods, the consequences of any given initiating event can vary greatly. For example, a loss of decay heat removal capability that occurs at the end of an extended outage has less significance than a similar loss occurring during the first week after shutdown. Compounding these events is the likelihood that instrumentation necessary for assessment may also be inoperable. The cold shutdown and refueling system malfunction EALs are based on performance capability to the extent possible with consideration given to RCS integrity, CONTAINMENT CLOSURE, and fuel clad integrity for the applicable operating modes (5 - Cold Shutdown, 6 - Refueling, DEF - Defueled).
The events of this category pertain to the following subcategories:
: 1. RCS Level RCS water level is directly related to the status of adequate core cooling and, therefore, fuel clad integrity.
: 2. Loss of Vital AC Power Loss of vital plant electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite power sources for 4.16 KV vital buses.
: 3. RCS Temperature Uncontrolled or inadvertent temperature or pressure rises are indicative of a potential loss of safety functions.
: 4. Loss of Vital DC Power Loss of emergency plant electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of power to or degraded voltage on the 125V DC vital buses.
: 5. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.
: 6. Hazardous Event Affecting Safety Systems Certain hazardous natural and technological events may result in VISIBLE DAMAGE to or degraded performance of safety systems warranting classification.
to 0CAN031801 Page 66 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                1 - RCS Level Initiating Condition:        UNPLANNED loss of RCS inventory EAL:
CU1.1      Unusual Event UNPLANNED loss of reactor coolant results in RCS water level less than a required lower limit for  15 min. (Note 1)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
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.
Basis:
This EAL addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.
Refueling evolutions that lower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level lowering below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.
This EAL recognizes that the minimum required RCS level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.
to 0CAN031801 Page 67 of 240 Attachment 1 - Emergency Action Level Technical Bases The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.
Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.
Reference(s):
: 1. OP-1015.002 Decay Heat Removal and LTOP System
: 2. OP-1015.008 Unit 2 SDC Control
: 3. NEI 99-01 CU1 to 0CAN031801 Page 68 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                C - Cold Shutdown / Refueling System Malfunction Subcategory:              1 - RCS Level Initiating Condition:    UNPLANNED loss of RCS inventory EAL:
CU1.2      Unusual Event RCS level cannot be monitored AND EITHER UNPLANNED rise in any Table 1[2]C-1 sump/tank level due to loss of RCS inventory Visual observation of UNISOLABLE RCS leakage Table 1C-1    Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank Table 2C-1    Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)
Holdup Tank Aux. Building Sump Quench Tank Mode Applicability:
5 - Cold Shutdown, 6 - Refueling to 0CAN031801 Page 69 of 240 Attachment 1 - Emergency Action Level Technical Bases Definition(s):
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.
Basis:
This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.
Refueling evolutions that lower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level lowering below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.
This EAL addresses a condition where all means to determine RCS level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels (Table C-1). Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.
Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.
Reference(s):
: 1. OP-1203.039 Excess RCS Leakage
: 2. OP-2203.016 Excess RCS Leakage
: 3. NEI 99-01 CU1 to 0CAN031801 Page 70 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                1 - RCS Level Initiating Condition:        Significant Loss of RCS inventory EAL:
CA1.1      Alert Loss of RCS inventory as indicated by EITHER:
RVLMS Levels 1 through 8[1 through 5] indicate DRY Reactor vessel level 368.5 ft. (LT-1195/LT-1196)[0 in. (L4791/L4792)] (bottom of hot leg)
Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
None Basis:
This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.
For this EAL, a lowering of RPV water level below the specified level indicates that operator actions have not been successful in restoring and maintaining RCS water level. The heat-up rate of the coolant will rise as the available water inventory is reduced. A continuing drop in water level will lead to core uncovery.
Although related, this EAL is concerned with the loss of RPV inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Decay Heat Removal suction point). A rise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA3.
If water level continues to lower, then escalation to Site Area Emergency would be via IC CS1.
The bottom of the RCS hot leg penetration into the reactor vessel is approximately RLVMS Level 8 (Unit 1) or RVLMS Level 5 (Unit 2). However, RVLMS may not be available in the cold shutdown modes. Redundant means of level indication is provided in these modes and included in this EAL. The bottom of the RCS hot leg penetration into the reactor vessel is 368 ft., 0 in. (Unit 1) or 369 ft., 1.5 in. (Unit 2). Below this level, reactor vessel level indication may be lost and loss of suction to decay heat removal systems will occur (ref. 1, 2, 3). Where to 0CAN031801 Page 71 of 240 Attachment 1 - Emergency Action Level Technical Bases redundant means of level indication cannot read below this level, the lowest indication that can be read on scale is used for this EAL. The inability to restore and maintain level after reaching this setpoint would be indicative of a failure of the RCS barrier.
Reference(s):
: 1. OP-1105.008 Inadequate Core Cooling Monitor and Display
: 2. OP-2105.003 Reactor Vessel Level Monitoring System Operations
: 3. Calculation No. 90-E-0116-01 ANO-2 EOP Setpoint Basis Document, Setpoints R.3 and R.9
: 4. NEI 99-01 CA1 to 0CAN031801 Page 72 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  C - Cold Shutdown / Refueling System Malfunction Subcategory:                1 - RCS Level Initiating Condition:      Significant Loss of RCS inventory EAL:
CA1.2      Alert RCS level cannot be monitored for  15 min. (Note 1)
AND EITHER UNPLANNED rise in any Table 1[2]C-1 sump/tank level due to a loss of RCS inventory Visual observation of UNISOLABLE RCS leakage Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1C-1      Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank Table 2C-1      Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)
Holdup Tank Aux. Building Sump Quench Tank to 0CAN031801 Page 73 of 240 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
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.
Basis:
This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.
For this EAL, the inability to monitor RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.
The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS1.
If the RCS inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS1.
Reference(s):
: 1. OP-1203.039 Excess RCS Leakage
: 2. OP-2203.016 Excess RCS Leakage
: 3. NEI 99-01 CA1 to 0CAN031801 Page 74 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                1 - RCS Level Initiating Condition:        Loss of RCS inventory affecting core decay heat removal capability EAL:
CS1.1      Site Area Emergency CONTAINMENT CLOSURE not established AND RVLMS Levels 1 through 9[1 through 6] indicate DRY Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
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.
Basis:
This IC addresses a significant and prolonged loss of RCS inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.
Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.
Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.
to 0CAN031801 Page 75 of 240 Attachment 1 - Emergency Action Level Technical Bases This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
Escalation of the emergency classification level would be via IC CG1 or AG1.
Reference(s):
: 1. OP-1105.008 Inadequate Core Cooling Monitor and Display
: 2. OP-2105.003 Reactor Vessel Level Monitoring System Operations
: 3. NEI 99-01 CS1 to 0CAN031801 Page 76 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  C - Cold Shutdown / Refueling System Malfunction Subcategory:                1 - RCS Level Initiating Condition:      Loss of RCS inventory affecting core decay heat removal capability EAL:
CS1.2      Site Area Emergency
[RVLMS Levels 1 through 7 indicate DRY OR]
RCS level cannot be monitored for  30 min. (Note 1)
AND Core uncovery is indicated by any of the following:
UNPLANNED rise in any Table 1[2]C-1 sump/tank level of sufficient magnitude to indicate core uncovery Containment high range radiation monitor RE-8060/8061[2RE-8925-1/8925-2] reading
          > 10 R/hr Erratic Source Range Monitor indication Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1C-1      Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank to 0CAN031801 Page 77 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2C-1    Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)
Holdup Tank Aux. Building Sump Quench Tank Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
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.
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.
Basis:
When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.
Level 7 DRY on this system is an indication of core uncovery.
This IC addresses a significant and prolonged loss of reactor vessel/RCS inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.
to 0CAN031801 Page 78 of 240 Attachment 1 - Emergency Action Level Technical Bases Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.
Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.
The difference in the specified RCS levels of EALs CS1.1 and CS1.2 reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.
The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.
The inability to monitor RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.
This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
Containment High Range Radiation Monitors RE-8060/8061 [2RE-8925-1/8925-2] are the site-specific radiation monitors that would be indicative of possible core uncovery in the Refueling mode. The dose rate due to core shine when the top of the core becomes uncovered should result in dose rates > 10 R/hr.
Escalation of the emergency classification level would be via IC CG1 or AG1.
Reference(s):
: 1. OP-1203.039 Excess RCS Leakage
: 2. OP-2203.016 Excess RCS Leakage
: 3. OP-2105.003 Reactor Vessel Level Monitoring System Operations
: 4. 1SAR Table 7-11
: 5. 2SAR 12.1.4.2
: 6. NEI 99-01 CS1 to 0CAN031801 Page 79 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                1 - RCS Level Initiating Condition:        Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL:
CG1.1        General Emergency - UNIT 2 ONLY RVLMS Levels 1 through 7 indicate DRY AND Any Containment Challenge indication, Table 2C-2 Note 6:    If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required.
Table 1[2]C-2 Containment Challenge Indications CONTAINMENT CLOSURE not established (Note 6)
Containment hydrogen concentration > 3%
UNPLANNED rise in containment pressure Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
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.
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.
to 0CAN031801 Page 80 of 240 Attachment 1 - Emergency Action Level Technical Bases Basis:
When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.
Level 7 DRY on this system is an indication of core uncovery.
This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.
Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS level cannot be restored, fuel damage is probable.
With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.
The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.
In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.
This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
to 0CAN031801 Page 81 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. OP-1203.039 Excess RCS Leakage
: 2. OP-2203.016 Excess RCS Leakage
: 3. OP-2105.003 Reactor Vessel Level Monitoring System Operations
: 4. 1SAR Table 7-11
: 5. 2SAR 12.1.4.2
: 6. Unit 1 SAMG Figure III-1B
: 7. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart
: 8. NEI 99-01 CG1 to 0CAN031801 Page 82 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  C - Cold Shutdown / Refueling System Malfunction Subcategory:                1 - RCS Level Initiating Condition:      Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL:
CG1.2      General Emergency RCS level cannot be monitored for  30 min. (Note 1)
AND Core uncovery is indicated by any of the following:
UNPLANNED rise in any Table 1[2]C-1 sump/tank level of sufficient magnitude to indicate core uncovery Containment High Range Radiation Monitor RE-8060/8061[2RE-8925-1/8925-2]
reading > 10 R/hr Erratic Source Range Monitor indication AND Any Containment Challenge indication, Table 1[2]C-2 Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 6:  If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required.
Table 1C-1      Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank to 0CAN031801 Page 83 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2C-1    Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)
Holdup Tank Aux. Building Sump Quench Tank Table 1[2]C-2    Containment Challenge Indications CONTAINMENT CLOSURE not established (Note 6)
Containment hydrogen concentration > 3%
UNPLANNED rise in containment pressure Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
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.
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.
to 0CAN031801 Page 84 of 240 Attachment 1 - Emergency Action Level Technical Bases Basis:
When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.
Level 7 DRY on this system is an indication of core uncovery.
This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.
Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS level cannot be restored, fuel damage is probable.
With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.
The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.
In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.
The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.
The inability to monitor RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.
to 0CAN031801 Page 85 of 240 Attachment 1 - Emergency Action Level Technical Bases Containment High Range Radiation Monitor RE-8060/8061 [2RE-8925-1/8925-2] are the site-specific radiation monitors that would be indicative of possible core uncovery in the Refueling mode. The dose rate due to core shine when the top of the core becomes uncovered should result in dose rates > 10 R/hr.
This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
Reference(s):
: 1. OP-1203.039 Excess RCS Leakage
: 2. OP-2203.016 Excess RCS Leakage
: 3. OP-2105.003 Reactor Vessel Level Monitoring System Operations
: 4. 1SAR Table 7-11
: 5. 2SAR 12.1.4.2
: 6. Unit 1 SAMG Figure III-1B
: 7. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart
: 8. NEI 99-01 CG1 to 0CAN031801 Page 86 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                2 - Loss of Vital AC Power Initiating Condition:        Loss of all but one AC power source to vital buses for 15 minutes or longer EAL:
CU2.1      Unusual Event AC power capability, Table 1[2]C-3, to vital 4.16 KV buses A3[2A3] and A4[2A4] reduced to a single power source for  15 min. (Note 1)
AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1C-3      Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)
Onsite DG1 DG2 AAC Gen to 0CAN031801 Page 87 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2C-3    Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)
Onsite 2DG1 2DG2 AAC Gen Mode Applicability:
5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):
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 (as defined in 10 CFR 50.2):
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.
When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the greater time available to restore another power source to service.
Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.
to 0CAN031801 Page 88 of 240 Attachment 1 - Emergency Action Level Technical Bases An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to a vital bus. Some examples of this condition are presented below.
A loss of all offsite power with a concurrent failure of all but one vital power source.
A loss of all offsite power and loss of all vital power sources with a single train of vital buses being back-fed from the unit main generator.
A loss of vital power sources (e.g., onsite diesel generators) with a single train of vital buses being back-fed from an offsite power source.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.
The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA2.
This EAL is the cold condition equivalent of the hot condition EAL SA1.1.
Reference(s):
: 1. 1SAR Figure 8-1 Station Single Line Diagram
: 2. OP-1202.007 Degraded Power
: 3. OP-1202.008 Blackout
: 4. OP-2104.037 Alternate AC Diesel Generator Operations
: 5. 2SAR Figure 8.3-1 Station Single Line Diagram
: 6. OP-2202.007 Loss of Off-Site Power
: 7. OP-2202.008 Station Blackout
: 8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
: 9. NEI 99-01 CU2 to 0CAN031801 Page 89 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                  2 - Loss of Vital AC Power Initiating Condition:        Loss of all offsite and all onsite AC power to vital buses for 15 minutes or longer EAL:
CA2.1      Alert Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3[2A3] and A4[2A4] for 15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):
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 (as defined in 10 CFR 50.2):
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
Although the AAC may be considered available, it will not prevent declaration of this EAL unless it is powering a vital bus within the 15-minute time period of the EAL.
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.
Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in to 0CAN031801 Page 90 of 240 Attachment 1 - Emergency Action Level Technical Bases accordance with abnormal or emergency operating procedures, or beyond design basis accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems.
When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the greater time available to restore a vital bus to service.
Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.
Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.
Escalation of the emergency classification level would be via IC CS1 or AS1.
This EAL is the cold condition equivalent of the hot condition EAL SS1.1.
Reference(s):
: 1. 1SAR Figure 8-1 Station Single Line Diagram
: 2. OP-1202.007 Degraded Power
: 3. OP-1202.008 Blackout
: 4. OP-2104.037 Alternate AC Diesel Generator Operations
: 5. 2SAR Figure 8.3-1 Station Single Line Diagram
: 6. OP-2202.007 Loss of Off-Site Power
: 7. OP-2202.008 Station Blackout
: 8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
: 9. NEI 99-01 CU2 to 0CAN031801 Page 91 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  C - Cold Shutdown / Refueling System Malfunction Subcategory:              3 - RCS Temperature Initiating Condition:      UNPLANNED rise in RCS temperature EAL:
CU3.1      Unusual Event UNPLANNED rise in RCS temperature to > 200&deg;F due to loss of decay heat removal capability Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
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.
Basis:
This IC addresses an UNPLANNED rise in RCS temperature above the Technical Specification cold shutdown temperature limit and represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to EAL CA3.1.
A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.
This EAL involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications.
During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.
to 0CAN031801 Page 92 of 240 Attachment 1 - Emergency Action Level Technical Bases During an outage, the level in the reactor vessel will normally be maintained at or above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at lowered inventory may result in a rapid rise in reactor coolant temperature depending on the time after shutdown.
Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria.
Reference(s):
: 1. Unit 1 and Unit 2 Technical Specifications Table 1.1-1
: 2. NEI 99-01 CU3 to 0CAN031801 Page 93 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  C - Cold Shutdown / Refueling System Malfunction Subcategory:                3 - RCS Temperature Initiating Condition:      UNPLANNED rise in RCS temperature EAL:
CU3.2      Unusual Event Loss of all RCS temperature and RCS level indication for  15 min. (Note 1)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
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.
Basis:
This EAL addresses the inability to determine RCS temperature and level, and represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to EAL CA3.1.
This EAL reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.
to 0CAN031801 Page 94 of 240 Attachment 1 - Emergency Action Level Technical Bases Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.
Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria.
Reference(s):
: 1. NEI 99-01 CU3 to 0CAN031801 Page 95 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                  3 - RCS Temperature Initiating Condition:        Inability to maintain plant in cold shutdown EAL:
CA3.1        Alert UNPLANNED rise in RCS temperature to > 200&deg;F for > Table 1[2]C-4 duration (Note 1)
OR UNPLANNED RCS pressure rise > 10 psig due to a loss of RCS cooling (this EAL does not apply during water-solid plant conditions)
Note 1:    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 is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1[2]C-4    RCS Heat-up Duration Thresholds CONTAINMENT RCS Status                                                    Heat-up Duration CLOSURE Status Intact (but not lowered inventory)                    N/A                      60 min.*
Not intact                                      established                  20 min.*
OR lowered inventory                            not established                    0 min.
* If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.
Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
to 0CAN031801 Page 96 of 240 Attachment 1 - Emergency Action Level Technical Bases As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.
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.
Basis:
In the absence of reliable RCS temperature indication caused by the loss of decay heat removal capability, classification should be based on the RCS pressure rise criteria when the RCS is intact in Mode 5 or based on time to boil data when in Mode 6 or the RCS is not intact in Mode 5.
This EAL addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant.
A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.
The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact, or RCS inventory is reduced (e.g., lowered inventory operation). The 20-minute criterion was included to allow time for operator action to address the temperature rise.
The RCS Heat-up Duration Thresholds table also addresses a rise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature rise without a substantial degradation in plant safety.
Finally, in the case where there is a rise in RCS temperature, the RCS is not intact or is at lowered inventory and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) the evaporated reactor coolant may be released directly into the containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel.
The RCS pressure rise threshold provides a pressure-based indication of RCS heat-up in the absence of RCS temperature monitoring capability.
Escalation of the emergency classification level would be via IC CS1 or AS1.
Reference(s):
: 1. Unit 1 and Unit 2 Technical Specifications Table 1.1-1
: 2. NEI 99-01 CA3 to 0CAN031801 Page 97 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                  4 - Loss of Vital DC Power Initiating Condition:        Loss of Vital DC power for 15 minutes or longer EAL:
CU4.1      Unusual Event Indicated voltage is < 105 VDC on vital 125 VDC buses for  15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC.
This IC addresses a loss of vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions raise the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant.
to 0CAN031801 Page 98 of 240 Attachment 1 - Emergency Action Level Technical Bases As used in this EAL, required means the vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment. For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification.
Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.
Depending upon the event, escalation of the emergency classification level would be via IC CA1 or CA3, or an IC in Recognition Category A.
This EAL is the cold condition equivalent of the hot condition EAL SS2.1.
Reference(s):
: 1. 1SAR 8.3.2.1.1 Batteries
: 2. 2SAR 8.3.2.1.1 Batteries
: 3. NEI 99-01 CU4 to 0CAN031801 Page 99 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  C - Cold Shutdown / Refueling System Malfunction Subcategory:                5 - Loss of Communications Initiating Condition:      Loss of all onsite or offsite communications capabilities EAL:
CU5.1      Unusual Event Loss of all Table 1[2]C-5 onsite communication methods OR Loss of all Table 1[2]C-5 State and local agency communication methods OR Loss of all Table 1[2]C-5 NRC communication methods Table 1[2]C-5          Communication Methods System                        Onsite    ORO        NRC Station radio system                                  X ANO plant phone system                                X Gaitronics                                            X Telephone Systems:
Commercial Microwave                                                  X        X Satellite VOIP INFORM Notification System                                      X Emergency Notification System (ENS)                                        X Mode Applicability:
5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):
None to 0CAN031801 Page 100 of 240 Attachment 1 - Emergency Action Level Technical Bases Basis:
This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to State and local agencies and the NRC.
This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).
The first EAL condition addresses a total loss of the communications methods used in support of routine plant operations.
The second EAL condition addresses a total loss of the communications methods used to notify all State and local agencies of an emergency declaration. The State and local agencies referred to here are the Arkansas Department of Health, Arkansas Department of Emergency Management, Pope, Yell, Johnson, and Logan County offsite agencies.
The third EAL addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.
This EAL is the cold condition equivalent of the hot condition EAL SU7.1.
Reference(s):
: 1. OP-1903.062 Communications System Operating Procedure
: 2. NEI 99-01 CU5 to 0CAN031801 Page 101 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    C - Cold Shutdown / Refueling System Malfunction Subcategory:                6 - Hazardous Event Affecting Safety Systems Initiating Condition:        Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode EAL:
CA6.1      Alert The occurrence of any Table 1[2]C-6 hazardous event AND Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode AND EITHER:
Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)
Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted.
Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.
Table 1[2]C-6    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 to 0CAN031801 Page 102 of 240 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:
5 - Cold Shutdown, 6 - Refueling Definition(s):
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 require a post-event inspection to determine if the attributes of an explosion are present.
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.
FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
VISIBLE DAMAGE - Damage to a SAFETY SYSTEM train 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 SAFETY SYSTEM train.
Basis:
This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS needed for the current operating mode. In order to provide the appropriate context for consideration of an ALERT classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues. Note that this second SAFETY SYSTEM to 0CAN031801 Page 103 of 240 Attachment 1 - Emergency Action Level Technical Bases train is from the same SAFETY SYSTEM that has indications of degraded performance; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events.
Indications of degraded performance addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.
VISIBLE DAMAGE addresses damage to a SAFETY SYSTEM train that is not in service/operation and that potentially could cause performance issues. 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.
This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.
Escalation of the emergency classification level would be via IC CS1 or AS1.
This EAL is the cold condition equivalent of the hot condition EAL SA9.1.
Reference(s):
: 1. EP FAQ 2016-002
: 2. NEI 99-01 CA6 to 0CAN031801 Page 104 of 240 Attachment 1 - Emergency Action Level Technical Bases Category E - Independent Spent Fuel Storage Installation (ISFSI)
EAL Group:        ANY (EALs in this category are applicable to any plant condition, hot or cold.)
An independent spent fuel storage installation (ISFSI) is a complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. A significant amount of the radioactive material contained within a canister must escape its packaging and enter the biosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel.
An Unusual Event is declared on the basis of the occurrence of an event of sufficient magnitude that a loaded cask CONFINEMENT BOUNDARY is damaged or violated.
The ANO ISFSI is located wholly within the plant PROTECTED AREA. Therefore any security event related to the ISFSI is classified under Category H1 security event related EALs.
to 0CAN031801 Page 105 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  E - ISFSI Subcategory:              Confinement Boundary Initiating Condition:      Damage to a loaded cask CONFINEMENT BOUNDARY EAL:
EU1.1      Unusual Event Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading on the surface of a loaded spent fuel cask (VSC-24 VCC or HI-STORM overpack) > any Table 1[2]E-1 value Table 1[2]E-1 ISFSI Dose Rates VSC-24 VCC                                  HI-STORM 200 mrem/hr on the sides              60 mrem/hr (gamma + neutron) on the top or outlet vent 400 mrem/hr on the top 600 mrem/hr (gamma + neutron on 700 mrem/hr at the air inlet the side of the side of the overpack 200 mrem/hr at the air outlet          (excluding inlet and outlet ducts)
Mode Applicability:
All Definition(s):
CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).
INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) - A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.
Basis:
This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the to 0CAN031801 Page 106 of 240 Attachment 1 - Emergency Action Level Technical Bases creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.
The existence of damage is determined by radiological survey. The specified EAL threshold values correspond to 2 times the cask technical specification values (ref. 1, 2). The technical specification (licensing bases document) multiple of 2 times, which is also used in Recognition Category A IC AU1, is used here to distinguish between non-emergency and emergency conditions. The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the on-contact dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.
Security-related events for ISFSIs are covered under ICs HU1 and HA1.
Reference(s):
: 1. Certificate of Compliance Appendix A Technical Specifications for the HI-STORM 100 Cask System Section 5.7.4
: 2. VSC-24 Storage Cask Final Safety Analysis Report Section 1.2.4 Maximum External Surface Dose Rate
: 3. NEI 99-01 E-HU1 to 0CAN031801 Page 107 of 240 Attachment 1 - Emergency Action Level Technical Bases Category F - Fission Product Barrier Degradation EAL Group:        Hot Conditions (RCS temperature > 200&deg;F); EALs in this category are applicable only in one or more hot operating modes.
EALs in this category represent threats to the defense in depth design concept that precludes the release of highly radioactive fission products to the environment. This concept relies on multiple physical barriers any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment. The primary fission product barriers are:
A. Fuel Clad Barrier (FCB): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.
B. Reactor Coolant System Barrier (RCB): The RCS Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.
C. Containment Barrier (CNB): The Containment Barrier includes the Reactor Building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the Reactor Building up to and including the outermost secondary side isolation valve.
Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency.
The EALs in this category require evaluation of the loss and potential loss thresholds listed in the fission product barrier matrix of Table F-1. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. Loss means the barrier no longer assures containment of radioactive materials. Potential Loss means integrity of the barrier is threatened and could be lost if conditions continue to degrade. The number of barriers that are lost or potentially lost and the following criteria determine the appropriate emergency classification level:
Alert:
Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency:
Loss or potential loss of any two barriers General Emergency:
Loss of any two barriers and loss or potential loss of third barrier to 0CAN031801 Page 108 of 240 Attachment 1 - Emergency Action Level Technical Bases The logic used for emergency classification based on fission product barrier monitoring should reflect the following considerations:
The Fuel Clad Barrier and the RCS Barrier are weighted more heavily than the Containment Barrier.
Unusual Event ICs associated with RCS and Fuel Clad Barriers are addressed under System Malfunction ICs.
For accident conditions involving a radiological release, evaluation of the fission product barrier thresholds will need to be performed in conjunction with dose assessments to ensure correct and timely escalation of the emergency classification. For example, an evaluation of the fission product barrier thresholds may result in a Site Area Emergency classification while a dose assessment may indicate that an EAL for General Emergency IC AG1 has been exceeded.
The fission product barrier thresholds specified within a scheme reflect plant-specific ANO design and operating characteristics.
As used in this category, the term RCS leakage encompasses not just those types defined in Technical Specifications but also includes the loss of RCS mass to any location - inside the containment, an interfacing system, or outside of the containment.
The release of liquid or steam mass from the RCS due to the as-designed/expected operation of a relief valve is not considered to be RCS leakage.
At the Site Area Emergency level, EAL users should maintain cognizance of how far present conditions are from meeting a threshold that would require a General Emergency declaration. For example, if the Fuel Clad and RCS fission product barriers were both lost, then there should be frequent assessments of containment radioactive inventory and integrity. Alternatively, if both the Fuel Clad and RCS fission product barriers were potentially lost, the Emergency Director would have more assurance that there was no immediate need to escalate to a General Emergency.
to 0CAN031801 Page 109 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    F - Fission Product Barrier Degradation Subcategory:                N/A Initiating Condition:        Any loss or any potential loss of either Fuel Clad or RCS EAL:
FA1.1    Alert Any loss or any potential loss of either Fuel Clad or RCS barrier (Table 1[2]F-1)
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
None Basis:
Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.
At the Alert classification level, Fuel Clad and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Clad 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 Clad or RCS barrier results in declaration of a Site Area Emergency under EAL FS1.1.
Reference(s):
: 1. NEI 99-01 FA1 to 0CAN031801 Page 110 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    F - Fission Product Barrier Degradation Subcategory:                  N/A Initiating Condition:        Loss or potential loss of any two barriers EAL:
FS1.1      Site Area Emergency Loss or potential loss of any two barriers (Table 1[2]F-1)
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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.
Basis:
Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.
At the Site Area Emergency classification level, each barrier is weighted equally. A Site Area Emergency is therefore appropriate for any combination of the following conditions:
One barrier loss and a second barrier loss (i.e., loss - loss)
One barrier loss and a second barrier potential loss (i.e., loss - potential loss)
One barrier potential loss and a second barrier potential loss (i.e., potential loss -
potential loss)
At the Site Area Emergency classification level, the ability to dynamically assess the proximity of present conditions with respect to the threshold for a General Emergency is important. For example, the existence of Fuel Clad and RCS Barrier loss thresholds in addition to offsite dose assessments would require continual assessments of radioactive inventory and Containment integrity in anticipation of reaching a General Emergency classification. Alternatively, if both Fuel Clad and RCS potential loss thresholds existed, the Emergency Director would have greater assurance that escalation to a General Emergency is less IMMINENT.
Reference(s):
: 1. NEI 99-01 FS1 to 0CAN031801 Page 111 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    F - Fission Product Barrier Degradation Subcategory:                N/A Initiating Condition:        Loss of any two barriers and loss or potential loss of third barrier EAL:
FG1.1    General Emergency Loss of any two barriers AND Loss or potential loss of the third barrier (Table 1[2]F-1)
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
None Basis:
Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.
At the General Emergency classification level each barrier is weighted equally. A General Emergency is therefore appropriate for any combination of the following conditions:
Loss of Fuel Clad, RCS and Containment Barriers Loss of Fuel Clad and RCS Barriers with potential loss of Containment Barrier Loss of RCS and Containment Barriers with potential loss of Fuel Clad Barrier Loss of Fuel Clad and Containment Barriers with potential loss of RCS Barrier Reference(s):
: 1. NEI 99-01 FG1 to 0CAN031801 Page 112 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1 Fission Product Barrier Threshold Matrix & Bases Table 1[2]F-1 lists the threshold conditions that define the Loss and Potential Loss of the three fission product barriers (Fuel Clad, Reactor Coolant System, and Containment). The table is structured so that each of the three barriers occupies adjacent columns. Each fission product barrier column is further divided into two columns; one for Loss thresholds and one for Potential Loss thresholds.
The first column of the table (to the left of the Fuel Clad Loss column) lists the categories (types) of fission product barrier thresholds. The fission product barrier categories are:
A. RCS or S/G Tube Leakage B. Inadequate Heat removal C. Containment Radiation / RCS Activity D. Containment Integrity or Bypass E. Emergency Director Judgment Each category occupies a row in Table 1[2]F-1 thus forming a matrix defined by the categories.
The intersection of each row with each Loss/Potential Loss column forms a cell in which one or more fission product barrier thresholds appear. If NEI 99-01 does not define a threshold for a barrier Loss/Potential Loss, the word None is entered in the cell.
Thresholds are assigned sequential numbers within each barrier column beginning with number one (ex., FCB1, FCB2FCB9).
If a cell in Table 1[2]F-1 contains more than one numbered threshold, each of the numbered thresholds, if exceeded, signifies a Loss or Potential Loss of the barrier. It is not necessary to exceed all of the thresholds in a category before declaring a barrier Loss/Potential Loss.
Subdivision of Table 1[2]F-1 by category facilitates association of plant conditions to the applicable fission product barrier Loss and Potential Loss thresholds. This structure promotes a systematic approach to assessing the classification status of the fission product barriers.
When equipped with knowledge of plant conditions related to the fission product barriers, the EAL-user first scans down the category column of Table 1[2]F-1, locates the likely category and then reads across the fission product barrier Loss and Potential Loss thresholds in that category to determine if a threshold has been exceeded. If a threshold has not been exceeded, the EAL-user proceeds to the next likely category and continues review of the thresholds in the new category.
If the EAL-user determines that any threshold has been exceeded, by definition, the barrier is lost or potentially lost - even if multiple thresholds in the same barrier column are exceeded, only that one barrier is lost or potentially lost. The EAL-user must examine each of the three fission product barriers to determine if other barrier thresholds in the category are lost or potentially lost. For example, if containment radiation is sufficiently high, a Loss of the Fuel to 0CAN031801 Page 113 of 240 Attachment 1 - Emergency Action Level Technical Bases Clad and RCS Barriers and a Potential Loss of the Containment Barrier can occur. Barrier Losses and Potential Losses are then applied to the algorithms given in EALs FG1.1, FS1.1, and FA1.1 to determine the appropriate emergency classification.
In the remainder of this Attachment, the Fuel Clad Barrier threshold bases appear first, followed by the RCS Barrier and finally the Containment Barrier threshold bases. In each barrier, the bases are given according category Loss followed by category Potential Loss beginning with Category A, then B,, E.
to 0CAN031801 Page 114 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1        Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FCB)                              Reactor Coolant System Barrier (RCB)                                              Containment Barrier (CNB)
Category          Loss                Potential Loss                      Loss                          Potential Loss                                Loss                  Potential Loss RCB2 UNISOLABLE RCS leakage or S/G tube leakage > 50[44] gpm excluding normal reductions in RCS inventory (e.g.,
letdown, RCP seal leakoff)
RCB3 RCB1                        Unit 1:    PTS limits apply (RT14)              CNB1 A                                                          An automatic or manual                    AND                                A S/G that is leaking FCB1                          ESAS [ESFAS] actuation                                                      > 50[44] gpm (excluding RCS or S/G                                                      required by EITHER:                    RCS pressure and temperature are left None        RVLMS Levels 1 through 9                                                                                    normal reductions in RCS                  None of the NDTT/LTOP limit lines on EOP Tube                          [1 through 7] indicate DRY          UNISOLABLE RCS                  Figure 3 (Note 12)                    inventory) or that is Leakage                                                              leakage Unit 2:    Uncontrolled RCS cooldown (50&deg;F RUPTURED is also FAULTED S/G tube RUPTURE                                                        outside of containment step change which is below 500&deg;F from NOT)
AND RCS pressure and temperature are to the left of line B (200 degrees MTS),
Standard Attachment 1, P-T Limits (Note 12)
FCB3 CETs > 700&deg;F B                          FCB4                                                      RCB4                                                                      CNB2 RCS heat removal cannot be established using                              CETs > 1200&deg;F Inadequate  FCB2                RCS heat removal cannot be established using steam                    None            steam generators                                              None            AND Heat    CETs > 1200&deg;F generators                                                      AND                                                                  Restoration procedures not effective Removal                              AND                                                  HPI [Once Through] cooling initiated                                      within 15 min. (Note 1)
HPI [Once Through] cooling initiated FCB5 Containment High C      Range Radiation RCB5 Monitor RE-8060/8061                                                                                                                                      CNB3 CTMT    [2RE-8925-1/ 8925-2]                                Containment High Range None                                                                  None                                None        Containment High Range Radiation Radiation / > 750 [700] R/hr                                    Radiation Monitor RE-Monitor RE-8060/8061 [2RE-8925-1/
8060/8061 [2RE-8925-1/
RCS    FCB6 8925-2] > 40[50] R/hr 8925-2] > 10,000[12,000] R/hr Activity  Coolant activity
            > 300 Ci/gm dose equivalent I-131 to 0CAN031801 Page 115 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1          Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FCB)                                  Reactor Coolant System Barrier (RCB)                                                  Containment Barrier (CNB)
Category            Loss                Potential Loss                            Loss                            Potential Loss                                  Loss                        Potential Loss CNB4 Containment isolation is        CNB6 required Containment pressure > 73.7 psia AND EITHER:
CNB7 Containment integrity D                                                                                                                                                        has been lost based on  Containment hydrogen concentration Emergency Director      > 3%
CTMT                None                      None                              None                                    None                              judgment                CNB8 Integrity or UNISOLABLE pathway      Containment pressure > 44.7 psia Bypass                                                                                                                                                      from Containment to the  [23.3 psia] with < one full train of environment exists      containment heat removal systems CNB5                            (Note 9) operating per design for 15 min. (Note 1)
Indications of RCS leakage outside of Containment FCB7 E      Any condition in the FCB8                              RCB6                          RCB7                                              CNB9                            CNB10 Any condition in the opinion of    Any condition in the opinion                                                    Any condition in the opinion of Any condition in the opinion of the Emergency    opinion of the        the Emergency Director that        of the Emergency Director Any condition in the opinion of the Emergency the Emergency Director that    Emergency Director that indicates Director  Emergency Director                                                                      Director that indicates potential loss of the RCS indicates potential loss of the    that indicates loss of the RCS                                                  indicates loss of the          potential loss of the Containment that indicates loss of                                                                  barrier Judgment    the Fuel Clad barrier Fuel Clad barrier                  barrier                                                                          Containment barrier            barrier to 0CAN031801 Page 116 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Fuel Clad Category:              A - RCS or S/G Tube Leakage Degradation Threat:    Loss Threshold:
None to 0CAN031801 Page 117 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Fuel Clad Category:                  A - RCS or S/G Tube Leakage Degradation Threat:        Potential Loss Threshold:
FCB1 RVLMS Levels 1 through 9[1 through 7] indicate DRY Definition(s):
None Basis:
This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage.
There is no Fuel Clad Barrier Loss threshold associated with RCS or S/G Tube Leakage.
Reference(s):
: 1. ULD-1-SYS-24 Unit 1 Inadequate Core Cooling System
: 2. Calculation 84-EQ-0080-02 Loop Error Analysis for Reactor Vessel Level Monitoring System
: 3. ULD-2-SYS-24 Unit 2 Inadequate Core Cooling Monitoring System
: 4. Calculation 90-E-0116-01 Unit 2 EOP Setpoint Document, Setpoint R.3
: 5. NEI 99-01 RCS or SG Tube Leakage Potential Loss 1.A to 0CAN031801 Page 118 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Fuel Clad Category:                B - Inadequate Heat Removal Degradation Threat:      Loss Threshold:
FCB2 CETs > 1200&deg;F Definition(s):
None Basis:
This reading indicates temperatures within the core are sufficient to cause significant superheating of reactor coolant.
Reference(s):
: 1. NEI 99-01 Inadequate Heat Removal Loss 2.A to 0CAN031801 Page 119 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Fuel Clad Category:                  B - Inadequate Heat Removal Degradation Threat:        Potential Loss Threshold:
FCB3 CETs > 700&deg;F Definition(s):
None Basis:
This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage.
Reference(s):
: 1. NEI 99-01 Inadequate Heat Removal Potential Loss 2.A to 0CAN031801 Page 120 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Fuel Clad Category:                  B - Inadequate Heat Removal Degradation Threat:        Potential Loss Threshold:
FCB4 RCS heat removal cannot be established using steam generators AND HPI[Once Through] cooling initiated Definition(s):
None Basis:
This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using this threshold is not warranted.
In combination with Potential Loss RCB4, meeting this threshold results in a Site Area Emergency.
Reference(s):
: 1. OP-1202.004 Overheating
: 2. OP-1202.013 Figure 4, Core Exit Thermocouple for Inadequate Core Cooling
: 3. OP-2202.006 Loss of Feedwater
: 4. OP-2202.009 Functional Recovery, Safety Function Status Check 5
: 5. NEI 99-01 Inadequate Heat Removal Potential Loss 2.B to 0CAN031801 Page 121 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Fuel Clad Category:                  C - CTMT Radiation / RCS Activity Degradation Threat:        Loss Threshold:
FCB5 Containment High Range Radiation Monitor RE-8060/8061[2RE-8925-1/8925-2]
> 750[700] R/hr Definition(s):
None Basis:
The containment radiation monitor reading (768[682] R/hr rounded to 750[700] R/hr for readability) corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals 300 &#xb5;Ci/gm dose equivalent I-131.
Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to 1.49[1.13]% 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 Loss threshold RCB5 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 ECL to a Site Area Emergency.
There is no Potential Loss threshold associated with CTMT Radiation/RCS Activity.
Reference(s):
: 1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values
: 2. NEI 99-01 RCS Activity/Containment Radiation FC Loss 3.A to 0CAN031801 Page 122 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Fuel Clad Category:                  C - CTMT Radiation / RCS Activity Degradation Threat:        Loss Threshold:
FCB6 Coolant activity > 300 &#xb5;Ci/gm dose equivalent I-131 Definition(s):
None Basis:
This threshold indicates that RCS radioactivity concentration is greater than 300 &#xb5;Ci/gm dose equivalent I-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.
It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications.
There is no Potential Loss threshold associated with CTMT Radiation/RCS Activity.
Reference(s):
: 1. NEI 99-01 RCS Activity/Containment Radiation Fuel Clad Loss 3.B to 0CAN031801 Page 123 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Fuel Clad Category:              C - CTMT Radiation / RCS Activity Degradation Threat:    Potential Loss Threshold:
None to 0CAN031801 Page 124 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Fuel Clad Category:              D - CTMT Integrity or Bypass Degradation Threat:    Loss Threshold:
None to 0CAN031801 Page 125 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Fuel Clad Category:              D - CTMT Integrity or Bypass Degradation Threat:    Potential Loss Threshold:
None to 0CAN031801 Page 126 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Fuel Clad Category:                E - Emergency Director Judgment Degradation Threat:      Loss Threshold:
FCB7 Any condition in the opinion of the Emergency Director that indicates loss of the Fuel Clad barrier Definition(s):
None Basis:
This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad barrier is lost.
Reference(s):
: 1. NEI 99-01 Emergency Director Judgment Fuel Clad Loss 6.A to 0CAN031801 Page 127 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Fuel Clad Category:                E - Emergency Director Judgment Degradation Threat:      Potential Loss Threshold:
FCB8 Any condition in the opinion of the Emergency Director that indicates potential loss of the Fuel Clad barrier Definition(s):
None Basis:
This threshold addresses any other factors that are to 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.
Reference(s):
: 1. NEI 99-01 Emergency Director Judgment Potential Fuel Clad Loss 6.A to 0CAN031801 Page 128 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Reactor Coolant System Category:                  A - RCS or S/G Tube Leakage Degradation Threat:        Loss Threshold:
RCB1 An automatic or manual ESAS[ESFAS] actuation required by EITHER:
UNISOLABLE RCS leakage S/G tube RUPTURE Definition(s):
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.
RUPTURED - The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).
UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.
Basis:
Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.
This 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 Loss threshold CNB1 will also be met.
to 0CAN031801 Page 129 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. OP-1202.010 ESAS
: 2. OP-2202.003 Loss of Coolant Accident
: 3. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Loss 1.A to 0CAN031801 Page 130 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Reactor Coolant System Category:                  A - RCS or S/G Tube Leakage Degradation Threat:        Potential Loss Threshold:
RCB2 UNISOLABLE RCS leakage or S/G tube leakage > 50[44] gpm excluding normal reductions in RCS inventory (e.g., letdown, RCP seal leakoff)
Definition(s):
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.
Basis:
Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.
This 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 makeup [charging]
pump, but an ESAS [ESFAS] actuation has not occurred.
This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system.
The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.
If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold CNB1 will also be met.
Reference(s):
: 1. 1SAR 9.1 Makeup and Purification System
: 2. 2SAR 9.3.4 Chemical and Volume Control System
: 3. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.A to 0CAN031801 Page 131 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Reactor Coolant System Category:                  A - RCS or S/G Tube Leakage Degradation Threat:        Potential Loss Threshold:
RCB3 Unit 1:
PTS limits apply (RT14)
AND RCS pressure and temperature are left of the NDTT/LTOP limit lines, on EOP Figure 3 (Note 12)
Unit 2:
Uncontrolled RCS cooldown (50&deg;F step change which is below 500&deg;F from NOT)
AND RCS pressure and temperature are to the left of line B (200 degrees MTS), Standard Attachment 1, P-T Limits (Note 12)
Note 12: Once PTS limits are first invoked, if RCS temperature and pressure are not brought within the limits within 15 minutes, this threshold is met and an immediate declaration is warranted. This threshold is met immediately upon exceeding the limits after this initial 15 minute period until PTS limits no longer apply.
Definition(s):
None 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).
to 0CAN031801 Page 132 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. OP-1202.012 Repetitive Task 14 Control RCS Pressure
: 2. OP-1202.013 EOP Figures, Figure 3 RCS Pressure vs Temperature Limits
: 3. OP-1202.011 HPI Cooldown
: 4. Calculation No: 90-E-0116-01 ANO- EOP Setpoint Basis Document OP Setpoint P.2, RCS Pressure-Temperature
: 5. OP-2202.010 Standard Attachments, Attachment 1, P-T Limits
: 6. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.B to 0CAN031801 Page 133 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Reactor Coolant System Category:              B - Inadequate Heat Removal Degradation Threat:    Loss Threshold:
None to 0CAN031801 Page 134 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Reactor Coolant System Category:                  B - Inadequate Heat Removal Degradation Threat:        Potential Loss Threshold:
RCB4 RCS heat removal cannot be established using steam generators AND HPI[Once Through] cooling initiated Definition(s):
None Basis:
This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using this threshold is not warranted.
In combination with Potential Loss FCB4, meeting this threshold results in a Site Area Emergency.
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 raise RCS pressure to the point where mass will be lost from the system.
There is no RCS barrier Loss threshold associated with Inadequate Heat Removal.
Reference(s):
: 1. OP-1202.004 Overheating
: 2. OP-1202.013 Figure 4, Core Exit Thermocouple for Inadequate Core Cooling
: 3. OP-2202.006 Loss of Feedwater
: 4. OP-2202.009 Functional Recovery, Safety Function Status Check 5
: 5. NEI 99-01 Inadequate Heat Removal RCS Potential Loss 2.B to 0CAN031801 Page 135 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Reactor Coolant System Category:                  C - CTMT Radiation/ RCS Activity Degradation Threat:        Loss Threshold:
RCB5 Containment High Range Radiation Monitor RE-8060/8061[2RE-8925-1/8925-2] > 40[50] R/hr Definition(s):
None Basis:
NRC Information Notice 97-045, Supplement 1, identifies the potential for erratic indications from the high range radiation monitors (HRRMs) as a result of thermally induced currents (TIC) which may cause the HRRM to read falsely high (for approximately 15 minutes) on a rapid temperature rise, and fail low intermittently on a rapid temperature fall. Because of this phenomenon, any trends or alarms on the HRRMs should be validated by comparison to the containment low range/area radiation monitors and Air Monitoring Systems trends before actions are taken.
The containment radiation monitor reading (42.8[50.4] R/hr rounded to 40[50] R/hr for readability) 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 Loss threshold FCB5 since it indicates a loss of the RCS Barrier only.
There is no Potential Loss threshold associated with CTMT Radiation/RCS Activity.
Reference(s):
: 1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values
: 2. NEI 99-01 CMT Radiation / RCS Activity RCS Loss 3.A to 0CAN031801 Page 136 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Reactor Coolant System Category:              B - CTMT Radiation/ RCS Activity Degradation Threat:    Potential Loss Threshold:
None to 0CAN031801 Page 137 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Reactor Coolant System Category:              D - CTMT Integrity or Bypass Degradation Threat:    Loss Threshold:
None to 0CAN031801 Page 138 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Reactor Coolant System Category:              D - CTMT Integrity or Bypass Degradation Threat:    Potential Loss Threshold:
None to 0CAN031801 Page 139 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Reactor Coolant System Category:                E - Emergency Director Judgment Degradation Threat:      Loss Threshold:
RCB6 Any condition in the opinion of the Emergency Director that indicates loss of the RCS barrier Definition(s):
None Basis:
This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is lost.
Reference(s):
: 1. NEI 99-01 Emergency Director Judgment RCS Loss 6.A to 0CAN031801 Page 140 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Reactor Coolant System Category:                E - Emergency Director Judgment Degradation Threat:      Potential Loss Threshold:
RCB7 Any condition in the opinion of the Emergency Director that indicates potential loss of the RCS barrier Definition(s):
None Basis:
This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.
Reference(s):
: 1. NEI 99-01 Emergency Director Judgment RCS Potential Loss 6.A to 0CAN031801 Page 141 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Containment Category:                    A - RCS or S/G Tube Leakage Degradation Threat:          Loss Threshold:
CNB1 A S/G that is leaking > 50[44] gpm (excluding normal reductions in RCS inventory) or that is RUPTURED is also FAULTED outside of containment Definition(s):
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.
RUPTURED - The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).
Basis:
This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAULTED outside of containment. The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the thresholds for RCS Barrier Potential Loss RCB2 and Loss RCB1, 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 dropping 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 SU4 for the fuel clad barrier (i.e., RCS activity values) and IC SU5 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. These types of conditions will result in a significant and 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.
to 0CAN031801 Page 142 of 240 Attachment 1 - Emergency Action Level Technical Bases 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 a 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 A ICs.
The ECLs 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?
P-to-S Leak Rate                        Yes                        No Less than or equal to 25 gpm                No classification        No classification Greater than 25 gpm                    Unusual Event per SU5.1    Unusual Event per SU5.1 Greater than 50[44] gpm (RCS            Site Area Emergency per Alert per FA1.1 Barrier Potential Loss)                          FS1.1 Requires an automatic or manual Site Area Emergency per ESAS[ESFAS] actuation (RCS                                              Alert per FA1.1 FS1.1 Barrier Loss)
There is no Potential Loss threshold associated with RCS or S/G Tube Leakage.
Reference(s):
: 1. NEI 99-01 RCS or SG Tube Leakage Containment Loss 1.A to 0CAN031801 Page 143 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Containment Category:              A - RCS or S/G Tube Leakage Degradation Threat:    Potential Loss Threshold:
None to 0CAN031801 Page 144 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Containment Category:              B - Inadequate Heat Removal Degradation Threat:    Loss Threshold:
None to 0CAN031801 Page 145 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Containment Category:                    B - Inadequate Heat Removal Degradation Threat:          Potential Loss Threshold:
CNB2 CETs > 1200&deg;F AND Restoration procedures not effective within 15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Definition(s):
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.
Basis:
The restoration procedure is considered effective if core exit thermocouple readings are dropping and/or if reactor vessel level is rising. 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.
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.
Severe accident analyses (e.g., NUREG-1150) 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.
Reference(s):
: 1. NEI 99-01 Inadequate Heat Removal Containment Potential Loss 2.A to 0CAN031801 Page 146 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:              Containment Category:              C - CTMT Radiation/RCS Activity Degradation Threat:    Loss Threshold:
None to 0CAN031801 Page 147 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Containment Category:                  C - CTMT Radiation/RCS Activity Degradation Threat:        Potential Loss Threshold:
CNB3 Containment High Range Radiation Monitor RE-8060/8061[2RE-8925-1/8925-2]
> 10,000[12,000] R/hr Definition(s):
None Basis:
The containment radiation monitor reading (10,300[12,100] R/hr rounded to 10,000[12,000] R/hr for readability) 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 ECL to a General Emergency.
There is no Loss threshold associated with CTMT Radiation/RCS Activity.
Reference(s):
: 1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values
: 2. NEI 99-01 CTMT Radiation / RCS Activity Containment Potential Loss 3.A to 0CAN031801 Page 148 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                    Containment Category:                  D - CTMT Integrity or Bypass Degradation Threat:        Loss Threshold:
CNB4 Containment isolation is required AND EITHER:
Containment integrity has been lost based on Emergency Director judgment UNISOLABLE pathway from Containment to the environment exists Definition(s):
UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.
Basis:
Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.
The status of the containment barrier during an event involving steam generator tube leakage is assessed using Loss Threshold CNB1.
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 bulleted thresholds.
First Threshold - 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.).
to 0CAN031801 Page 149 of 240 Attachment 1 - Emergency Action Level Technical Bases Refer to the middle piping run of Figure 1. Two simplified examples are provided. One is leakage from a penetration and the other is leakage from an in-service system valve.
Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure.
Another example would be a loss or potential loss of the RCS barrier, and the simultaneous occurrence of two FAULTED locations on a steam generator where one fault is located inside containment (e.g., on a steam or feedwater line) and the other outside of containment. In this case, the associated steam line provides a pathway for the containment atmosphere to escape to an area outside the containment.
Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A ICs.
Second Threshold - 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 1. In this simplified example, the inboard and outboard isolation valves remained open after a containment isolation was required (i.e., containment isolation was not successful). There is now an UNISOLABLE pathway from the containment to the environment.
The existence of a filter is not considered in the threshold assessment. Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.
Leakage between two interfacing liquid systems, by itself, does not meet this threshold.
Refer to the bottom piping run of Figure 1. In this simplified example, leakage in an RCP seal cooler is allowing radioactive material to enter the Auxiliary Building. The radioactivity would be detected by the Process Monitor. If there is no leakage from the closed water cooling system to the Auxiliary Building, then no threshold has been met. If the pump developed a leak that allowed steam/water to enter the Auxiliary Building, then second threshold 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 the first threshold to be met as well.
to 0CAN031801 Page 150 of 240 Attachment 1 - Emergency Action Level Technical Bases Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable 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 an enclosed system.
These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A ICs.
Reference(s):
: 1. NEI 99-01 CTMT Integrity or Bypass Containment Loss 4.A to 0CAN031801 Page 151 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Containment Category:                  D - CTMT Integrity or Bypass Degradation Threat:        Loss Threshold:
CNB5 Indications of RCS leakage outside of Containment Definition(s):
None Basis:
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 Loss RCB1 and/or Potential Loss RCB2 threshold to be met.
The status of the containment barrier during an event involving steam generator tube leakage is assessed using Containment Loss Threshold CNB1.
Containment sump, temperature, pressure and/or radiation levels will rise if reactor coolant mass is leaking into the containment. If these parameters have not risen, then the reactor coolant mass may be leaking outside of containment (i.e., a containment bypass sequence).
Rises in sump, temperature, pressure, flow and/or radiation level readings outside of the containment may indicate that the RCS mass is being lost outside of containment.
Unexpected elevated readings and alarms on radiation monitors with detectors outside containment should be corroborated with other available indications to confirm that the source is a loss of RCS mass outside of containment. If the fuel clad barrier has not been lost, radiation monitor readings outside of containment may not rise significantly; however, other unexpected changes in sump levels, area temperatures or pressures, 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 1. In this simplified example, a leak has occurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause threshold CNB4 to be met as well.
Reference(s):
: 1. NEI 99-01 CTMT Integrity or Bypass Containment Loss 4.B to 0CAN031801 Page 152 of 240 Attachment 1 - Emergency Action Level Technical Bases Figure 1: Containment Integrity or Bypass Examples nd 2    Threshold - Airborne release from pathway Effluent Inside                Auxiliary              Monitor Reactor                Building Building Damper                                                                          Area Monitor Open valve                Open valve Damper st Penetration                      1 Threshold -
Airborne Airborne Monitor nd Open valve                            Open valve                                          2    Threshold -
st RCS leakage Interface          1 Threshold - Airborne                                                outside AB leakage          release from penetration Process Monitor Closed Cooling Open valve                Open valve                                                  Pump RCP Seal Cooling to 0CAN031801 Page 153 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Containment Category:                  D - CTMT Integrity or Bypass Degradation Threat:        Potential Loss Threshold:
CNB6 Containment pressure > 73.7 psia Definition(s):
None Basis:
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.
Reference(s):
: 1. 1SAR 1.4.43 Criterion 50 - Containment Design Basis
: 2. 2SAR Table 6.2-7 Principle Containment Design Parameters
: 3. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.A to 0CAN031801 Page 154 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Containment Category:                D - CTMT Integrity or Bypass Degradation Threat:      Potential Loss Threshold:
CNB7 Containment hydrogen concentration > 3%
Definition(s):
None Basis:
The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a potential loss of the Containment Barrier.
Reference(s):
: 1. Unit 1 SAMG Figure III-1B
: 2. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart
: 3. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.B to 0CAN031801 Page 155 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                      Containment Category:                      D - CTMT Integrity or Bypass Degradation Threat:            Potential Loss Threshold:
CNB8 Containment pressure > 44.7 psia[23.3 psia] with < one full train of containment heat removal systems (Note 9) operating per design for  15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 9:    One full train of containment heat removal systems consists of one train of RB [Containment]
Spray and one train of RB [Containment] Cooling System.
Definition(s):
None Basis:
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 but not including containment venting strategies) are either lost or performing in a degraded manner.
Reference(s):
: 1. 1SAR 6.2 Reactor Building Spray System
: 2. 1SAR 6.3 Reactor Building Cooling System
: 3. OP-2202.003 Loss of Coolant Accident
: 4. OP-2202.010 Standard Attachments, Attachment 22
: 5. 2SAR 6.2.2 Containment Heat Removal Systems
: 6. 2SAR 7.3.1.1.11.2 Containment Spray System
: 7. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.C to 0CAN031801 Page 156 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Containment Category:                E - Emergency Director Judgment Degradation Threat:      Loss Threshold:
CNB9 Any condition in the opinion of the Emergency Director that indicates loss of the Containment barrier Definition(s):
None Basis:
This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is lost.
Reference(s):
: 1. NEI 99-01 Emergency Director Judgment Containment Loss 6.A to 0CAN031801 Page 157 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier:                  Containment Category:                E - Emergency Director Judgment Degradation Threat:      Potential Loss Threshold:
CNB10 Any condition in the opinion of the Emergency Director that indicates potential loss of the Containment barrier Definition(s):
None Basis:
This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.
Reference(s):
: 1. NEI 99-01 Emergency Director Judgment Containment Potential Loss 6.A to 0CAN031801 Page 158 of 240 Attachment 1 - Emergency Action Level Technical Bases Category H - Hazards and Other Conditions Affecting Plant Safety EAL Group:        ANY (EALs in this category are applicable to any plant condition, hot or cold.)
Hazards are non-plant, system-related events that can directly or indirectly affect plant operation, reactor plant safety or personnel safety.
: 1. Security Unauthorized entry attempts into the PROTECTED AREA, bomb threats, sabotage attempts, and actual security compromises threatening loss of physical control of the plant.
: 2. Seismic Event Natural events such as earthquakes have potential to cause plant structure or equipment damage of sufficient magnitude to threaten personnel or plant safety.
: 3. Natural or Technological Hazard Other natural and non-naturally occurring events that can cause damage to plant facilities include tornados, FLOODING, hazardous material releases and events restricting site access warranting classification.
: 4. Fire FIRES can pose significant hazards to personnel and reactor safety. Appropriate for classification are FIRES within the plant PROTECTED AREA or which may affect operability of equipment needed for safe shutdown.
: 5. Hazardous Gas Toxic, corrosive, asphyxiant or flammable gas leaks can affect normal plant operations or preclude access to plant areas required to safely shutdown the plant.
: 6. Control Room Evacuation Events that are indicative of loss of Control Room habitability. If the Control Room must be evacuated, additional support for monitoring and controlling plant functions is necessary through the emergency response facilities.
: 7. Emergency Director Judgment The EALs defined in other categories specify the predetermined symptoms or events that are indicative of emergency or potential emergency conditions and thus warrant classification.
While these EALs have been developed to address the full spectrum of possible emergency conditions which may warrant classification and subsequent implementation of the Emergency Plan, a provision for classification of emergencies based on operator/management experience and judgment is still necessary. The EALs of this category provide the Emergency Director the latitude to classify emergency conditions consistent with the established classification criteria based upon Emergency Director judgment.
to 0CAN031801 Page 159 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards Subcategory:                1 - Security Initiating Condition:        Confirmed SECURITY CONDITION or threat EAL:
HU1.1      Unusual Event A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by ANO Security Shift Supervision OR Notification of a credible security threat directed at the site OR A validated notification from the NRC providing information of an aircraft threat Mode Applicability:
All Definition(s):
HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.
HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).
OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.
Access to this area is controlled by the SOCA Personnel Access Control Point.
PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.
to 0CAN031801 Page 160 of 240 Attachment 1 - Emergency Action Level Technical Bases PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)    The integrity of the reactor coolant pressure boundary; (2)    The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)    The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
SECURITY CONDITION - Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A security condition does not involve a HOSTILE ACTION.
Basis:
This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1 and HS1.
Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and Offsite Response Organizations.
Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
The first threshold references the Security Shift Supervision because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR 2.39 information.
The second threshold addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with OP-1203.048 Security Event .
to 0CAN031801 Page 161 of 240 Attachment 1 - Emergency Action Level Technical Bases The third threshold addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC.
Validation of the threat is performed in accordance with 11-S-82-1 Security Contingency Events (ref. 2).
Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).
Escalation of the emergency classification level would be via IC HA1.
Reference(s):
: 1. ANO Security Plan
: 2. OP-1203.048 Security Event
: 3. NEI 99-01 HU1 to 0CAN031801 Page 162 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards Subcategory:                1 - Security Initiating Condition:        HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes EAL:
HA1.1    Alert A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by ANO Security Shift Supervision OR A validated notification from NRC of an aircraft attack threat within 30 min. of the site Mode Applicability:
All Definition(s):
HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.
HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).
HOSTILE FORCE - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.
Access to this area is controlled by the SOCA Personnel Access Control Point.
PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.
PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
to 0CAN031801 Page 163 of 240 Attachment 1 - Emergency Action Level Technical Bases Basis:
This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.
Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.
Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations (OROs), allowing them to be better prepared should it be necessary to consider further actions.
This EAL does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.
Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.
The first threshold is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA.
The second threshold addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with OP-1203.048 Security Event (ref. 2).
The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRC.
In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.
to 0CAN031801 Page 164 of 240 Attachment 1 - Emergency Action Level Technical Bases Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).
Escalation of the emergency classification level would be via IC HS1.
Reference(s):
: 1. ANO Security Plan
: 2. OP-1203.048 Security Event
: 3. NEI 99-01 HA1 to 0CAN031801 Page 165 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  H - Hazards Subcategory:                1 - Security Initiating Condition:      HOSTILE ACTION within the PROTECTED AREA EAL:
HS1.1    Site Area Emergency A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by ANO Security Shift Supervision Mode Applicability:
All Definition(s):
HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.
HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).
HOSTILE FORCE - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.
Access to this area is controlled by the SOCA Personnel Access Control Point.
PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.
PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
to 0CAN031801 Page 166 of 240 Attachment 1 - Emergency Action Level Technical Bases Basis:
This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment.
Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event (ref. 1, 2).
Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Site Area Emergency declaration will mobilize Offsite Response Organization (ORO) resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.
This EAL does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.
Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.
Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).
Reference(s):
: 1. ANO Security Plan
: 2. OP-1203.048 Security Event
: 3. NEI 99-01 HS1 to 0CAN031801 Page 167 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                2 - Seismic Event Initiating Condition:      Seismic event greater than OBE levels EAL:
HU2.1      Unusual Event Seismic event > OBE as indicated by annunciation of the 0.10 g acceleration alarm Mode Applicability:
All Definition(s):
None Basis:
This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (OBE). An earthquake greater than an OBE but less than a Design Basis Earthquake (DBE) should have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections). Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety of the plant.
Event verification with external sources should not be necessary during or following an OBE.
Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., lateral accelerations in excess of 0.1g). The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA6 or SA9.
Two strong motion triaxial accelerometers, ACS-8001 and ACS-8003, located at the base slab provide alarms to the Unit 1 control room via the seismic network control center, C529-NCC.
One alarm from C529-NCC is triggered when a setpoint of 0.01g has been exceeded. This alarm indicates that an earthquake has occurred and the seismic monitoring system is recording seismic data. Another alarm from C529-NCC is triggered when the pre-determined value of 0.1g, indicating the OBE has been exceeded (ref. 2, 3).
to 0CAN031801 Page 168 of 240 Attachment 1 - Emergency Action Level Technical Bases To avoid inappropriate emergency classification resulting from spurious actuation of the seismic instrumentation or felt motion not attributable to seismic activity, an offsite agency (USGS, National Earthquake Information Center (NEIC)) can confirm that an earthquake has occurred in the area of the plant. Such confirmation should not, however, preclude a timely emergency declaration based on receipt of the OBE alarm. If requested, provide the analyst with the following ANO coordinates: 35&#xba; 18' 36" north latitude, 93&#xba; 13' 53" west longitude (ref. 4).
Alternatively, near real-time seismic activity can be accessed via the NEIC website:
Reference(s):
: 1. 1SAR 2.2.1 Location
: 2. 1SAR 2.7.2 Site Seismic Evaluation
: 3. 1SAR 2.7.6 Time-History Accelerograph
: 4. OP-1203.025 Natural Emergencies
: 5. OP-2203.008 Natural Emergencies
: 6. NEI 99-01 HU2 to 0CAN031801 Page 169 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                3 - Natural or Technological Hazard Initiating Condition:      Hazardous event EAL:
HU3.1      Unusual Event A tornado strike within the PROTECTED AREA Mode Applicability:
All Definition(s):
PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
Basis:
This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.
This EAL addresses a tornado striking (touching down) within the PROTECTED AREA.
Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.
If damage is confirmed visually or by other in-plant indications, the event may be escalated to an Alert under EAL CA6.1 or SA9.1.
A tornado striking (touching down) within the PROTECTED AREA warrants declaration of an Unusual Event regardless of the measured wind speed at the meteorological tower. A tornado is defined as a violently rotating column of air in contact with the ground and extending from the base of a thunderstorm.
Reference(s):
: 1. OP-1203.025 Natural Emergencies
: 2. OP-2203.008 Natural Emergencies
: 3. NEI 99-01 HU3 to 0CAN031801 Page 170 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                3 - Natural or Technological Hazard Initiating Condition:        Hazardous event EAL:
HU3.2      Unusual Event 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 Mode Applicability:
All Definition(s):
FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.
This EAL addresses FLOODING of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.
Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.
to 0CAN031801 Page 171 of 240 Attachment 1 - Emergency Action Level Technical Bases Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.
Refer to EAL CA6.1 or SA9.1 for internal FLOODING affecting more than one SAFETY SYSTEM train.
Reference(s):
: 1. OP-1203.025 Natural Emergencies
: 2. OP-2203.008 Natural Emergencies
: 3. NEI 99-01 HU3 to 0CAN031801 Page 172 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                3 - Natural or Technological Hazard Initiating Condition:      Hazardous event EAL:
HU3.3      Unusual Event Movement of personnel within the PROTECTED AREA is IMPEDED due to an event external to the PROTECTED AREA involving hazardous materials (e.g., an offsite chemical spill or toxic gas release)
Mode Applicability:
All Definition(s):
IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
Basis:
This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.
This EAL addresses a hazardous materials event originating at a location outside the PROTECTED AREA and of sufficient magnitude to IMPEDE the movement of personnel within the PROTECTED AREA.
Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.
Reference(s):
: 1. NEI 99-01 HU3 to 0CAN031801 Page 173 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                3 - Natural or Technological Hazard Initiating Condition:      Hazardous event EAL:
HU3.4      Unusual Event A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles (Note 7)
Note 7:  This EAL does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.
Mode Applicability:
All Definition(s):
FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.
Basis:
This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.
This EAL addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.
Examples of such an event include site FLOODING caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.
This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the FLOODING around the Cooper Station during the Midwest floods of 1993, or the FLOODING around Ft. Calhoun Station in 2011.
Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.
Reference(s):
: 1. NEI 99-01 HU3 to 0CAN031801 Page 174 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                  4 - Fire Initiating Condition:        FIRE potentially degrading the level of safety of the plant EAL:
HU4.1      Unusual Event A FIRE is not extinguished within 15 min. of any of the following FIRE detection indications (Note 1):
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 The FIRE is located within any Table 1[2]H-1 area Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1H-1      Unit 1 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Penthouse/MSIV Room Exceptions:
Boric Acid Mix Tank Room (Chem Add Area), 404 (157-B), EDG Exhaust Fan area on 386 (1-E and 2-E)
Turbine Building All elevations including: Pipechase under ICW Coolers, CRD Pump Pit/T-28 Room/Area under ICW Pumps Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)
Manholes adjacent to Intake Structure (MH-05/MH-06)
Intake Structure (354 and 366)
Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10) to 0CAN031801 Page 175 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2H-1 Unit 2 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Aux Extension Turbine Building All elevations Outside Areas Intake Structure (354 and 366)
Concrete Manhole East, NE of intake (2MH-01)
Concrete Manhole East of Turbine Building next to train bay (2MH-03)
Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)
Mode Applicability:
All Definition(s):
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.
VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
Basis:
This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.
The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.
to 0CAN031801 Page 176 of 240 Attachment 1 - Emergency Action Level Technical Bases Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via EAL CA6.1 or SA9.1.
The 15 minute requirement begins with a credible notification that a FIRE is occurring, or receipt of multiple VALID fire detection system alarms or field validation of a single fire alarm. The alarm is to be validated using available Control Room indications or alarms to prove that it is not spurious, or by reports from the field.
Table 1[2]H-1 Fire Areas are those areas that contain equipment necessary for safe operation and shutdown of the plant (ref. 1, 2).
Reference(s):
: 1. OP-1203.049 Fires in Areas Affecting Safe Shutdown
: 2. OP- 2203.049 Fires in Areas Affecting Safe Shutdown
: 3. NEI 99-01 HU4 to 0CAN031801 Page 177 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                  4 - Fire Initiating Condition:        FIRE potentially degrading the level of safety of the plant EAL:
HU4.2      Unusual Event Receipt of a single fire alarm (i.e., no other indications of a FIRE)
AND The fire alarm is indicating a FIRE within any Table 1[2]H-1 area AND The existence of a FIRE is not verified within 30 min. of alarm receipt (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1H-1      Unit 1 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Penthouse/MSIV Room Exceptions:
Boric Acid Mix Tank Room (Chem Add Area), 404 (157-B), EDG Exhaust Fan area on 386 (1-E and 2-E)
Turbine Building All elevations including: Pipechase under ICW Coolers, CRD Pump Pit/T-28 Room/Area under ICW Pumps Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)
Manholes adjacent to Intake Structure (MH-05/MH-06)
Intake Structure (354 and 366)
Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10) to 0CAN031801 Page 178 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2H-1 Unit 2 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Aux Extension Turbine Building All elevations Outside Areas Intake Structure (354 and 366)
Concrete Manhole East, NE of intake (2MH-01)
Concrete Manhole East of Turbine Building next to train bay (2MH-03)
Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)
Mode Applicability:
All Definition(s):
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.
VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.
Basis:
This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.
This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.
to 0CAN031801 Page 179 of 240 Attachment 1 - Emergency Action Level Technical Bases A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.
If an actual FIRE is verified by a report from the field, then HU4.1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report.
If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.
Basis-Related Fire Protection Requirements Criterion 3 of 10 CFR 50, Appendix A, states, in part:
Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.
In this respect, noncombustible and heat resistant materials are used wherever practical throughout the unit, particularly in locations such as the containment and Control Room. Fire detection and fighting systems of appropriate capacity and capability are provided and designed to minimize the adverse effects of fires on SSCs important to safety. Firefighting systems are designed to assure that the rupture or inadvertent operation of a fire system does not significantly impair the safety capability of these structures, systems, and components.
In addition, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train is employed. As used in HU4.2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via EAL CA6.1 or SA9.1.
The 30-minute requirement begins upon receipt of a single VALID fire detection system alarm.
The alarm is to be validated using available Control Room indications or alarms to prove that it is not spurious, or by reports from the field. Actual field reports must be made within the 30-minute time limit or a classification must be made. If a fire is verified to be occurring by field report, classification shall be made based on EAL HU4.1, with the 15-minute requirement beginning with the verification of the fire by field report.
Table 1[2]H-1 Fire Areas are those areas that contain equipment necessary for safe operation and shutdown of the plant (ref. 1, 2).
to 0CAN031801 Page 180 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. OP-1203.049 Fires in Areas Affecting Safe Shutdown
: 2. OP- 2203.049 Fires in Areas Affecting Safe Shutdown
: 3. NEI 99-01 HU4 to 0CAN031801 Page 181 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                4 - Fire Initiating Condition:      FIRE potentially degrading the level of safety of the plant EAL:
HU4.3      Unusual Event A FIRE within the PROTECTED AREA not extinguished within 60 min. of the initial report, alarm or indication (Note 1)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
All Definition(s):
FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.
PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
Basis:
This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.
In addition to a FIRE addressed by EAL HU4.1 or HU4.2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via EAL CA6.1 or SA8.1.
Reference(s):
: 1. NEI 99-01 HU4 to 0CAN031801 Page 182 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                4 - Fire Initiating Condition:      FIRE potentially degrading the level of safety of the plant EAL:
HU4.4        Unusual Event A FIRE within the PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish Mode Applicability:
All Definition(s):
FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.
PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
Basis:
This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.
If a FIRE within the plant PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish. Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via EAL CA6.1 or SA9.1.
Reference(s):
: 1. NEI 99-01 HU4 to 0CAN031801 Page 183 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                5 - Hazardous Gas Initiating Condition:        Gaseous release IMPEDING access to equipment necessary for normal plant operations, cooldown or shutdown EAL:
HA5.1      Alert Release of a toxic, corrosive, asphyxiant or flammable gas into any Table 1[2]H-2 room or area AND Entry into the room or area is prohibited or IMPEDED (Note 5)
Note 5:  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.
Table 1H-2    Unit 1 Safe Operation & Shutdown Rooms/Areas Room/Area                            Mode A-4 Switchgear Room                                            3, 4 Upper North Electrical Penetration Room                        3, 4 Lower South Electrical Equipment Room                          3, 4 Table 2H-2    Unit 2 Safe Operation & Shutdown Rooms/Areas Room/Area                            Mode Aux Building 317 Emergency Core Cooling Rooms                  3, 4 Aux Building 317 Tendon Gallery Access                        3, 4 Aux Building 335 Charging Pumps / MCC 2B-52                    3, 4 Aux Building 354 MCC 2B-62 Area                                3, 4 Emergency Diesel Generator Corridor                            3, 4 Lower South Piping Penetration Room                            3, 4 Aux Building 386 Containment Hatch                            3, 4 to 0CAN031801 Page 184 of 240 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:
3 - Hot Standby, 4 - Hot Shutdown Definition(s):
IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
Basis:
This IC addresses an event involving a release of a hazardous gas that precludes or IMPEDES access to equipment necessary to maintain normal plant operation, or required for a normal plant cooldown and shutdown. This condition represents an actual or potential substantial degradation of the level of safety of the plant.
An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.
Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Directors judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly IMPEDE procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards.
Access should be considered as IMPEDED if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
An emergency declaration is not warranted if any of the following conditions apply:
The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release). For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.
The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).
The access control measures are of a conservative or precautionary nature, and would not actually prevent or IMPEDE a required action.
to 0CAN031801 Page 185 of 240 Attachment 1 - Emergency Action Level Technical Bases If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact 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.
This EAL does not apply to firefighting activities that generate smoke and that automatically or manually activate a fire suppression system in an area.
The list of plant rooms or areas with entry-related mode applicability identified specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations) are not included. In addition, the list specifies the plant mode(s) during which entry would be required for each room or area (ref. 1).
Escalation of the emergency classification level would be via Recognition Category A, C or F ICs.
EAL HA5.1 mode applicability has been limited to the mode limitations of Table 1[2]H-2 (Modes 3 and 4 only).
Reference(s):
: 1. Attachment 2 Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases
: 2. NEI 99-01 HA5 to 0CAN031801 Page 186 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  H - Hazards and Other Conditions Affecting Plant Safety Subcategory:              6 - Control Room Evacuation Initiating Condition:      Control Room evacuation resulting in transfer of plant control to alternate locations EAL:
HA6.1      Alert An event has resulted in plant control being transferred from the Control Room to alternate locations Mode Applicability:
All Definition(s):
None Basis:
This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety.
Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations. The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel. Activation of the ERO and emergency response facilities will assist in responding to these challenges.
Transfer of plant control begins when the last licensed operator leaves the Control Room.
Escalation of the emergency classification level would be via IC HS6.
Reference(s):
: 1. OP-1203.002 Alternate Shutdown
: 2. OP-2203.014 Alternate Shutdown
: 3. NEI 99-01 HA6 to 0CAN031801 Page 187 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                6 - Control Room Evacuation Initiating Condition:      Inability to control a key safety function from outside the Control Room EAL:
HS6.1      Site Area Emergency An event has resulted in plant control being transferred from the Control Room to alternate locations AND Control of any of the following key safety functions is not re-established within 15 min. (Note 1):
Reactivity (Modes 1, 2 and 3 only)
Core cooling RCS heat removal Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling Definition(s):
None Basis:
This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plant control to alternate locations is a precursor to a challenge to one or more fission product barriers within a relatively short period of time.
The determination of whether or not control is established at the remote safe shutdown location(s) is based on Emergency Director judgment. The Emergency Director is expected to make a reasonable, informed judgment within 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).
to 0CAN031801 Page 188 of 240 Attachment 1 - Emergency Action Level Technical Bases Transfer of plant control and the time period to establish control begins when the last licensed operator leaves the Control Room.
Escalation of the emergency classification level would be via IC FG1 or CG1 Reference(s):
: 1. OP-1203.002 Alternate Shutdown
: 2. OP-2203.014 Alternate Shutdown
: 3. NEI 99-01 HS6 to 0CAN031801 Page 189 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                7 - Emergency Director Judgment Initiating Condition:        Other conditions exist that in the judgment of the Emergency Director warrant declaration of a UE EAL:
HU7.1      Unusual Event 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.
Mode Applicability:
All Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an UNUSUAL EVENT.
Reference(s):
: 1. NEI 99-01 HU7 to 0CAN031801 Page 190 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                7 - Emergency Director Judgment Initiating Condition:        Other conditions exist that in the judgment of the Emergency Director warrant declaration of an ALERT EAL:
HA7.1      Alert 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.
Mode Applicability:
All Definition(s):
HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.
HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).
OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.
Access to this area is controlled by the SOCA Personnel Access Control Point.
PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.
PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
to 0CAN031801 Page 191 of 240 Attachment 1 - Emergency Action Level Technical Bases Basis:
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an ALERT.
Reference(s):
: 1. NEI 99-01 HA7 to 0CAN031801 Page 192 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                7 - Emergency Director Judgment Initiating Condition:        Other conditions exist that in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY EAL:
HS7.1      Site Area Emergency 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.
Mode Applicability:
All Definition(s):
HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.
HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).
OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.
Access to this area is controlled by the SOCA Personnel Access Control Point.
PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.
to 0CAN031801 Page 193 of 240 Attachment 1 - Emergency Action Level Technical Bases PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.
Basis:
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a SITE AREA EMERGENCY.
Reference(s):
: 1. NEI 99-01 HS7 to 0CAN031801 Page 194 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    H - Hazards and Other Conditions Affecting Plant Safety Subcategory:                7 - Emergency Director Judgment Initiating Condition:        Other conditions exist that in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY EAL:
HG7.1      General Emergency Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.
Mode Applicability:
All Definition(s):
HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.
HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).
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.
OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.
Access to this area is controlled by the SOCA Personnel Access Control Point.
PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.
to 0CAN031801 Page 195 of 240 Attachment 1 - Emergency Action Level Technical Bases PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.
Basis:
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a GENERAL EMERGENCY.
Reference(s):
: 1. NEI 99-01 HG7 to 0CAN031801 Page 196 of 240 Attachment 1 - Emergency Action Level Technical Bases Category S - System Malfunction EAL Group:      Hot Conditions (RCS temperature > 200&deg;F); EALs in this category are applicable only in one or more hot operating modes.
Numerous system-related equipment failure events that warrant emergency classification have been identified in this category. They may pose actual or potential threats to plant safety.
The events of this category pertain to the following subcategories:
: 1. Loss of Vital AC Power Loss of vital electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite sources for vital 4.16 KV buses.
: 2. Loss of Vital DC Power Loss of emergency electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of vital plant 125V DC power sources.
: 3. Loss of Control Room Indications Certain events that degrade plant operator ability to effectively assess plant conditions within the plant warrant emergency classification. Losses of indicators are in this subcategory.
: 4. RCS Activity During normal operation, reactor coolant fission product activity is very low. Small concentrations of fission products in the coolant are primarily from the fission of tramp uranium in the fuel clad or minor perforations in the clad itself. Any significant rise from these base-line levels (2% - 5% clad failures) is indicative of fuel failures and is covered under the Fission Product Barrier Degradation category. However, lesser amounts of clad damage may result in coolant activity exceeding Technical Specification limits. These fission products will be circulated with the reactor coolant and can be detected by coolant sampling.
: 5. RCS Leakage The reactor vessel provides a volume for the coolant that covers the reactor core. The reactor pressure vessel and associated pressure piping (reactor coolant system) together provide a barrier to limit the release of radioactive material should the reactor fuel clad integrity fail. Excessive RCS leakage greater than Technical Specification limits indicates potential pipe cracks that may propagate to an extent threatening fuel clad, RCS and containment integrity.
to 0CAN031801 Page 197 of 240 Attachment 1 - Emergency Action Level Technical Bases
: 6. RPS Failure This subcategory includes events related to failure of the Reactor Protection System (RPS) to initiate and complete reactor trips. In the plant licensing basis, postulated failures of the RPS to complete a reactor trip comprise a specific set of analyzed events referred to as Anticipated Transient Without Scram (ATWS) events. For EAL classification, however, ATWS is intended to mean any trip failure event that does not achieve reactor shutdown. If RPS actuation fails to assure reactor shutdown, positive control of reactivity is at risk and could cause a threat to fuel clad, RCS and containment integrity.
: 7. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.
: 8. Containment Failure Failure of containment isolation capability (under conditions in which the containment is not currently challenged) warrants emergency classification. Failure of containment pressure control capability also warrants emergency classification.
: 9. Hazardous Event Affecting Safety Systems Various natural and technological events that result in degraded plant safety system performance or significant VISIBLE DAMAGE warrant emergency classification under this subcategory.
to 0CAN031801 Page 198 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                1 - Loss of Vital AC Power Initiating Condition:        Loss of all offsite AC power capability to vital buses for 15 minutes or longer EAL:
SU1.1      Unusual Event Loss of all offsite AC power capability, Table 1[2]S-1, to vital 4.16 KV buses A3[2A3] and A4[2A4] for  15 min. (Note 1)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1S-1 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)
Onsite Unit Auxiliary Transformer (main generator via main transformer)
DG1 DG2 AAC Gen to 0CAN031801 Page 199 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2S-1 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)
Onsite Unit Auxiliary Transformer (main generator via main transformer) 2DG1 2DG2 AAC Gen Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
None 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 vital 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 vital buses, whether or not the buses are powered from it.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power.
Escalation of the emergency classification level would be via IC SA1.
Reference(s):
: 1. 1SAR Figure 8-1 Station Single Line Diagram
: 2. OP-1202.007 Degraded Power
: 3. OP-1202.008 Blackout
: 4. OP-2104.037 Alternate AC Diesel Generator Operations to 0CAN031801 Page 200 of 240 Attachment 1 - Emergency Action Level Technical Bases
: 5. 2SAR Figure 8.3-1 Station Single Line Diagram
: 6. OP-2202.007 Loss of Off-Site Power
: 7. OP-2202.008 Station Blackout
: 8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
: 9. NEI 99-01 SU1 to 0CAN031801 Page 201 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                1 - Loss of Vital AC Power Initiating Condition:        Loss of all but one AC power source to vital buses for 15 minutes or longer EAL:
SA1.1      Alert AC power capability, Table 1[2]S-1, to vital 4.16 KV buses A3[2A3] and A4[2A4] reduced to a single power source for  15 min. (Note 1)
AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1S-1      Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)
Onsite Unit Auxiliary Transformer (main generator via main transformer)
DG1 DG2 AAC Gen to 0CAN031801 Page 202 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2S-1    Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)
Onsite Unit Auxiliary Transformer (main generator via main transformer) 2DG1 2DG2 AAC Gen Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
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 SU1.
to 0CAN031801 Page 203 of 240 Attachment 1 - Emergency Action Level Technical Bases An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to a vital bus. Some examples of this condition are presented below.
A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).
A loss of all offsite power and loss of all vital power sources (e.g., onsite diesel generators) with a single train of vital buses being back-fed from the unit main generator.
A loss of vital power sources (e.g., onsite diesel generators) with a single train of vital 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 SS1.
This EAL is the hot condition equivalent of the cold condition EAL CU2.1.
Reference(s):
: 1. 1SAR Figure 8-1 Station Single Line Diagram
: 2. OP-1202.007 Degraded Power
: 3. OP-1202.008 Blackout
: 4. OP-2104.037 Alternate AC Diesel Generator Operations
: 5. 2SAR Figure 8.3-1 Station Single Line Diagram
: 6. OP-2202.007 Loss of Off-Site Power
: 7. OP-2202.008 Station Blackout
: 8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
: 9. NEI 99-01 SA1 to 0CAN031801 Page 204 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                  1 - Loss of Vital AC Power Initiating Condition:        Loss of all offsite power and all onsite AC power to vital buses for 15 minutes or longer EAL:
SS1.1      Site Area Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3[2A3] and A4[2A4] for 15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
Although the AAC may be considered available, it will not prevent declaration of this EAL unless it is powering a vital bus within the 15 minute time period of the EAL.
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.
Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or emergency operating procedures, or beyond design basis to 0CAN031801 Page 205 of 240 Attachment 1 - Emergency Action Level Technical Bases accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.
Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.
Escalation of the emergency classification level would be via IC AG1, FG1 or SG1.
This EAL is the hot condition equivalent of the cold condition EAL CA2.1.
Reference(s):
: 1. 1SAR Figure 8-1 Station Single Line Diagram
: 2. OP-1202.007 Degraded Power
: 3. OP-1202.008 Blackout
: 4. OP-2104.037 Alternate AC Diesel Generator Operations
: 5. 2SAR Figure 8.3-1 Station Single Line Diagram
: 6. OP-2202.007 Loss of Off-Site Power
: 7. OP-2202.008 Station Blackout
: 8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
: 9. NEI 99-01 SS1 to 0CAN031801 Page 206 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                1 - Loss of Vital AC Power Initiating Condition:        Prolonged loss of all offsite and all onsite AC power to vital buses EAL:
SG1.1      General Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3[2A3] and A4[2A4]
AND EITHER:
Restoration of at least one vital 4.16 KV bus in < 4 hours is not likely (Note 1)
CETs > 1200&deg;F Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
This IC addresses a prolonged loss of all power sources to AC vital buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or to 0CAN031801 Page 207 of 240 Attachment 1 - Emergency Action Level Technical Bases emergency operating procedures, or beyond design basis accident response guidelines (e.g.,
FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. A prolonged loss of these buses will lead to a loss of one or more 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 vital 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 a greater likelihood of challenges to multiple fission product barriers. 4 hours is the site-specific SBO coping analysis time (ref. 4, 5).
The estimate for restoring at least one vital bus should be based on a realistic appraisal of the situation. Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public.
The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.
Reference(s):
: 1. OP-1202.005 Inadequate Core Cooling
: 2. OP-2202.009 Functional Recovery
: 3. OP-2202.011 Lower Mode Functional Recovery
: 4. Unit 1 Calculation 85-E-0072-02 Time from Loss of All AC Power to Loss of Subcooling
: 5. Unit 2 Calculation 85-E-0072-01 Time from Loss of All AC Power to Loss of Subcooling
: 6. 1SAR Figure 8-1 Station Single Line Diagram
: 7. OP-1202.007 Degraded Power
: 8. OP-1202.008 Blackout
: 9. OP-2104.037 Alternate AC Diesel Generator Operations
: 10. 2SAR Figure 8.3-1 Station Single Line Diagram
: 11. OP-2202.007 Loss of Off-Site Power
: 12. OP-2202.008 Station Blackout
: 13. OP-2107.006 Backfeed of Unit Auxiliary Transformer
: 14. NEI 99-01 SG1 to 0CAN031801 Page 208 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                      S - System Malfunction Subcategory:                  1 - Loss of Vital AC Power Initiating Condition:          Loss of all vital AC and vital DC power sources for 15 minutes or longer EAL:
SG1.2        General Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3[2A3] and A4[2A4] for 15 min. (Note 1)
AND Indicated voltage is < 105 VDC on D01[2D01] and D02[2D02] vital 125 VDC buses for 15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)    The integrity of the reactor coolant pressure boundary; (2)    The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)    The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC (ref. 9, 10).
This IC addresses a concurrent and prolonged loss of both vital AC and Vital DC power. A loss of all vital AC power compromises the performance of all SAFETY SYSTEMS requiring electric to 0CAN031801 Page 209 of 240 Attachment 1 - Emergency Action Level Technical Bases power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or emergency operating procedures, or beyond design basis accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. A loss of vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both vital AC and vital 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 both EAL thresholds are met.
Reference(s):
: 1. 1SAR Figure 8-1 Station Single Line Diagram
: 2. OP-1202.007 Degraded Power
: 3. OP-1202.008 Blackout
: 4. OP-2104.037 Alternate AC Diesel Generator Operations
: 5. 2SAR Figure 8.3-1 Station Single Line Diagram
: 6. OP-2202.007 Loss of Off-Site Power
: 7. OP-2202.008 Station Blackout
: 8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
: 9. 1SAR 8.3.2.1.1 Batteries
: 10. 2SAR 8.3.2.1.1 Batteries
: 11. OP-1203.036 Loss of 125V DC
: 12. OP-2203.037 Loss of 125V DC
: 13. 2SAR Figure 8.3-6 Low Voltage Safety System Power Supplies
: 14. NEI 99-01 SG8 to 0CAN031801 Page 210 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                2 - Loss of Vital DC Power Initiating Condition:        Loss of all vital DC power for 15 minutes or longer EAL:
SS2.1      Site Area Emergency Indicated voltage is < 105 VDC on D01[2D01] and D02[2D02] vital 125 VDC buses for 15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
Basis:
Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC (ref. 2, 3).
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 IC AG1, FG1 or SG1.
This EAL is the hot condition equivalent of the cold condition EAL CU4.1.
to 0CAN031801 Page 211 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. 1SAR Figure 8-1 Station Single Line Diagram
: 2. 1SAR 8.3.2.1.1 Batteries
: 3. 2SAR 8.3.2.1.1 Batteries
: 4. OP-1203.036 Loss of 125V DC
: 5. OP-2203.037 Loss of 125V DC
: 6. 2SAR Figure 8.3-6 Low Voltage Safety System Power Supplies
: 7. NEI 99-01 SS8 to 0CAN031801 Page 212 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                3 - Loss of Control Room Indications Initiating Condition:        UNPLANNED loss of Control Room indications for 15 minutes or longer EAL:
SU3.1      Unusual Event An UNPLANNED event results in the inability to monitor one or more Table 1[2]S-2 parameters from within the Control Room for  15 min. (Note 1)
Note 1:    The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1[2]S-2      Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one S/G EFW flow to at least one S/G Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
to 0CAN031801 Page 213 of 240 Attachment 1 - Emergency Action Level Technical Bases 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.
Basis:
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 one or more of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.
An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.
This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level 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 EAL SA3.1.
Reference(s):
: 1. 1SAR 7.5 Safety-Related Display Instrumentation
: 2. 2SAR 7.5 Safety-Related Display Instrumentation
: 3. NEI 99-01 SU2 to 0CAN031801 Page 214 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                3 - Loss of Control Room Indications Initiating Condition:        UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress EAL:
SA3.1      Alert An UNPLANNED event results in the inability to monitor one or more Table 1[2]S-2 parameters from within the Control Room for  15 min. (Note 1)
AND Any significant transient is in progress, Table 1[2]S-3 Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Table 1[2]S-2      Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one S/G EFW flow to at least one S/G Table 1[2]S-3      Significant Transients Reactor trip Runback > 25% thermal power Electrical load rejection > 25% electrical load Safety injection actuation to 0CAN031801 Page 215 of 240 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 (as defined in 10 CFR 50.2):
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
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.
Basis:
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 one or more of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.
An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.
This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be to 0CAN031801 Page 216 of 240 Attachment 1 - Emergency Action Level Technical Bases more significant than simply a reportable condition. In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level 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 FS1 or AS1.
Reference(s):
: 1. 1SAR 7.1.3 Engineered Safeguards Actuation System
: 2. 2SAR 7.3 Engineered Safety Features Systems
: 3. NEI 99-01 SA2 to 0CAN031801 Page 217 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  S - System Malfunction Subcategory:              4 - RCS Activity Initiating Condition:      RCS activity greater than Technical Specification allowable limits EAL:
SU4.1      Unusual Event Failed Fuel Iodine radiation monitor RI-1237S[2RITS-4806B] > 9.0 E5 cpm Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
None 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.
Escalation of the emergency classification level would be via IC FA1 or the Recognition Category A ICs.
Unit 1 RE-1237S, Failed Fuel Monitor, is in the letdown system to monitor the letdown line for evidence of fuel damage.
Unit 2 specific activity monitor 2RITS-4806B monitors the Letdown fluid for the presence of Iodine-131.
A monitor reading corresponding to the instantaneous dose equivalent I-131 value of 60 uCi/gm is determined by multiplying by 30 the monitor reading listed in the table in OP-1203.019[OP-2203.020] that represents a projected 2.0 uCi/gm I-131 RCS activity(ref. 2, 5).
This yields values of 3.1E6 cpm for Unit 1 and 3.9E6 cpm for Unit 2. The top of scale of the monitor is 1E6. The EAL value is set at 9.0 E5 cpm for both units which is 90% of the top of the scale.
to 0CAN031801 Page 218 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. 1SAR Table 11-7
: 2. OP-1203-019 High Activity in Reactor Coolant
: 3. Unit 1 Technical Specifications LCO 3.4.12 RCS Specific Activity
: 4. 2SAR 9.3.5 Failed Fuel Detection System
: 5. OP-2203.020 High Activity in RCS
: 6. OP- 2203.012L ANNUNCIATOR 2K12 CORRECTIVE ACTION, A-1
: 7. Unit 2 Technical Specifications LCO 3.4.8 Reactor Coolant System Specific Activity
: 8. NEI 99-01 SU3 to 0CAN031801 Page 219 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  S - System Malfunction Subcategory:                4 - RCS Activity Initiating Condition:      RCS activity greater than Technical Specification allowable limits EAL:
SU4.2      Unusual Event RCS sample activity > 1.0 &#xb5;Ci/gm dose equivalent I-131 for > 48 hours (Note 1)
OR RCS sample activity > 60 &#xb5;Ci/gm dose equivalent I-131 OR RCS sample activity > 2200[3100] &#xb5;Ci/gm dose equivalent Xe-133 for > 48 hours (Note 1)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
None 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.
Escalation of the emergency classification level would be via IC FA1 or the Recognition Category A ICs.
Reference(s):
: 1. Unit 1 Technical Specifications LCO 3.4.12 RCS Specific Activity
: 2. Unit 2 Technical Specifications LCO 3.4.8 Reactor Coolant System Specific Activity
: 3. NEI 99-01 SU3 to 0CAN031801 Page 220 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  S - System Malfunction Subcategory:                5 - RCS Leakage Initiating Condition:      RCS leakage for 15 minutes or longer EAL:
SU5.1      Unusual Event RCS unidentified or pressure boundary leakage > 10 gpm for  15 min. (Note 1)
OR RCS identified leakage > 25 gpm for  15 min. (Note 1)
OR Reactor coolant leakage to a location outside containment > 25 gpm for  15 min. (Note 1)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.
Basis:
Failure to isolate the leak (from the Control Room or locally) within 15 minutes, or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.
Steam generator tube leakage is identified RCS leakage.
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.
The first and second EAL conditions 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). The third condition addresses an RCS mass loss caused by an UNISOLABLE leak through an interfacing system. These conditions thus apply to leakage into the containment, a secondary-side system (e.g., steam generator tube leakage) or a location outside of containment.
to 0CAN031801 Page 221 of 240 Attachment 1 - Emergency Action Level Technical Bases The leak rate values for each condition 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). The first condition 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 A or F.
Reference(s):
: 1. Unit 1 and Unit 2 Technical Specifications Section 1.1 Definitions
: 2. NEI 99-01 SU4 to 0CAN031801 Page 222 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                      S - System Malfunction Subcategory:                  6 - RPS Failure Initiating Condition:          Automatic or manual trip fails to shut down the reactor EAL:
SU6.1      Unusual Event An automatic trip did not shut down the reactor as indicated by reactor power > 5% after any RPS setpoint is exceeded AND A subsequent automatic trip or manual trip action taken at the reactor control console (C03
[2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) is successful in shutting down the reactor as indicated by reactor power  5% (Note 8)
Note 8:    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.
Mode Applicability:
1 - Power Operation Definition(s):
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.
Basis:
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic trip is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.
In the event that the operator identifies a reactor trip is IMMINENT and initiates a successful manual reactor trip before the automatic trip setpoint is reached, no declaration is required. The successful manual trip of the reactor before it reaches its automatic trip setpoint or reactor trip signals caused by instrumentation channel failures do not lead to a potential fission product barrier loss.
to 0CAN031801 Page 223 of 240 Attachment 1 - Emergency Action Level Technical Bases Following the failure of 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 plants decay heat removal systems.
If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles 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 plants decay heat removal systems.
A manual action at the reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor 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 reactor control consoles.
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 reactor control consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC SA6. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC SA6 or FA1, an Unusual Event declaration is appropriate for this event.
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 results in a condition that should have included an automatic reactor trip and the RPS fails to automatically shutdown the reactor, then this IC and associated EALs are applicable, and should be evaluated.
If the signal generated as a result of plant work does not cause a plant transient and the trip failure is determined through other means (e.g., assessment of test results), then this IC and associated EALs are not applicable and no classification is warranted.
to 0CAN031801 Page 224 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
: 2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
: 3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
: 4. OP-1202.001 Reactor Trip
: 5. OP-2202.001 Standard Post Trip Actions
: 6. NEI 99-01 SU5 to 0CAN031801 Page 225 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                      S - System Malfunction Subcategory:                  6 - RPS Failure Initiating Condition:          Automatic or manual trip fails to shut down the reactor EAL:
SU6.2      Unusual Event A manual trip did not shut down the reactor as indicated by reactor power > 5% after any manual trip action was initiated AND A subsequent automatic trip or manual trip action taken at the reactor control console (C03
[2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) is successful in shutting down the reactor as indicated by reactor power  5% (Note 8)
Note 8:    A manual scram 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.
Mode Applicability:
1 - Power Operation Definition(s):
None Basis:
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic trip is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.
This EAL addresses a failure of a manually initiated trip in the absence of having exceeded an automatic RPS trip setpoint and a subsequent automatic or manual trip is successful in shutting down the reactor.
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 plants decay heat removal systems.
to 0CAN031801 Page 226 of 240 Attachment 1 - Emergency Action Level Technical Bases If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles 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 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 plants decay heat removal systems.
A manual action at the reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor 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 reactor control consoles.
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 reactor control consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC SA6. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC SA6 or FA1, an Unusual Event declaration is appropriate for this event.
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 results in a condition that should have included an automatic reactor trip and the RPS fails to automatically shutdown the reactor, then this IC and associated EALs are applicable, and should be evaluated.
If the signal generated as a result of plant work does not cause a plant transient and the trip failure is determined through other means (e.g., assessment of test results), then this IC and associated EALs are not applicable and no classification is warranted.
Reference(s):
: 1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
: 2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
: 3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
: 4. OP-1202.001 Reactor Trip
: 5. OP-2202.001 Standard Post Trip Actions
: 6. NEI 99-01 SU5 to 0CAN031801 Page 227 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                      S - System Malfunction Subcategory:                  6 - RPS Failure Initiating Condition:          Automatic or manual trip fails to shut down the reactor and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor EAL:
SA6.1      Alert An automatic or manual trip fails to shut down the reactor as indicated by reactor power > 5%
AND Manual trip actions taken at the reactor control console (C03[2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) are not successful in shutting down the reactor as indicated by reactor power > 5% (Note 8)
Note 8:    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.
Mode Applicability:
1 - Power Operation Definition(s):
None 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 reactor control console 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 console (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 console.
to 0CAN031801 Page 228 of 240 Attachment 1 - Emergency Action Level Technical Bases 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 shut down the reactor is prolonged enough to cause a challenge to the core cooling or RCS heat removal safety functions, the emergency classification level will escalate to a Site Area Emergency via IC SS6. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC SS6 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.
Reference(s):
: 1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
: 2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
: 3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
: 4. OP-1202.001 Reactor Trip
: 5. OP-2202.001 Standard Post Trip Actions
: 6. NEI 99-01 SA5 to 0CAN031801 Page 229 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                    S - System Malfunction Subcategory:                6 - RPS Failure Initiating Condition:        Inability to shut down the reactor causing a challenge to core cooling or RCS heat removal EAL:
SS6.1      Site Area Emergency An automatic or manual trip fails to shut down the reactor as indicated by reactor power > 5%
AND All actions to shut down the reactor are not successful as indicated by reactor power > 5%
AND EITHER:
CETs > 1200&deg;F RCS heat removal cannot be established using steam generators and HPI[Once Through] cooling initiated.
Mode Applicability:
1 - Power Operation Definition(s):
None 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 actions to manually shutdown the reactor are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.
In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs. This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor.
Escalation of the emergency classification level would be via IC AG1 or FG1.
to 0CAN031801 Page 230 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):
: 1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
: 2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
: 3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
: 4. OP-1202.001 Reactor Trip
: 5. OP-2202.001 Standard Post Trip Actions
: 6. OP-1202.004 Overheating
: 7. OP-2202.006 Loss of Feedwater
: 8. OP-1202.013 Figure 1, Saturation and Adequate SCM
: 9. Calculation 90-E-0116-07 Unit 1 EOP Setpoint Document, Setpoint B.19
: 10. OP-2202.009 Functional Recovery
: 11. Calculation 90-E-0116-01 Unit 2 EOP Setpoint Document
: 12. NEI 99-01 SS5 to 0CAN031801 Page 231 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  S - System Malfunction Subcategory:              7 - Loss of Communications Initiating Condition:      Loss of all onsite or offsite communications capabilities EAL:
SU7.1      Unusual Event Loss of all Table 1[2]S-4 onsite communication methods OR Loss of all Table 1[2]S-4 State and local agency communication methods OR Loss of all Table 1[2]S-4 NRC communication methods Table 1[2]S-4    Communication Methods System                          Onsite    State / Local NRC Station radio system                                  X ANO plant phone system                                X Gaitronics                                            X Telephone Systems:
Commercial Microwave                                                      X        X Satellite VOIP INFORM Notification System                                          X Emergency Notification System (ENS)                                          X Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown to 0CAN031801 Page 232 of 240 Attachment 1 - Emergency Action Level Technical Bases Definition(s):
None Basis:
This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to State and local agencies and the NRC.
This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).
The first EAL condition addresses a total loss of the communications methods used in support of routine plant operations.
The second EAL condition addresses a total loss of the communications methods used to notify all State and local agencies of an emergency declaration. The State and local agencies referred to here are the Arkansas Department of Health, Arkansas Department of Emergency Management, Pope, Yell, Johnson, and Logan County agencies.
The third EAL addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.
This EAL is the hot condition equivalent of the cold condition EAL CU5.1.
Reference(s):
: 1. OP-1903.062 Communications System Operating Procedure
: 2. NEI 99-01 SU6 to 0CAN031801 Page 233 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                      S - System Malfunction Subcategory:                  8 - Containment Failure Initiating Condition:          Failure to isolate containment or loss of containment pressure control EAL:
SU8.1      Unusual Event Any penetration is not closed within 15 min. of an ESAS[CIAS] actuation signal OR Containment pressure > 44.7 psia[23.3 psia] with < one full train of containment heat removal systems (Note 9) operating per design for  15 min. (Note 1)
Note 1:  The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.
Note 9:    One full train of containment heat removal systems consists of one train of RB [Containment]
Spray and one train of RB [Containment] Cooling System.
Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
None Basis:
A penetration is closed for this EAL if either side of the penetration has a closed valve or a check valve is intact (for penetrations that only have one automatic valve and a check valve).
This EAL addresses a failure of one or more containment penetrations to automatically isolate (close) when required by an actuation signal. It also addresses an event that results in high containment pressure with a concurrent failure of containment pressure control systems.
Absent challenges to another fission product barrier, either condition represents potential degradation of the level of safety of the plant.
For the first condition, the containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); a failure resulting from testing or maintenance does not warrant classification. The determination of containment and penetration status - isolated or not isolated - should be made in accordance with the appropriate criteria contained in the plant AOPs and EOPs. The 15-minute criterion is included to allow operators time to manually isolate the required penetrations, if possible.
to 0CAN031801 Page 234 of 240 Attachment 1 - Emergency Action Level Technical Bases The second condition addresses a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. The inability to start the required equipment indicates that containment heat removal/depressurization systems (e.g., containment sprays) are either lost or performing in a degraded manner.
This event would escalate to a Site Area Emergency in accordance with IC FS1 if there were a concurrent loss or potential loss of either the Fuel Clad or RCS fission product barriers.
Reference(s):
: 1. OP-1202.010 ESAS
: 2. 1SAR 6.2 Reactor Building Spray System
: 3. 1SAR 6.3 Reactor Building Cooling System
: 4. OP-2202.003 Loss of Coolant Accident
: 5. OP-2202.010 Standard Attachments, Attachment 22
: 6. 2SAR 6.2.2 Containment Heat Removal Systems
: 7. 2SAR 7.3.1.1.11.2 Containment Spray System
: 8. NEI 99-01 SU7 to 0CAN031801 Page 235 of 240 Attachment 1 - Emergency Action Level Technical Bases Category:                  S - System Malfunction Subcategory:                9 - Hazardous Event Affecting Safety Systems Initiating Condition:      Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode EAL:
SA9.1      Alert The occurrence of any Table 1[2]S-5 hazardous event AND Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode AND EITHER:
Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)
Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted.
Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.
Table 1[2]S-5    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 to 0CAN031801 Page 236 of 240 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:
1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):
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 require a post-event inspection to determine if the attributes of an explosion are present.
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.
FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.
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 (as defined in 10 CFR 50.2).
Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
(1)  The integrity of the reactor coolant pressure boundary; (2)  The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)  The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.
VISIBLE DAMAGE - Damage to a SAFETY SYSTEM train 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 SAFETY SYSTEM train.
Basis:
This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS needed for the current operating mode. In order to provide the appropriate context for consideration of an ALERT classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues.
to 0CAN031801 Page 237 of 240 Attachment 1 - Emergency Action Level Technical Bases Note that this second SAFETY SYSTEM train is from the same SAFETY SYSTEM that has indications of degraded performance; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events.
Indications of degraded performance addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.
VISIBLE DAMAGE addresses damage to a SAFETY SYSTEM train that is not in service/operation and that potentially could cause performance issues. Operators will make a determination of VISIBLE DAMAGE 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. This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.
Escalation of the emergency classification level would be via IC FS1 or AS1.
This EAL is the hot condition equivalent of the cold condition EAL CA6.1.
Reference(s):
: 1. EP FAQ 2016-002
: 2. NEI 99-01 SA9 to 0CAN031801 Page 238 of 240 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases
 
===Background===
NEI 99-01 Revision 6 ICs AA3 and HA5 prescribe declaration of an Alert based on impeded access to rooms or areas (due to either area radiation levels or hazardous gas concentrations) where equipment necessary for normal plant operations, cooldown or shutdown is located.
These areas are intended to be plant operating mode dependent. Specifically the Developers Notes for AA3 and HA5 states:
The site-specific list of plant rooms or areas with entry-related mode applicability identified should specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Do not include rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations). In addition, the list should specify the plant mode(s) during which entry would be required for each room or area.
The list should 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).
Further, as specified in IC HA5:
The list need not include the Control Room if adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas. Such features may include, but are not limited to, capability to draw air from multiple air intakes at different and separate locations, inner and outer atmospheric boundaries, or the capability to acquire and maintain positive pressure within the Control Room envelope.
to 0CAN031801 Page 239 of 240 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases ANO Table 1[2]A-3 and 1[2]H-2 Bases A review of station operating procedures identified the following mode dependent in-plant actions and associated areas that are required for normal plant operation, cooldown or shutdown:
Unit 1 AREA              MODES              PURPOSE                  REFERENCE Core flood tank valves,          OP-1102.010 A-4 Switchgear Room              3, 4 decay heat removal (DHR)          OP-1104.004 Upper North Electrical 3, 4    DHR alignment                    OP-1104.004 Penetration Room Lower South Electrical 3, 4    DHR alignment                    OP-1104.004 Equipment Room Unit 2 AREA              MODES              PURPOSE                  REFERENCE Aux Building 317 Emergency              Shutdown Cooling (SDC) 3, 4                                      OP-2104.004 Core Cooling Rooms                      venting and alignment Aux Building 317 Tendon 3, 4    SDC alignment                    OP-2104.004 Gallery Access Aux Building 335 Charging              Charging low pressure            OP-2102.010 Pumps / Motor Control Center    3, 4    operation, T-Hot injection (MCC) 2B-52                              valves, and SDC alignment        OP-2104.004 SDC alignment and T-Hot          OP-2102.010 Auxiliary Building 354 3, 4    injection valves at MCC 2B-62 Area                                                            OP-2104.004 MCC 2B-62 Close Safety Injection Tank (SIT) valves and SDC / Low Emergency Diesel Generator 3, 4    Temperature Overpressure          OP-2102.010 Corridor (LTOP) valve alignment at MCC 2B-51 Lower South Piping 3, 4    SDC alignment                      OP-2104.004 Penetration Room Aux Building 386                        Close SIT valves at 3, 4                                      OP-2102.010 Containment Hatch                        MCC 2B-61 Mode 3 is included above for DHR- and SDC-related activities because the procedures begin alignment in Mode 3; however, these actions could be delayed until Mode 4, if necessary. In order to ensure adequate guidance to emergency response personnel, the above areas are added to the EAL in order to provide prompt operator guidance for EAL declaration.
to 0CAN031801 Page 240 of 240 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases Both ANO-1 and ANO-2 Control Room ventilation systems have adequate engineered safety/design features in place to preclude a Control Room evacuation due to the release of a hazardous gas. Therefore the Control Room is not included in this assessment or in Tables 1[2]H-2.
Table 1[2]A-3 & 1[2]H-2 Results Table 1[2]A-3 & 1[2]H-2      Safe Operation & Shutdown Rooms/Areas Unit 1 Room/Area                              Mode Applicability A-4 Switchgear Room                                                            3, 4 Upper North Electrical Penetration Room                                        3, 4 Lower South Electrical Equipment Room                                          3, 4 Unit 2 Room/Area                              Mode Applicability Aux Building 317 Emergency Core Cooling Rooms                                3, 4 Aux Building 317 Tendon Gallery Access                                        3, 4 Aux Building 335 Charging Pumps / MCC 2B-52                                  3, 4 Auxiliary Building 354 MCC 2B-62 Area                                        3, 4 Emergency Diesel Generator Corridor                                            3, 4 Lower South Piping Penetration Room                                            3, 4 Aux Building 386 Containment Hatch                                            3, 4
 
Enclosure 4 to 0CAN031801 NEI 99-01, Rev. 6, Deviations and Differences, ANO Units 1 and 2 to 0CAN031801 Page 1 of 120 Table of Contents Section                                                                                                              Page Introduction ------------------------------------------------------------------------------------------------------------ 2 Comparison Matrix Format ---------------------------------------------------------------------------------------- 2 EAL Wording ---------------------------------------------------------------------------------------------------------- 2 EAL Emphasis Techniques ---------------------------------------------------------------------------------------- 2 Global Differences --------------------------------------------------------------------------------------------------- 3 Differences and Deviations ---------------------------------------------------------------------------------------- 5 Category A - Abnormal Rad Levels / Rad Effluent -------------------------------------------------------- 17 Category C - Cold Shutdown / Refueling System Malfunction ----------------------------------------- 38 Category D - Permanently Defueled Station Malfunction ----------------------------------------------- 61 Category E -Independent Spent Fuel Storage Installation (ISFSI) ----------------------------------- 62 Category F - Fission Product Barrier Degradation -------------------------------------------------------- 63 Category H - Hazards and Other Conditions Affecting Plant Safety --------------------------------- 76 Category S - System Malfunction ----------------------------------------------------------------------------- 95 Table 1 - ANO EAL Categories/Subcategories -------------------------------------------------------------- 8 Table 2 - NEI / ANO EAL Identification Cross-Reference ------------------------------------------------- 9 Table 3 - Summary of Deviations ----------------------------------------------------------------------------- 14 to 0CAN031801 Page 2 of 120 Introduction This document provides a line-by-line comparison of the Initiating Conditions (ICs), Mode Applicability, and Emergency Action Levels (EALs) in NEI 99-01, Rev. 6, Final, Development of Emergency Action Levels for Non-Passive Reactors, ADAMS Accession Number ML12326A805, and Arkansas Nuclear One (ANO) Initiating Conditions (ICs), Mode Applicability, and EALs. This document provides a means of assessing ANO differences and deviations from the NRC endorsed guidance given in NEI 99-01. Discussion of ANO EAL bases and lists of source document references are given in the EAL Technical Bases Document. It is, therefore, advisable to reference the EAL Technical Bases Document for background information while using this document.
Comparison Matrix Format The ICs and EALs discussed in this document are grouped according to NEI 99-01 Recognition Categories. Within each Recognition Category, the ICs and EALs are listed in tabular format according to the order in which they are given in NEI 99-01. Generally, each row of the comparison matrix provides the following information:
NEI EAL/IC identifier NEI EAL/IC wording ANO EAL/IC identifier ANO EAL/IC wording Description of any differences or deviations EAL Wording In Section 4.1, NEI recommends the following: The guidance in NEI 99-01 is not intended to be applied to plants as-is; however, developers should attempt to keep their site-specific schemes as close to the generic guidance as possible. The goal is to meet the intent of the generic Initiating Conditions (ICs) and Emergency Action Levels (EALs) within the context of site-specific characteristics - locale, plant design, operating features, terminology, etc. Meeting this goal will result in a shorter and less cumbersome NRC review and approval process, closer alignment with the schemes of other nuclear power plant sites and better positioning to adopt future industry-wide scheme enhancements.
To assist the Emergency Director (ED), the ANO EALs have been written in a clear and concise style (to the extent that the differences from the NEI EAL wording could be reasonably documented and justified). This supports timely and accurate classification in the tense atmosphere of an emergency event. The EAL differences introduced to reduce reading burden comprise almost all of the differences justified in this document.
EAL Emphasis Techniques Due to the width of the table columns and table formatting constraints in this document, line breaks and indentation may differ slightly from the appearance of comparable wording in the source documents. NEI 99-01 is the source document for the NEI EALs; the ANO EAL Technical Bases Document for the ANO EALs.
to 0CAN031801 Page 3 of 120 Development of the ANO IC/EAL wording has attempted to minimize inconsistencies and apply sound human factors principles. As a result, differences occur between NEI and ANO ICs/EALs for these reasons alone. When such difference may infer a technical difference in the associated NEI IC/EAL, the difference is identified and a justification provided.
The print and paragraph formatting conventions summarized below guide presentation of the ANO EALs in accordance with the EAL writing criteria. Space restrictions in the EAL table of this document sometimes override this criteria in cases when following the criteria would introduce undesirable complications in the EAL layout.
Upper case-bold print is used for the logic terms AND, OR, and EITHER.
Bold font is used for certain logic terms, negative terms (not, cannot, etc.), any, all.
Upper case print is reserved for defined terms, acronyms, system abbreviations, logic terms (and, or, etc. when not used as a conjunction), annunciator window engravings.
Three or more items in a list are normally introduced with Any of the following... or All of the following... Items of the list begin with bullets when a priority or sequence is not inferred.
The use of AND/OR logic within the same EAL has been avoided when possible. When such logic cannot be avoided, indentation and separation of subordinate contingent phrases is employed.
Global Differences The differences listed below generally apply throughout the set of EALs and are not repeated in the Justification sections of this document. The global differences do not decrease the effectiveness of the intent of NEI 99-01.
: 1. The NEI phrase Notification of Unusual Event has been changed to Unusual Event or abbreviated "UE" to reduce EAL-user reading burden.
: 2. NEI 99-01 IC Example EALs are implemented in separate plant EALs to improve clarity and readability. For example, NEI lists all IC HU3 Example EALs under one IC. The corresponding ANO EALs appear as unique EALs (e.g., HU3.1 through HU3.4).
: 3. Mode applicability identifiers (numbers/letter) modify the NEI 99-01 mode applicability names as follows: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling, DEF - Defueled. NEI 99-01defines Defueled as follows: Reactor Vessel contains no irradiated fuel (full core off-load during refueling or extended outage).
: 4. NEI 99-01 uses the terms greater than, less than, greater than or equal to, etc., in the wording of some example EALs. For consistency and to reduce EAL-user reading burden, ANO has adopted use of boolean symbols in place of the NEI 99-01 text modifiers within the EAL wording.
to 0CAN031801 Page 4 of 120
: 5. min. is the standard abbreviation for minutes and is used to reduce EAL user reading burden.
: 6. Wherever the generic bracketed PWR term reactor vessel/RCS is provided, ANO uses the term RCS as the site-specific nomenclature.
: 7. IC/EAL identification:
NEI 99-01 defines the thresholds requiring emergency classification (example EALs) and assigns them to ICs which, in turn, are grouped in Recognition Categories.
ANO endeavors to optimize the NEI EAL organization and identification scheme to enhance usability of the plant-specific EAL set. To this end, the ANO IC/EAL scheme includes the following features:
: a. Division of the NEI EAL set into three groups:
o  EALs applicable under all plant operating modes - This group would be reviewed by the EAL-user any time emergency classification is considered.
o  EALs applicable only under hot operating modes - This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby, Startup, or Power Operation mode.
o  EALs applicable only under cold operating modes - This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refueling, or Defueled mode.
The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency.
: b. Within each of the above three groups, EALs are assigned to categories and subcategories. Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. Subcategories are used as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The ANO EAL categories/subcategories and their relationship to NEI Recognition Categories are listed in Table 1.
to 0CAN031801 Page 5 of 120
: c. Unique identification of each EAL - Four characters comprise the EAL identifier as illustrated in Figure 1.
Figure 1 - EAL Identifier EAL Identifier XXX.X Category (A, H, E, S, F, C)        Sequential number within subcategory/classification Emergency classification (G, S, A, U)      Subcategory number (1 if no subcategory)
The first character is a letter associated with the category in which the EAL is located. The second character is a letter associated with the emergency classification level (G for General Emergency, S for Site Area Emergency, A for Alert, and U for Notification of Unusual Event). The third character is a number associated with one or more subcategories within a given category.
Subcategories are sequentially numbered beginning with the number 1. If a category does not have a subcategory, this character is assigned the number
: 1. The fourth character is a number preceded by a period for each EAL within a subcategory. EALs are sequentially numbered within the emergency classification level of a subcategory beginning with the number 1.
The EAL identifier is designed to fulfill the following objectives:
o  Uniqueness - The EAL identifier ensures that there can be no confusion over which EAL is driving the need for emergency classification.
o  Speed in locating the EAL of concern - When the EALs are displayed in a matrix format, knowledge of the EAL identifier alone can lead the EAL-user to the location of the EAL within the classification matrix. The identifier conveys the category, subcategory and classification level. This assists Emergency Response Organization (ERO) responders (who may not be in the same facility as the ED) to find the EAL of concern in a timely manner without the need for a word description of the classification threshold.
o  Possible classification upgrade - The category/subcategory/identifier scheme helps the EAL-user find higher emergency classification EALs that may become active if plant conditions worsen.
Table 2 lists the ANO ICs and EALs that correspond to the NEI ICs/Example EALs when the above EAL/IC organization and identification scheme is implemented.
Differences and Deviations In accordance NRC Regulatory Issue Summary (RIS) 2003-18 Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels Supplements 1 and 2, a difference is an EAL change in which the basis scheme guidance differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the ANO EAL. A deviation is an EAL change in which the basis to 0CAN031801 Page 6 of 120 scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the ANO proposed EAL.
Administrative changes that do not actually change the textual content are neither differences nor deviations. Likewise, any format change that does not alter the wording of the IC or EAL is considered neither a difference nor a deviation.
The following are examples of differences:
Choosing the applicable EAL based upon plant type (i.e., BWR vs. PWR).
Using a numbering scheme other than that provided in NEI 99-01 that does not change the intent of the overall scheme.
Where the NEI 99-01 guidance specifically provides an option to not include an EAL, if equipment for the EAL does not exist at ANO (e.g., automatic real-time dose assessment capability).
Pulling information from the bases section up to the actual EAL that does not change the intent of the EAL.
Choosing to state ALL Operating Modes are applicable instead of stating N/A, or listing each mode individually under the Abnormal Rad Level/Radiological Effluent and Hazard and Other Conditions Affecting Plant Safety sections.
Using synonymous wording (e.g., greater than or equal to vs. at or above, less than or equal vs. at or below, greater than or less than vs. above or below, etc.)
Adding ANO equipment/instrument identification and/or noun names to EALs.
Combining like ICs that are exactly the same, but have different operating modes as long as the intent of each IC is maintained and the overall progression of the EAL scheme is not affected.
Any change to the IC and/or EAL, and/or basis wording, as stated in NEI 99-01, that does not alter the intent of the IC and/or EAL, i.e., the IC and/or EAL continues to:
o  Classify at the correct classification level.
o  Logically integrate with other EALs in the EAL scheme.
o  Ensure that the resulting EAL scheme is complete (i.e., classifies all potential emergency conditions).
The following are examples of deviations:
Use of altered mode applicability.
Altering key words or time limits.
to 0CAN031801 Page 7 of 120 Changing words of physical reference (protected area, safety-related equipment, etc.).
Eliminating an IC. This includes the removal of an IC from the Fission Product Barrier Degradation category as this impacts the logic of Fission Product Barrier ICs.
Changing a Fission Product Barrier from a Loss to a Potential Loss or vice-versa.
Not using NEI 99-01definitions as the intent is for all NEI 99-01 users to have a standard set of defined terms as defined in NEI 99-01. Differences due to plant types are permissible (BWR or PWR). Verbatim compliance to the wording in NEI 99-01 is not necessary as long as the intent of the defined word is maintained. Use of the wording provided in NEI 99-01 is encouraged since the intent is for all users to have a standard set of defined terms as defined in NEI 99-01.
Any change to the IC and/or EAL, and/or basis wording as stated in NEI 99-01 that does alter the intent of the IC and/or EAL, i.e., the IC and/or EAL:
o  Does not classify at the classification level consistent with NEI 99-01.
o  Is not logically integrated with other EALs in the EAL scheme.
o  Results in an incomplete EAL scheme (i.e., does not classify all potential emergency conditions).
The Difference/Deviation Justification columns in the remaining sections of this document identify each difference between the NEI 99-01 IC/EAL wording and the ANO IC/EAL wording.
An explanation that justifies the reason for each difference is then provided. If the difference is determined to be a deviation, a statement is made to that affect and explanation is given that states why classification may be different from the NEI 99-01 IC/EAL and the reason for its acceptability. In all cases, however, the differences and deviations do not decrease the effectiveness of the intent of NEI 99-01. A summary list of ANO EAL deviations from NEI 99-01 is given in Table 3.
to 0CAN031801 Page 8 of 120 Table 1 - ANO EAL Categories/Subcategories ANO EALs                                                          NEI Category                                        Subcategory                      Recognition Category Group: Any Operating Mode:
1 - Radiological Effluent A - Abnormal Rad Levels/Rad Effluent          2 - Irradiated Fuel Event                    Abnormal Rad Levels/Radiological Effluent 3 - Area Radiation Levels                    ICs/EALs H - Hazards and Other Conditions Affecting    1 - Security                                Hazards and Other Conditions Affecting Plant Safety                              2 - Seismic Event                            Plant Safety ICs/EALs 3 - Natural or Technological Hazard 4 - Fire 5 - Hazardous Gas 6 - Control Room Evacuation 7 - Emergency Director Judgment E - ISFSI                                    1 - Confinement Boundary                    ISFSI ICs/EALs Group: Hot Conditions:
1 - Loss of Vital AC Power 2 - Loss of Vital DC Power 3 - Loss of Control Room Indications 4 - RCS Activity S - System Malfunction                        5 - RCS Leakage                              System Malfunction ICs/EALs 6 - RPS Failure 7 - Loss of Communications 8 - Containment Failure 9 - Hazardous Event Affecting Safety Systems F - Fission Product Barrier                  None                                        Fission Product Barrier ICs/EALs Group: Cold Conditions:
1 - RCS Level 2 - Loss of Vital AC Power C - Cold Shutdown/Refueling System            3 - RCS Temperature                          Cold Shutdown./ Refueling System Malfunction                              4 - Loss of Vital DC Power                  Malfunction ICs/EALs 5 - Loss of Communications 6 - Hazardous Event Affecting Safety Systems to 0CAN031801 Page 9 of 120 Table 2 - NEI / ANO EAL Identification Cross-Reference NEI                                                          ANO Example IC                                            Category and Subcategory            EAL EAL AU1        1    A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AU1.1 AU1        2    A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AU1.1 AU1        3    A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AU1.2 AU2        1    A - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event AU2.1 AA1        1    A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AA1.1 AA1        2    A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AA1.2 AA1        3    A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AA1.3 AA1        4    A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AA1.4 AA2        1    A - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event AA2.1 AA2        2    A - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event AA2.2 AA2        3    A - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event AA2.3 AA3        1    A - Abnormal Rad Levels / Rad Effluent, 3 - Area Radiation Levels AA3.1 AA3        2    A - Abnormal Rad Levels / Rad Effluent, 3 - Area Radiation Levels AA3.2 AS1        1    A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AS1.1 AS1        2    A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AS1.2 AS1        3    A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AS1.3 to 0CAN031801 Page 10 of 120 NEI                                                            ANO Example IC                                              Category and Subcategory                                  EAL EAL AS2          1    A - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event                      AS2.1 AG1            1    A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent                      AG1.1 AG1            2    A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent                      AG1.2 AG1            3    A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent                      AG1.3 AG2            1    A - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event                      AG2.1 CU1            1    C - Cold SD/ Refueling System Malfunction, 1 - RCS Level                                CU1.1 CU1            2    C - Cold SD/ Refueling System Malfunction, 1 - RCS Level                                CU1.2 CU2            1    C - Cold SD/ Refueling System Malfunction, 2 - Loss of Vital AC Power                  CU2.1 CU3            1    C - Cold SD/ Refueling System Malfunction, 3 - RCS Temperature                          CU3.1 CU3            2    C - Cold SD/ Refueling System Malfunction, 3 - RCS Temperature                          CU3.2 CU4            1    C - Cold SD/ Refueling System Malfunction, 4 - Loss of Vital DC Power                  CU4.1 CU5        1, 2, 3 C - Cold SD/ Refueling System Malfunction, 5 - Loss of Communications                  CU5.1 CA1          1    C - Cold SD/ Refueling System Malfunction, 1 - RCS Level                                CA1.1 CA1          2    C - Cold SD/ Refueling System Malfunction, 1 - RCS Level                                CA1.2 CA2          1    C - Cold SD/ Refueling System Malfunction, 1 - Loss of Vital AC Power                  CA2.1 CA3        1, 2  C - Cold SD/ Refueling System Malfunction, 3 - RCS Temperature                          CA3.1 CA6          1    C - Cold SD/ Refueling System Malfunction, 6 - Hazardous Event Affecting Safety Systems HA4.1 CS1          1    C - Cold SD/ Refueling System Malfunction, 1 - RCS Level                                CS1.1 to 0CAN031801 Page 11 of 120 NEI                                                          ANO Example IC                                                Category and Subcategory                                    EAL EAL CS1          2                                                N/A                                              N/A CS1          3    C - Cold SD/ Refueling System Malfunction, 1 - RCS Level                                    CS1.2 CG1            1    C - Cold SD/ Refueling System Malfunction, 1 - RCS Level                                    CG1.1 CG1            2    C - Cold SD/ Refueling System Malfunction, 1 - RCS Level                                    CG1.2 E-HU1          1    E - ISFSI                                                                                    EU1.1 FA1          1    F - Fission Product Barrier Degradation                                                      FA1.1 FS1          1    F - Fission Product Barrier Degradation                                                      FS1.1 FG1          1    F - Fission Product Barrier Degradation                                                      FG1.1 HU1        1, 2, 3 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security                        HU1.1 HU2            1    H - Hazards and Other Conditions Affecting Plant Safety, 2 - Seismic Event                  HU2.1 HU3            1    H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.1 HU3            2    H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.2 HU3            3    H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.3 HU3            4    H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.4 HU3            5    H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard  N/A HU4            1    H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion              HU4.1 HU4            2    H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion              HU4.2 HU4            3    H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion              HU4.3 to 0CAN031801 Page 12 of 120 NEI                                                          ANO Example IC                                                Category and Subcategory                              EAL EAL HU4            4    H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion      HU4.4 HU7            1    H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment                HU7.1 HA1        1, 2  H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security                HA1.1 HA5          1    H - Hazards and Other Conditions Affecting Plant Safety, 5 - Hazardous Gases        HA5.1 HA6          1    H - Hazards and Other Conditions Affecting Plant Safety, 6 - Control Room Evacuation HA6.1 HA7          1    H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment                HA7.1 HS1          1    H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security                HS1.1 HS6          1    H - Hazards and Other Conditions Affecting Plant Safety, 6 - Control Room Evacuation HS6.1 HS7          1    H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment                HS7.1 HG1            1    N/A                                                                                  N/A HG7            2    H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment                HG7.1 SU1          1    S - System Malfunction, 1 - Loss of Emergency AC Power                              SU1.1 SU2          1    S - System Malfunction, 3 - Loss of Control Room Indications                        SU3.1 SU3          1    S - System Malfunction, 4 - RCS Activity                                            SU4.1 SU3          2    S - System Malfunction, 4 - RCS Activity                                            SU4.2 SU4        1, 2, 3 S - System Malfunction, 5 - RCS Leakage                                              SU5.1 SU5          1    S - System Malfunction, 6 - RPS Failure                                              SU6.1 SU5          2    S - System Malfunction, 6 - RPS Failure                                              SU6.2 to 0CAN031801 Page 13 of 120 NEI                                                          ANO Example IC                                                Category and Subcategory      EAL EAL SU6        1, 2, 3 S - System Malfunction, 7 -Loss of Communications            SU7.1 SU7        1, 2  S - System Malfunction, 8 -Containment Failure              SU8.1 SA1          1    S - System Malfunction, 1 - Loss of Emergency AC Power      SA1.1 SA2          1    S - System Malfunction, 3 - Loss of Control Room Indications SA3.1 SA5          1    S - System Malfunction, 6 - RPS Failure                      SA6.1 SA9          1    S - Hazardous Event Affecting Safety Systems                SA9.1 SS1          1    S - System Malfunction, 1 - Loss of Emergency AC Power      SS1.1 SS5          1    S - System Malfunction, 6 - RPS Failure                      SS6.1 SS8          1    S - System Malfunction, 2 - Loss of Vital DC Power          SS2.1 SG1            1    S - System Malfunction, 1 - Loss of Emergency AC Power      SG1.1 SG8            2    S - System Malfunction, 1 - Loss of Emergency AC Power      SG1.2 to 0CAN031801 Page 14 of 120 Table 3 - Summary of Deviations NEI        ANO Description IC      Example EAL EAL HG1          1      N/A IC HG1 and associated example EAL not implemented in the ANO scheme.
There are several other ICs that are redundant with this IC, and are better suited to ensure timely and effective emergency declarations. In addition, the development of new spent fuel pool level EALs, as a result of NRC Order EA-12-051, clarified the intended emergency classification level for spent fuel pool level events. This deviation is justified because:
: 1. Hostile Action in the Protected Area is bounded by ICs HS1 and HS7. Hostile Action resulting in a loss of physical control is bound by EAL HG7, as well as any event that may lead to radiological releases to the public in excess of Environmental Protection Agency (EPA)
Protective Action Guides (PAGs).
: a. If, for whatever reason, the Control Room must be evacuated, and control of safety functions (e.g., reactivity control, core cooling, and RCS heat removal) cannot be reestablished, then IC HS6 would apply, as well as IC HS7 if desired by the EAL decision-maker.
: b. Also, as stated above, any event (including Hostile Action) that could reasonably be expected to have a release exceeding EPA PAGs would be bound by IC HG7.
: c. From a Hostile Action perspective, ICs HS1, HS7 and HG7 are appropriate, and therefore, make this part of HG1 redundant and unnecessary.
: d. From a loss of physical control perspective, ICs HS6, HS7 and HG7 are appropriate, and therefore, make this part of HG1 redundant and unnecessary.
: 2. Any event which causes a loss of spent fuel pool level will be bounded by ICs AA2, AS2 and AG2, regardless of whether it was based upon a Hostile Action or not, thus making this part of HG1 redundant and unnecessary.
: a. An event that leads to a radiological release will be bounded by ICs AU1, AA1, AS1 and AG1. Events that lead to radiological releases in excess of EPA PAGs will be bounded by EALs AG1 and HG7, thus making this part of HG1 redundant and unnecessary.
ICs AA2, AS2, AG2, AS1, AG1, HS1, HS6, HS7 and HG7 have been implemented consistent with NEI 99-01, Revision 6, and thus HG1 is adequately bounded as described above.
Therefore, this is an acceptable deviation from the generic NEI 99-01, Revision 6, guidance and is consistent with NRC approved EP FAQ 2015-013.
to 0CAN031801 Page 15 of 120 NEI        ANO Description IC      Example EAL  EAL HS6          1      HS6.1 Deleted defueled mode applicability. Control of the cited safety functions are not critical for a defueled reactor as there is no energy source in the reactor vessel or RCS.
The Mode applicability for the reactivity control safety function has been limited to Modes 1, 2, and 3 (hot operating conditions). In the cold operating modes adequate shutdown margin exists under all conditions.
Therefore, this is an acceptable deviation from the generic NEI 99-01, Revision 6, guidance and is consistent with NRC approved EP FAQ 2015-014.
CA6          1      CA6.1 The proposed ANO CA6.1 and SA9.1 wording is intended to ensure that an Alert should be declared SA9          1      SA9.1 only when actual or potential performance issues with SAFETY SYSTEMS have occurred as a result of a hazardous event. The occurrence of a hazardous event will result in an Unusual Event classification at a minimum. In order to warrant escalation to the Alert classification, the hazardous event should cause indications of degraded performance to one train of a SAFETY SYSTEM with either indications of degraded performance on the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second SAFETY SYSTEM train, such that the operability or reliability of the second train is a concern. In addition, escalation to the Alert classification should not occur if the damage from the hazardous event is limited to a SAFETY SYSTEM that was inoperable, or out of service, prior to the event occurring. As such, the proposed EALs will reduce the potential of declaring an Alert when events are in progress that do not involve an actual or potential substantial degradation of the level of safety of the plant, i.e., does not cause significant concern with shutting down or cooling down the plant.
EALs CA6.1 and SA9.1 do not directly escalate to a Site Area Emergency or a General Emergency due to a hazardous event. The Fission Product Barrier and/or Abnormal Radiation Levels/Radiological Effluent recognition categories would provide an escalation path to a Site Area Emergency or a General Emergency.
The EALs and the Basis sections have been revised to ensure potential escalations from an Unusual Event to an Alert, due to a hazardous event, is appropriate as the concern with these EALs is: (1) a hazardous event has occurred, (2) one SAFETY SYSTEM train is having performance issues as a result of the hazardous event, and (3) either the second SAFETY SYSTEM train is having performance issues or the VISIBLE DAMAGE is enough to be concerned that the second SAFETY SYSTEM train may have operability or reliability issues.
The definition for VISIBLE DAMAGE has been revised to reflect the fact that the EALs are based upon SAFETY SYSTEM trains rather than individual components or structures.
to 0CAN031801 Page 16 of 120 NEI        ANO Description IC      Example EAL  EAL CA6          1      CA6.1 (continued)
SA9          1      SA9.1 Note 10 has been added to CA6.1 and SA9.1 as it meets the intent of the EALs, is consistent with other EALs (e.g., EAL HA5.1 which was previously endorsed by the NRC), and ensures that declared emergencies are based upon unplanned events with the potential to pose a radiological risk to the public.
Note 11 has been added to CA6.1 and SA9.1 to help reinforce and succinctly capture the more detailed information from the revised basis section related to when conditions would require the declaration of an Alert.
CA6.1 and SA9.1 are consistent with NRC FAQ 2016-002 addressing degraded performance or visible damage to more than one safety system train caused by the specified events.
Based on the above information, this revised wording is an acceptable deviation from the generic NEI 99-01, Revision 6, guidance and is consistent with NRC-approved EP FAQ 2016-002.
to 0CAN031801 Page 17 of 120 Category A Abnormal Rad Levels / Radiological Effluent NEI      NEI IC Wording and Mode      ANO      ANO IC Wording and Mode Difference/Deviation Justification IC#              Applicability        IC#(s)            Applicability Release of gaseous or liquid radioactivity greater than            Release of gaseous or liquid 2 times the (site-specific            radioactivity greater than 2 times effluent release controlling          the ODCM limits for 60 minutes    The ANO ODCM is the site-specific effluent release AU1                                    AU1 document) limits for 60 minutes        or longer                          controlling document.
or longer.                            MODE: All MODE: All NEI Ex.                                  ANO NEI Example EAL Wording                    ANO EAL Wording                        Difference/Deviation Justification EAL #                                  EAL #
Reading on ANY effluent                                                  Example EALs #1 and #2 have been combined into a radiation monitor greater than                                          single EAL to simplify presentation.
2 times the (site-specific                                              The NEI phrase effluent radiation monitor greater effluent release controlling                                            than 2 times the (site-specific effluent release document) limits for                                                    controlling document) and "effluent radiation monitor 1      60 minutes or longer:                                                    greater than 2 times the alarm setpoint established by (site-specific monitor list and                                          a current radioactivity discharge permit " have been Reading on any Table 1[2]A-1 threshold values                                                          replaced with any Table 1[2]A-1 effluent radiation effluent radiation monitor corresponding to 2 times the    AU1.1                                    monitor > column "UE".
                                                > column "UE" for  60 min.
controlling document limits)                                              UE thresholds for all ANO continuously monitored (Notes 1, 2, 3) gaseous and liquid release pathways are listed in Reading on ANY effluent                                                  Tables 1[2]A-1 to consolidate the information in a radiation monitor greater than                                            single location and, thereby, simplify identification of 2 times the alarm setpoint                                                the thresholds by the EAL user. The values shown in 2
established by a current                                                  Table 1[2]A-1 column UE, consistent with the NEI radioactivity discharge permit                                            bases, represent two times the ODCM release limits for 60 minutes or longer.                                                for gaseous and liquid releases.
to 0CAN031801 Page 18 of 120 NEI Ex.                                  ANO NEI Example EAL Wording                      ANO EAL Wording                          Difference/Deviation Justification EAL #                                    EAL #
Sample analysis for a gaseous or liquid release indicates a          Sample analysis for a gaseous concentration or release rate          or liquid release indicates a The ANO ODCM is the site-specific effluent release 3    greater than 2 times the (site-  AU1.2 concentration or release rate controlling document.
specific effluent release              > 2 x ODCM limits for  60 min.
controlling document) limits for      (Notes 1, 2) 60 minutes or longer.
Note 1: The Emergency                The classification timeliness note has been Director should declare  standardized across the ANO EAL scheme by the event promptly        referencing the "time limit" specified within the EAL upon determining that    wording.
the time limit has been  Added The Emergency Director is not allowed an The Emergency Director exceeded, or will likely  additional 15 minutes to declare after the time limit is should declare the Unusual be exceeded. The          exceeded. To reinforce the concept that the EAL Event promptly upon Emergency Director is    timing component runs concurrent with the determining that 60 minutes not allowed an            classification timeliness clock.
has been exceeded, or will additional 15 minutes to likely be exceeded.
declare after the time If an ongoing release is                        limit is exceeded.
detected and the release Note 2: If an ongoing release is    The classification timeliness note has been start time is unknown, detected and the          standardized across the ANO EAL scheme by Notes    assume that the release        N/A release start time is    referencing the "time limit" specified within the EAL duration has exceeded unknown, assume that      wording.
60 minutes.
the release duration If the effluent flow past an                    has exceeded the effluent monitor is known to                    specified time limit.
have stopped due to actions Note 3: If the effluent flow past    None to isolate the release path, an effluent monitor is then the effluent monitor known to have stopped reading is no longer valid for due to actions to isolate classification purposes.
the release path, then the effluent monitor reading is no longer VALID for classification purposes.
to 0CAN031801 Page 19 of 120 Table 1A-1        Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point      Monitor          GE              SAE              Alert              UE RX-9820 Containment Purge                4.15E+01 Ci/cc  4.15E+00 &#xb5;Ci/cc  4.15E-01 &#xb5;Ci/cc  1.21E-03 &#xb5;Ci/cc (SPING 1)
RX-9825 Radwaste Area                    2.67E+01 Ci/cc  2.67E+00 &#xb5;Ci/cc  2.67E-01 &#xb5;Ci/cc  4.94E-04 &#xb5;Ci/cc Gaseous (SPING 2)
RX-9830 Fuel Handling Area              6.20E+02 Ci/cc  6.20E+01 &#xb5;Ci/cc  6.20E+00 &#xb5;Ci/cc  5.44E-04 &#xb5;Ci/cc (SPING 3)
Emergency            RX-9835 6.55E+02 Ci/cc  6.55E+01 &#xb5;Ci/cc  6.55E+00 &#xb5;Ci/cc  1.21E-02 &#xb5;Ci/cc Penetration Room    (SPING 4)
Liquid Liquid Radwaste      RE-4642          ----              ----              ----        2.46E+05 cpm to 0CAN031801 Page 20 of 120 Table 2A-1        Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)
Release Point      Monitor          GE              SAE              Alert              UE 2RX-9820 Containment Purge                1.88E+01 Ci/cc  1.88E+00 &#xb5;Ci/cc  1.88E-01 &#xb5;Ci/cc  5.48E-04 &#xb5;Ci/cc (SPING 5) 2RX-9825 Radwaste Area                    2.35E+01 Ci/cc  2.35E+00 &#xb5;Ci/cc  2.35E-01 &#xb5;Ci/cc  4.35E-04 &#xb5;Ci/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area              6.86E+02 Ci/cc  6.86E+01 &#xb5;Ci/cc  6.86E+00 &#xb5;Ci/cc  6.04E-04 &#xb5;Ci/cc (SPING 7)
Emergency            2RX-9835 5.88E+02 Ci/cc  5.88E+01 &#xb5;Ci/cc  5.88E+00 &#xb5;Ci/cc  1.09E-02 &#xb5;Ci/cc Penetration Room    (SPING 8)
BMS Liquid 2RE-2330          ----              ----              ----        2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423          ----              ----              ----        2.45E+05 cpm Waste Discharge to 0CAN031801 Page 21 of 120 NEI      NEI IC Wording and Mode        ANO ANO IC Wording and Mode Applicability            Difference/Deviation Justification IC#              Applicability        IC#(s)
UNPLANNED loss of water                UNPLANNED loss of water level above AU2    level above irradiated fuel.      AU2  irradiated fuel.                          None MODE: All                              MODE: All NEI Ex.                                  ANO NEI Example EAL Wording                          ANO EAL Wording                      Difference/Deviation Justification EAL #                                    EAL #
UNPLANNED water level drop in the REFUELING PATHWAY as indicated by low water level alarm, visual observation,
: a. UNPLANNED water level              or BWST[RWT] level drop due to drop in the REFUELING              makeup demands PATHWAY as indicated by                AND ANY of the following:
UNPLANNED rise in corresponding area (site-specific level              radiation levels as indicated by any of indications).                      the following radiation monitors:          Site-specific level indications incorporated.
AND 1                                      AU2.1      Unit 1                                Site-specific area radiation monitors
: b. UNPLANNED rise in area                                                        incorporated.
o RE-8009 Spent Fuel Area radiation levels as indicated by ANY of the                o RE-8017 Fuel Handling Area following radiation                    Unit 2 monitors.                              o 2RE-8914 Spent Fuel Area (site-specific list of area            o 2RE-8915 Spent Fuel Area radiation monitors) o 2RE-8916 Spent Fuel Area o 2RE-8912 Containment Incore Instrumentation to 0CAN031801 Page 22 of 120 NEI                                        ANO NEI IC Wording                                  ANO IC Wording                      Difference/Deviation Justification IC#                                      IC#(s)
Release of gaseous or liquid radioactivity resulting in offsite        Release of gaseous or liquid radioactivity dose greater than 10 mrem                resulting in offsite dose greater than AA1    TEDE or 50 mrem thyroid            AA1  10 mrem TEDE or 50 mrem thyroid CDE.      None CDE.                                      MODE: All MODE: All NEI Ex.                                    ANO NEI Example EAL Wording                    ANO EAL Wording                          Difference/Deviation Justification EAL #                                      EAL #
The ANO radiation monitors that detect Reading on ANY of the                                                                radioactivity effluent release to the following radiation monitors                                                        environment are listed in Table 1[2]A-1. UE, greater than the reading                  Reading on any Table 1[2]A-1 effluent    Alert, SAE and GE thresholds for all ANO 1    shown for 15 minutes or            AA1.1  radiation monitor > column "ALERT" for    continuously monitored gaseous and liquid longer:                                    15 min. (Notes 1, 2, 3, 4)              release pathways are listed in Table 1[2]A-1 (site-specific monitor list and                                                      to consolidate the information in a single threshold values)                                                                    location and, thereby, simplify identification of the thresholds by the EAL-user.
Dose assessment using actual meteorology indicates doses                Dose assessment using actual greater than 10 mrem TEDE or              meteorology indicates doses > 10 mrem    The site boundary is the site-specific receptor 2                                        AA1.2 50 mrem thyroid CDE at or                  TEDE or 50 mrem thyroid CDE at or        point.
beyond (site-specific dose                beyond the SITE BOUNDARY (Note 4) receptor point).
Analysis of a liquid effluent sample indicates a Analysis of a liquid effluent sample concentration or release rate indicates a concentration or release rate that would result in doses that would result in doses > 10 mrem      The site boundary is the site-specific receptor 3    greater than 10 mrem TEDE or      AA1.3 TEDE or 50 mrem thyroid CDE at or        point.
50 mrem thyroid CDE at or beyond the SITE BOUNDARY for beyond (site-specific dose 60 min. of exposure (Notes 1, 2) receptor point) for one hour of exposure.
to 0CAN031801 Page 23 of 120 NEI Ex.                                ANO NEI Example EAL Wording              ANO EAL Wording                          Difference/Deviation Justification EAL #                                  EAL #
Field survey results indicate EITHER of the following at or        Field survey results indicate EITHER of beyond (site-specific dose            the following at or beyond the SITE receptor point):                      BOUNDARY:
Closed window dose rates              Closed window dose rates greater than 10 mR/hr                  > 10 mR/hr expected to continue for  The site boundary is the site-specific receptor 4                                    AA1.4      60 min.
expected to continue for                                                      point.
60 minutes or longer.                  Analyses of field survey samples Analyses of field survey                indicate thyroid CDE > 50 mrem for samples indicate thyroid                60 min. of inhalation.
CDE greater than 50 mrem            (Notes 1, 2) for one hour of inhalation.
Note 1: The Emergency Director should    The classification timeliness note has been declare the event promptly upon standardized across the ANO EAL scheme by determining that the time limit referencing the "time limit" specified within the The Emergency Director                        has been exceeded, or will      EAL wording.
should declare the Alert                      likely be exceeded. The        Added The Emergency Director is not promptly upon determining                    Emergency Director is not      allowed an additional 15 minutes to declare that the applicable time has                  allowed an additional          after the time limit is exceeded. To reinforce been exceeded, or will likely                15 minutes to declare after the the concept that the EAL timing component be exceeded.                                  time limit is exceeded.
Notes                                  N/A                                            runs concurrent with the classification If an ongoing release is                                                      timeliness clock.
detected and the release start time is unknown, assume that the release            Note 2: If an ongoing release is          The classification timeliness note has been duration has exceeded                        detected and the release start  standardized across the ANO EAL scheme by 15 minutes.                                  time is unknown, assume that    referencing the "time limit" specified within the the release duration has        EAL wording.
exceeded the specified time limit.
to 0CAN031801 Page 24 of 120 NEI Ex.                                  ANO NEI Example EAL Wording                ANO EAL Wording                            Difference/Deviation Justification EAL #                                    EAL #
If the effluent flow past an        Note 3: If the effluent flow past an      None effluent monitor is known to                effluent monitor is known to have stopped due to actions                  have stopped due to actions to to isolate the release path,                isolate the release path, then then the effluent monitor                    the effluent monitor reading is reading is no longer valid for              no longer valid for classification classification purposes.                    purposes.
Notes The pre-calculated effluent    N/A  Note 4 The pre-calculated effluent        Incorporated site-specific EAL numbers (cont.)
monitor values presented in                  monitor values presented in        associated with generic EAL#1.
EAL #1 should be used for                    EALs AA1.1, AS1.1 and AG1.1 emergency classification                    should be used for emergency assessments until the results                classification assessments until from a dose assessment                      the results from a dose using actual meteorology are                assessment using actual available.                                  meteorology are available.
to 0CAN031801 Page 25 of 120 NEI                                        ANO NEI IC Wording                                ANO IC Wording                    Difference/Deviation Justification IC#                                        IC#(s)
Significant lowering of water Significant lowering of water level level above, or damage to, AA2                                        AA2  above, or damage to, irradiated fuel. None irradiated fuel.
MODE: All MODE: All NEI Ex.                                      ANO NEI Example EAL Wording                            ANO EAL Wording                    Difference/Deviation Justification EAL #                                      EAL #
Added the defined term IMMINENT.
Determination of irradiated fuel uncovery in the Uncovery of irradiated fuel in              IMMINENT uncovery of irradiated fuel  refueling pathway will always be an anticipatory 1                                        AA2.1 the REFUELING PATHWAY.                      in the REFUELING PATHWAY.            determination as no direct indication is available to determine when the irradiated fuel has become uncovered.
Damage to irradiated fuel resulting in a release of                                                        The EAL is clarified to refer to mechanical radioactivity from the fuel as            Damage to irradiated fuel resulting in damage to irradiated fuel in alignment with the indicated by ANY of the                  a release of radioactivity basis description.
2      following radiation monitors:      AA2.2      AND Site-specific list of radiation monitors (site-specific listing of radiation        High alarm on any Table 1[2]A-2        incorporated.
monitors, and the associated              radiation monitor.
readings, setpoints and/or                                                        Radiation monitor high alarms specified.
alarms)
For ANO, Level 2, which corresponds to ~10 ft.
Lowering of spent fuel pool              Lowering of spent fuel pool level to  above the top of the fuel racks in the SFP, is an 3      level to (site-specific Level 2    AA2.3  387.0 ft. [389.5 ft.] (Alarm 2) on    indicated level of:
value). [See Developer Notes]            LIT-2020-3(4) [2LIT-2020-1(2)]        Unit 1: 387.0 ft. (Alarm 2) on LIT-2020-3(4)
Unit 2: 389.5 ft. (Alarm 2) on 2LIT-2020-1(2) to 0CAN031801 Page 26 of 120 Table 1A-2    Unit 1 Fuel Damage Radiation Monitors RE-8009 Spent Fuel Area RE-8017 Fuel Handling RE-8060 Containment High Range Radiation Monitors RE-8061 Containment High Range Radiation Monitors RX-9820 (SPING 1) Containment Purge RX-9825 (SPING 2) Radwaste Area RX-9830 (SPING 3) Fuel Handling Area Table 2A-2    Unit 2 Fuel Damage Radiation Monitors 2RE-8905 Containment Equipment Hatch Area 2RE-8909 Containment Personnel Access Area 2RE-8912 Containment Incore Inst.
2RE-8914 Spent Fuel Area 2RE-8915 Spent Fuel Area 2RE-8916 Spent Fuel Area 2RE-8925-1 Containment High Range Radiation Monitors 2RE-8925-2 Containment High Range Radiation Monitors 2RX-9820 (SPING 5) Containment Purge 2RX-9825 (SPING 6) Radwaste Area 2RX-9830 (SPING 7) Fuel Handling Area to 0CAN031801 Page 27 of 120 NEI                                  ANO NEI IC Wording                          ANO IC Wording                  Difference/Deviation Justification IC#                                IC#(s)
AA3    Radiation levels that impede  AA3  Radiation levels that IMPEDE access to  EAL AA3.2 mode applicability has been access to equipment                equipment necessary for normal plant    limited to the applicable mode of necessary for normal plant          operations, cooldown or shutdown.      Table 1[2]A-3 (Modes 3 and 4).
operations, cooldown or            MODE: All (AA3.2 Modes 3 and 4 only) shutdown MODE: All NEI Ex.                              ANO NEI Example EAL Wording                      ANO EAL Wording                  Difference/Deviation Justification EAL #                                EAL #
Dose rate greater than                                                      No other site-specific areas requiring 15 mR/hr in ANY of the                                                      continuous occupancy exist at ANO.
following areas:                                                            The Control Room envelope (Unit 1 and Control Room                                                          Unit 2) is monitored for excessive radiation Central Alarm Station        Dose rate > 15 mR/hr in EITHER of the    by five detectors. These radiation following areas:                        detectors are RE-8001, 2RE-8001A, 1          (other site-specific  AA3.1                                          2RE-8001B, 2RE-8750-1A, and areas/rooms)                      Control Room 2RE-8750-1B. There are no permanently Central Alarm Station (by survey)  installed area radiation monitors in CAS that may be used to assess this EAL threshold. Therefore, this threshold is evaluated using local radiation survey for this area.
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An UNPLANNED event                                                                  The site-specific list of plant rooms or results in radiation levels that                                                    areas with entry-related mode applicability prohibit or impede access to                                                        are tabularized in Tables 1[2]A-3.
any of the following plant                                                          The bulleted bases item the action for rooms or areas:                                                                      which room/area entry is required is of an (site-specific list of plant                                                        administrative or record keeping nature rooms or areas with entry-            An UNPLANNED event results in radiation      (e.g., normal rounds or routine 2      related mode applicability      AA3.2 levels that prohibit or IMPEDE access to      inspections) was removed from the list of identified)                            any Table 1[2]A-3 room or area. (Note 5)      exceptions to classification in the basis information. These actions are a consideration when the site-specific list was developed. Rooms requiring entry for these types of actions are already excluded from the list when it was developed.
If the equipment in the listed Note 5    If the equipment in the listed room room or area was already or area was already inoperable or inoperable or out-of-service Note                                      N/A            out-of-service before the event    None before the event occurred, occurred, then no emergency then no emergency classification is warranted.
classification is warranted.
to 0CAN031801 Page 29 of 120 Table 1A-3      Unit 1 Safe Operation & Shutdown Rooms/Areas Room/Area                        Mode A-4 Switchgear Room                                      3, 4 Upper North Electrical Penetration Room                  3, 4 Lower South Electrical Equipment Room                    3, 4 Table 2A-3      Unit 2 Safe Operation & Shutdown Rooms/Areas Room/Area                        Mode Aux Building 317 Emergency Core Cooling Rooms          3, 4 Aux Building 317 Tendon Gallery Access                  3, 4 Aux Building 335 Charging Pumps / MCC 2B-52            3, 4 Aux Building 354 MCC 2B-62 Area                        3, 4 Emergency Diesel Generator Corridor                      3, 4 Lower South Piping Penetration Room                      3, 4 Aux Building 386 Containment Hatch                      3, 4 to 0CAN031801 Page 30 of 120 NEI                                        ANO NEI IC Wording                                  ANO IC Wording                        Difference/Deviation Justification IC#                                      IC#(s)
Release of gaseous radioactivity resulting in offsite        Release of gaseous radioactivity resulting in dose greater than 100 mrem                offsite dose greater than 100 mrem TEDE AS1    TEDE or 500 mrem thyroid            AS1  or 500 mrem thyroid CDE.                      None CDE.                                      MODE: All MODE: All MODE: All NEI Ex.                                    ANO NEI Example EAL Wording                              ANO EAL Wording                        Difference/Deviation Justification EAL #                                      EAL #
The ANO radiation monitors that detect Reading on ANY of the                                                                  radioactivity effluent release to the following radiation monitors                                                            environment are listed in Tables 1[2]A-1.
greater than the reading                                                                UE, Alert, SAE and GE thresholds for all Reading on any Table 1[2]A-1 effluent shown for 15 minutes or                                                                ANO continuously monitored gaseous and 1                                        AS1.1  radiation monitor > column "SAE" for longer:                                                                                liquid release pathways are listed in 15 min. (Notes 1, 2, 3, 4)
Table 1[2]A-1 to consolidate the (site-specific monitor list and                                                        information in a single location and, threshold values)                                                                      thereby, simplify identification of the thresholds by the EAL-user.
Dose assessment using actual meteorology indicates doses              Dose assessment using actual meteorology greater than 100 mrem TEDE                indicates doses > 100 mrem TEDE or            The site boundary is the site-specific 2                                        AS1.2 or 500 mrem thyroid CDE at or            500 mrem thyroid CDE at or beyond the        receptor point.
beyond (site-specific dose                SITE BOUNDARY. (Note 4) receptor point) to 0CAN031801 Page 31 of 120 NEI Ex.                                  ANO NEI Example EAL Wording                            ANO EAL Wording                      Difference/Deviation Justification EAL #                                    EAL #
Field survey results indicate EITHER of the following at or beyond (site-specific dose            Field survey results indicate EITHER of the receptor point):                      following at or beyond the SITE Closed window dose BOUNDARY:
rates greater than                  Closed window dose rates 100 mR/hr expected to                > 100 mR/hr expected to continue for    The site boundary is the site-specific 3                                    AS1.3      60 min.
continue for 60 minutes or                                                    receptor point.
longer.                            Analyses of field survey samples Analyses of field survey              indicate thyroid CDE > 500 mrem for samples indicate thyroid              60 min. of inhalation.
CDE greater than                (Notes 1, 2) 500 mrem for one hour of inhalation.
The Emergency Director              Note 1: The Emergency Director should        The classification timeliness note has been should declare the Site                    declare the event promptly upon    standardized across the ANO EAL scheme Area Emergency promptly                    determining that the time limit has by referencing the "time limit" specified upon determining that the                  been exceeded, or will likely be    within the EAL wording.
applicable time has been                    exceeded. The Emergency            Added The Emergency Director is not exceeded, or will likely be                Director is not allowed an          allowed an additional 15 minutes to exceeded.                                  additional 15 minutes to declare    declare after the time limit is exceeded. To If an ongoing release is                      after the time limit is exceeded    reinforce the concept that the EAL timing Notes      detected and the release                                                        component runs concurrent with the start time is unknown,                                                          classification timeliness clock.
assume that the release duration has exceeded 15 minutes.                          Note 2: If an ongoing release is detected    The classification timeliness note has been and the release start time is      standardized across the ANO EAL scheme unknown, assume that the release    by referencing the "time limit" specified duration has exceeded the          within the EAL wording.
specified time limit.
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If the effluent flow past an        Note 3: If the effluent flow past an effluent None effluent monitor is known to              monitor is known to have stopped have stopped due to actions                due to actions to isolate the to isolate the release path,              release path, then the effluent then the effluent monitor                  monitor reading is no longer reading is no longer valid                VALID for classification purposes.
for classification purposes.      Note 4 The pre-calculated effluent monitor Notes                                                                                      Incorporated site-specific EAL numbers (cont.)  The pre-calculated effluent                  values presented in EALs AA1.1,      associated with generic EAL#1.
monitor values presented in                AS1.1 and AG1.1 should be used EAL #1 should be used for                  for emergency classification emergency classification                  assessments until the results from assessments until the                      a dose assessment using actual results from a dose                        meteorology are available.
assessment using actual meteorology are available.
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Spent fuel pool level at (site-        Spent fuel pool level at the top of the specific Level 3 description).        fuel racks.                            Top of the fuel racks is the site-specific Level 3 AS2                                    AS2 description.
MODE: All                              MODE: All NEI Ex.                                  ANO NEI Example EAL Wording                        ANO EAL Wording                      Difference/Deviation Justification EAL #                                  EAL #
For ANO, Level 3, which corresponds to the top Lowering of spent fuel pool            Lowering of spent fuel pool level to    of the fuel racks in the SFP, is an indicated level 1    level to (site-specific Level 3 AS2.1  377.0 ft.[379.5 ft.] (Alarm 3) on      of:
value)                                LIT-2020-3(4)[2LIT-2020-1(2)].          Unit 1: 377.0 ft. (Alarm 3) on LIT-2020-3(4)
Unit 2: 379.5 ft. (Alarm 3) on 2LIT-2020-1(2) to 0CAN031801 Page 34 of 120 NEI                                        ANO NEI IC Wording                                ANO IC Wording                      Difference/Deviation Justification IC#                                      IC#(s)
Release of gaseous Release of gaseous radioactivity radioactivity resulting in offsite resulting in offsite dose greater than dose greater than AG1                                        AG1  1,000 mrem TEDE or 5,000 mrem          None 1,000 mrem TEDE or thyroid CDE 5,000 mrem thyroid CDE.
MODE: All MODE: All NEI Ex.                                    ANO NEI Example EAL Wording                            ANO EAL Wording                      Difference/Deviation Justification EAL #                                      EAL #
The ANO radiation monitors that detect Reading on ANY of the                                                            radioactivity effluent release to the environment following radiation monitors                                                    are listed in Tables 1[2]A-1.
greater than the reading                  Reading on any Table A-1 effluent      UE, Alert, SAE and GE thresholds for all ANO 1    shown for 15 minutes or            AG1.1  radiation monitor > column "GE" for    continuously monitored gaseous and liquid longer:                                    15 min. (Notes 1, 2, 3, 4)          release pathways are listed in Tables 1[2]A-1 to (site-specific monitor list and                                                  consolidate the information in a single location threshold values)                                                                and, thereby, simplify identification of the thresholds by the EAL-user.
Dose assessment using actual meteorology indicates              Dose assessment using actual doses greater than                        meteorology indicates doses The site boundary is the site-specific receptor 2    1,000 mrem TEDE or                AG1.2  > 1000 mrem TEDE or 5000 mrem point.
5,000 mrem thyroid CDE at                thyroid CDE at or beyond the SITE or beyond (site-specific dose            BOUNDARY. (Note 4) receptor point).
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Field survey results indicate EITHER of the following at or        Field survey results indicate EITHER beyond (site-specific dose          of the following at or beyond the SITE receptor point):                    BOUNDARY:
Closed window dose                  Closed window dose rates rates greater than                  > 1000 mR/hr expected to 1,000 mR/hr expected to            continue for  60 min.            The site boundary is the site-specific receptor 3                                    AG1.3 continue for 60 minutes                                              point.
or longer.                        Analyses of field survey samples indicate thyroid CDE Analyses of field survey              > 5000 mrem for 60 min. of samples indicate thyroid            inhalation.
CDE greater than 5,000 mrem for one hour        (Notes 1, 2) of inhalation.
to 0CAN031801 Page 36 of 120 NEI Ex.                                ANO NEI Example EAL Wording                      ANO EAL Wording                      Difference/Deviation Justification EAL #                                  EAL #
Note 1: The Emergency Director          The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme by The Emergency Director                      promptly upon determining      referencing the "time limit" specified within the should declare the Site                  that the time limit has been    EAL wording.
Area Emergency promptly                  exceeded, or will likely be    Added The Emergency Director is not allowed upon determining that the                exceeded. The Emergency        an additional 15 minutes to declare after the applicable time has been                  Director is not allowed an      time limit is exceeded. To reinforce the exceeded, or will likely be              additional 15 minutes to        concept that the EAL timing component runs exceeded.                                declare after the time limit is concurrent with the classification timeliness If an ongoing release is                    exceeded.                      clock.
detected and the release start time is unknown,            Note 2: If an ongoing release is        The classification timeliness note has been assume that the release                  detected and the release start  standardized across the ANO EAL scheme by duration has exceeded                    time is unknown, assume that    referencing the "time limit" specified within the 15 minutes.                              the release duration has        EAL wording.
If the effluent flow past an                exceeded the specified time effluent monitor is known                limit.
Notes to have stopped due to            Note 3: If the effluent flow past an    None actions to isolate the                    effluent monitor is known to release path, then the                    have stopped due to actions effluent monitor reading is              to isolate the release path, no longer valid for                      then the effluent monitor classification purposes.                  reading is no longer VALID for classification purposes for The pre-calculated effluent classification purposes.
monitor values presented in EAL #1 should be used          Note 4 The pre-calculated effluent      Incorporated site-specific EAL numbers for emergency                            monitor values presented in    associated with generic EAL#1.
classification assessments                EALs AA1.1, AS1.1 and until the results from a                  AG1.1 should be used for dose assessment using                    emergency classification actual meteorology are                    assessments until the results available.                                from a dose assessment using actual meteorology are available.
to 0CAN031801 Page 37 of 120 NEI                                    ANO NEI IC Wording                            ANO IC Wording                        Difference/Deviation Justification IC#                                  IC#(s)
Spent fuel pool level cannot Spent fuel pool level cannot be be restored to at least (site-restored to at least the top of the fuel  Top of the fuel racks is the site-specific Level 3 AG2    specific Level 3 description)  AG2  racks for 60 minutes or longer.          description.
for 60 minutes or longer.
MODE: All MODE: All NEI Ex.                                ANO NEI Example EAL Wording                        ANO EAL Wording                        Difference/Deviation Justification EAL #                                  EAL #
For ANO, Level 3, which corresponds to the top Spent fuel pool level cannot          Spent fuel pool level cannot be          of the fuel racks in the SFP, is an indicated level be restored to at least (site-        restored to at least 377.0 ft.[379.5 ft.] of:
1                                    AG2.1 specific Level 3 value) for          (Alarm 3) on LIT-2020-3(4)
Unit 1: 377.0 ft. (Alarm 3) on LIT-2020-3(4) 60 minutes or longer.                [2LIT-2020-1(2)] for  60 min. (Note 1)
Unit 2: 379.5 ft. (Alarm 3) on 2LIT-2020-1(2)
Note 1: The Emergency Director            The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme by The Emergency Director                        promptly upon determining        referencing the "time limit" specified within the should declare the General                    that the time limit has been    EAL wording.
Emergency promptly upon                        exceeded, or will likely be      Added The Emergency Director is not allowed Note                                  N/A determining that 60 minutes                    exceeded. The Emergency          an additional 15 minutes to declare after the has been exceeded, or will                    Director is not allowed an      time limit is exceeded. To reinforce the likely be exceeded.                            additional 15 minutes to        concept that the EAL timing component runs declare after the time limit is  concurrent with the classification timeliness exceeded.                        clock.
to 0CAN031801 Page 38 of 120 Category C Cold Shutdown / Refueling System Malfunction NEI                                    ANO NEI IC Wording                            ANO IC Wording                      Difference/Deviation Justification IC#                                    IC#(s)
UNPLANNED loss of (reactor vessel/RCS [PWR] or RPV UNPLANNED loss of RCS inventory.
[BWR]) inventory for                                                          Deleted the words for 15 minutes or longer CU1    15 minutes or longer.            CU1  MODE: 5 - Cold Shutdown,              as the 15 minute criteria only applies to EAL #1.
6 - Refueling MODE: Cold Shutdown, Refueling NEI Ex.                                  ANO NEI Example EAL Wording                        ANO EAL Wording                      Difference/Deviation Justification EAL #                                  EAL #
UNPLANNED loss of reactor coolant results in (reactor          UNPLANNED loss of reactor coolant vessel/RCS [PWR] or RPV              results in RCS water level less than a 1                                    CU1.1                                        None
[BWR]) level less than a              required lower limit for  15 min.
required lower limit for              (Note 1) 15 minutes or longer.
Added the words due to loss of RCS
: a. (Reactor vessel/RCS                                                      inventory to be consistent with the IC wording.
RCS level cannot be monitored
[PWR] or RPV [BWR])                                                      Replaced the term increase with the word rise level cannot be                    AND EITHER consistent with allowed usage.
monitored.                          UNPLANNED rise in any 2                                    CU1.2                                        Site-specific applicable sumps and tanks are AND                                      Table 1[2]C-1 sump/tank level listed in Table 1[2]C-1 to improve the readability due to loss of RCS inventory
: b. UNPLANNED increase in                                                    of the EAL.
(site-specific sump and/or          Visual observation of UNISOLABLE RCS leakage            Added bulleted criteria Visual observation to tank) levels.                                                            include direct observation of significant RCS unisolable leakage.
to 0CAN031801 Page 39 of 120 NEI Ex.                                  ANO NEI Example EAL Wording                          ANO EAL Wording                          Difference/Deviation Justification EAL #                                  EAL #
Note 1: The Emergency Director          The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme by The Emergency Director                            promptly upon determining      referencing the "time limit" specified within the should declare the Unusual                        that the time limit has been    EAL wording.
Event promptly upon                              exceeded, or will likely be Note                                    N/A                                            Added The Emergency Director is not allowed determining that 15 minutes                      exceeded. The Emergency has been exceeded, or will                        Director is not allowed an      an additional 15 minutes to declare after the time likely be exceeded.                              additional 15 minutes to        limit is exceeded. To reinforce the concept that declare after the time limit is the EAL timing component runs concurrent with exceeded.                      the classification timeliness clock.
Table 1C-1    Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank Table 2C-1    Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)
Holdup Tank Aux. Building Sump Quench Tank to 0CAN031801 Page 40 of 120 NEI                                    ANO NEI IC Wording                            ANO IC Wording                      Difference/Deviation Justification IC#                                  IC#(s)
Loss of all but one AC power Loss of all but one AC power source source to emergency buses to vital buses for 15 minutes or longer. vital buses is the ANO-specific terminology for CU2    for 15 minutes or longer.      CU2 MODE: 5 - Cold Shutdown,                  emergency buses.
MODE: Cold Shutdown, 6 - Refueling, DEF - Defueled Refueling, Defueled NEI Ex.                                ANO NEI Example EAL Wording                        ANO EAL Wording                        Difference/Deviation Justification EAL #                                  EAL #
: a. AC power capability to (site-specific emergency AC power capability, Table 1[2]C-3, to buses) is reduced to a vital 4.16 KV buses A3[2A3] and single power source for A4[2A4] reduced to a single power        4.16KV buses A3[2A3] and A4[2A4] are the 15 minutes or longer.
source for  15 min. (Note 1)            emergency (vital) buses.
1    AND                            CU2.1 AND                                  Site-specific AC power sources are tabularized
: b. Any additional single                                                        in Table 1[2]C-3.
Any additional single power source power source failure will failure will result in loss of all AC result in loss of all AC power to SAFETY SYSTEMS power to SAFETY SYSTEMS.
Note 1: The Emergency Director            The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme by The Emergency Director                          promptly upon determining      referencing the "time limit" specified within the should declare the Unusual                      that the time limit has been    EAL wording.
Event promptly upon                            exceeded, or will likely be    Added The Emergency Director is not allowed Note                                  N/A determining that 15 minutes                    exceeded. The Emergency        an additional 15 minutes to declare after the has been exceeded, or will                      Director is not allowed an      time limit is exceeded. To reinforce the likely be exceeded.                            additional 15 minutes to        concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded.                      clock.
to 0CAN031801 Page 41 of 120 Table 1C-3    Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)
Onsite DG1 DG2 AAC Gen Table 2C-3    Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)
Onsite 2DG1 2DG2 AAC Gen to 0CAN031801 Page 42 of 120 NEI                                  ANO NEI IC Wording                          ANO IC Wording                        Difference/Deviation Justification IC#                                  IC#(s)
Unplanned increase in RCS Unplanned rise in RCS temperature temperature.                                                                  Replaced the term increase with the word CU3                                  CU3  MODE: 5 - Cold Shutdown, MODE: Cold Shutdown,                                                          rise consistent with allowed usage.
6 - Refueling Refueling NEI Ex.                                ANO NEI Example EAL Wording                      ANO EAL Wording                        Difference/Deviation Justification EAL #                                EAL #
Replaced the term increase with the word rise consistent with allowed usage.
UNPLANNED increase in 200&deg;F is the site-specific Tech. Spec. cold RCS temperature to greater          UNPLANNED rise in RCS temperature shutdown temperature limit.
1    than (site-specific Technical CU3.1  to > 200&deg;F due to loss of decay heat Specification cold shutdown          removal capability                        Added due to loss of decay heat removal temperature limit)                                                            capability to reinforce the generic bases that states EAL #1 involves a loss of decay heat removal capability Loss of ALL RCS temperature and (reactor Loss of all RCS temperature and RCS 2    vessel/RCS [PWR] or RPV      CU3.2                                            None level indication for  15 min. (Note 1)
[BWR]) level indication for 15 minutes or longer.
Note 1: The Emergency Director            The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme by The Emergency Director                        promptly upon determining      referencing the "time limit" specified within the should declare the Unusual                    that the time limit has been    EAL wording.
Event promptly upon                            exceeded, or will likely be    Added The Emergency Director is not allowed Note                                  N/A determining that 15 minutes                    exceeded. The Emergency        an additional 15 minutes to declare after the has been exceeded, or will                    Director is not allowed an      time limit is exceeded. To reinforce the likely be exceeded                            additional 15 minutes to        concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded.                      clock.
to 0CAN031801 Page 43 of 120 NEI                                    ANO NEI IC Wording                            ANO IC Wording                      Difference/Deviation Justification IC#                                  IC#(s)
Loss of Vital DC power for            Loss of Vital DC power for 15 minutes 15 minutes or longer.                or longer.
CU4                                    CU4                                            None MODE: Cold Shutdown,                  MODE: 5 - Cold Shutdown, Refueling                            6 - Refueling NEI Ex.                                ANO NEI Example EAL Wording                      ANO EAL Wording                      Difference/Deviation Justification EAL #                                  EAL #
Indicated voltage is less than                                                105 VDC is the site-specific minimum vital DC (site-specific bus voltage            Indicated voltage is < 105 VDC on        bus voltage.
1    value) on required Vital DC    CU4.1  required vital 125 VDC buses for buses for 15 minutes or                15 min. (Note 1)                      Safety-related DC bus operability requirements longer.                                                                        are specified in Technical Specifications.
Note 1: The Emergency Director          The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme by The Emergency Director                        promptly upon determining      referencing the "time limit" specified within the should declare the Unusual                    that the time limit has been    EAL wording.
Event promptly upon                            exceeded, or will likely be    Added The Emergency Director is not allowed Note                                  N/A determining that 15 minutes                    exceeded. The Emergency        an additional 15 minutes to declare after the has been exceeded, or will                    Director is not allowed an      time limit is exceeded. To reinforce the likely be exceeded.                            additional 15 minutes to        concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded.                      clock.
to 0CAN031801 Page 44 of 120 NEI                                  ANO NEI IC Wording                          ANO IC Wording                    Difference/Deviation Justification IC#                                  IC#(s)
Loss of all onsite or offsite        Loss of all onsite or offsite communications capabilities.        communications capabilities.
CU5                                  CU5                                      None MODE: Cold Shutdown,                MODE: 5 - Cold Shutdown, Refueling, Defueled                  6 - Refueling, DEF - Defueled NEI Ex.                                ANO NEI Example EAL Wording                      ANO EAL Wording                    Difference/Deviation Justification EAL #                                EAL #
Loss of ALL of the following onsite communication 1    methods:
(site specific list of communications methods)              Loss of all Table 1[2]C-5 onsite    Example EALs #1, 2 and 3 have been combined communication methods              into a single EAL for simplification of Loss of ALL of the following ORO communications                      OR                              presentation.
2    methods:                            Loss of all Table 1[2]C-5 State and Replaced ORO with State and local agency CU5.1 local agency communication methods  for clarification.
(site specific list of communications methods)                OR                              Table 1[2]C-5 provides a site-specific list of Loss of all Table 1[2]C-5 NRC      onsite, State and local agency (ORO) and NRC Loss of ALL of the following        communication methods              communications methods.
NRC communications 3    methods:
(site specific list of communications methods) to 0CAN031801 Page 45 of 120 Table 1[2]C-5 Communication Methods System                  Onsite  State/Local NRC Station radio system                          X ANO plant phone system                        X Gaitronics                                    X Telephone Systems:
Commercial Microwave                                          X      X Satellite VOIP INFORM Notification System                              X Emergency Notification System (ENS)                              X to 0CAN031801 Page 46 of 120 NEI                                    ANO NEI IC Wording                            ANO IC Wording                      Difference/Deviation Justification IC#                                  IC#(s)
Loss of (reactor vessel/RCS
[PWR] or RPV [BWR])                  Significant loss of RCS inventory      Added the word Significant to differentiate inventory                                                                    the Alert loss of RCS inventory IC from the CA1                                    CA1  MODE: 5 - Cold Shutdown,                Unusual Event IC which is Unplanned loss of MODE: Cold Shutdown,                  6 - Refueling                          RCS inventory.
Refueling NEI Ex.                                ANO NEI Example EAL Wording                        ANO EAL Wording                      Difference/Deviation Justification EAL #                                  EAL #
Loss of RCS inventory as indicated by  RVLMS Levels 1 through 8 [RVLMS Levels 1 Loss of (reactor vessel/RCS          EITHER:                                through 5] indicating DRY is the site-specific
[PWR] or RPV [BWR])                      RVLMS Levels 1 through 8            reactor vessel level corresponding to lowest 1    inventory as indicated by      CA1.1      [1 through 5] indicate DRY        RVLMS indicated level above the bottom of the level less than (site-specific                                                RCS Hot Leg.
Reactor vessel level 368.5 ft.
level).                                    (LT-1195/LT-1196)[0 in.            Reactor vessel level 368.5 ft.[0 in.] corresponds (L4791/L4792)] (bottom of hot leg) to the bottom of RCS Hot Leg.
: a. (Reactor vessel/RCS
[PWR] or RPV [BWR])                RCS level cannot be monitored for      Site-specific applicable sumps and tanks are level cannot be monitored          15 min. (Note 1)                      listed in Table 1[2]C-1 to improve the readability for 15 minutes or longer AND EITHER                            of the EAL.
AND 2                                    CA1.2    UNPLANNED rise in any                Replaced the term increase with the word
: b. UNPLANNED increase in                Table 1[2]C-1 Sump / Tank level    rise consistent with allowed usage.
(site-specific sump and/or            due to a loss of RCS inventory tank) levels due to a loss                                                Added bulleted criteria Visual observation to of (reactor vessel/RCS              Visual observation of UNISOLABLE    include direct observation of significant RCS
[PWR] or RPV [BWR])                  RCS leakage                        leakage.
inventory.
to 0CAN031801 Page 47 of 120 NEI Ex.                            ANO NEI Example EAL Wording                  ANO EAL Wording                        Difference/Deviation Justification EAL #                              EAL #
Note 1: The Emergency Director          The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme by The Emergency Director                    promptly upon determining      referencing the "time limit" specified within the should declare the Alert                  that the time limit has been    EAL wording.
promptly upon determining                exceeded, or will likely be    Added The Emergency Director is not allowed Note                                N/A that 15 minutes has been                  exceeded. The Emergency        an additional 15 minutes to declare after the exceeded, or will likely be              Director is not allowed an      time limit is exceeded. To reinforce the exceeded.                                additional 15 minutes to        concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded.                      clock.
to 0CAN031801 Page 48 of 120 NEI                                  ANO NEI IC Wording                          ANO IC Wording                        Difference/Deviation Justification IC#                                  IC#(s)
Loss of all offsite and all Loss of all offsite and all onsite AC onsite AC power to power to vital buses for 15 minutes or emergency buses for                                                          Vital buses is the ANO-specific terminology for CA2                                  CA2  longer.
15 minutes or longer.                                                        emergency buses.
MODE: 5 - Cold Shutdown, MODE: Cold Shutdown, 6 - Refueling, DEF - Defueled Refueling, Defueled NEI Ex.                                ANO NEI Example EAL Wording                      ANO EAL Wording                        Difference/Deviation Justification EAL #                                EAL #
Loss of ALL offsite and ALL Loss of all offsite and all onsite AC onsite AC Power to (site-                                                    4.16KV buses A3[2A3] and A4[2A4] are the site-1                                  CA2.1  power to vital 4.16 KV buses A3[2A3]
specific emergency buses) for                                                specific emergency buses.
and A4[2A4] for  15 min. (Note 1) 15 minutes or longer.
Note 1: The Emergency Director          The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme by The Emergency Director                        promptly upon determining      referencing the "time limit" specified within the should declare the Unusual                    that the time limit has been    EAL wording.
Event promptly upon                          exceeded, or will likely be    Added The Emergency Director is not allowed Note                                  N/A determining that 15 minutes                  exceeded. The Emergency        an additional 15 minutes to declare after the has been exceeded, or will                    Director is not allowed an      time limit is exceeded. To reinforce the likely be exceeded.                          additional 15 minutes to        concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded.                      clock.
to 0CAN031801 Page 49 of 120 NEI                                    ANO NEI IC Wording                            ANO IC Wording                        Difference/Deviation Justification IC#                                    IC#(s)
Inability to maintain the plant        Inability to maintain plant in cold in cold shutdown.                      shutdown.
CA3                                    CA3                                              None MODE: Cold Shutdown,                  MODE: 5 - Cold Shutdown, Refueling                              6 - Refueling NEI Ex.                                  ANO NEI Example EAL Wording                          ANO EAL Wording                        Difference/Deviation Justification EAL #                                  EAL #
UNPLANNED increase in                                                            Example EALs #1 and #2 have been combined RCS temperature to greater                                                        into a single EAL as EAL #2 is the alternative than (site-specific Technical                                                    threshold based on a loss of RCS temperature 1    Specification cold shutdown            UNPLANNED rise in RCS temperature          indication.
temperature limit) for greater        to > 200&deg;F for > Table 1[2]C-4 duration    Replaced the term increase with the word than the duration specified in        (Note 1)                                  rise consistent with allowed usage the following table.
CA3.1      OR                                    200&deg;F is the site-specific Tech. Spec. cold UNPLANNED RCS pressure                Unplanned RCS pressure rise                shutdown temperature limit.
increase greater than (site-          > 10 psig (this EAL does not apply        Table 1[2]C-3 is the site-specific implementation specific pressure reading).            during water-solid plant conditions)      of the generic RCS Reheat Duration Threshold 2    (This EAL does not apply                                                          table.
during water-solid plant 10 psig is the site-specific pressure rise conditions. [PWR])
readable by Control Room indications.
Note 1: The Emergency Director            The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme by The Emergency Director                            promptly upon determining      referencing the "time limit" specified within the should declare the Unusual                        that the time limit has been    EAL wording.
Event promptly upon                              exceeded, or will likely be    Added The Emergency Director is not allowed Note                                    N/A determining that 15 minutes                      exceeded. The Emergency        an additional 15 minutes to declare after the has been exceeded, or will                        Director is not allowed an      time limit is exceeded. To reinforce the likely be exceeded.                              additional 15 minutes to        concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded.                      clock.
to 0CAN031801 Page 50 of 120 Table:    RCS Heat-up Duration Thresholds RCS Status                        Containment Closure Status            Heat-up Duration Intact (but not at reduced inventory [PWR])                    Not applicable                  60 minutes*
Established                    20 minutes*
Not intact (or at 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 1[2]C-4:    RCS Heat-up Duration Thresholds CONTAINMENT RCS Status                                                  Heat-up Duration CLOSURE Status Intact (but not lowered inventory)                N/A                      60 min.*
Not intact                                    established                  20 min.*
OR lowered inventory                            not established                  0 min.
* If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.
to 0CAN031801 Page 51 of 120 NEI                                ANO NEI IC Wording                        ANO IC Wording              Difference/Deviation Justification IC#                                IC#(s)
Hazardous event affecting a Hazardous event affecting SAFETY SAFETY SYSTEM needed                                                Pluralized safety systems to be consistent with SYSTEMS needed for the current for the current operating                                          NRC EP FAQ 2016-002 that specifies degraded CA6                                CA6  operating mode.
mode.                                                              performance or visible damage in more than MODE: 5 - Cold Shutdown,        one safety system train.
MODE: Cold Shutdown, 6 - Refueling Refueling to 0CAN031801 Page 52 of 120 NEI Ex.                                    ANO NEI Example EAL Wording                          ANO EAL Wording                    Difference/Deviation Justification EAL #                                      EAL #
: a. The occurrence of ANY of the following hazardous events:
Seismic event (earthquake)
Internal or external flooding event The occurrence of any Table 1[2]C-6    The hazardous events have been tabularized High winds or tornado hazardous event                        in Table 1[2]C-6.
strike AND                                CA6.1 reflects NRC FAQ 2016-002 requiring FIRE Event damage has caused indications    degraded performance or visible damage to EXPLOSION                        of degraded performance on one train of more than one train of a safety system caused (site-specific hazards)          a SAFETY SYSTEM needed for the          by the specified events.
Other events with similar        current operating mode                  This wording is a deviation from NEI 99-01, hazard characteristics as            AND EITHER:                        Revision 6, CA6 generic wording and determined by the Shift                Event damage has caused          bases but is deemed acceptable in order to 1            Manager                    CA6.1        indications of degraded          ensure that an Alert is declared only when AND                                  performance to the second train  a hazardous event causes actual or
: b. EITHER of the following:                    of the SAFETY SYSTEM needed      potential performance issues with safety for the current operating mode  systems. This is consistent with
: 1. Event damage has                                                        NRC-approved EP FAQ 2016-002.
caused indications of                  Event damage has resulted in degraded performance                    VISIBLE DAMAGE to the second    The word a is replaced with the in the FAQ in at least one train of a              train of the SAFETY SYSTEM      wording to provide agreement with the FAQ SAFETY SYSTEM                          needed for the current operating basis information indicating that the criteria is needed for the current                  mode                            applicable to another train of the same safety operating mode.                  (Notes 10, 11)                        system.
OR
: 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.
to 0CAN031801 Page 53 of 120 Note 10: If the affected SAFETY SYSTEM train was already inoperable Added Note 10 consistent with the N/A    N/A                      N/A  or out of service before the hazardous recommendation of NRC EP FAQ 2016-002.
event occurred, then emergency classification is not warranted Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to Added Note 11 consistent with the N/A    N/A                      N/A at least one train of a SAFETY        recommendation of NRC EP FAQ 2016-002.
SYSTEM, then this emergency classification is not warranted.
Table 1[2]C-6  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 to 0CAN031801 Page 54 of 120 NEI                                    ANO NEI IC Wording                          ANO IC Wording                    Difference/Deviation Justification IC#                                  IC#(s)
Loss of (reactor vessel/RCS
[PWR] or RPV [BWR])                  Loss of RCS inventory affecting core inventory affecting core decay        decay heat removal capability CS1    heat removal capability.        CS1                                        None MODE: 5 - Cold Shutdown, MODE: Cold Shutdown,                  6 - Refueling Refueling NEI Ex.                                ANO NEI Example EAL Wording                      ANO EAL Wording                    Difference/Deviation Justification EAL #                                  EAL #
Unit 1: RVLMS Level 9 is at elevation 367.69 ft.
: a. CONTAINMENT                                                                      The bottom of the hotleg is at 368 ft.
CLOSURE not                                                                    RVLMS Level 9 corresponds to CONTAINMENT CLOSURE not established.                                                                  approximately 6 below the bottom of established AND                                                                            the hotleg.
1                                    CS1.1      AND
: b. (Reactor vessel/RCS                                                    Unit 2: The top of active fuel is 61.4 in. below RVLMS Levels 1 through 9                      the bottom of the hotleg. RVLMS
[PWR] or RPV [BWR])
[1 through 6] indicate DRY                    Level 6 is 47 in. above the top of active level less than (site-specific level).                                                        fuel, which is 61.4 in. - 47 in. = 14.4 in.
below the bottom ID of the hot leg.
Unit 1 cannot measure reactor vessel at or near the top of active fuel or below. The Unit 2 RVLMS does not provide a positive indication of
: a. CONTAINMENT                                                            level at or near the top of active fuel, but does CLOSURE established.                                                  provide an indication of core uncovery at Level 7. Consistent with the generic developers AND                                                                  guidance: If the design and operation of water 2    b. (Reactor vessel/RCS          N/A  N/A                                  level instrumentation is such that this level value
[PWR] or RPV [BWR])                                                  cannot be determined at any time during Cold level less than                                                      Shutdown or Refueling modes, then do not (site-specific level).                                                include EAL #2 (classification will be accomplished in accordance with EAL #3).
Unit 2 RVLMS levels 7 through 11 are indications of core uncovery.
to 0CAN031801 Page 55 of 120 NEI Ex.                                  ANO NEI Example EAL Wording                        ANO EAL Wording                        Difference/Deviation Justification EAL #                                    EAL #
: a. (Reactor vessel/RCS
[PWR] or RPV [BWR])              [1. RVLMS Levels 1 through 7 level cannot be monitored            indicate DRY]                        On Unit 2, RVLMS level 7 is an indication of for 30 minutes or longer.                                                  core uncovery when the RVLMS system is in
[OR]
AND                                                                        service. An ANO CS1.2 EAL threshold is
[2] RCS level cannot be monitored
: b. Core uncovery is                        for  30 min. (Note 1)              provided for Unit 2 only where there is indication indicated by ANY of the                                                    of core uncovery without applying the 30-minute following:                              AND                                time period because of the known core (Site-specific radiation            Core uncovery is indicated by        uncovery condition.
monitor) reading                  any of the following:
Replaced the term increase with the word greater than (site-                UNPLANNED rise in any              rise consistent with allowed usage.
3                                      CS1.2      Table 1[2]C-1 sump/tank level specific value)                                                        Table 1[2]C-1 provides a tabularized list of site-Erratic source range                  of sufficient magnitude to specific applicable sumps and tanks.
monitor indication                  indicate core uncovery Containment High Range Radiation Monitors
[PWR]                              Containment high range            RE-8060/8061[2RE-8925-1/8925-2] are the UNPLANNED increase                    radiation monitor                  site-specific radiation monitors that would be in (site-specific sump              RE-8060/8061                      indicative of likely core uncovery in the and/or tank) levels of              [2RE-8925-1/8925-2] reading        Refueling mode. The dose rate due to core sufficient magnitude to            > 10 R/hr                          shine when the top of the core becomes indicate core uncovery            Erratic Source Range Monitor      uncovered should result in dose rates > 10 R/hr.
(Other site-specific                  indication indications)
Note 1: The Emergency Director          The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme by The Emergency Director                          promptly upon determining      referencing the "time limit" specified within the should declare the Site Area                    that the time limit has been    EAL wording.
Emergency promptly upon                        exceeded, or will likely be    Added The Emergency Director is not allowed Note                                    N/A determining that 30 minutes                    exceeded. The Emergency        an additional 15 minutes to declare after the has been exceeded, or will                      Director is not allowed an      time limit is exceeded. To reinforce the likely be exceeded                              additional 15 minutes to        concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded.                      clock.
to 0CAN031801 Page 56 of 120 NEI                                  ANO NEI IC Wording                          ANO IC Wording                    Difference/Deviation Justification IC#                                  IC#(s)
Loss of (reactor vessel/RCS
[PWR] or RPV [BWR])                  Loss of RCS inventory affecting fuel inventory affecting fuel clad        clad integrity with containment CG1    integrity with containment    CG1  challenged                          None challenged                          MODE: 5 - Cold Shutdown, MODE: Cold Shutdown,                6 - Refueling Refueling NEI Ex.                                ANO NEI Example EAL Wording                      ANO EAL Wording                    Difference/Deviation Justification EAL #                                EAL #
: a. (Reactor vessel/RCS                                                  Unit 1 cannot measure reactor vessel at or near
[PWR] or RPV [BWR])                                                  the top of active fuel or below. The Unit 2 level less than (site-                                              RVLMS does not provide a positive indication of specific level) for                                                  level at or near the top of active fuel, but does 30 minutes or longer.                                                provide an indication of core uncovery at AND                                                                  Level 7. Consistent with the generic developers guidance: If the design and operation of water 1      b. ANY indication from the    N/A  N/A                                  level instrumentation is such that this level value Containment Challenge cannot be determined at any time during Cold Table (see below).
Shutdown or Refueling modes, then do not include EAL #2 (classification will be accomplished in accordance with EAL #3).
Unit 2 RVLMS levels 7 through 11 are indications of core uncovery.
to 0CAN031801 Page 57 of 120 NEI Ex.                                  ANO NEI Example EAL Wording                        ANO EAL Wording                  Difference/Deviation Justification EAL #                                    EAL #
: a. (Reactor vessel/RCS
[PWR] or RPV [BWR])
level cannot be monitored for 30 minutes or longer.                                          On Unit 2, RVLMS level 7 is an indication of AND                                                                core uncovery when the RVLMS system is in service. An ANO CG1.1 EAL threshold is
: b. Core uncovery is provided for Unit 2 only where there is indication indicated by ANY of the of core uncovery without applying the 30-minute following:
time period because of the known core (Site-specific radiation                                          uncovery condition. Entergy EAL CG1.2 is monitor) reading                                                provided for both units.
greater than (site-specific value)              RVLMS Levels 1 through 7 indicate Replaced the term increase with the word DRY                              rise consistent with allowed usage.
Erratic source range 2              monitor indication      CG1.1 AND                              Table 1[2]C-2 provides a tabularized list of
[PWR]                                                          containment challenge indications.
Any Containment Challenge UNPLANNED                      indication, Table 1[2]C-2        Containment High Range Radiation Monitors increase in (site-                                              RE-8060/8061 [2RE-8925-1/8925-2] are the specific sump and/or                                            site-specific radiation monitors that would be tank) levels of                                                indicative of likely core uncovery in the sufficient magnitude to                                        Refueling mode. The dose rate due to core indicate core uncovery                                          shine when the top of the core becomes uncovered should result in dose rates > 10 R/hr.
(Other site-specific indications)                                                    3% hydrogen concentration in the presence of oxygen represents an explosive mixture in AND containment.
: c. ANY indication from the Containment Challenge Table (see below).
to 0CAN031801 Page 58 of 120 NEI Ex.                                  ANO NEI Example EAL Wording                        ANO EAL Wording                    Difference/Deviation Justification EAL #                                    EAL #
: a. (Reactor vessel/RCS
[PWR] or RPV [BWR])
level cannot be monitored for 30 minutes or longer.                                              On Unit 2, RVLMS level 7 is an indication of AND                              RCS level cannot be monitored for    core uncovery when the RVLMS system is in 30 min. (Note 1)                  service. Entergy EAL CG1.1 is provided for
: b. Core uncovery is indicated by ANY of the          AND                                  Unit 2. Entergy EAL CG1.2 is provided for both following:                        Core uncovery is indicated by any of units.
(Site-specific radiation        the following:                      Replaced the term increase with the word monitor) reading                  UNPLANNED rise in any          rise consistent with allowed usage.
greater than (site-                Table 1[2] C-1 sump/tank level Table 1[2]C-1 provides a tabularized list of site-specific value)                    of sufficient magnitude to    specific applicable sumps and tanks.
Erratic source range                  indicate core uncovery Table 1[2]C-2 provides a tabularized list of 2              monitor indication      CG1.2    Containment High Range          containment challenge indications.
[PWR]                              Radiation Monitor              Containment High Range Radiation Monitors UNPLANNED                            RE-8060/8061                  RE-8060/8061[2RE-8925-1/8925-2] are the increase in (site-                  [2RE-8925-1/8925-2] reading    site-specific radiation monitors that would be specific sump and/or                > 10 R/hr                      indicative of likely core uncovery in the tank) levels of                  Erratic Source Range Monitor    Refueling mode. The dose rate due to core sufficient magnitude to            indication                    shine when the top of the core becomes indicate core uncovery                                            uncovered should result in dose rates > 10 R/hr.
AND (Other site-specific                                                3% hydrogen concentration in the presence of Any Containment Challenge indications)                                                      oxygen represents an explosive mixture in indication, Table 1[2]C-2 AND                                                                    containment.
: c. ANY indication from the Containment Challenge Table (see below).
to 0CAN031801 Page 59 of 120 NEI Ex.                            ANO NEI Example EAL Wording                  ANO EAL Wording                        Difference/Deviation Justification EAL #                              EAL #
The Emergency Director          Note 1: The Emergency Director          The classification timeliness note has been should declare the General                should declare the event        standardized across the ANO EAL scheme by Emergency promptly upon                  promptly upon determining      referencing the "time limit" specified within the determining that 30 minutes              that the time limit has been    EAL wording.
has been exceeded, or will                exceeded, or will likely be Added The Emergency Director is not allowed likely be exceeded.                      exceeded. The Emergency an additional 15 minutes to declare after the Director is not allowed an additional 15 minutes to        time limit is exceeded. To reinforce the declare after the time limit is concept that the EAL timing component runs Note                                N/A                                          concurrent with the classification timeliness exceeded.
clock.
N/A                              Note 6: If CONTAINMENT                  Note 6 implements the asterisked note CLOSURE is re-established      associated with the Containment Closure prior to exceeding the          requirement.
30-minute time limit, declaration of a General Emergency is not required.
to 0CAN031801 Page 60 of 120 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 time limit, then declaration of a General Emergency is not required.
Table 1[2]C-2    Containment Challenge Indications CONTAINMENT CLOSURE not established (Note 6)
Containment hydrogen concentration > 3%
UNPLANNED rise in containment pressure to 0CAN031801 Page 61 of 120 Category D Permanently Defueled Station Malfunction ANO      ANO IC NEI IC#          NEI IC Wording                                              Difference/Deviation Justification IC#(s)  Wording PD-AU1 PD-AU2 PD-SU1 PD-HU1 PD-HU2    Recognition Category D                            NEI Recognition Category PD ICs and EALs are applicable only to N/A      N/A PD-HU3    Permanently Defueled Station                      permanently defueled stations. ANO is not a defueled station.
PD-AA1 PD-AA2 PD-HA1 PD-HA3 to 0CAN031801 Page 62 of 120 Category E Independent Spent Fuel Storage Installation (ISFSI)
NEI                                        ANO NEI IC Wording                                ANO IC Wording                    Difference/Deviation Justification IC#                                      IC#(s)
Damage to a loaded cask                    Damage to a loaded cask E-HU1  confinement BOUNDARY.              EU1    confinement BOUNDARY.                None MODE: All                                  MODE: All NEI Ex.                                    ANO NEI Example EAL Wording                            ANO EAL Wording                    Difference/Deviation Justification EAL #                                      EAL #
Damage to a loaded cask confinement BOUNDARY as                      Damage to a loaded cask indicated by an on-contact                  CONFINEMENT BOUNDARY as The specified dose rates represent 2 times the radiation reading greater than              indicated by an on-contact radiation site-specific cask technical specification 1    (2 times the site-specific cask    EU1.1    reading on the surface of a loaded allowable levels per the ISFSI Technical specific technical                          spent fuel cask (VSC-24 VCC or Specifications (licensing document).
specification allowable                      HI-STORM overpack) > any radiation level) on the surface              Table 1[2]E-1 value of the spent fuel cask.
Table 1[2]E-1  ISFSI Dose Rates VSC-24 VCC                                  HI-STORM 200 mrem/hr on the sides                60 mrem/hr (gamma + neutron) on the top or outlet vent 400 mrem/hr on the top 600 mrem/hr (gamma + neutron on 700 mrem/hr at the air inlet the side of the side of the overpack 200 mrem/hr at the air outlet            (excluding inlet and outlet ducts) to 0CAN031801 Page 63 of 120 Category F Fission Product Barrier Degradation NEI                                  ANO NEI IC Wording                            ANO IC Wording                    Difference/Deviation Justification IC#                                IC#(s)
Any Loss or any Potential Any loss or any potential loss of Loss of either the Fuel Clad either Fuel Clad or RCS barrier or RCS barrier.
FA1                                  FA1      MODE: 1 - Power Operation,            None MODE: Power Operation, Hot 2 - Startup, 3 - Hot Standby, 4 - Hot Standby, Startup, Hot Shutdown Shutdown NEI Ex.                              ANO NEI Example EAL Wording                        ANO EAL Wording                    Difference/Deviation Justification EAL #                                EAL #
Any Loss or any Potential              Any loss or any potential loss of Table 1[2]F-1 provides the fission product 1    Loss of either the Fuel Clad FA1.1    either Fuel Clad or RCS barrier loss and potential loss thresholds.
or RCS barrier.                        (Table 1[2]F-1).
to 0CAN031801 Page 64 of 120 NEI                                  ANO NEI IC Wording                          ANO IC Wording                    Difference/Deviation Justification IC#                                  IC#(s)
Loss or Potential Loss of any        Loss or potential loss of any two two barriers.                        barriers.
FS1    MODE: Power Operation,        FS1  MODE: 1 - Power Operation,            None Hot Standby, Startup, Hot            2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown                            Shutdown NEI Ex.                                ANO NEI Example EAL Wording                      ANO EAL Wording                    Difference/Deviation Justification EAL #                                EAL #
Loss or Potential Loss of any        Loss or potential loss of any two    Table 1[2]F-1 provides the fission product 1                                  FS1.1 two barriers.                        barriers (Table 1[2]F-1).            barrier loss and potential loss thresholds.
to 0CAN031801 Page 65 of 120 NEI                                    ANO NEI IC Wording                            ANO IC Wording                    Difference/Deviation Justification IC#                                    IC#(s)
Loss of any two barriers and Loss of any two barriers and loss or Loss or Potential Loss of third potential loss of the third barrier.
barrier.
FG1                                    FG1  MODE: 1 - Power Operation,            None MODE: Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Hot Standby, Startup, Hot Shutdown Shutdown NEI Ex.                                  ANO EAL #
NEI Example EAL Wording EAL #
ANO EAL Wording                  Difference/Deviation Justification Loss of any two barriers Loss of any two barriers and AND                                Table 1[2]F-1 provides the fission product 1    Loss or Potential Loss of third FG1.1 Loss or potential loss of the third  barrier loss and potential loss thresholds.
barrier.
barrier (Table 1[2]F-1).
to 0CAN031801 Page 66 of 120 PWR Fuel Clad Fission Product Barrier Degradation Thresholds ANO NEI FPB#        NEI Threshold Wording                        ANO FPB Wording                  Difference/Deviation Justification FPB #(s)
FC Loss    RCS or SG Tube Leakage N/A    N/A                            N/A 1      Not Applicable Inadequate Heat Removal FC Loss    A. Core exit thermocouple                                                  Consistent with the generic developers notes FCB2    CETs > 1200&deg;F.
2          readings greater than (site-                                            1200&deg;F CET temperature is used.
specific temperature value).
RCS Activity/CMNT Rad                                                      A 750[700] R/hr (768[682] R/hr rounded for A. Containment radiation                                                    readability) reading in the containment is used monitor reading greater than                                            to indicate a loss of the Fuel Clad barrier and a (site-specific value)                                                  release of reactor coolant, with elevated Containment high range activity indicative of fuel damage, into the OR                                      radiation monitor RE-8060/8061 FCB5                                    containment. This value assumes an FC Loss    B. (Site-specific indications that          [2RE-8925-1/8925-2]
instantaneous release and dispersal of the reactor coolant activity is            > 750[700] R/hr.
3                                                                                  reactor coolant noble gas and iodine inventory greater than 300 Ci/gm                                                associated with a concentration of dose equivalent I-131).                                                approximately 300 &#xb5;Ci/gm Dose Equivalent I-131 into the containment atmosphere.
Coolant activity > 300 &#xb5;Ci/gm  300 &#xb5;Ci/gm DEI-131 is the site-specific FCB6 dose equivalent I-131.          indication for this reactor coolant activity.
FC Loss    CNMT Integrity or Bypass N/A    N/A                            N/A 4      Not Applicable FC Loss    Other Indications                                                          No other site-specific Fuel Clad Loss indication N/A    N/A 5      A. (site-specific as applicable)                                            has been identified for ANO.
ED Judgment Any condition in the opinion of FC Loss    A. ANY condition in the opinion            the Emergency Director that of the Emergency Director      FCB7                                    None 6                                                  indicates loss of the fuel clad that indicates Loss of the              barrier.
Fuel Clad barrier.
to 0CAN031801 Page 67 of 120 ANO NEI FPB#        NEI Threshold Wording                          ANO FPB Wording              Difference/Deviation Justification FPB #(s)
The above core level indication on Unit 1 is used to monitor the approach to and recovery from ICC conditions, but the CETs are used to identify core uncovery, and are the only positive indication of core uncovery.
RCS or SG Tube Leakage FC P-Loss                                                RVLMS Levels 1 through 9    The reactor vessel level indicators installed in A. RCS/reactor vessel level          FCB1 1                                                    [1 through 7] indicate DRY. Unit 1 extend from the top of the reactor vessel less than (site-specific level)                                      to the fuel alignment plate and indicate that the lowest sensor is greater than 2 feet above the top of active fuel.
For Unit 2, RVLMS level 7 is an indication of core uncovery.
Inadequate Heat Removal A. Core exit thermocouple                                                Consistent with the generic developers notes readings greater than            FCB3    CETs > 700&deg;F.
700&deg;F CET temperature is used.
(site-specific temperature value)
FC P-Loss OR                                        RCS heat removal cannot be 2                                                    established using steam    The initiation of HPI[Once Through] cooling is a B. Inadequate RCS heat generators                  readily identifiable procedurally driven action removal capability via steam generators as indicated by      FCB4                                that is taken when steam generators are not AND (site-specific indications).                                        functioning as an effective RCS heat removal HPI[Once Through] cooling  source.
initiated.
FC P-Loss  RCS Activity/CMNT Rad N/A    N/A                        N/A 3      Not Applicable FC P-Loss  CNMT Integrity or Bypass N/A    N/A                        N/A 4      Not Applicable FC P-Loss  Other Indications                                                        No other site-specific Fuel Clad Potential Loss N/A    N/A 5      A. (site-specific as applicable)                                        indication has been identified for ANO.
to 0CAN031801 Page 68 of 120 ANO NEI FPB#        NEI Threshold Wording                        ANO FPB Wording              Difference/Deviation Justification FPB #(s)
Emergency Director Judgment Any condition in the opinion of FC P-Loss  A. Any condition in the opinion          the Emergency Director that of the Emergency Director      FCB8                                    None 6                                                indicates potential loss of the that indicates Potential Loss          Fuel Clad barrier of the Fuel Clad barrier.
to 0CAN031801 Page 69 of 120 PWR RCS Fission Product Barrier Degradation Thresholds ANO NEI FPB#              NEI IC Wording                          ANO FPB Wording                  Difference/Deviation Justification FPB #(s)
RCS or SG Tube Leakage                                                    ESAS[ESFAS] is the site-specific A. An automatic or manual                                                  nomenclature for ECCS (SI).
ECCS (SI) actuation is                  An automatic or manual ESAS    Added Failure to isolate the leak (from the required by EITHER of the              [ESFAS] actuation required by  Control Room or locally), within 15 minutes or if RCS Loss        following:                              EITHER:                        known that the leak cannot be isolated within RCB1                                  15 minutes, from the start of the leak requires 1          1. UNISOLABLE RCS                          UNISOLABLE RCS leakage                                leakage                  immediate classification to the basis. This provides agreement with the definition of OR                                    SG tube RUPTURE            Unisolable and ensures isolation attempts,
: 2. SG tube RUPTURE.                                                    both locally and remotely, are achieved in a timely manner.
RCS Loss    Inadequate Heat Removal N/A    N/A                            N/A 2      Not Applicable A 40[50] R/hr (42.8[50.4] R/hr rounded for readability) reading in containment is used to indicate a loss of the RCS barrier and a release of reactor coolant, at the T.S. coolant activity limit, into the containment. This value RCS Activity/CMNT Rad                      Containment high range        assumes an instantaneous release and RCS Loss    A. Containment radiation                    radiation monitor RE-8060/8061 RCB5                                  dispersal of the reactor coolant noble gas and 3          monitor reading greater than            [2RE-8925-1/8925-2]            iodine inventory associated T.S. coolant (site-specific value).                  > 40[50] R/hr.                activity into the containment atmosphere.
Site-specific information added to the basis on the phenomenon of thermally induced current and its potential effects on the radiation monitor indication.
RCS Loss    CNMT Integrity or Bypass N/A    N/A                            N/A 4      Not Applicable RCS Loss    Other Indications                                                          No other site-specific RCS Loss indication has N/A    N/A 5      A. (site-specific as applicable).                                          been identified for ANO.
to 0CAN031801 Page 70 of 120 ANO NEI FPB#            NEI IC Wording                        ANO FPB Wording                Difference/Deviation Justification FPB #(s)
Emergency Director Judgment Any condition in the opinion of RCS Loss    A. ANY condition in the opinion          the Emergency Director that of the Emergency Director    RCB6                                    None 6                                                indicates loss of the RCS that indicates Loss of the            barrier.
RCS barrier.
ANO uses the alternative indication of the RCS or SG Tube Leakage capacity of one pump for the threshold leakage A. Operation of a standby                                                value as described in the NEI guidance.
charging (makeup) pump is UNISOLABLE RCS leakage or      Added Failure to isolate the leak (from the required by EITHER of the S/G tube leakage > 50[44] gpm  Control Room or locally), within 15 minutes or if RCS          following:
RCB2    excluding normal reductions in  known that the leak cannot be isolated within P-Loss 1      1. UNISOLABLE RCS                                                    15 minutes, from the start of the leak requires leakage                          RCS inventory (e.g., letdown, RCP seal leakoff)              immediate classification to the basis. This OR                                                                provides agreement with the definition of
: 2. SG tube leakage.                                                  Unisolable and ensures isolation attempts, both locally and remotely, are achieved in a OR timely manner.
to 0CAN031801 Page 71 of 120 ANO NEI FPB#              NEI IC Wording                              ANO FPB Wording                  Difference/Deviation Justification FPB #(s)
B. RCS cooldown rate greater                  UNISOLABLE RCS leakage or than (site-specific                      S/G tube leakage > 50[44] gpm pressurized thermal shock                excluding normal reductions in criteria/limits defined by site-          RCS inventory (e.g., letdown, specific indications).                    RCP seal leakoff)              Unit 1 and Unit 2 specific PTS criteria is Unit 1:                        specified.
PTS limits apply (RT14)        Note 12 - Once PTS limits are first invoked, if AND                            RCS temperature and pressure are not brought RCS pressure and temperature    within the limits within 15 minutes, this are left of the NDTT/LTOP limit threshold is met and an immediate declaration RCB3    lines on EOP Figure 3 (Note 12) is warranted. This threshold is met immediately upon exceeding the limits after Unit 2:                        this initial 15 minute period until PTS limits no Uncontrolled RCS cooldown      longer apply is added to allow RCS (50&deg;F step change which is      parameters to be brought within the limits in a below 500&deg;F from NOT)          timely manner when they are first outside the AND                            limits. RCS parameters must be maintained RCS pressure and temperature    within afterward.
are to the left of line B (200 degrees MTS), Standard Attachment 1, P-T Limits (Note 12)
Inadequate Heat Removal                      RCS heat removal cannot be      The initiation of HPI[Once Through] cooling is a A. Inadequate RCS heat                        established                    readily identifiable procedurally driven action RCS removal capability via steam      RCB4        AND                        that is taken when steam generators are not P-Loss 2        generators as indicated by                                                functioning as an effective RCS heat removal HPI[Once Through] cooling (site-specific indications).              initiated.                      source.
RCS      CS Activity/CMNT Rad N/A    N/A                            N/A P-Loss 3    Not Applicable RCS      CNMT Integrity or Bypass N/A    N/A                            N/A P-Loss 4    Not Applicable to 0CAN031801 Page 72 of 120 ANO NEI FPB#            NEI IC Wording                          ANO FPB Wording                  Difference/Deviation Justification FPB #(s)
RCS      Other Indications                                                        No other site-specific RCS Potential Loss N/A    N/A P-Loss 5    A. (site-specific as applicable)                                          indication has been identified for ANO.
Emergency Director Judgment Any condition in the opinion of RCS      A. ANY condition in the opinion          the Emergency Director that of the Emergency Director      RCB7                                    None P-Loss 6                                              indicates potential loss of the that indicates Potential Loss          RCS barrier of the RCS barrier.
to 0CAN031801 Page 73 of 120 PWR Containment Fission Product Barrier Degradation Thresholds ANO NEI FPB#              NEI IC Wording                          ANO FPB Wording              Difference/Deviation Justification FPB #(s)
RCS or SG Tube Leakage                                                      The threshold is reworded to clarify that A. A leaking or RUPTURED SG                                                the steam generator leakage is that is FAULTED outside of                A S/G that is leaking            level of leakage associated with the containment.                          > 50[44] gpm (excluding normal    related the NEI RCS barrier potential CNMT Loss CNB1    reductions in RCS inventory) or  loss threshold 1.A (ANO RCB2).
1                                                that is RUPTURED is also          Revised the table on page 2 of the FAULTED outside of containment    basis information to reflect pump capacity values to align with the change made to the EAL.
CNMT Loss    Inadequate Heat Removal N/A    N/A                              N/A 2      Not Applicable CNMT Loss    RCS Activity/CMNT Rad N/A    N/A                              N/A 3      Not applicable CNMT Integrity or Bypass                  Containment isolation is required Added Failure to isolate the leak (from A. Containment isolation is                                                the Control Room or locally), within AND EITHER:                    15 minutes or if known that the leak required Containment integrity has    cannot be isolated within 15 minutes, AND been lost based on        from the start of the leak requires EITHER of the following:      CNB4          Emergency Director        immediate classification to the basis.
: 1. Containment integrity has                judgment                  This provides agreement with the been lost based on                                                definition of Unisolable and ensures CNMT Loss                                                  UNISOLABLE pathway from Emergency Director                                                isolation attempts, both locally and Containment to the 4                judgment.                                                          remotely, are achieved in a timely environment exists        manner.
OR
: 2. UNISOLABLE pathway from the containment to the environment exists.          Indications of RCS leakage CNB5                                      None OR                                    outside of containment B. Indications of RCS leakage outside of containment.
to 0CAN031801 Page 74 of 120 ANO NEI FPB#              NEI IC Wording                            ANO FPB Wording              Difference/Deviation Justification FPB #(s)
CNMT Loss    Other Indications                                                            No other site-specific Containment Loss N/A    N/A 5      A. (site-specific as applicable)                                            indication has been identified for ANO.
Emergency Director Judgment Any condition in the opinion of CNMT Loss    ANY condition in the opinion of            the Emergency Director that the Emergency Director that        CNB9                                      None 6                                                  indicates loss of the containment indicates Loss of the Containment          barrier.
barrier.
CNMT P-Loss  RCS or SG Tube Leakage N/A    N/A                              N/A 1      Not Applicable Inadequate Heat Removal A. 1. (Site-specific criteria for entry into core cooling          CETs > 1200&deg;F                    Consistent with the generic developers CNMT P-Loss            restoration procedure)              AND                            notes 1200&deg;F CET temperature is used.
CNB2 2              AND                                Restoration procedures not        Added Note 1 consistent with other
: 2. Restoration procedure not          effective within 15 min. (Note 1) thresholds with a timing component.
effective within 15 minutes.
10,000[12,000] R/hr (10,300[12,100] R/hr rounded for readability) reading in the containment is used to indicate a potential loss of the containment barrier and a release of RCS Activity/CMNT Rad                      Containment high range            reactor coolant, with significant activity CNMT P-Loss  A. Containment radiation monitor          radiation monitor RE-8060/8061    indicative of 20% fuel damage, into the CNB3 3          reading greater than                  [2RE-8925-1/8925-2] reading      containment. This value assumes an (site-specific value).                > 10,000[12,000] R/hr            instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with a concentration associated with 20% clad damage into the containment atmosphere.
to 0CAN031801 Page 75 of 120 ANO NEI FPB#              NEI IC Wording                              ANO FPB Wording                  Difference/Deviation Justification FPB #(s)
Containment pressure                73.7 psia is the site specific CNMT Integrity or Bypass            CNB6
                                                            > 73.7 psia.                        containment design pressure.
A. Containment pressure greater than (site-specific value)
OR B. Explosive mixture exists                                                      3% hydrogen concentration in the inside containment                        Containment hydrogen CNB7                                        presence of oxygen represents an concentration > 3%.
OR                                                                              explosive mixture in containment.
CNMT P-Loss C. 1. Containment pressure 4                greater than (site-specific pressure setpoint)                                                        The Containment pressure setpoint is AND                                                                        the pressure at which the Containment
: 2. Less than one full train of          Containment pressure > 44.7 psia    Spray System should actuate and begin (site-specific system or            [23.3 psia] with < one full train of performing its function.
equipment) is operating      CNB8    containment heat removal            Added Note 1 consistent with other per design for 15 minutes            systems (Note 9) operating per      thresholds with a timing component.
or longer.                          design for  15 min. (Note 1)        Added Note 9 to clarify what constitutes a full train of containment heat removal systems.
CNMT P-Loss  Other Indications                                                                No other site-specific Containment A. (site-specific as applicable)      N/A    N/A                                  Potential Loss indication has been 5                                                                                          identified for ANO.
Emergency Director Judgment Any condition in the opinion of CNMT P-Loss  A. ANY condition in the opinion              the Emergency Director that of the Emergency Director        CNB10                                        None 6                                                    indicates potential loss of the that indicates Potential Loss            containment barrier.
of the Containment barrier.
to 0CAN031801 Page 76 of 120 Category H Hazards and Other Conditions Affecting Plant Safety NEI                                      ANO NEI IC Wording                                ANO IC Wording                          Difference/Deviation Justification IC#                                      IC#(s)
Confirmed SECURITY                        Confirmed SECURITY CONDITION or HU1    CONDITION or threat                HU1    threat.                                    None MODE: All                                MODE: All NEI Ex.                                    ANO NEI Example EAL Wording                            ANO EAL Wording                          Difference/Deviation Justification EAL #                                    EAL #
A SECURITY CONDITION                      A SECURITY CONDITION that does that does not involve a                  not involve a HOSTILE ACTION as 1    HOSTILE ACTION as                        reported by ANO Security Shift reported by the (site-specific            Supervision security shift supervision).                OR                                      Example EALs #1, 2 and 3 have been combined Notification of a credible        HU1.1  Notification of a credible security threat into a single EAL for ease of presentation and 2    security threat directed at the          directed at the site                      use.
site.                                        OR A validated notification from            A validated notification from the NRC 3    the NRC providing information            providing information of an aircraft of an aircraft threat.                    threat.
to 0CAN031801 Page 77 of 120 NEI                                      ANO NEI IC Wording                            ANO IC Wording                      Difference/Deviation Justification IC#                                    IC#(s)
Seismic event greater than              Seismic event greater than OBE HU2    OBE levels.                      HU2  levels.                                None MODE: All                              MODE: All NEI Ex.                                  ANO NEI Example EAL Wording                        ANO EAL Wording                      Difference/Deviation Justification EAL #                                    EAL #
Seismic event greater than Operating Basis Earthquake (OBE) as indicated by:                  Seismic event > OBE as indicated by    The ANO OBE alarm is located on the seismic 1                                      HU2.1  annunciation of the 0.10 g acceleration network control center, C529-NCC in the Unit 1 (site-specific indication that a        alarm                                  Control Room.
seismic event met or exceeded OBE limits) to 0CAN031801 Page 78 of 120 NEI                                        ANO NEI IC Wording                                ANO IC Wording                      Difference/Deviation Justification IC#                                        IC#(s)
Hazardous event.                          Hazardous event.
HU3                                        HU3                                              None MODE: All                                  MODE: All NEI Ex.                                      ANO NEI Example EAL Wording                            ANO EAL Wording                      Difference/Deviation Justification EAL #                                      EAL #
A tornado strike within the                A tornado strike within the 1                                        HU3.1                                            None PROTECTED AREA.                            PROTECTED AREA.
Internal room or area flooding of          Internal room or area FLOODING of a a magnitude sufficient to require          magnitude sufficient to require manual Replaced the word needed with required manual or automatic electrical            or automatic electrical isolation of a 2                                        HU3.2                                            by Technical Specifications consistent isolation of a SAFETY SYSTEM              SAFETY SYSTEM component with the generic bases.
component needed for the                  required by Technical Specifications current operating mode.                    for the current operating mode.
Movement of personnel within              Movement of personnel within the the PROTECTED AREA is                      PROTECTED AREA is IMPEDED due              Changed the term offsite to external to the impeded due to an offsite event            to an event external to the                PROTECTED AREA to address events 3                                        HU3.3 involving hazardous materials              PROTECTED AREA involving                  located external to the PROTECTED AREA (e.g., an offsite chemical spill or        hazardous materials (e.g., an offsite      but not considered offsite.
toxic gas release).                        chemical spill or toxic gas release).
A hazardous event that results in A hazardous event that results in on-on-site conditions sufficient to site conditions sufficient to prohibit the 4    prohibit the plant staff from      HU4.1                                            Added reference to Note 7.
plant staff from accessing the site via accessing the site via personal personal vehicles. (Note 7) vehicles.
(Site-specific list of natural or                                                    No other site-specific hazard has been 5                                          N/A  N/A technological hazard events)                                                          identified for ANO.
EAL #3 does not apply to routine          Note 7: This EAL does not apply to traffic impediments such as fog,                      routine traffic impediments    This note, designated Note #7, is intended to Note  snow, ice, or vehicle                N/A              such as fog, snow, ice, or      apply to generic example EAL #4, not #3 as breakdowns or accidents.                              vehicle breakdowns or          specified in the generic guidance.
accidents.
to 0CAN031801 Page 79 of 120 NEI                                          ANO NEI IC Wording                              ANO IC Wording                    Difference/Deviation Justification IC#                                        IC#(s)
FIRE potentially degrading the              FIRE potentially degrading the level of HU4    level of safety of the plant.        HU4  safety of the plant.                    None MODE: All                                  MODE: All NEI Ex.                                      ANO NEI Example EAL Wording                            ANO EAL Wording                    Difference/Deviation Justification EAL #                                        EAL #
: a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:                          A FIRE is not extinguished within 15 min. of any of the following FIRE Report from the field              detection indications (Note 1):
(i.e., visual observation)
Report from the field (i.e., visual Receipt of multiple (more                observation) than 1) fire alarms or indications                          Receipt of multiple (more than 1)  Table 1[2]H-1 provides a tabularized list of 1                                          HU4.1      fire alarms or indications        site-specific fire areas.
Field verification of a single fire alarm                    Field verification of a single fire alarm AND AND
: b. The FIRE is located within ANY of the following plant            The FIRE is located within any rooms or areas:                      Table 1[2]H-1 area.
(site-specific list of plant rooms or areas) to 0CAN031801 Page 80 of 120 NEI Ex.                                    ANO NEI Example EAL Wording                          ANO EAL Wording                    Difference/Deviation Justification EAL #                                      EAL #
: a. Receipt of a single fire                                                    Table 1[2]H-1 provides a tabularized list of alarm (i.e., no other                                                      site-specific fire areas.
indications of a FIRE).                                                    In addition, the wording in the Basis section AND                                                                            supporting fire detection and response
: b. The FIRE is located within                                                    design is modified to remove specific ANY of the following plant        Receipt of a single fire alarm (i.e., no reference to 10 CFR 50, Appendix R. The rooms or areas:                    other indications of a FIRE)            Basis statement relating to Criterion 3 of AND                                  10 CFR 50, Appendix A is maintained, along (site-specific list of plant The fire alarm is indicating a FIRE      with generic statements that are applicable rooms or areas) 2                                        HU4.2 within any Table 1[2]H-1 area            without regard to Appendix R. Both ANO AND                                                                            units are NFPA 805 plants; therefore, the
: c. The existence of a FIRE is                AND                                  requirements of Appendix R are no longer not verified within                The existence of a FIRE is not verified  applicable. This wording is a difference 30-minutes of alarm receipt.      within 30 min. of alarm receipt.        from NEI 99-01, Revision 6, HU4 generic (Note 1)                                wording and bases. This difference is acceptable in order eliminate reference to an inappropriate licensing basis while maintaining sufficient information to address fire prevention and fire system functions A FIRE within the plant or ISFSI
[for plants with an ISFSI outside A FIRE within the PROTECTED AREA the plant Protected Area]
not extinguished within 60 min. of the  ANO has an ISFSI located inside the plant 3    PROTECTED AREA not                HU4.3 initial report, alarm or indication. Protected Area.
extinguished within 60-minutes (Note 1) of the initial report, alarm or indication.
A FIRE within the plant or ISFSI
[for plants with an ISFSI outside A FIRE within the PROTECTED AREA the plant Protected Area]
that requires firefighting support by an ANO has an ISFSI located inside the plant 4    PROTECTED AREA that                HU4.4 offsite fire response agency to          Protected Area.
requires firefighting support by extinguish an offsite fire response agency to extinguish.
to 0CAN031801 Page 81 of 120 NEI Ex.                                        ANO NEI Example EAL Wording                              ANO EAL Wording                      Difference/Deviation Justification EAL #                                        EAL #
Note 1: The Emergency Director          The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme Note: The Emergency Director                                                          by referencing the "time limit" specified within promptly upon determining should declare the                                                            the EAL wording.
that the time limit has been Unusual Event promptly exceeded, or will likely be    Added The Emergency Director is not Note            upon determining that        N/A exceeded. The Emergency        allowed an additional 15 minutes to declare the applicable time has Director is not allowed an      after the time limit is exceeded. To reinforce been exceeded, or will additional 15 minutes to        the concept that the EAL timing component likely be exceeded.
declare after the time limit is runs concurrent with the classification exceeded.                      timeliness clock.
Table 1H-1  Unit 1 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Penthouse/MSIV Room Exceptions:
Boric Acid Mix Tank Room (Chem Add Area), 404 (157-B), EDG Exhaust Fan area on 386 (1-E and 2-E)
Turbine Building All elevations including: Pipechase under ICW Coolers, CRD Pump Pit/T-28 Room/Area under ICW Pumps Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)
Manholes adjacent to Intake Structure (MH-05/MH-06)
Intake Structure (354 and 366)
Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10) to 0CAN031801 Page 82 of 120 Table 2H-1 Unit 2 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Aux Extension Turbine Building All elevations Outside Areas Intake Structure (354 and 366)
Concrete Manhole East, NE of intake (2MH-01)
Concrete Manhole East of Turbine Building next to train bay (2MH-03)
Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10) to 0CAN031801 Page 83 of 120 NEI                                        ANO NEI IC Wording                                ANO IC Wording                    Difference/Deviation Justification IC#                                        IC#(s)
Other conditions exist which in Other conditions exist that in the the judgment of the Emergency judgment of the Emergency Director HU7    Director warrant declaration of a    HU7                                              None warrant declaration of a UE.
(NO)UE.
MODE: All MODE: All NEI Ex.                                      ANO NEI Example EAL Wording                            ANO EAL Wording                    Difference/Deviation Justification EAL #                                      EAL #
Other conditions exist which in the judgment of the Emergency              Other conditions exist which in the Director indicate that events are          judgment of the Emergency Director in progress or have occurred              indicate that events are in progress or which indicate a potential                have occurred which indicate a degradation of the level of safety        potential degradation of the level of of the plant or indicate a security        safety of the plant or indicate a security 1                                        HU7.1                                            None threat to facility protection has          threat to facility protection has been been initiated. No releases of            initiated. No releases of radioactive radioactive material requiring            material requiring offsite response or offsite response or monitoring            monitoring are expected unless further are expected unless further                degradation of SAFETY SYSTEMS degradation of safety systems              occurs.
occurs.
to 0CAN031801 Page 84 of 120 NEI                                      ANO NEI IC Wording                              ANO IC Wording                  Difference/Deviation Justification IC#                                      IC#(s)
HOSTILE ACTION within the HOSTILE ACTION within the OWNER OWNER CONTROLLED AREA CONTROLLED AREA or airborne HA1    or airborne attack threat within  HA1                                            None attack threat within 30 minutes.
30 minutes.
MODE: All MODE: All NEI Ex.                                    ANO NEI Example EAL Wording                          ANO EAL Wording                  Difference/Deviation Justification EAL #                                    EAL #
A HOSTILE ACTION is occurring            A HOSTILE ACTION is occurring or or has occurred within the              has occurred within the OWNER 1    OWNER CONTROLLED AREA                    CONTROLLED AREA as reported by as reported by the (site-specific        ANO Security Shift Supervision          Example EALs #1 and #2 have been security shift supervision).      HA1.1 OR                                    combined into a single EAL for ease of use.
A validated notification from            A validated notification from NRC of an 2    NRC of an aircraft attack threat        aircraft attack threat within 30 min. of within 30 minutes of the site.          the site.
to 0CAN031801 Page 85 of 120 NEI                                          ANO NEI IC Wording                              ANO IC Wording                  Difference/Deviation Justification IC#                                        IC#(s)
Gaseous release impeding                    Gaseous release IMPEDING access to access to equipment necessary              equipment necessary for normal plant  The mode applicability has been limited to HA5    for normal plant operations,          HA5  operations, cooldown or shutdown.      the modes restrictions of Table H-2, Modes 3 cooldown or shutdown.                      MODE: 3 - Hot Standby, 4 - Hot        and 4 only.
MODE: All                                  Shutdown NEI Ex.                                      ANO NEI Example EAL Wording                            ANO EAL Wording                  Difference/Deviation Justification EAL #                                        EAL #
: a. Release of a toxic, corrosive,                                                  The site-specific list of plant rooms or areas asphyxiant or flammable gas                                                  with entry-related mode applicability are into any of the following plant                                              tabularized in Table 1[2]H-2.
rooms or areas:                                                              The bulleted bases item the action for which (site-specific list of plant          Release of a toxic, corrosive,        room/area entry is required is of an rooms or areas with entry-            asphyxiant or flammable gas into any  administrative or record keeping nature (e.g.,
related mode applicability            Table 1[2]H-2 room or area            normal rounds or routine inspections) was 1                                          HA5.1 identified)                              AND                                removed from the list of exceptions to AND                                      Entry into the room or area is        classification in the basis information. These prohibited or IMPEDED. (Note 5)        actions are a consideration when the site-
: b. Entry into the room or area is specific list was developed. Rooms requiring prohibited or impeded.
entry for these types of actions are already excluded from the list when it was developed.
Note: If the equipment in the Note 5: If the equipment in the listed listed room or area was room or area was already already inoperable or inoperable or out-of-service Note            out-of-service before the  N/A                                          None before the event occurred, event occurred, then no then no emergency emergency classification classification is warranted.
is warranted.
to 0CAN031801 Page 86 of 120 Table 1H-2    Unit 1 Safe Operation & Shutdown Rooms/Areas Room/Area                        Mode A-4 Switchgear Room                                      3, 4 Upper North Electrical Penetration Room                  3, 4 Lower South Electrical Equipment Room                    3, 4 Table 2H-2    Unit 2 Safe Operation & Shutdown Rooms/Areas Room/Area                        Mode Aux Building 317 Emergency Core Cooling Rooms          3, 4 Aux Building 317 Tendon Gallery Access                  3, 4 Aux Building 335 Charging Pumps / MCC 2B-52            3, 4 Aux Building 354 MCC 2B-62 Area                        3, 4 Emergency Diesel Generator Corridor                      3, 4 Lower South Piping Penetration Room                      3, 4 Aux Building 386 Containment Hatch                      3, 4 to 0CAN031801 Page 87 of 120 NEI                                    ANO NEI IC Wording                          ANO IC Wording                    Difference/Deviation Justification IC#                                    IC#(s)
Control Room evacuation                Control Room evacuation resulting in resulting in transfer of plant        transfer of plant control to alternate HA6    control to alternate locations. HA6  locations.                            None MODE: All                              MODE: All NEI Ex.                                  ANO NEI Example EAL Wording                      ANO EAL Wording                    Difference/Deviation Justification EAL #                                  EAL #
An event has resulted in plant control being transferred from An event has resulted in plant control Shutdown activities at ANO are transferred the Control Room to 1                                    HA6.1  being transferred from the Control    from the Control Room to multiple locations (site-specific remote shutdown Room to alternate locations.          within the plant.
panels and local control stations).
to 0CAN031801 Page 88 of 120 NEI                                        ANO NEI IC Wording                                ANO IC Wording                    Difference/Deviation Justification IC#                                        IC#(s)
Other conditions exist which in Other conditions exist that in the the judgment of the Emergency judgment of the Emergency Director HA7    Director warrant declaration of      HA7                                              None warrant declaration of an Alert.
an Alert.
MODE: All MODE: All NEI Ex.                                      ANO NEI Example EAL Wording                            ANO EAL Wording                    Difference/Deviation Justification EAL #                                      EAL #
Other conditions exist which, in the judgment of the Emergency Other conditions exist which, in the Director, indicate that events are judgment of the Emergency Director, in progress or have occurred indicate that events are in progress or which involve an actual or have occurred which involve an actual potential substantial degradation or potential substantial degradation of of the level of safety of the plant the level of safety of the plant or a or a security event that involves 1                                        HA7.1  security event that involves probable      None probable life threatening risk to life threatening risk to site personnel or site personnel or damage to site damage to site equipment because of equipment because of HOSTILE HOSTILE ACTION. Any releases are ACTION. Any releases are expected to be limited to small expected to be limited to small fractions of the EPA Protective Action fractions of the EPA Protective Guideline exposure levels.
Action Guideline exposure levels.
to 0CAN031801 Page 89 of 120 NEI                                          ANO NEI IC Wording                                ANO IC Wording              Difference/Deviation Justification IC#                                        IC#(s)
HOSTILE ACTION within the                  HOSTILE ACTION within the HS1    PROTECTED AREA.                      HS1  PROTECTED AREA.                  None MODE: All                                  MODE: All NEI Ex.                                      ANO NEI Example EAL Wording                          ANO EAL Wording              Difference/Deviation Justification EAL #                                        EAL #
A HOSTILE ACTION is occurring A HOSTILE ACTION is occurring or or has occurred within the has occurred within the PROTECTED 1    PROTECTED AREA as reported          HS1.1                                    None AREA as reported by ANO Security by the (site-specific security shift Shift Supervision.
supervision).
to 0CAN031801 Page 90 of 120 NEI                                        ANO NEI IC Wording                              ANO IC Wording                      Difference/Deviation Justification IC#                                      IC#(s)
Inability to control a key safety function Deleted defueled mode applicability. Control Inability to control a key safety        from outside the Control Room.            of the cited safety functions is not critical for function from outside the Control        MODE: 1 - Power Operation,                a defueled reactor as there is no energy HS6    Room.                              HS6                                              source in the reactor vessel or RCS.
2 - Startup, 3 - Hot Standby, 4 - Hot MODE: All                                Shutdown, 5 - Cold Shutdown,              This is an acceptable deviation from the 6 - Refueling                              generic NEI 99-01 Revision 6 guidance.
NEI Ex.                                    ANO NEI Example EAL Wording                          ANO EAL Wording                      Difference/Deviation Justification EAL #                                      EAL #
: a. An event has resulted in plant control being transferred from the Control Room to (site-specific              An event has resulted in plant control    Shutdown activities at ANO are transferred remote shutdown panels              being transferred from the Control        from the Control Room to multiple locations and local control stations).        Room to alternate locations                within the plant.
AND                                    AND                                    The Mode applicability for the reactivity
: b. Control of ANY of the                  Control of any of the following key        control safety function has been limited to 1          following key safety        HS6.1  safety functions is not reestablished      Modes 1, 2, and 3 (hot operating conditions).
functions is not                    within 15 min. (Note 1):                  In the cold operating modes adequate reestablished within                  Reactivity (Modes 1, 2 and 3          shutdown margin exists under all conditions.
(site-specific number of                only)                                EP FAQ 2015-014.
minutes).
Core cooling                          This is an acceptable deviation from the Reactivity control                                                          generic NEI 99-01 Revision 6 guidance.
RCS heat removal Core cooling [PWR] /
RPV water level [BWR]
RCS heat removal to 0CAN031801 Page 91 of 120 NEI                                        ANO NEI IC Wording                              ANO IC Wording                        Difference/Deviation Justification IC#                                        IC#(s)
Other conditions exist which in            Other conditions exist that in the the judgment of the Emergency              judgment of the Emergency Director HS7    Director warrant declaration of a    HS7  warrant declaration of a Site Area          None Site Area Emergency.                      Emergency.
MODE: All                                  MODE: All NEI Ex.                                      ANO NEI Example EAL Wording                          ANO EAL Wording                        Difference/Deviation Justification EAL #                                      EAL #
Other conditions exist which in the judgment of the Emergency Other conditions exist which in the Director indicate that events are judgment of the Emergency Director in progress or have occurred indicate that events are in progress or which involve actual or likely have occurred which involve actual or major failures of plant functions likely major failures of plant functions needed for protection of the needed for protection of the public or public or HOSTILE ACTION that HOSTILE ACTION that results in results in intentional damage or intentional damage or malicious acts, malicious acts, (1) toward site 1                                        HS7.1  (1) toward site personnel or equipment      None personnel or equipment that that could lead to the likely failure of or, could lead to the likely failure of (2) that prevent effective access to or, (2) that prevent effective equipment needed for the protection of access to equipment needed for the public. Any releases are not the protection of the public. Any expected to result in exposure levels releases are not expected to which exceed EPA Protective Action result in exposure levels which Guideline exposure levels beyond the exceed EPA Protective Action SITE BOUNDARY.
Guideline exposure levels beyond the site boundary.
to 0CAN031801 Page 92 of 120 NEI                                    ANO NEI IC Wording              ANO IC Wording        Difference/Deviation Justification IC#                                    IC#(s)
IC HG1 and associated example EAL are not implemented in the ANO scheme.
There are several other ICs that are redundant with this IC, and are better suited HOSTILE ACTION resulting in                          to ensure timely and effective emergency loss of physical control of the                      declarations. In addition, the development of HG1    facility.                        N/A        N/A new spent fuel pool level EALs, as a result of MODE: All                                            NRC Order EA-12-051, clarified the intended emergency classification level for spent fuel pool level events.
This is an acceptable deviation from the generic NEI 99-01 Revision 6 guidance.
to 0CAN031801 Page 93 of 120 NEI Ex. NEI Example EAL        ANO  ANO EAL Difference/Deviation Justification EAL #            Wording          EAL # Wording IC HG1 and associated example EAL are not implemented in the ANO scheme.
: a. A HOSTILE                            There are several other ICs that are redundant with this IC, and are better suited to ACTION is                          ensure timely and effective emergency declarations. In addition, the development of occurring or has                    new spent fuel pool level EALs, as a result of NRC Order EA-12-051, clarified the occurred within the                intended emergency classification level for spent fuel pool level events. This deviation PROTECTED                          is justified because:
AREA as reported by the (site-specific              1. Hostile Action in the Protected Area is bounded by ICs HS1 and HS7. Hostile security shift                          Action resulting in a loss of physical control is bound by EAL HG7, as well as any supervision).                          event that may lead to radiological releases to the public in excess of Environmental Protection Agency (EPA) Protective Action Guides (PAGs).
AND
: a. If, for whatever reason, the Control Room must be evacuated, and control of
: b. EITHER of the                                  safety functions (e.g., reactivity control, core cooling, and RCS heat removal) following has                                cannot be reestablished, then IC HS6 would apply, as well as IC HS7 if desired occurred:                                    by the EAL decision-maker.
: 1. ANY of the                          b. Also, as stated above, any event (including Hostile Action) that could following safety                        reasonably be expected to have a release exceeding EPA PAGs would be functions                                bound by IC HG7.
1              cannot be        N/A    N/A controlled or                      c. From a Hostile Action perspective, ICs HS1, HS7 and HG7 are appropriate, and maintained.                              therefore, make this part of HG1 redundant and unnecessary.
Reactivity                      d. From a loss of physical control perspective, ICs HS6, HS7 and HG7 are control                              appropriate, and therefore, make this part of HG1 redundant and unnecessary.
Core cooling                2. Any event which causes a loss of spent fuel pool level will be bounded by ICs AA2,
[PWR]/RPV                      AS2 and AG2, regardless of whether it was based upon a Hostile Action or not, thus water level                    making this part of HG1 redundant and unnecessary.
[BWR]                          a. An event that leads to a radiological release will be bounded by ICs AU1, AA1, RCS heat                              AS1 and AG1. Events that lead to radiological releases in excess of EPA PAGs removal                              will be bounded by EALs AG1 and HG7, thus making this part of HG1 redundant and unnecessary.
OR ICs AA2, AS2, AG2, AS1, AG1, HS1, HS6, HS7 and HG7 have been implemented
: 2. Damage to                        consistent with NEI 99-01, Revision 6, and thus HG1 is adequately bounded as spent fuel has                described above.
occurred or is IMMINENT.                      EP FAQ 2015-013 This is an acceptable deviation from the generic NEI 99-01 Revision 6 guidance.
to 0CAN031801 Page 94 of 120 NEI                                      ANO NEI IC Wording                              ANO IC Wording                  Difference/Deviation Justification IC#                                      IC#(s)
Other conditions exist which in          Other conditions exist that in the the judgment of the Emergency            judgment of the Emergency Director HG7    Director warrant declaration of a  HG7  warrant declaration of a General        None General Emergency.                      Emergency.
MODE: All                                MODE: All NEI Ex.                                    ANO NEI Example EAL Wording                          ANO EAL Wording                  Difference/Deviation Justification EAL #                                    EAL #
Other conditions exist which in the judgment of the Emergency            Other conditions exist which in the Director indicate that events are        judgment of the Emergency Director in progress or have occurred            indicate that events are in progress or which involve actual or                  have occurred which involve actual or IMMINENT substantial core                IMMINENT substantial core degradation or melting with              degradation or melting with potential potential for loss of containment        for loss of containment integrity or 1                                      HG7.1                                          None integrity or HOSTILE ACTION              HOSTILE ACTION that results in an that results in an actual loss of        actual loss of physical control of the physical control of the facility.        facility. Releases can be reasonably Releases can be reasonably              expected to exceed EPA Protective expected to exceed EPA                  Action Guideline exposure levels Protective Action Guideline              offsite for more than the immediate site exposure levels offsite for more        area.
than the immediate site area.
to 0CAN031801 Page 95 of 120 Category S System Malfunction NEI                                    ANO NEI IC Wording                        ANO IC Wording                        Difference/Deviation Justification IC#                                  IC#(s)
Loss of all offsite AC power Loss of all offsite AC power capability capability to emergency buses to vital buses for 15 minutes or longer.
for 15 minutes or longer.                                                      vital buses is the ANO-specific terminology SU1                                    SU1  MODE: 1 - Power Operation, MODE: Power Operation,                                                          for emergency buses.
2 - Startup, 3 - Hot Standby, 4 - Hot Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex.                                ANO NEI Example EAL Wording                      ANO EAL Wording                        Difference/Deviation Justification EAL #                                  EAL #
Loss of ALL offsite AC power          Loss of all offsite AC power capability,  4.16 KV buses A3[2A3] and A4[2A4] are the capability to (site-specific          Table 1[2]S-1, to vital 4.16 KV buses    site-specific emergency buses.
1                                    SU1.1 emergency buses) for                  A3[2A3] and A4[2A4] for  15 min.        Site-specific AC power sources are 15 minutes or longer.                (Note 1)                                  tabularized in Table 1[2]S-1.
Note 1: The Emergency Director            The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme promptly upon determining      by referencing the "time limit" specified within The Emergency Director should                                                  the EAL wording.
that the time limit has been declare the Unusual Event exceeded, or will likely be    Added The Emergency Director is not Note  promptly upon determining that  N/A exceeded. The Emergency        allowed an additional 15 minutes to declare 15 minutes has been exceeded, Director is not allowed an      after the time limit is exceeded. To reinforce or will likely be exceeded.
additional 15 minutes to        the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded.                      timeliness clock.
to 0CAN031801 Page 96 of 120 Table 1S-1    Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)
Onsite Unit Auxiliary Transformer (main generator via main transformer)
DG1 DG2 AAC Gen Table 2S-1    Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)
Onsite Unit Auxiliary Transformer (main generator via main transformer) 2DG1 2DG2 AAC Gen to 0CAN031801 Page 97 of 120 NEI                                        ANO NEI IC Wording                              ANO IC Wording                        Difference/Deviation Justification IC#                                      IC#(s)
UNPLANNED loss of Control UNPLANNED loss of Control Room Room indications for 15 minutes indications for 15 minutes or longer.
or longer.
SU2                                        SU3  MODE: 1 - Power Operation,                None MODE: Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex.                                    ANO NEI Example EAL Wording                          ANO EAL Wording                        Difference/Deviation Justification EAL #                                      EAL #
An UNPLANNED event results                An UNPLANNED event results in the          The site-specific Safety System Parameter in the inability to monitor one or        inability to monitor one or more          list is tabulated in Table 1[2]S-2.
1    more of the following parameters  SU3.1  Table 1[2]S-2 parameters from within      Added the words to at least one S/G to from within the Control Room for          the Control Room for  15 min.            Auxiliary or emergency feedwater flow. This 15 minutes or longer.                    (Note 1)                                  is consistent with Level in at least on S/G.
Note 1: The Emergency Director            The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme promptly upon determining      by referencing the "time limit" specified within The Emergency Director should                                                        the EAL wording.
that the time limit has been declare the Unusual Event exceeded, or will likely be    Added The Emergency Director is not Note  promptly upon determining that      N/A exceeded. The Emergency        allowed an additional 15 minutes to declare 15 minutes has been exceeded, Director is not allowed an      after the time limit is exceeded. To reinforce or will likely be exceeded.
additional 15 minutes to        the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded.                      timeliness clock.
to 0CAN031801 Page 98 of 120
[BWR parameter list]                                [PWR parameter list]
Reactor Power                        Reactor Power RPV Water Level                      RCS Level RPV Pressure                        RCS Pressure Primary Containment Pressure        In-Core/Core Exit Temperature Suppression Pool Level              Levels in at least (site-specific number) steam generators Suppression Pool Temperature        Steam Generator Auxiliary or Emergency Feed Water Flow Table 1[2]S-2    Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one S/G EFW flow to at least one S/G to 0CAN031801 Page 99 of 120 NEI                                      ANO NEI IC Wording                            ANO IC Wording                      Difference/Deviation Justification IC#                                      IC#(s)
Reactor coolant activity greater        RCS activity greater than Technical than Technical Specification            Specification allowable limits.
allowable limits                        MODE: 1 - Power Operation,              Changed Reactor coolant to read RCS for SU3                                      SU4 MODE: Power Operation,                  2 - Startup, 3 - Hot Standby, 4 - Hot    consistency with normally used terminology.
Startup, Hot Standby, Hot                Shutdown Shutdown NEI Ex.                                    ANO NEI Example EAL Wording                        ANO EAL Wording                      Difference/Deviation Justification EAL #                                    EAL #
Unit 1 RE-1237S, Failed Fuel Monitor, is in the letdown system to monitor the letdown (Site-specific radiation monitor)        Failed Fuel Iodine radiation monitor    line for evidence of fuel damage.
1    reading greater than (site-      SU4.1  RI-1237S[2RITS-4806B] reading specific value).                        > 9.0 E5 cpm                            Unit 2 specific activity monitor 2RITS-4806B monitors the letdown fluid for the presence of Iodine-131.
RCS sample activity > 1.0 uCi/gm dose    Changed Reactor coolant to read RCS for equivalent I-131 for > 48 hours (Note 1) consistency with normally used terminology.
Sample analysis indicates that a        OR                                      ANO Unit 1 T.S. LCO 3.4.12 and Unit 2 T.S.
reactor coolant activity value is        RCS sample activity > 60 uCi/gm dose    LCO 3.4.8 provides the TS allowable coolant 2    greater than an allowable limit  SU4.2  equivalent I-131                        activity limits that are duplicated in the EAL.
specified in Technical                  OR Specifications.
RCS sample activity
                                                  > 2200[3100] uCi/gm dose equivalent Xe-133 for > 48 hours (Note 1) to 0CAN031801 Page 100 of 120 NEI                                    ANO NEI IC Wording                        ANO IC Wording                        Difference/Deviation Justification IC#                                  IC#(s)
RCS leakage for 15 minutes or RCS leakage for 15 minutes or longer.
longer.
SU4                                    SU5  MODE: 1 - Power Operation,                None MODE: Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex.                                ANO NEI Example EAL Wording                      ANO EAL Wording                        Difference/Deviation Justification EAL #                                  EAL #
RCS unidentified or pressure                                                    Example EALs #1, 2 and 3 have been boundary leakage greater than                                                  combined into a single EAL for usability.
1 (site-specific value) for                                                      Changed the term RCS to Reactor coolant 15 minutes or longer.                RCS unidentified or pressure boundary for the third threshold. For ANO, leakage leakage > 10 gpm for  15 min. (Note 1)
RCS identified leakage greater                                                  outside containment is not termed RCS OR                                    leakage.
2    than (site-specific value) for 15 minutes or longer.                RCS identified leakage > 25 gpm for      Added Failure to isolate the leak (from the SU5.1  15 min. (Note 1)                        Control Room or locally), within 15 minutes OR                                    or if known that the leak cannot be isolated Leakage from the RCS to a            Reactor coolant leakage to a location    within 15 minutes, from the start of the leak location outside containment          outside containment > 25 gpm for          requires immediate classification to the 3                                                                                    basis. This provides agreement with the greater than 25 gpm for                15 min. (Note 1) 15 minutes or longer.                                                          definition of Unisolable and ensures isolation attempts, both locally and remotely, are achieved in a timely manner.
Note 1: The Emergency Director            The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme promptly upon determining      by referencing the "time limit" specified within The Emergency Director should                                                  the EAL wording.
that the time limit has been declare the Unusual Event exceeded, or will likely be    Added The Emergency Director is not Note  promptly upon determining that  N/A exceeded. The Emergency        allowed an additional 15 minutes to declare 15 minutes has been exceeded, Director is not allowed an      after the time limit is exceeded. To reinforce or will likely be exceeded.
additional 15 minutes to        the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded.                      timeliness clock.
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Automatic or manual (trip [PWR]
Automatic or manual trip fails to shut
        / scram [BWR]) fails to shutdown SU5                                      SU6  down the reactor.                        None the reactor.
MODE: 1 - Power Operation MODE: Power Operation NEI Ex.                                    ANO NEI Example EAL Wording                          ANO EAL Wording                    Difference/Deviation Justification EAL #                                    EAL #
As specified in the generic developers guidance Developers may include site-An automatic trip did not shut down      specific EOP criteria indicative of a the reactor as indicated by reactor      successful reactor shutdown in an EAL
: a. An automatic (trip [PWR] /        power > 5% after any RPS setpoint is    statement, the Basis or both (e.g., a reactor scram [BWR]) did not              exceeded                                power level). Reactor power < 5% is the shutdown the reactor.
AND                                  site-specific indication of a successful reactor AND                                                                            trip.
1    b. A subsequent manual            SU6.1  A subsequent automatic trip or manual Added the words "... as indicated by reactor action taken at the reactor        trip action taken at the reactor control power > 5% after any RPS setpoint is control consoles is                console (C03[2C03/2C14]) (manual exceeded" to clarify that it is a failure of the successful in shutting down        reactor trip pushbuttons or automatic trip when a valid trip signal has the reactor.                      DROPS[DSS]) is successful in shutting been exceeded.
down the reactor as indicated by reactor power  5% (Note 8)              Panels C03[2C03/2C14] are the site-specific reactor control consoles with manual trip capability.
to 0CAN031801 Page 102 of 120 NEI Ex.                                      ANO NEI Example EAL Wording                            ANO EAL Wording                      Difference/Deviation Justification EAL #                                        EAL #
: a. A manual trip ([PWR] /                                                        As specified in the generic developers scram [BWR]) did not                                                          guidance Developers may include shutdown the reactor.                                                        site-specific EOP criteria indicative of a A manual trip did not shut down the      successful reactor shutdown in an EAL AND reactor as indicated by reactor power    statement, the Basis or both (e.g., a reactor
: b. EITHER of the following:                > 5% after any manual trip action was    power level). Reactor power < 5% is the
: 1. A subsequent manual              initiated                                site-specific indication of a successful reactor action taken at the                                                      trip.
AND reactor control                                                          Added the words "... as indicated by reactor 2              consoles is successful    SU6.2 A subsequent automatic trip or manual    power > 5% after any manual trip action was in shutting down the            trip action taken at the reactor control initiated" to clarify that it is a failure of any reactor.                        console (C03[2C03/2C14]) (manual        manual trip when an actual manual trip signal OR                                reactor trip pushbuttons or              has been inserted.
DROPS[DSS]) is successful in shutting 2    A subsequent                    down the reactor as indicated by        Combined conditions b.1 and b.2 into a automatic (trip [PWR] /        reactor power  5% (Note 8)              single statement to simplify the presentation.
scram [BWR]) is                                                          Panels C03[2C03/2C14] are the site-specific successful in shutting                                                  reactor control consoles with manual trip down the reactor.                                                        capability.
Note:    A manual action is any operator action, or set          Note 8: A manual action is any of actions, which                          operator action, or set of causes the control rods                    actions, which causes the to be rapidly inserted                    control rods to be rapidly Notes            into the core, and does    N/A            inserted into the core, and    None not include manually                      does not include manually driving in control rods or                driving in control rods or implementation of                          implementation of boron boron injection                            injection strategies.
strategies.
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Loss of all onsite or offsite        Loss of all onsite or offsite communications capabilities.        communications capabilities.
SU6    MODE: Power Operation,        SU7  MODE: 1 - Power Operation,            None Startup, Hot Standby, Hot            2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown                            Shutdown NEI Ex.                                ANO NEI Example EAL Wording                    ANO EAL Wording                  Difference/Deviation Justification EAL #                                EAL #
Loss of ALL of the following onsite communication methods:
1 (site-specific list of communications methods)              Loss of all Table 1[2]S-4 onsite      Example EALs #1, 2 and 3 have been communication methods                combined into a single EAL for simplification Loss of ALL of the following            OR                                of presentation.
ORO communications methods:
2                                          Loss of all Table 1[2]S-4 State and  Replaced ORO with State and local (site-specific list of        SU7.1 local agency communication methods    agency for clarification.
communications methods)                OR                                Table 1[2]S-4 provides a site-specific list of Loss of all Table 1[2]S-4 NRC        onsite, State and local agency (ORO) and Loss of ALL of the following                                              NRC communications methods.
communication methods.
NRC communications methods:
3 (site-specific list of communications methods) to 0CAN031801 Page 104 of 120 Table 1[2]S-4 Communication Methods System                  Onsite    State/Local NRC Station radio system                            X ANO plant phone system                          X Gaitronics                                      X Telephone Systems:
Commercial Microwave                                            X      X Satellite VOIP INFORM Notification System                                  X Emergency Notification System (ENS)                                X to 0CAN031801 Page 105 of 120 NEI                                      ANO NEI IC Wording                            ANO IC Wording                    Difference/Deviation Justification IC#                                      IC#(s)
Failure to isolate containment or Failure to isolate containment or loss loss of containment pressure of containment pressure control.
control. [PWR]
SU7                                      SU8  MODE: 1 - Power Operation,            None MODE: Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex.                                    ANO NEI Example EAL Wording                        ANO EAL Wording                    Difference/Deviation Justification EAL #                                    EAL #
: a. Failure of containment to                                                Reworded EAL to better describe the intent.
isolate when required by an                                              Penetrations cannot close, but they can be actuation signal.                                                        isolated by closure of one or more isolation AND                                                                          valves associated with that penetration. The 1                                                                                    revised wording maintains the generic
: b. ALL required penetrations example EAL intent while more clearly are not closed within Any penetration is not closed within  describing failure to isolate threshold.
15 minutes of the actuation signal.                            15 min. of an ESAS[CIAS] actuation    ESAS[CIAS] is the site-specific system that signal                                initiates containment isolation signals.
: a. Containment pressure                  OR                                The Containment pressure setpoint is the greater than (site-specific SU8.1                                        pressure at which the Containment Spray Containment pressure > 44.7 psia pressure).                                                                System should actuate and begin performing
[23.3 psia] with < one full train of AND                                  containment heat removal systems      its function.
: b. Less than one full train of          (Note 9) operating per design for      Added statement to the NEI basis that 2          (site-specific system or            15 min. (Note 1)                    penetrations are considered closed when equipment) is operating per                                              one of the two associated valves are closed design for 15 minutes or                                                  or a check valve is intact. This change longer.                                                                  provides clarification and meets the intent of the EAL of ensuring that a functional boundary is maintained between the containment and the outside environment.
to 0CAN031801 Page 106 of 120 NEI Ex.                            ANO NEI Example EAL Wording                ANO EAL Wording                      Difference/Deviation Justification EAL #                              EAL #
Note 1: The Emergency Director          The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme promptly upon determining      by referencing the "time limit" specified within that the time limit has been    the EAL wording.
exceeded, or will likely be    Added The Emergency Director is not N/A    N/A                          N/A exceeded. The Emergency        allowed an additional 15 minutes to declare Director is not allowed an      after the time limit is exceeded. To reinforce additional 15 minutes to        the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded.                      timeliness clock.
Note 9: One full train of containment heat removal systems consists Added new Note 9 to clarify what constitutes of one train of N/A    N/A                          N/A                                          one full train of containment heat removal RB[Containment] Spray and systems.
one train of RB[Containment]
Cooling System.
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Loss of all but one AC power source to emergency buses for                Loss of all but one AC power source 15 minutes or longer.                        to vital buses for 15 minutes or longer. vital buses is the ANO-specific terminology SA1                                          SA1 for emergency buses.
MODE: Power Operation,                      MODE: 1 - Power Operation Startup NEI Ex.                                        ANO NEI Example EAL Wording                              ANO EAL Wording                      Difference/Deviation Justification EAL #                                        EAL #
: a. AC power capability to (site-specific emergency buses)              AC power capability, Table 1[2]S-1, to is reduced to a single power          vital 4.16 KV buses A3[2A3] and source for 15 minutes or              A4[2A4] reduced to a single power        4.16KV buses A3[2A3] and A4[2A4] are the longer.                                source for  15 min. (Note 1)            site-specific emergency buses.
1                                          SA1.1 AND                                            AND                                  Site-specific AC power sources are listed in
: b. Any additional single power              Any additional single power source        Table 1[2]S-1.
source failure will result in a        failure will result in loss of all AC loss of all AC power to                power to SAFETY SYSTEMS.
SAFETY SYSTEMS.
Note 1: The Emergency Director            The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme promptly upon determining      by referencing the "time limit" specified within The Emergency Director should                                                          the EAL wording.
that the time limit has been declare the Alert promptly upon exceeded, or will likely be    Added The Emergency Director is not Note  determining that 15 minutes has        N/A exceeded. The Emergency        allowed an additional 15 minutes to declare been exceeded, or will likely be Director is not allowed an      after the time limit is exceeded. To reinforce exceeded.
additional 15 minutes to        the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded.                      timeliness clock.
to 0CAN031801 Page 108 of 120 Table 1S-1    Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)
Onsite Unit Auxiliary Transformer (main generator via main transformer)
DG1 DG2 AAC Gen Table 2S-1    Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)
Onsite Unit Auxiliary Transformer (main generator via main transformer) 2DG1 2DG2 AAC Gen to 0CAN031801 Page 109 of 120 NEI                                        ANO NEI IC Wording                              ANO IC Wording                        Difference/Deviation Justification IC#                                      IC#(s)
UNPLANNED loss of Control UNPLANNED loss of Control Room Room indications for 15 minutes indications for 15 minutes or longer or longer with a significant with a significant transient in progress.
SA2    transient in progress.              SA3                                            None MODE: 1 - Power Operation, MODE: Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex.                                    ANO NEI Example EAL Wording                          ANO EAL Wording                        Difference/Deviation Justification EAL #                                      EAL #
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.
AND ANY of the following transient            An UNPLANNED event results in the events in progress.                      inability to monitor one or more          The site-specific Safety System Parameter Table 1[2]S-2 parameters from within      list to listed in Table 1[2]S-2.
Automatic or manual                  the Control Room for  15 min.
runback greater than 25%                                                    The site-specific significant transients list to 1                                        SA3.1  (Note 1) thermal reactor power                                                        listed in Table 1[2]S-3.
AND                                  ANO is a PWR and thus does not include Electrical load rejection greater than 25% full              Any significant transient is in progress, thermal power oscillations > 10%.
electrical load                    Table 1[2]S-3 Reactor scram [BWR] / trip
[PWR]
ECCS (SI) actuation Thermal power oscillations greater than 10% [BWR]
to 0CAN031801 Page 110 of 120 NEI Ex.                                ANO NEI Example EAL Wording                  ANO EAL Wording                      Difference/Deviation Justification EAL #                                  EAL #
Note 1: The Emergency Director          The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme promptly upon determining      by referencing the "time limit" specified within The Emergency Director should                                                the EAL wording.
that the time limit has been declare the Unusual Event exceeded, or will likely be    Added The Emergency Director is not Note  promptly upon determining that  N/A exceeded. The Emergency        allowed an additional 15 minutes to declare 15 minutes has been exceeded, Director is not allowed an      after the time limit is exceeded. To reinforce or will likely be exceeded.
additional 15 minutes to        the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded.                      timeliness clock.
to 0CAN031801 Page 111 of 120
[BWR parameter list]                                [PWR parameter list]
Reactor Power                        Reactor Power RPV Water Level                      RCS Level RPV Pressure                          RCS Pressure Primary Containment Pressure          In-Core/Core Exit Temperature Suppression Pool Level                Levels in at least (site-specific number) steam generators Suppression Pool Temperature          Steam Generator Auxiliary or Emergency Feed Water Flow Table 1[2]S-2    Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one S/G EFW flow to at least one S/G Table 1[2]S-3    Significant Transients Reactor trip Runback > 25% thermal power Electrical load rejection > 25% electrical load Safety injection actuation to 0CAN031801 Page 112 of 120 NEI                                        ANO NEI IC Wording                              ANO IC Wording                      Difference/Deviation Justification IC#                                      IC#(s)
Automatic or manual (trip [PWR]
        / scram [BWR]) fails to shutdown          Automatic or manual trip fails to shut the reactor, and subsequent                down the reactor and subsequent manual actions taken at the                manual actions taken at the reactor SA5    reactor control consoles are not    SA6  control consoles are not successful in  None successful in shutting down the            shutting down the reactor.
reactor.                                  MODE: 1 - Power Operation MODE: Power Operation NEI Ex.                                      ANO NEI Example EAL Wording                          ANO EAL Wording                      Difference/Deviation Justification EAL #                                      EAL #
An automatic or manual trip fails to    As specified in the generic developers
: a. An automatic or manual (trip            shut down the reactor as indicated by    guidance Developers may include site-
[PWR] / scram [BWR]) did              reactor power > 5%                      specific EOP criteria indicative of a not shutdown the reactor.                                                      successful reactor shutdown in an EAL AND                                  statement, the Basis or both (e.g., a reactor AND                                                                              power level). Reactor power < 5% is the 1                                        SA6.1  Manual trip actions taken at the reactor
: b. Manual actions taken at the            control console (C03[2C03/2C14])        site-specific indication of a successful reactor reactor control consoles are          (manual reactor trip pushbuttons or      trip.
not successful in shutting            DROPS[DSS]) are not successful in        Panels C03[2C03/2C14] are the site-specific down the reactor.                    shutting down the reactor as indicated  reactor control consoles with manual trip by reactor power > 5%. (Note 8)          capability.
Note: A manual action is any Note 8:  A manual action is any operator action, or set of operator action, or set of actions, which causes actions, which causes the the control rods to be control rods to be rapidly rapidly inserted into the Notes                                      N/A            inserted into the core, and    None core, and does not does not include manually include manually driving driving in control rods or in control rods or implementation of boron implementation of boron injection strategies.
injection strategies.
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Hazardous event affecting a        Hazardous event affecting SAFETY SAFETY SYSTEM needed for          SYSTEMS needed for the current        Pluralized safety systems to be consistent the current operating mode.        operating mode.                      with NRC EP FAQ 2016-002 that specifies SA9                                SA9.1 MODE: Power Operation,            MODE: 1 - Power Operation,            degraded performance or visible damage in Startup, Hot Standby, Hot          2 - Startup, 3 - Hot Standby, 4 - Hot more than one safety system train.
Shutdown                          Shutdown to 0CAN031801 Page 114 of 120 NEI Ex.                                      ANO NEI Example EAL Wording                            ANO EAL Wording                  Difference/Deviation Justification EAL #                                        EAL #
: a. The occurrence of ANY of the following hazardous events:
Seismic event (earthquake)
Internal or external flooding event                    The occurrence of any Table 1[2]S-5 High winds or tornado              hazardous event                      The hazardous events have been tabularized strike                                  AND                            in Table 1[2]S-5.
FIRE                                Event damage has caused indications  SA9.1 reflects NRC FAQ 2016-002 requiring EXPLOSION                          of degraded performance on one train degraded performance or visible damage to of a SAFETY SYSTEM needed for the    more than one train of a safety system (site-specific hazards)                                                  caused by the specified events.
current operating mode Other events with similar                                                This wording is a deviation from NEI 99-hazard characteristics as              AND EITHER:
01 Revision 6 SA9 generic wording and determined by the Shift                  Event damage has caused      bases but is deemed acceptable in order 1            Manager                      SA9.1          indications of degraded    to ensure that an Alert is declared only AND                                              performance to the second  when a hazardous event causes actual or train of the SAFETY SYSTEM  potential performance issues with safety
: b. EITHER of the following:
needed for the current      systems. This is consistent with
: 1. Event damage has                            operating mode caused indications of                                                NRC-approved EP FAQ 2016-002.
Event damage has resulted in The word a is replaced with the in the degraded performance VISIBLE DAMAGE to the      FAQ wording to provide agreement with the in at least one train of a second train of the SAFETY  FAQ basis information indicating that the SAFETY SYSTEM SYSTEM needed for the      criteria is applicable to another train of the needed for the current current operating mode. same safety system.
operating mode.
(Notes 10, 11)
OR
: 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.
to 0CAN031801 Page 115 of 120 NEI Ex.                                  ANO NEI Example EAL Wording                      ANO EAL Wording                  Difference/Deviation Justification EAL #                                    EAL #
Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service Added Note 10 consistent with the N/A    N/A                              N/A            before the hazardous event recommendation of NRC EP FAQ 2016-002.
occurred, then emergency classification is not warranted Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded Added Note 11 consistent with the N/A    N/A                              N/A            performance to at least one recommendation of NRC EP FAQ 2016-002.
train of a SAFETY SYSTEM, then this emergency classification is not warranted.
Table 1[2]S-5  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 to 0CAN031801 Page 116 of 120 NEI                                        ANO NEI IC Wording                            ANO IC Wording                        Difference/Deviation Justification IC#                                      IC#(s)
Loss of all offsite and all onsite        Loss of all offsite and all onsite AC AC power to emergency buses              power to vital buses for 15 minutes or for 15 minutes or longer.                longer.                                  vital buses is the ANO-specific terminology SS1                                        SS1 MODE: Power Operation,                    MODE: 1 - Power Operation,                for emergency buses.
Startup, Hot Standby, Hot                2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown                                  Shutdown NEI Ex.                                    ANO NEI Example EAL Wording                          ANO EAL Wording                        Difference/Deviation Justification EAL #                                      EAL #
Loss of ALL offsite and ALL Loss of all offsite and all onsite AC onsite AC power to (site-specific                                                  4.16KV buses A3[2A3] and A4[2A4] are the 1                                        SS1.1  power to vital 4.16 KV buses A3[2A3]
emergency buses) for                                                                site-specific emergency buses.
and A4[2A4] for  15 min. (Note 1) 15 minutes or longer.
Note 1: The Emergency Director            The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme promptly upon determining      by referencing the "time limit" specified within The Emergency Director should                                                      the EAL wording.
that the time limit has been declare the Unusual Event exceeded, or will likely be    Added The Emergency Director is not Note  promptly upon determining that      N/A exceeded. The Emergency        allowed an additional 15 minutes to declare 15 minutes has been exceeded, Director is not allowed an      after the time limit is exceeded. To reinforce or will likely be exceeded.
additional 15 minutes to        the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded.                      timeliness clock.
to 0CAN031801 Page 117 of 120 NEI                                      ANO IC#
NEI IC Wording IC#(s)
ANO IC Wording                  Difference/Deviation Justification Inability to shutdown the reactor Inability to shut down the reactor causing a challenge to (core causing a challenge to core cooling or SS5    cooling [PWR] / RPV water level    SS6                                          None RCS heat removal.
[BWR]) or RCS heat removal.
MODE: 1 - Power Operation MODE: Power Operation NEI Ex.                                    ANO NEI Example EAL Wording                          ANO EAL Wording                  Difference/Deviation Justification EAL #                                    EAL #
: a. An automatic or manual (trip [PWR] / scram [BWR])                                                As specified in the generic developers did not shutdown the                                                      guidance Developers may include site-reactor.                          An automatic or manual trip fails to  specific EOP criteria indicative of a AND                                  shut down the reactor as indicated by  successful reactor shutdown in an EAL reactor power > 5%                    statement, the Basis or both (e.g., a reactor
: b. All manual actions to AND                                power level). Reactor power < 5% is the shutdown the reactor have site-specific indication of a successful reactor been unsuccessful.                All actions to shut down the reactor  trip.
AND                                  are not successful as indicated by reactor power > 5%                    Deleted the term manual actions from the 1    c. EITHER of the following        SS6.1 second condition. For generic IC SS5, all conditions exist:                      AND EITHER:                        actions to shut down the reactor can be (Site-specific indication            CETs > 1200&deg;F                    credited, not just those actions from the of an inability to                  RCS heat removal cannot be      reactor control panel that may be identified adequately remove heat              established using steam          as manual actions.
from the core)                      generators and HPI[Once          Indication that heat removal is extremely (Site-specific indication              Through] cooling initiated      challenged is manifested by the loss of both of an inability to                                                    steam generators as a heat sink, requiring adequately remove heat                                                the initiation of HPI [Once Through] cooling.
from the RCS) to 0CAN031801 Page 118 of 120 NEI                                      ANO NEI IC Wording                            ANO IC Wording                      Difference/Deviation Justification IC#                                      IC#(s)
Loss of all Vital DC power for 15        Loss of all vital DC power for minutes or longer.                      15 minutes or longer.
SS8    MODE: Power Operation,            SS2  MODE: 1 - Power Operation,                None Startup, Hot Standby, Hot                2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown                                Shutdown NEI Ex.                                    ANO NEI Example EAL Wording                        ANO EAL Wording                      Difference/Deviation Justification EAL #                                    EAL #
Indicated voltage is less than                                                    105 VDC is the site-specific minimum vital Indicated voltage is < 105 VDC on D01    DC bus voltage.
(site-specific bus voltage value) 1                                      SS2.1  [2D01] and D02[2D02] vital 125 VDC on ALL (site-specific Vital DC                                                    DC buses on D01[2D01] and D02[2D02] are buses for  15 min. (Note 1) busses) for 15 minutes or longer.                                                  the site-specific credited vital DC buses.
Note 1: The Emergency Director            The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme promptly upon determining      by referencing the "time limit" specified within The Emergency Director should                                                      the EAL wording.
that the time limit has been declare the Unusual Event exceeded, or will likely be    Added The Emergency Director is not Note  promptly upon determining that    N/A exceeded. The Emergency        allowed an additional 15 minutes to declare 15 minutes has been exceeded, Director is not allowed an      after the time limit is exceeded. To reinforce or will likely be exceeded.
additional 15 minutes to        the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded.                      timeliness clock.
to 0CAN031801 Page 119 of 120 NEI                                        ANO NEI IC Wording                              ANO IC Wording                        Difference/Deviation Justification IC#                                        IC#(s)
Prolonged loss of all offsite and Prolonged loss of all offsite and all all onsite AC power to onsite AC power to vital buses.
emergency buses.                                                                    vital buses is the ANO-specific terminology SG1                                        SG1a  MODE: 1 - Power Operation, MODE: Power Operation,                                                              for emergency buses.
2 - Startup, 3 - Hot Standby, 4 - Hot Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex.                                      ANO NEI Example EAL Wording                          ANO EAL Wording                        Difference/Deviation Justification EAL #                                      EAL #
: a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses).
Loss of all offsite and all onsite AC AND                                  power to vital 4.16 KV buses A3[2A3]      4.16KV buses A3[2A3] and A4[2A4] are the
: b. EITHER of the following:                and A4[2A4]                              site-specific emergency buses.
Restoration of at least                AND EITHER:                            4 hours is the site-specific SBO coping 1            one AC emergency bus in    SG1.1 Restoration of at least one vital  analysis time.
less than (site-specific                  4.16 KV bus in < 4 hrs is not      CETs reading > 1200&deg;F indicates significant hours) is not likely.                    likely (Note 1)                    core exit superheating and core uncovery.
(Site-specific indication of            CETs > 1200&deg;F an inability to adequately remove heat from the core)
Note 1: The Emergency Director            The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme The Emergency Director should                        promptly upon determining      by referencing the "time limit" specified within declare the General Emergency                        that the time limit has been    the EAL wording.
promptly upon determining that                      exceeded, or will likely be    Added The Emergency Director is not Note                                        N/A            exceeded. The Emergency (site-specific hours) has been                                                      allowed an additional 15 minutes to declare exceeded, or will likely be                          Director is not allowed an      after the time limit is exceeded. To reinforce exceeded.                                            additional 15 minutes to        the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded.                      timeliness clock.
to 0CAN031801 Page 120 of 120 NEI                                        ANO NEI IC Wording                              ANO IC Wording                      Difference/Deviation Justification IC#                                        IC#(s)
Loss of all AC and Vital DC Loss of all vital AC and vital DC power power sources for 15 minutes or sources for 15 minutes or longer.
longer.                                                                              Vital buses is the ANO-specific terminology SG8                                        SG1b  MODE: 1 - Power Operation, MODE: Power Operation,                                                              for emergency buses.
2 - Startup, 3 - Hot Standby, 4 - Hot Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex.                                      ANO NEI Example EAL Wording                          ANO EAL Wording                      Difference/Deviation Justification EAL #                                      EAL #
: a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency            Loss of all offsite and all onsite AC    4.16KV buses A3[2A3] and A4[2A4] are the buses) for 15 minutes or            power to vital 4.16 KV buses A3[2A3]      site-specific emergency buses.
longer.                              and A4[2A4] for  15 min.
1        AND                              SG1.2    AND                                    105 VDC is the site-specific minimum vital DC bus voltage.
: b. Indicated voltage is less              Indicated voltage is < 105 VDC on D01 than (site-specific bus              [2D01] and D02[2D02] vital 125 VDC        D01[2D01] and D02[2D02] are the credited voltage value) on ALL (site-        buses for  15 min. (Note 1)              site-specific vital DC buses.
specific Vital DC busses) for 15 minutes or longer.
Note 1: The Emergency Director            The classification timeliness note has been should declare the event        standardized across the ANO EAL scheme promptly upon determining      by referencing the "time limit" specified within The Emergency Director should                                                        the EAL wording.
that the time limit has been declare the Unusual Event exceeded, or will likely be    Added The Emergency Director is not Note  promptly upon determining that      N/A exceeded. The Emergency        allowed an additional 15 minutes to declare 15 minutes has been exceeded, Director is not allowed an      after the time limit is exceeded. To reinforce or will likely be exceeded.
additional 15 minutes to        the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded.                      timeliness clock.
 
Enclosure 5 to 0CAN031801 Proposed EAL Matrix Chart and Review Table (for information only) to 0CAN031801 Page 1 of 22 UNIT 1 GENERAL EMERGENCY                                                            SITE AREA EMERGENCY                                                                      ALERT                                                UNUSUAL EVENT Release of gaseous radioactivity resulting in offsite dose                        Release of gaseous radioactivity resulting in offsite dose          Release of gaseous OR liquid radioactivity resulting in offsite    Release of gaseous or liquid radioactivity greater than 2 greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE                            greater than 100 mrem TEDE or 500 mrem thyroid CDE                  dose greater than 10 mrem TEDE or 50 mrem thyroid CDE              times the ODCM limits for 60 minutes or longer 1        2      3      4          5      6    DEF                      1          2  3      4          5  6      DEF                    1        2      3        4      5  6      DEF                1      2      3      4      5      6    DEF AG1.1                                                                              AS1.1                                                                AA1.1                                                              AU1.1 Reading on any Table 1A-1 effluent radiation monitor                              Reading on any Table 1A-1 effluent radiation monitor                Reading on any Table 1A-1 effluent radiation monitor                Reading on any Table 1A-1 effluent radiation
                        > column GE for  15 min. (Notes 1, 2, 3, 4)                                    > column SAE for  15 min. (Notes 1, 2, 3, 4)                      > column ALERT for  15 min. (Notes 1, 2, 3, 4)                  monitor > column UE for  60 min. (Notes 1, 2, 3)
AG1.2                                                                              AS1.2                                                                AA1.2                                                              AU1.2 Dose assessment using actual meteorology indicates                                Dose assessment using actual meteorology indicates                  Dose assessment using actual meteorology indicates                  Sample analysis for a gaseous or liquid release doses > 1000 mrem TEDE or 5000 mrem thyroid                                        doses > 100 mrem TEDE or 500 mrem thyroid CDE at                    doses > 10 mrem TEDE or 50 mrem thyroid CDE at or                  indicates a concentration or release rate > 2 x CDE at or beyond the SITE BOUNDARY (Note 4)                                        or beyond the SITE BOUNDARY (Note 4)                                beyond the SITE BOUNDARY (Note 4)                                  ODCM limits for  60 min. (Notes 1, 2) 1        AG1.3 Field survey results indicate EITHER of the following AS1.3 Field survey results indicate EITHER of the following AA1.3 Analysis of a liquid effluent sample indicates a Rad      at or beyond the SITE BOUNDARY:                                                    at or beyond the SITE BOUNDARY:                                      concentration or release rate that would result in doses Effluent                                                                                                                                                            > 10 mrem TEDE or 50 mrem thyroid CDE at or
                          - Closed window dose rates > 1000 mR/hr                                            - Closed window dose rates > 100 mR/hr expected to continue for  60 min.                                                expected to continue for  60 min.                            beyond the SITE BOUNDARY for 60 min. of exposure (Notes 1, 2)
                          - Analyses of field survey samples indicate                                        - Analyses of field survey samples indicate thyroid CDE > 5000 mrem for 60 min. of                                            thyroid CDE > 500 mrem for 60 min. of                        AA1.4 inhalation                                                                        inhalation                                                    Field survey results indicate EITHER of the following at (Notes 1, 2)                                                                      (Notes 1, 2)                                                        or beyond the SITE BOUNDARY:
                                                                                                                                                                                  - Closed window dose rates > 10 mR/hr expected to continue for  60 min.
                                                                                                                                                                                  - Analyses of field survey samples indicate thyroid CDE > 50 mrem for 60 min. of inhalation (Notes 1, 2)
A                      Spent fuel pool level cannot be restored to at least the top of the fuel racks for 60 minutes or longer Spent fuel pool level at the top of the fuel racks                  Significant lowering of water level above, or damage to, irradiated fuel UNPLANNED loss of water level above irradiated fuel Abnorm.                            1        2      3      4          5      6      DEF                        1          2    3      4          5  6      DEF                    1        2      3        4      5      6  DEF                1      2      3      4      5      6    DEF Rad                  AG2.1                                                                              AS2.1                                                                AA2.1                                                              AU2.1 Levels /
Rad                  Spent fuel pool level cannot be restored to at least                              Lowering of spent fuel pool level to 377.0 ft. (Alarm 3)            IMMINENT uncovery of irradiated fuel in the                        UNPLANNED water level drop in the REFUELING Effluent      2        377.0 ft. (Alarm 3) on LIT-2020-3(4) for  60 min.
(Note 1) on LIT-2020-3(4)                                                    REFUELING PATHWAY AA2.2 PATHWAY as indicated by low water level alarm, visual observation, or BWST level drop due to Irradiated                                                                                                                                                                                                                              makeup demands Fuel                                                                                                                                                              Damage to irradiated fuel resulting in a release of Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds                                              radioactivity                                                          AND Event Monitor                GE                      SAE                Alert                    UE          AND                                                              UNPLANNED rise in corresponding area radiation levels as indicated by any of the following radiation RX-9820                                                                                                High alarm on any Table 1A-2 radiation monitor                      monitors:
Containment Purge                                4.15E+01 &#xb5;Ci/cc        4.15E+00 &#xb5;Ci/cc        4.15E-01 &#xb5;Ci/cc      1.21E-03 &#xb5;Ci/cc (SPING 1)                                                                                                AA2.3                                                                  - RE-8009 Spent Fuel Area Gaseous RX-9825                                                                                                Lowering of spent fuel pool level to 387.0 ft. (Alarm 2)
Radwaste Area                                    2.67E+01 &#xb5;Ci/cc        2.67E+00 &#xb5;Ci/cc        2.67E-01 &#xb5;Ci/cc      4.94E-04 &#xb5;Ci/cc                                                                          - RE-8017 Fuel Handling (SPING 2)                                                                                                on LIT-2020-3(4)
RX-9820                                                                                                  Radiation levels that IMPEDE access to equipment Fuel Handling Area                              6.20E+02 &#xb5;Ci/cc        6.20E+01 &#xb5;Ci/cc        6.20E+00 &#xb5;Ci/cc      5.44E-04 &#xb5;Ci/cc (SPING 3)                                                                                                  necessary for normal plant operations, cooldown or shutdown Emergency                      RX-9835                                                                                                                                                                        Table 1A-2 Unit 1 Fuel Damage Radiation Monitors Penetration Room              (SPING 4) 6.55E+02 &#xb5;Ci/cc        6.55E+01 &#xb5;Ci/cc        6.55E+00 &#xb5;Ci/cc      1.21E-02 &#xb5;Ci/cc  AA3.1        1      2        3      4      5      6  DEF RE-8009 Spent Fuel Area Dose rate > 15 mR/hr in EITHER of the following                      RE-8017 Fuel Handling Liquid Liquid Radwaste                RE-4642                ----                    ----                  ----          2.46E+05 cpm      areas:                                                                RE-8060 Containment High Range Radiation Monitor
                                                                                                                                                                                  - Control Room 3                                                                                                                                                                  - Central Alarm Station (by survey)
RE-8061 Containment High Range Radiation Monitor RE-9820 (SPING 1) Containment Purge Area                                                                                                                                                                                                                                    RE-9825 (SPING 2) Radwaste Area Rad                                                                        Table 1A-3 Unit 1 Safe Operation & Shutdown Rooms/Areas                                AA3.2                                                                RE-9830 (SPING 3) Fuel Handling Area 3      4 Levels Room / Area                                        Mode              An UNPLANNED event results in radiation levels that None                                                                                                                              prohibit or IMPEDE access to any Table 1A-3 room or A-4 Switchgear Room                                                        3, 4 area (Note 5)
Upper North Electrical Penetration Room                                    3, 4 Lower South Electrical Equipment Room                                      3, 4 to 0CAN031801 Page 2 of 22 GENERAL EMERGENCY                                          SITE AREA EMERGENCY                                                        ALERT                                                UNUSUAL EVENT Loss of RCS inventory affecting fuel clad integrity with  Loss of RCS inventory affecting core decay heat removal  Significant loss of RCS inventory                                UNPLANNED loss of RCS inventory containment challenged                                    capability 5      6                                                5    6                                                      5    6                                                        5      6 CG1.1 [Unit 2 ONLY]                                        CS1.1                                                    CA1.1                                                            CU1.1 CONTAINMENT CLOSURE not established                      Loss of RCS inventory as indicated by EITHER:                    UNPLANNED loss of reactor coolant results in RCS CG1.2                                                          AND                                                      - RVLMS Levels 1 through 8 indicate DRY                      water level less than a required lower limit for 15 min. (Note 1)
RCS level cannot be monitored for  30 min. (Note 1)      RVLMS Levels 1 through 9 indicate DRY                        - Reactor vessel level 368.5 ft. (LT-1195/LT-1196)
CU1.2 1        AND                                                    CS1.2                                                            (bottom of hot leg)
RCS level cannot be monitored Core uncovery is indicated by any of the following:        RCS level cannot be monitored for  30 min. (Note 1)      CA1.2 RCS RCS level cannot be monitored for  15 min. (Note 1)                AND EITHER Level    - UNPLANNED rise in any Table 1C-1 sump/tank                AND level of sufficient magnitude to indicate core                                                                  AND EITHER                                                        - UNPLANNED rise in any Table 1C-1 Core uncovery is indicated by any of the following:                                                                              sump/tank level due to loss of RCS inventory uncovery                                                                                                        - UNPLANNED rise in any Table 1C-1
                                                                                - UNPLANNED rise in any Table 1C-1 sump/tank
                    - Containment High Range Radiation Monitor                    level of sufficient magnitude to indicate core            Sump/Tank level due to a loss of RCS inventory                -  Visual observation of UNISOLABLE RCS RE-8060/8061 reading > 10 R/hr                                                                                                                                                        leakage uncovery                                              -  Visual observation of UNISOLABLE RCS leakage
                    - Erratic Source Range Monitor indication                  - Containment high range radiation monitor AND                                                          RE-8060/8061 reading > 10 R/hr Any Containment Challenge indication, Table 1C-2            - Erratic Source Range Monitor indication Loss of all offsite and all onsite AC power to vital buses for    Loss of all but one AC power source to vital buses for 15 minutes or longer                                              15 minutes or longer 5    6    DEF                                              5      6    DEF 2                                                                                                                          CA2.1                                                            CU2.1 Loss of                            None                                                        None                          Loss of all offsite and all onsite AC power to vital            AC power capability, Table 1C-3, to vital 4.16 KV Vital AC                                                                                                                      4.16 KV buses A3 and A4 for  15 min. (Note 1)                  buses A3 and A4 reduced to a single power source Power                                                                                                                                                                                        for  15 min. (Note 1)
C                                                                                                                                                                                                        AND Any additional single power source failure will result Cold in loss of all AC power to SAFETY SYSTEMS SD/Refuel System                                                                                                                                  Inability to maintain plant in cold shutdown                      UNPLANNED rise in RCS temperature Malfunct.
5    6                                                        5      6 CA3.1                                                            CU3.1 3                                                                                                                          UNPLANNED rise in RCS temperature to > 200&deg;F for                UNPLANNED rise in RCS temperature to > 200&deg;F None                                                        None                          > Table 1C-4 duration (Note 1)                                  due to loss of decay heat removal capability RCS Temp.                                                                                                                          OR                                                            CU3.2 UNPLANNED RCS pressure rise > 10 psig due to a                  Loss of all RCS temperature and RCS level loss of RCS cooling (this EAL does not apply during              indication for  15 min. (Note 1) water-solid plant conditions)
Loss of Vital DC power for 15 minutes or longer 4                                                                                                                                                                                                                                    5      6 Loss of                            None                                                        None                                                          None                            CU4.1 Vital DC Indicated voltage is < 105 VDC on vital 125 VDC Power buses for  15 min. (Note 1)
Loss of all onsite or offsite communications capabilities 5      6    DEF CU5.1 5                                                                                                                                                                                          Loss of all Table 1C-5 onsite communication methods None                                                        None                                                          None Loss of OR Comm.
Loss of all Table 1C-5 State and local agency communication methods OR Loss of all Table 1C-5 NRC communication methods to 0CAN031801 Page 3 of 22 GENERAL EMERGENCY                                        SITE AREA EMERGENCY                                            ALERT                                  UNUSUAL EVENT Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode 5    6 CA6.1 The occurrence of any Table 1C-6 hazardous event AND C            6                                                                                                                Event damage has caused indications of degraded Hazardous                                                                                                              performance on one train of a SAFETY SYSTEM Cold        Event                            None                                                      None                  needed for the current operating mode                                      None SD/Refuel  Affecting                                                                                                                AND EITHER System      Safety                                                                                                                  - Event damage has caused indications of Malfunct. Systems                                                                                                                      degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode
                                                                                                                                    - Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)
Table 1C-1    Unit 1 Sumps / Tanks                              Table 1C-3    Unit 1 AC Power Sources                      Table 1C-5      Communication Methods                        Table 1C-6    Hazardous Events Offsite                                                      System                        Onsite  State / Local  NRC
* Reactor Building Sump
* Seismic event (earthquake)
* Reactor Drain Tank
* Startup Transformer No. 1            Station radio system                            X
* Internal or external FLOODING event
* Aux. Building Equipment Drain Tank
* Startup Transformer No. 2
* High winds or tornado strike
* Aux. Building Sump
* Unit Auxiliary Transformer (from      ANO plant phone system                          X
* FIRE 22 KV switchyard)
* EXPLOSION
* Quench Tank Onsite                                      Gaitronics                                      X
* Other events with similar hazard characteristics as determined by the
* DG1                                  Telephone Systems:                                                            Shift Manager
* DG2
* Commercial Table 1C-2    Containment Challenge Indications
* AAC Gen
* Microwave                                            X          X
* Satellite
* CONTAINMENT CLOSURE not established (Note 6)
* VOIP
* Containment hydrogen concentration > 3%
* UNPLANNED rise in containment pressure INFORM Notification System                                  X Emergency Notification System (ENS)                                      X Table 1C-4    RCS Heat-up Duration Thresholds CONTAINMENT                Heat-up RCS Status CLOSURE Status              Duration Intact (but not lowered inventory)              N/A                  60 min.*
Not intact Established              20 min.*
OR Lowered inventory                        not established            0 min.
* If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable to 0CAN031801 Page 4 of 22 GENERAL EMERGENCY                                        SITE AREA EMERGENCY                                                  ALERT                                        UNUSUAL EVENT Damage to a loaded cask CONFINEMENT BOUNDARY 1      2      3    4    5    6    DEF EU1.1 Table 1E-1 ISFSI Dose Rates                Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation VSC-24 VCC                    HI-STORM          reading on the surface of a loaded spent fuel cask (VSC-24 VCC or HI-STORM overpack) > any
                                                                                                                                    -  200 mrem/hr on the      -    60 mrem/hr          Table 1E-1 value sides                        (gamma +
E                                                                                                                          -  400 mrem/hr on the            neutron) on the ISFSI                                                                                                                            top                          top or outlet vent None                                                    None
                                                                                                                                    -  700 mrem/hr at the      -    600 mrem/hr air inlet                    (gamma +
neutron on the
                                                                                                                                    -  200 mrem/hr at the            side of the side of air outlet                    the overpack (excluding inlet and outlet ducts)
GENERAL EMERGENCY                                        SITE AREA EMERGENCY                                                  ALERT                                        UNUSUAL EVENT 1    2      3    4                                    1    2      3    4                                  1      2    3    4 F        FG1.1                                                    FS1.1                                                  FS1.1 None Fission Product Loss of any two barriers                                Loss or potential loss of any two barriers (Table 1F-1) Any loss or any potential loss of either Fuel Clad or Barriers      AND                                                                                                          RCS barrier (Table 1F-1)
Loss or potential loss of the third barrier (Table 1F-1) to 0CAN031801 Page 5 of 22 Table 1F-1            Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FCB)                              Reactor Coolant System Barrier (RCB)                                    Containment Barrier (CNB)
Category Loss                    Potential Loss                        Loss                    Potential Loss                            Loss                      Potential Loss RCB2 UNISOLABLE RCS leakage or S/G tube leakage
                                                                                                                > 50 gpm excluding normal RCB1 An automatic or manual        reductions in RCS inventory  CNB1 A S/G that is leaking ESAS actuation required        (e.g., letdown, RCP seal          > 50 gpm (excluding A. RCS or S/G                                                                    by EITHER:                    leakoff)                          normal reductions in RCS FCB1  RVLMS Levels 1 Tube                    None through 9 indicate DRY          -  UNISOLABLE RCS      RCB3 PTS limits apply (RT14)            inventory) or that is                    None RUPTURED is also Leakage                                                                            leakage                      AND                            FAULTED outside of
                                                                                  -  S/G tube RUPTURE          RCS pressure and                  containment temperature are left of the NDTT/LTOP limit lines on EOP Figure 3 (Note 12)
FCB3  CETs > 700&deg;F RCB4 RCS heat removal cannot                                          CNB2 CETs > 1200&deg;F B  Inadequate                              FCB4  RCS heat removal                                              be established using steam cannot be established                                                                                                                  AND Heat        FCB2 CETs > 1200&deg;F                                                    None                    generators                                None using steam generators                                                                                                              Restoration procedures Removal                                                                                                        AND                                                                not effective within AND HPI cooling initiated                                                  15 min. (Note 1)
HPI cooling initiated FCB5 Containment High Range Radiation C  CTMT              Monitor RE-8060/8061                                                                                                                                      CNB3 Containment High Range RCB5 Containment High Range Radiation Monitor Radiation /      > 750 R/hr                        None                    Radiation Monitor                      None                              None RE-8060/8061 RCS Activity FCB6 Coolant activity                                            RE-8060/8061 > 40 R/hr
                                                                                                                                                                                      > 10,000 R/hr
                    > 300 Ci/gm dose equivalent I-131 CNB4 Containment isolation is required                    CNB6 Containment pressure AND EITHER:                    > 73.7 psia
                                                                                                                                                  - Containment integrity      CNB7 Containment hydrogen D  CTMT                                                                                                                                                has been lost based on        concentration > 3%
Emergency Director      CNB8 Containment pressure Integrity or            None                        None                          None                              None judgment                      > 44.7 psia with < one full Bypass                                                                                                                                          - UNISOLABLE pathway              train of containment heat from Containment to the        removal systems (Note 9) environment exists            operating per design for CNB5 Indications of RCS leakage          15 min. (Note 1) outside of Containment FCB7 Any condition in the  FCB8  Any condition in the                                                                                                          CNB10 Any condition in the E  Emergency                                                                RCB6 Any condition in the    RCB7 Any condition in the opinion  CNB9 Any condition in the opinion of the              opinion of the                                                                                                                      opinion of the opinion of the Emergency      of the Emergency Director          opinion of the Emergency Director          Emergency Director          Emergency Director that Director that indicates        that indicates potential loss      Director that indicates loss Emergency Director that that indicates loss of      indicates potential loss                                                                                                            indicates potential loss of Judgment          the Fuel Clad barrier        of the Fuel Clad barrier loss of the RCS barrier        of the RCS barrier                of the Containment barrier the Containment barrier to 0CAN031801 Page 6 of 22 GENERAL EMERGENCY                                          SITE AREA EMERGENCY                                          ALERT                                          UNUSUAL EVENT HOSTILE ACTION within the PROTECTED AREA      HOSTILE ACTION within the OWNER CONTROLLED              Confirmed SECURITY CONDITION or threat AREA or airborne attack threat within 30 minutes 1    2    3    4    5    6  DEF          1      2      3      4      5      6    DEF          1      2      3    4      5    6  DEF HS1.1                                        HA1.1                                                  HU1.1 A HOSTILE ACTION is occurring or has occurred A HOSTILE ACTION is occurring or has occurred          A SECURITY CONDITION that does not involve a within the PROTECTED AREA as reported by ANO  within the OWNER CONTROLLED AREA as reported            HOSTILE ACTION as reported by ANO Security Shift 1                          None Security Shift Supervision                    by ANO Security Shift Supervision                      Supervision Security                                                                                                          OR                                                      OR A validated notification from NRC of an aircraft attack Notification of a credible security threat directed at the NOTES                                                  threat within 30 min. of the site                      site Note 1:  The Emergency Director should declare the event promptly upon determining that the                                                                      OR time limit has been exceeded, or will likely be exceeded. The Emergency Director is                                                                A validated notification from the NRC providing not allowed an additional 15 minutes to declare after the time limit is exceeded.                                                                  information of an aircraft threat Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.                                                                                          Seismic event greater than OBE levels
[Refer to CA6.1 or SA9.1 for potential 2      Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate theNone release path, then the effluent monitor reading is no longer                        escalation due to a seismic event]
1      2      3    4      5    6  DEF NoneVALID for                                                                HU2.1 Seismic            classification purposes.
Event    Note 4: The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and                                                                      Seismic event > OBE as indicated by annunciation of None H                        AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
the 0.10 g acceleration alarm Natural or Technological Hazard Hazards            Note 5: 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      2      3    4      5    6  DEF Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time                                                                      HU3.1 limit, declaration of a General Emergency is not required.
Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, ice, or                                                                  A tornado strike within the PROTECTED AREA vehicle breakdowns or accidents.                                                                                                                  HU3.2 Note 8: A manual action is any operator action, or set of actions, which causes the control                                                                Internal room or area FLOODING of a magnitude rods to be rapidly inserted into the core, and does not include manually driving in                                                                sufficient to require manual or automatic electrical 3              control rods or implementation of boron injection strategies.
Note 9: One full train of containment heat removal systems consists of one train of RB
[Refer to CA6.1 or SA9.1 for potential escalation due to a hazardous event]
isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating Natural or          [Containment]
NoneSpray and one train of RB [Containment] Cooling System.
None                                                                          mode Technical  Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service None                      HU3.3 Hazard            before the hazardous event occurred, then emergency classification is not warranted.
Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of                                                                    Movement of personnel within the PROTECTED AREA degraded performance to at least one train of a SAFETY SYSTEM, then this                                                                          is IMPEDED due to an event external to the emergency classification is not warranted.                                                                                                        PROTECTED AREA involving hazardous materials Note 12: Once PTS limits are first invoked, if RCS temperature and pressure are not brought                                                                (e.g., an offsite chemical spill or toxic gas release) within the limits within 15 minutes, this threshold is met and an immediate declaration                                                            HU3.4 is warranted. This threshold is met immediately upon exceeding the limits after this                                                              A hazardous event that results in on-site conditions initial 15 minute period until PTS limits no longer apply.                                                                                        sufficient to prohibit the plant staff from accessing the site via personal vehicles (Note 7) to 0CAN031801 Page 7 of 22 GENERAL EMERGENCY                            SITE AREA EMERGENCY                                                      ALERT                                                    UNUSUAL EVENT Fire potentially degrading the level of safety of the plant 1      2      3      4        5      6    DEF Table 1H-1    Unit 1 Fire Areas                                                                                                  HU4.1 A FIRE is not extinguished within 15 min. of any of the Reactor Building                                                                                                                                following FIRE detection indications (Note 1):
All elevations                                                                                                                                    - Report from the field (i.e., visual observation)
                                                                                                                                                                                    - Receipt of multiple (more than 1) fire alarms or Auxiliary Building                                                                                                                                      indications All elevations including: Penthouse/MSIV Room                                                                                                    - Field verification of a single fire alarm Exceptions:                                                                                                                                        AND Boric Acid Mix Tank Room (Chem Add Area),                                                                                                The FIRE is located within any Table 1H-1 area 404 (157-B), EDG Exhaust Fan area on 386                                                                                                HU4.2 (1-E and 2-E)
[Refer to CA6.1 or SA9.1 for potential Receipt of a single fire alarm (i.e., no other indications 4            None None escalation due to a fire]
of a FIRE)
Fire                Turbine Building AND All elevations including: Pipechase under ICW Coolers,                                                  None The fire alarm is indicating a FIRE within any CRD Pump Pit/T-28 Room/Area under ICW Pumps                                                                                                  Table 1H-1 area Outside Areas                                                                                                                                        AND The existence of a FIRE is not verified within 30 min.
Manholes adjacent to Startup #2 XFMR (MH-03/MH-04) of alarm receipt (Note 1)
Manholes adjacent to Intake Structure (MH-05/MH-06)                                                                                          HU4.3 Intake Structure (354 and 366)                                                                                                              A FIRE within the PROTECTED AREA not Diesel Fuel Vault                                                                                                                            extinguished within 60 min. of the initial report, alarm or indication (Note 1)
Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)
HU4.4 H                                                                                                                                                                            A FIRE within the PROTECTED AREA that requires firefighting support by an offsite fire response agency Hazards to extinguish Gaseous release IMPEDING access to Table 1H-2    Unit 1 Safe Operation & Shutdown Rooms/Areas                  equipment necessary for normal plant operations, cooldown or shutdown Room/Area                                        Mode                                3  4 5            None                                                                                HA5.1 A-4 Switchgear Room                          None                3, 4                                                                                                      None Hazardous                                                                                            Release of a toxic, corrosive, asphyxiant or flammable Gases                    Upper North Electrical Penetration Room                          3, 4    gas into any Table 1H-2 room or area Lower South Electrical Equipment Room                            3, 4        AND Entry into the room or area is prohibited or IMPEDED (Note 5)
Inability to control a key safety function from        Control Room evacuation resulting in transfer of plant control outside the Control Room                                to alternate locations DEF                1      2      3  4      5      6      DEF HS6.1                                                  HA6.1 An event has resulted in plant control being            An event has resulted in plant control being transferred 6                                        transferred from the Control Room to alternate          from the Control Room to alternate locations Control          None                        locations                                                                                                                                                None Room                                            AND Evacuation                                    Control of any of the following key safety functions is not re-established within 15 min. (Note 1):
                                                          - Reactivity (Modes 1, 2 and 3 only)
                                                          - Core cooling
                                                          - RCS heat removal to 0CAN031801 Page 8 of 22 GENERAL EMERGENCY                                  SITE AREA EMERGENCY                                                  ALERT                                          UNUSUAL EVENT Other conditions exist that in the judgment of the    Other conditions exist that in the judgment of the    Other conditions exist that in the judgment of the    Other conditions exist that in the judgment of the Emergency Director warrant declaration of a          Emergency Director warrant declaration of a            Emergency Director warrant declaration of an          Emergency Director warrant declaration of a UE GENERAL EMERGENCY                                    SITE AREA EMERGENCY                                    ALERT 1      2      3    4    5    6    DEF              1      2      3      4      5    6    DEF            1      2    3    4      5    6    DEF              1      2    3      4      5      6    DEF HG7.1                                                HS7.1                                                  HA7.1                                                HU7.1 Other conditions exist which, in the judgment of the Other conditions exist which, in the judgment of the    Other conditions exist which, in the judgment of the  Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in      Emergency Director, indicate that events are in        Emergency Director, indicate that events are in      Emergency Director, indicate that events are in H        7    progress or have occurred which involve actual or    progress or have occurred which involve actual or      progress or have occurred which involve an actual or  progress or have occurred which indicate a potential IMMINENT substantial core degradation or melting    likely major failures of plant functions needed for    potential substantial degradation of the level of    degradation of the level of safety of the plant or ED Hazards          with potential for loss of containment integrity or  protection of the public or HOSTILE ACTION that        safety of the plant or a security event that involves indicate a security threat to facility protection has Judgment HOSTILE ACTION that results in an actual loss of    results in intentional damage or malicious acts,        probable life threatening risk to site personnel or  been initiated. No releases of radioactive material physical control of the facility. Releases can be    (1) toward site personnel or equipment that could lead  damage to site equipment because of HOSTILE          requiring offsite response or monitoring are expected reasonably expected to exceed EPA Protective        to the likely failure of or, (2) that prevent effective ACTION. Any releases are expected to be limited to    unless further degradation of SAFETY SYSTEMS Action Guideline exposure levels offsite for more    access to equipment needed for the protection of the    small fractions of the EPA Protective Action          occurs.
than the immediate site area.                        public. Any releases are not expected to result in      Guideline exposure levels.
exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the SITE BOUNDARY.
to 0CAN031801 Page 9 of 22 GENERAL EMERGENCY                                                SITE AREA EMERGENCY                                                              ALERT                                                      UNUSUAL EVENT Prolonged loss of all offsite and all onsite AC power to vital  Loss of all offsite and all onsite AC power to vital buses for  Loss of all but one AC power source to vital buses for              Loss of all offsite AC power capability to vital buses for buses                                                            15 minutes or longer                                            15 minutes or longer                                                15 minutes or longer 1      2      3      4                                        1        2      3      4                                        1      2      3      4                                            1        2      3    4 SG1.1                                                            SS1.1                                                            SA1.1                                                              SU1.1 Loss of all offsite and all onsite AC power to vital            Loss of all offsite and all onsite AC power to vital            AC power capability, Table 1S-1, to vital 4.16 KV                  Loss of all offsite AC power capability, Table 1S-1, 4.16 KV buses A3 and A4                                          4.16 KV buses A3 and A4 for  15 min. (Note 1)                  buses A3 and A4 reduced to a single power source for                to vital 4.16 KV buses A3 and A4 for  15 min.
AND EITHER:                                                                                                                    15 min. (Note 1)                                                  (Note 1)
                          - Restoration of at least one vital 4.16 KV bus                                                                                  AND 1              in < 4 hours is not likely (Note 1)                                                                                      Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Loss of      - CETs > 1200&deg;F Vital AC  Loss of all vital AC and vital DC power sources for Power    15 minutes or longer                                                                                                                                                                        Table 1S-1  Unit 1 AC Power Sources Offisite SG1.2
* Startup Transformer No. 1 Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3 and A4 for  15 min. (Note 1)
* Startup Transformer No. 2 AND
* Unit Auxiliary Transformer (from 22 KV switchyard)
Indicated voltage is < 105 VDC on D01 and D02 vital                                                                                                                      Onsite 125 VDC buses for  15 min. (Note 1)
* Unit Auxiliary Transformer (main generator via main transformer)
Loss of all vital DC power for 15 minutes or longer
* DG1 2                                                                              1        2      3      4
* DG2 Loss of                                None                              SS2.1                                                                                        None
* AAC Gen                                          None Vital DC S        Power Indicated voltage is < 105 VDC on D01 and D02 vital 125 VDC buses for  15 min. (Note 1)
System Malfunct.                                                                                                                                                UNPLANNED loss of Control Room indications for                      UNPLANNED loss of Control Room indications for Table 1S-3        Significant Transients                  15 minutes or longer with a significant transient in progress        15 minutes or longer None 1        2    3      4 3
* Reactor trip SA3.1                                                              SU3.1 1        2      3    4 Loss of
* Runback > 25% thermal power None                                                                                                An UNPLANNED event results in the inability to                      An UNPLANNED event results in the inability to Control
* Electrical load rejection > 25% electrical load            monitor one or more Table 1S-2 parameters from                      monitor one or more Table 1S-2 parameters from Room Indications
* Safety injection actuation                                within the Control Room for  15 min. (Note 1)                      within the Control Room for  15 min. (Note 1)
AND Any significant transient is in progress, Table 1S-3 RCS activity greater than Technical Specification allowable limits Table 1S-2 Unit 2 Safety System Parameters 1        2      3    4
* Reactor power                                                SU4.1 None                                  Failed Fuel Iodine radiation monitor RI-1237S
* RCS level
                                                                                                                                                                                                                            > 9.0 E5 cpm
* RCS pressure 4
* CET temperature SU4.2 None                                                              None                                                                                                  RCS sample activity > 1.0 &#xb5;Ci/gm dose equivalent RCS Activity
* Level in at least one S/G                                    I-131 for > 48 hours (Note 1)
* EFW flow to at least one S/G                                      OR RCS sample activity > 60 &#xb5;Ci/gm dose equivalent I-131 OR RCS sample activity > 2200 &#xb5;Ci/gm dose equivalent Xe-133 for > 48 hours (Note 1) to 0CAN031801 Page 10 of 22 GENERAL EMERGENCY            SITE AREA EMERGENCY                                                              ALERT                                                UNUSUAL EVENT RCS leakage for 15 minutes or longer 1        2      3        4 SU5.1 RCS unidentified or pressure boundary leakage 5                                                                                                                                                        > 10 gpm for  15 min. (Note 1)
None                                    None                                                              None RCS                                                                                                                                                            OR Leakage RCS identified leakage > 25 gpm for  15 min. (Note 1)
OR Reactor coolant leakage to a location outside containment > 25 gpm for  15 min. (Note 1)
Inability to shut down the reactor causing a challenge to          Automatic or manual trip fails to shut down the reactor and    Automatic or manual trip fails to shut down the reactor core cooling or RCS heat removal                                    subsequent manual actions taken at the reactor control consolers are not successful in shutting down the reactor 1                                                                1                                                              1 SS6.1                                                              SA6.1                                                          SU6.1 An automatic or manual trip fails to shut down the                An automatic or manual trip fails to shut down the            An automatic trip did not shut down the reactor as reactor as indicated by reactor power > 5%                        reactor as indicated by reactor power > 5%                    indicated by reactor power > 5% after any RPS AND                                                                AND                                                        setpoint is exceeded All actions to shut down the reactor are not                      Manual trip actions taken at the reactor control                  AND successful as indicated by reactor power > 5%                      console (C03) (manual reactor trip pushbuttons or              A subsequent automatic trip or manual trip action 6                          AND EITHER                                                      DROPS) are not successful in shutting down the reactor as indicated by reactor power > 5% (Note 8) taken at the reactor control console (C03) (manual reactor trip pushbuttons or DROPS) is successful in None          - CETs >1200&deg;F RPS                                                                                                                                                        shutting down the reactor as indicated by reactor Failure                      - RCS heat removal cannot be established                                                                                      power  5% (Note 8) using steam generators and HPI cooling                                                                                    SU6.2 initiated A manual trip did not shut down the reactor as S                                                                                                                                                                  indicated by reactor power > 5% after any manual trip action was initiated System                                                                                        Table 1S-4  Communication Methods                                        AND Malfunct.                                                                                                                                                              A subsequent automatic trip or manual trip action System                    Onsite        State / Local      NRC      taken at the reactor control console (C03 ) (manual reactor trip pushbuttons or DROPS) is successful in Station radio system                              X                                      shutting down the reactor as indicated by reactor power  5% (Note 8)
ANO plant phone system                            X                                          Loss of all onsite or offsite communications capabilities None                                                                                                        1        2      3        4 Gaitronics                                        X                                      SU7.1 Loss of all Table 1S-4 onsite communication 7                                                              Telephone Systems:                                                                        methods None
* Commercial                                        None                                OR Loss of Comm.
* Microwave                                                    X            X      Loss of all Table 1S-4 State and local agency communication methods
* Satellite OR
* VOIP Loss of all Table 1S-4 NRC communication methods INFORM Notification System                                            X Failure to isolate containment or loss of containment pressure control Emergency Notification System (ENS)                                                X 1        2      3        4 SU8.1 8                                                                                                                                                        Any penetration is not closed within 15 min. of an None                                    None                                                              None CTMT                                                                                                                                                        ESAS actuation signal Failure                                                                                                                                                        OR Containment pressure > 44.7 psia with < one full train of containment heat removal systems (Note 9) operating per design for  15 min. (Note 1) to 0CAN031801 Page 11 of 22 GENERAL EMERGENCY                    SITE AREA EMERGENCY                                        ALERT                      UNUSUAL EVENT Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode Table 1S-5    Hazardous Events                      1      2      3    4 SA9.1
* Seismic event (earthquake)                          The occurrence of any Table 1S-5 hazardous event
* Internal or external FLOODING event                    AND None 9
* High winds or tornado strike                        Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM S      Hazardous
* FIRE needed for the current operating mode Event
* EXPLOSION                        None                                                                          None System                                                                                        AND EITHER Affecting Malfunct.
* Other events with similar hazard characteristics as    - Event damage has caused indications of Safety determined by the Shift Manager                            degraded performance to the second train of Systems the SAFETY SYSTEM needed for the current operating mode
                                                                                                - Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11) to 0CAN031801 Page 12 of 22 UNIT 2 GENERAL EMERGENCY                                                            SITE AREA EMERGENCY                                                                      ALERT                                                UNUSUAL EVENT Release of gaseous radioactivity resulting in offsite dose                        Release of gaseous radioactivity resulting in offsite dose          Release of gaseous OR liquid radioactivity resulting in offsite    Release of gaseous or liquid radioactivity greater than 2 greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE                            greater than 100 mrem TEDE or 500 mrem thyroid CDE                  dose greater than 10 mrem TEDE or 50 mrem thyroid CDE              times the ODCM limits for 60 minutes or longer 1        2      3      4          5      6  DEF                        1          2  3      4          5  6      DEF                    1        2      3        4      5  6      DEF                1      2      3      4      5      6    DEF AG1.1                                                                              AS1.1                                                                AA1.1                                                              AU1.1 Reading on any Table 2A-1 effluent radiation monitor                              Reading on any Table 2A-1 effluent radiation monitor                Reading on any Table 2A-1 effluent radiation monitor                Reading on any Table 2A-1 effluent radiation
                        > column GE for  15 min. (Notes 1, 2, 3, 4)                                    > column SAE for  15 min. (Notes 1, 2, 3, 4)                      > column ALERT for  15 min. (Notes 1, 2, 3, 4)                  monitor > column UE for  60 min. (Notes 1, 2, 3)
AG1.2                                                                              AS1.2                                                                AA1.2                                                              AU1.2 Dose assessment using actual meteorology indicates                                Dose assessment using actual meteorology indicates                  Dose assessment using actual meteorology indicates                  Sample analysis for a gaseous or liquid release doses > 1000 mrem TEDE or 5000 mrem thyroid                                        doses > 100 mrem TEDE or 500 mrem thyroid CDE at                    doses > 10 mrem TEDE or 50 mrem thyroid CDE at or                  indicates a concentration or release rate > 2 x CDE at or beyond the SITE BOUNDARY (Note 4)                                        or beyond the SITE BOUNDARY (Note 4)                                beyond the SITE BOUNDARY (Note 4)                                  ODCM limits for  60 min. (Notes 1, 2) 1        AG1.3 Field survey results indicate EITHER of the following AS1.3 Field survey results indicate EITHER of the following AA1.3 Analysis of a liquid effluent sample indicates a Rad      at or beyond the SITE BOUNDARY:                                                    at or beyond the SITE BOUNDARY:                                      concentration or release rate that would result in doses Effluent                                                                                                                                                            > 10 mrem TEDE or 50 mrem thyroid CDE at or
                          - Closed window dose rates > 1000 mR/hr                                            - Closed window dose rates > 100 mR/hr expected to continue for  60 min.                                                expected to continue for  60 min.                            beyond the SITE BOUNDARY for 60 min. of exposure (Notes 1, 2)
                          - Analyses of field survey samples indicate                                        - Analyses of field survey samples indicate thyroid CDE > 5000 mrem for 60 min. of                                            thyroid CDE > 500 mrem for 60 min. of                        AA1.4 inhalation                                                                        inhalation                                                    Field survey results indicate EITHER of the following at (Notes 1, 2)                                                                      (Notes 1, 2)                                                        or beyond the SITE BOUNDARY:
                                                                                                                                                                                  - Closed window dose rates > 10 mR/hr expected to continue for  60 min.
                                                                                                                                                                                  - Analyses of field survey samples indicate thyroid CDE > 50 mrem for 60 min. of inhalation (Notes 1, 2)
Spent fuel pool level cannot be restored to at least the top                      Spent fuel pool level at the top of the fuel racks                  Significant lowering of water level above, or damage to,            UNPLANNED loss of water level above irradiated fuel A                      of the fuel racks for 60 minutes or longer                                                                                                              irradiated fuel Abnorm.                            1        2      3      4          5      6      DEF                        1          2    3      4          5  6      DEF                    1        2      3        4      5      6  DEF                1      2      3      4      5      6    DEF Rad                  AG2.1                                                                              AS2.1                                                                AA2.1                                                              AU2.1 Levels /
Rad                  Spent fuel pool level cannot be restored to at least                              Lowering of spent fuel pool level to 379.5 ft. (Alarm 3)            IMMINENT uncovery of irradiated fuel in the                        UNPLANNED water level drop in the REFUELING Effluent                379.5 ft. (Alarm 3) on 2LIT-2020-1(2) for  60 min.                                on 2LIT-2020-1(2)                                                    REFUELING PATHWAY                                                  PATHWAY as indicated by low water level alarm, 2        (Note 1)                                                                                                                                                AA2.2                                                              visual observation, or RWT level drop due to makeup demands Irradiated Table 2A-1 Unit 1 Effluent Monitor Classification Thresholds                                              Damage to irradiated fuel resulting in a release of radioactivity                                                          AND Fuel                                                      Monitor              GE                        SAE                Alert                    UE Event                                                                                                                                                                AND                                                              UNPLANNED rise in corresponding area radiation Containment Purge 2RX-9820 1.88E+01 &#xb5;Ci/cc        1.88E+00 &#xb5;Ci/cc        1.88E-01 &#xb5;Ci/cc      5.84E-04 &#xb5;Ci/cc                                                                      levels as indicated by any of the following radiation (SPING 5)                                                                                                High alarm on any Table 2A-2 radiation monitor                      monitors:
Gaseous 2RX-9825                                                                                                AA2.3                                                                - 2RE-8914 Spent Fuel Area Radwaste Area                                    2.35E+01 &#xb5;Ci/cc        2.35E+00 &#xb5;Ci/cc        2.35E-01 &#xb5;Ci/cc      4.35E-04 &#xb5;Ci/cc (SPING 6)                                                                                                Lowering of spent fuel pool level to 389.5 ft. (Alarm 2)            - 2RE-8915 Spent Fuel Area 2RX-9820                                                                                                on 2LIT-2020-1(2)
Fuel Handling Area                              6.86E+02 &#xb5;Ci/cc        6.86E+01 &#xb5;Ci/cc        6.86E+00 &#xb5;Ci/cc      6.04E-04 &#xb5;Ci/cc                                                                        - 2RE-8916 Spent Fuel Area (SPING 7)
                                                                                                                                                                                                                                                    - 2RE-8912 Containment Incore Instrumentation Emergency                      2RX-9835 5.88E+02 &#xb5;Ci/cc        5.88E+01 &#xb5;Ci/cc        5.88E+00 &#xb5;Ci/cc      1.09E-02 &#xb5;Ci/cc Penetration Room              (SPING 8)                                                                                                  Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown BMS Liquid Radwaste            2RE-2330                ----                    ----                  ----          2.46E+05 cpm                                                                            Table 2A-2 Unit 1 Fuel Damage Radiation Monitors AA3.1 Liquid 1      2        3      4      5      6  DEF Regenerative Waste                                                                                                                                                                                            2RE-8905 Containment Equipment Hatch Area 2RE-4423                ----                    ----                  ----          2.46E+05 cpm Discharge                                                                                                                              Dose rate > 15 mR/hr in EITHER of the following                      2RE-8909 Containment Personnel Access Area areas:                                                                2RE-8912 Containment Incore Instrumentation 3                                                                          Table 2A-3      Unit 2 Safe Operation & Shutdown Rooms/Areas                            - Control Room                                                    2RE-8914 Spent Fuel Area Area                                                                                                                                                                  - Central Alarm Station (by survey)                                2RE-8916 Spent Fuel Area None                                                          Room / Area                                      Mode Rad                                                                                                                                                                                                                                      2RE-9825-1 Containment High Range Radiation Monitors Levels                                                                        Aux Building 317 Emergency Core Cooling Rooms                      3, 4              AA3.2                          3      4                              2RE-9825-2 Containment High Range Radiation Monitors Aux Building 317 Tendon Gallery Access                            3, 4                                                                                    2Rx-9820 (SPING 5) Containment Purge Aux Building 335 Charging Pumps/MCC 2B-52                          3, 4              An UNPLANNED event results in radiation levels that Aux Building 354 MCC 2B-62 Area                                    3, 4                                                                                    2Rx-9825 (SPING 6) Radwaste Area prohibit or IMPEDE access to any Table 2A-3 room or Emergency Diesel Generator Corridor                                3, 4                                                                                    2Rx-9830 (SPING 7) Fuel Handling Area area (Note 5)
Lower South Piping Penetration Room                                3, 4 Aux Building 386 Containment Hatch                                3, 4 to 0CAN031801 Page 13 of 22 GENERAL EMERGENCY                                          SITE AREA EMERGENCY                                                        ALERT                                                UNUSUAL EVENT Loss of RCS inventory affecting fuel clad integrity with  Loss of RCS inventory affecting core decay heat removal  Significant loss of RCS inventory                                UNPLANNED loss of RCS inventory containment challenged                                    capability 5      6                                                5    6                                                      5    6                                                        5      6 CG1.1                                                      CS1.1                                                    CA1.1                                                            CU1.1 RVLMS Levels 1 through 7 indicate DRY                      CONTAINMENT CLOSURE not established                      Loss of RCS inventory as indicated by EITHER:                    UNPLANNED loss of reactor coolant results in RCS AND                                                        AND                                                      - RVLMS Levels 1 through 5 indicate DRY                      water level less than a required lower limit for 15 min. (Note 1)
Any Containment Challenge indication, Table 2C-2          RVLMS Levels 1 through 6 indicate DRY                        - Reactor vessel level 0 in. (L4791/L4792) (bottom of hot leg)                                              CU1.2 CG1.2                                                      CS1.2 RCS level cannot be monitored 1    RCS level cannot be monitored for  30 min. (Note 1)      RVLMS Levels 1 through 7 indicate DRY                    CA1.2 AND EITHER AND                                                        OR                                                    RCS level cannot be monitored for  15 min. (Note 1)
RCS AND EITHER                                                        - UNPLANNED rise in any Table 2C-1 Level  Core uncovery is indicated by any of the following:        RCS level cannot be monitored for  30 min. (Note 1)                                                                            sump/tank level due to loss of RCS inventory
                    - UNPLANNED rise in any Table 2C-1 sump/tank                  AND                                                    - UNPLANNED rise in any Table 2C-1 level of sufficient magnitude to indicate core                                                                      Sump/Tank level due to a loss of RCS inventory                -  Visual observation of UNISOLABLE RCS Core uncovery is indicated by any of the following:                                                                              leakage uncovery
                                                                                - UNPLANNED rise in any Table 2C-1 sump/tank
                                                                                                                                          -  Visual observation of UNISOLABLE RCS leakage
                    - Containment High Range Radiation Monitor                      level of sufficient magnitude to indicate core 2RE-8925-1/8925-2 reading > 10 R/hr                        uncovery
                    - Erratic Source Range Monitor indication                  - Containment high range radiation monitor AND                                                            2RE-8925-1/8925-2 reading > 10 R/hr Any Containment Challenge indication, Table 2C-2              - Erratic Source Range Monitor indication Loss of all offsite and all onsite AC power to vital buses for    Loss of all but one AC power source to vital buses for 15 minutes or longer                                              15 minutes or longer 5    6    DEF                                              5      6    DEF 2                                                                                                                          CA2.1                                                            CU2.1 Loss of                            None                                                        None                          Loss of all offsite and all onsite AC power to vital            AC power capability, Table 2C-3, to vital 4.16 KV 4.16 KV buses 2A3 and 2A4 for  15 min. (Note 1)                buses 2A3 and 2A4 reduced to a single power C      Vital AC Power                                                                                                                                                                                        source for  15 min. (Note 1)
Cold                                                                                                                                                                                                      AND SD/Refuel                                                                                                                                                                                                Any additional single power source failure will result System                                                                                                                                                                                                  in loss of all AC power to SAFETY SYSTEMS Malfunct.
Inability to maintain plant in cold shutdown                      UNPLANNED rise in RCS temperature 5    6                                                        5      6 CA3.1                                                            CU3.1 3                                                                                                                          UNPLANNED rise in RCS temperature to > 200&deg;F for                UNPLANNED rise in RCS temperature to > 200&deg;F None                                                        None                          > Table 2C-4 duration (Note 1)                                  due to loss of decay heat removal capability RCS Temp.                                                                                                                          OR                                                            CU3.2 UNPLANNED RCS pressure rise > 10 psig due to a                  Loss of all RCS temperature and RCS level loss of RCS cooling (this EAL does not apply during              indication for  15 min. (Note 1) water-solid plant conditions)
Loss of Vital DC power for 15 minutes or longer 4                                                                                                                                                                                                                                    5      6 Loss of                            None                                                        None                                                          None                            CU4.1 Vital DC Indicated voltage is < 105 VDC on vital 125 VDC Power buses for  15 min. (Note 1)
Loss of all onsite or offsite communications capabilities 5      6    DEF CU5.1 5                                                                                                                                                                                          Loss of all Table 2C-5 onsite communication methods None                                                        None                                                          None Loss of                                                                                                                                                                                            OR Comm.                                                                                                                                                                                          Loss of all Table 2C-5 State and local agency communication methods OR Loss of all Table 2C-5 NRC communication methods to 0CAN031801 Page 14 of 22 GENERAL EMERGENCY                                        SITE AREA EMERGENCY                                            ALERT                                  UNUSUAL EVENT Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode 5    6 CA6.1 The occurrence of any Table 2C-6 hazardous event AND C            6                                                                                                                Event damage has caused indications of degraded Hazardous                                                                                                            performance on one train of a SAFETY SYSTEM Cold        Event                            None                                                      None                  needed for the current operating mode                                      None SD/Refuel  Affecting                                                                                                              AND EITHER System      Safety                                                                                                                - Event damage has caused indications of Malfunct. Systems                                                                                                                    degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode
                                                                                                                                    - Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)
Table 2C-1    Unit 2 Sumps / Tanks                              Table 2C-3    Unit 2 AC Power Sources                      Table 2C-5      Communication Methods                        Table 2C-6    Hazardous Events Offsite                                                      System                        Onsite  State / Local  NRC
* Seismic event (earthquake)
* CNTMT Sump
* Startup Transformer No. 3            Station radio system                            X
* Internal or external FLOODING event
* Reactor Drain Tank
* Startup Transformer No. 2
* High winds or tornado strike
* LRW Waste Tank (2T-20)
* Unit Auxiliary Transformer (backfed  ANO plant phone system                          X
* FIRE
* Holdup Tank                                                        from main transformer)
* EXPLOSION
* Aux. Building Sump                                          Onsite                                      Gaitronics                                      X
* Other events with similar hazard
* Quench Tank                                                                                                                                                                          characteristics as determined by the
* 2DG1                                Telephone Systems:                                                            Shift Manager
* 2DG2
* Commercial Table 2C-2    Containment Challenge Indications
* AAC Gen
* Microwave                                            X          X
* Satellite
* CONTAINMENT CLOSURE not established (Note 6)
* VOIP
* Containment hydrogen concentration > 3%
* UNPLANNED rise in containment pressure INFORM Notification System                                  X Emergency Notification System (ENS)                                      X Table 2C-4    RCS Heat-up Duration Thresholds CONTAINMENT                Heat-up RCS Status CLOSURE Status              Duration Intact (but not lowered inventory)              N/A                60 min.*
Not intact Established              20 min.*
OR Lowered inventory                        not established            0 min.
* If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable to 0CAN031801 Page 15 of 22 GENERAL EMERGENCY                                        SITE AREA EMERGENCY                                                  ALERT                                        UNUSUAL EVENT Damage to a loaded cask CONFINEMENT BOUNDARY 1      2      3    4    5    6    DEF EU1.1 Table 2E-1 ISFSI Dose Rates                Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation VSC-24 VCC                    HI-STORM          reading on the surface of a loaded spent fuel cask (VSC-24 VCC or HI-STORM overpack) > any
                                                                                                                                    -  200 mrem/hr on the      -    60 mrem/hr          Table 2E-1 value sides                        (gamma +
E                                                                                                                          -  400 mrem/hr on the            neutron) on the ISFSI                                                                                                                            top                          top or outlet vent None                                                    None
                                                                                                                                    -  700 mrem/hr at the      -    600 mrem/hr air inlet                    (gamma +
neutron on the
                                                                                                                                    -  200 mrem/hr at the            side of the side of air outlet                    the overpack (excluding inlet and outlet ducts)
GENERAL EMERGENCY                                        SITE AREA EMERGENCY                                                  ALERT                                        UNUSUAL EVENT 1    2      3    4                                    1    2      3    4                                  1      2    3    4 F        FG1.1                                                    FS1.1                                                  FS1.1 None Fission Product Loss of any two barriers                                Loss or potential loss of any two barriers (Table 2F-1) Any loss or any potential loss of either Fuel Clad or Barriers      AND                                                                                                          RCS barrier (Table 2F-1)
Loss or potential loss of the third barrier (Table 2F-1) to 0CAN031801 Page 16 of 22 Table 2F-1            Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FCB)                            Reactor Coolant System Barrier (RCB)                                        Containment Barrier (CNB)
Category Loss                    Potential Loss                        Loss                        Potential Loss                          Loss                      Potential Loss FCB1  RVLMS Levels 1          RCB1 An automatic or manual      RCB2 UNISOLABLE RCS leakage        CNB1 A S/G that is leaking through 7 indicate DRY        ESFAS actuation required          or S/G tube leakage                > 44 gpm (excluding by EITHER:                        > 44 gpm excluding normal          normal reductions in RCS
                                                                                - UNISOLABLE RCS                reductions in RCS inventory        inventory) or that is leakage                    (e.g., letdown, RCP seal          RUPTURED is also leakoff)                          FAULTED outside of
                                                                                - S/G tube RUPTURE A. RCS or S/G                                                                                                RCB3 Uncontrolled RCS cooldown          containment Tube                  None                                                                                    (50&deg;F step change which is                                                  None below 500&deg;F from NOT)
Leakage AND RCS pressure and temperature are left of line B (200 degrees MTS)
Standard Attachment 1, P-T Limits (Note 12)
FCB2 CETs > 1200&deg;F          FCB3  CETs > 700&deg;F                                              RCB4 RCS heat removal cannot                                        CNB2 CETs > 1200&deg;F FCB4  RCS heat removal                                                be established using steam                                                AND B  Inadequate                                    cannot be established                                          generators Restoration procedures Heat                                          using steam generators                None                          AND                                    None                        not effective within Removal                                          AND                                                          Once Through cooling                                                  15 min. (Note 1)
Once Through cooling                                            initiated initiated FCB5 Containment High                                      RCB5 Containment High Range                                                                            CNB3 Containment High Range Range Radiation                                            Radiation Monitor                                                                                      Radiation Monitor C  CTMT              Monitor 2RE-8925-1/                                        2RE-8925-1/8925-2                                                                                      2RE-8925-1/8925-2 Radiation /      8925-2 > 700 R/hr                  None                  > 50 R/hr                                  None                            None                      > 12,000 R/hr RCS Activity FCB6 Coolant activity
                    > 300 Ci/gm dose equivalent I-131 CNB4 Containment isolation is    CNB6 Containment pressure required                          > 73.7 psia AND EITHER:              CNB7 Containment hydrogen
                                                                                                                                                    - Containment integrity            concentration > 3%
D  CTMT                                                                                                                                                  has been lost based on  CNB8 Containment pressure Emergency Director            > 23.3 psia with < one full Integrity or          None                          None                          None                                None judgment                      train of containment heat Bypass                                                                                                                                            - UNISOLABLE pathway              removal systems from Containment to the        (Note 9) operating per environment exists            design for  15 min.
(Note 1)
CNB5 Indications of RCS leakage outside of Containment FCB7 Any condition in the  FCB8  Any condition in the    RCB6 Any condition in the        RCB7 Any condition in the opinion  CNB9 Any condition in the        CNB10    Any condition in the E  Emergency        opinion of the              opinion of the                opinion of the Emergency          of the Emergency Director          opinion of the Emergency              opinion of the Emergency Director          Emergency Director            Director that indicates loss      that indicates potential loss      Director that indicates loss          Emergency Director Director          that indicates loss of      that indicates potential      of the RCS barrier                of the RCS barrier                of the Containment barrier            that indicates potential Judgment          the Fuel Clad barrier        loss of the Fuel Clad                                                                                                                    loss of the barrier                                                                                                                                  Containment barrier to 0CAN031801 Page 17 of 22 GENERAL EMERGENCY                                          SITE AREA EMERGENCY                                          ALERT                                          UNUSUAL EVENT HOSTILE ACTION within the PROTECTED AREA      HOSTILE ACTION within the OWNER CONTROLLED              Confirmed SECURITY CONDITION or threat AREA or airborne attack threat within 30 minutes 1    2    3    4    5    6  DEF          1      2      3      4      5      6    DEF          1      2      3    4      5    6  DEF HS1.1                                        HA1.1                                                  HU1.1 A HOSTILE ACTION is occurring or has occurred A HOSTILE ACTION is occurring or has occurred          A SECURITY CONDITION that does not involve a within the PROTECTED AREA as reported by ANO  within the OWNER CONTROLLED AREA as reported            HOSTILE ACTION as reported by ANO Security Shift 1                          None Security Shift Supervision                    by ANO Security Shift Supervision                      Supervision Security                                                                                                          OR                                                      OR A validated notification from NRC of an aircraft attack Notification of a credible security threat directed at the NOTES                                                  threat within 30 min. of the site                      site Note 1:  The Emergency Director should declare the event promptly upon determining that the                                                                      OR time limit has been exceeded, or will likely be exceeded. The Emergency Director is                                                                A validated notification from the NRC providing not allowed an additional 15 minutes to declare after the time limit is exceeded.                                                                  information of an aircraft threat Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.                                                                                          Seismic event greater than OBE levels
[Refer to CA6.1 or SA9.1 for potential 2      Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate theNone release path, then the effluent monitor reading is no longer                        escalation due to a seismic event]
1      2      3    4      5    6  DEF NoneVALID for                                                                HU2.1 Seismic            classification purposes.
Event    Note 4: The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and                                                                      Seismic event > OBE as indicated by annunciation of None H                        AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
the 0.10 g acceleration alarm Natural or Technological Hazard Hazards            Note 5: 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      2      3    4      5    6  DEF Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time                                                                      HU3.1 limit, declaration of a General Emergency is not required.
Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, ice, or                                                                  A tornado strike within the PROTECTED AREA vehicle breakdowns or accidents.                                                                                                                  HU3.2 Note 8: A manual action is any operator action, or set of actions, which causes the control                                                                Internal room or area FLOODING of a magnitude rods to be rapidly inserted into the core, and does not include manually driving in                                                                sufficient to require manual or automatic electrical 3              control rods or implementation of boron injection strategies.
Note 9: One full train of containment heat removal systems consists of one train of RB
[Refer to CA6.1 or SA9.1 for potential escalation due to a hazardous event]
isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating Natural or          [Containment]
NoneSpray and one train of RB [Containment] Cooling System.
None                                                                          mode Technical  Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service None                      HU3.3 Hazard            before the hazardous event occurred, then emergency classification is not warranted.
Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of                                                                    Movement of personnel within the PROTECTED AREA degraded performance to at least one train of a SAFETY SYSTEM, then this                                                                          is IMPEDED due to an event external to the emergency classification is not warranted.                                                                                                        PROTECTED AREA involving hazardous materials Note 12: Once PTS limits are first invoked, if RCS temperature and pressure are not brought                                                                (e.g., an offsite chemical spill or toxic gas release) within the limits within 15 minutes, this threshold is met and an immediate declaration                                                            HU3.4 is warranted. This threshold is met immediately upon exceeding the limits after this                                                              A hazardous event that results in on-site conditions initial 15 minute period until PTS limits no longer apply.                                                                                        sufficient to prohibit the plant staff from accessing the site via personal vehicles (Note 7) to 0CAN031801 Page 18 of 22 GENERAL EMERGENCY                            SITE AREA EMERGENCY                                                      ALERT                                                    UNUSUAL EVENT Fire potentially degrading the level of safety of the plant Table 2H-1    Unit 2 Fire Areas                                                                                                            1      2      3      4        5      6    DEF Reactor Building                                                                                                                                HU4.1 A FIRE is not extinguished within 15 min. of any of the All elevations following FIRE detection indications (Note 1):
Auxiliary Building                                                                                                                                  - Report from the field (i.e., visual observation)
All elevations including: Aux Extension                                                                                                          - Receipt of multiple (more than 1) fire alarms or indications Turbine Building                                                                                                                                    - Field verification of a single fire alarm All elevations                                                                                                                                    AND The FIRE is located within any Table 2H-1 area Outside Areas                                                                                                                                    HU4.2 Intake Structure (354 and 366)
[Refer to CA6.1 or SA9.1 for potential Receipt of a single fire alarm (i.e., no other indications 4            None Concrete Manhole East, NE of intake (2MH-01)  None escalation due to a fire]
of a FIRE)
Fire                                                                                                                                                                      AND Concrete Manhole East of Turbine Building next to train                                                  None bay (2MH-03)                                                                                                                                  The fire alarm is indicating a FIRE within any Table 2H-1 area Diesel Fuel Vault AND Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)
The existence of a FIRE is not verified within 30 min.
of alarm receipt (Note 1)
HU4.3 A FIRE within the PROTECTED AREA not extinguished within 60 min. of the initial report, alarm Table 2H-2    Unit 2 Safe Operation & Shutdown Rooms/Areas                                                                                  or indication (Note 1)
HU4.4 H                                                Room/Area                                        Mode A FIRE within the PROTECTED AREA that requires firefighting support by an offsite fire response agency Hazards                            Aux Building 317 Emergency Core Cooling Rooms                    3, 4                                                                      to extinguish Aux Building 317 Tendon Gallery Access                          3, 4      Gaseous release IMPEDING access to Aux Building 335 Charging Pumps / MCC 2B-52                      3, 4      equipment necessary for normal plant operations, cooldown or shutdown Aux Building 354 MCC 2B-62 Area                                  3, 4 3  4 5            None Emergency Diesel Generator Corridor                              3, 4 HA5.1 Lower South Piping Penetration Room None                          3, 4                                                                                                      None Hazardous                                                                                            Release of a toxic, corrosive, asphyxiant or flammable Gases                    Aux Building 386 Containment Hatch                              3, 4    gas into any Table 2H-2 room or area AND Entry into the room or area is prohibited or IMPEDED (Note 5)
Inability to control a key safety function from        Control Room evacuation resulting in transfer of plant control outside the Control Room                                to alternate locations DEF                1      2      3  4      5      6      DEF HS6.1                                                  HA6.1 An event has resulted in plant control being            An event has resulted in plant control being transferred 6                                        transferred from the Control Room to alternate          from the Control Room to alternate locations Control          None                        locations                                                                                                                                                None Room                                            AND Evacuation                                    Control of any of the following key safety functions is not re-established within 15 min. (Note 1):
                                                          - Reactivity (Modes 1, 2 and 3 only)
                                                          - Core cooling
                                                          - RCS heat removal to 0CAN031801 Page 19 of 22 GENERAL EMERGENCY                                  SITE AREA EMERGENCY                                                  ALERT                                          UNUSUAL EVENT Other conditions exist that in the judgment of the    Other conditions exist that in the judgment of the    Other conditions exist that in the judgment of the    Other conditions exist that in the judgment of the Emergency Director warrant declaration of a          Emergency Director warrant declaration of a            Emergency Director warrant declaration of an          Emergency Director warrant declaration of a UE GENERAL EMERGENCY                                    SITE AREA EMERGENCY                                    ALERT 1      2      3    4    5    6    DEF              1      2      3      4      5    6    DEF            1      2    3    4      5    6    DEF              1      2    3      4      5      6    DEF HG7.1                                                HS7.1                                                  HA7.1                                                HU7.1 Other conditions exist which, in the judgment of the Other conditions exist which, in the judgment of the    Other conditions exist which, in the judgment of the  Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in      Emergency Director, indicate that events are in        Emergency Director, indicate that events are in      Emergency Director, indicate that events are in H        7    progress or have occurred which involve actual or    progress or have occurred which involve actual or      progress or have occurred which involve an actual or  progress or have occurred which indicate a potential IMMINENT substantial core degradation or melting    likely major failures of plant functions needed for    potential substantial degradation of the level of    degradation of the level of safety of the plant or ED Hazards          with potential for loss of containment integrity or  protection of the public or HOSTILE ACTION that        safety of the plant or a security event that involves indicate a security threat to facility protection has Judgment HOSTILE ACTION that results in an actual loss of    results in intentional damage or malicious acts,        probable life threatening risk to site personnel or  been initiated. No releases of radioactive material physical control of the facility. Releases can be    (1) toward site personnel or equipment that could lead  damage to site equipment because of HOSTILE          requiring offsite response or monitoring are expected reasonably expected to exceed EPA Protective        to the likely failure of or, (2) that prevent effective ACTION. Any releases are expected to be limited to    unless further degradation of SAFETY SYSTEMS Action Guideline exposure levels offsite for more    access to equipment needed for the protection of the    small fractions of the EPA Protective Action          occurs.
than the immediate site area.                        public. Any releases are not expected to result in      Guideline exposure levels.
exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the SITE BOUNDARY.
to 0CAN031801 Page 20 of 22 GENERAL EMERGENCY                                                SITE AREA EMERGENCY                                                              ALERT                                                        UNUSUAL EVENT Prolonged loss of all offsite and all onsite AC power to vital    Loss of all offsite and all onsite AC power to vital buses for    Loss of all but one AC power source to vital buses for                Loss of all offsite AC power capability to vital buses for buses                                                            15 minutes or longer                                              15 minutes or longer                                                  15 minutes or longer 1      2        3      4                                        1        2      3      4                                          1      2      3      4                                              1        2      3    4 SG1.1                                                            SS1.1                                                            SA1.1                                                                SU1.1 Loss of all offsite and all onsite AC power to vital              Loss of all offsite and all onsite AC power to vital              AC power capability, Table 1S-1, to vital 4.16 KV                    Loss of all offsite AC power capability, Table 2S-1, 4.16 KV buses 2A3 and 2A4                                        4.16 KV buses 2A3 and 2A4 for  15 min. (Note 1)                  buses 2A3 and 2A4 reduced to a single power source                    to vital 4.16 KV buses 2A3 and 2A4 for  15 min.
AND EITHER:                                                                                                                    for  15 min. (Note 1)                                                (Note 1)
                          - Restoration of at least one vital 4.16 KV bus                                                                                    AND 1              in < 4 hours is not likely (Note 1)                                                                                        Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Loss of        - CETs > 1200&deg;F Vital AC  Loss of all vital AC and vital DC power sources for                                                                                                                                              Table 2S-1    Unit 2 AC Power Sources Power    15 minutes or longer Offisite SG1.2
* Startup Transformer No. 3 Loss of all offsite and all onsite AC power to vital
* Startup Transformer No. 2 4.16 KV buses A3 and A4 for  15 min. (Note 1)
* Unit Auxiliary Transformer (backfed from main transformer)
AND                                                                                                                                                                      Onsite Indicated voltage is < 105 VDC on 2D01 and 2D02
* Unit Auxiliary Transformer (main generator via main transformer) vital 125 VDC buses for  15 min. (Note 1)
* 2DG1 Loss of all vital DC power for 15 minutes or longer 2                                                                                1        2      3      4
* 2DG2 None                                                                                                                              None
* AAC Gen                                          None Loss of                                                                    SS2.1 Vital DC Indicated voltage is < 105 VDC on 2D01 and 2D02 S        Power vital 125 VDC buses for  15 min. (Note 1)
System                                                                                                                                                      UNPLANNED loss of Control Room indications for                        UNPLANNED loss of Control Room indications for Malfunct.                                                                                        Table 1S-3        Significant Transients                  15 minutes or longer with a significant transient in progress        15 minutes or longer None                                        1        2    3      4                                            1        2      3    4 3
* Reactor trip                                              SA3.1                                                                SU3.1 Loss of
* Runback > 25% thermal power                                An UNPLANNED event results in the inability to                        An UNPLANNED event results in the inability to None Control                                                                                                                                      monitor one or more Table 2S-2 parameters from                        monitor one or more Table 2S-2 parameters from
* Electrical load rejection > 25% electrical load Room                                                                                                                                        within the Control Room for  15 min. (Note 1)                        within the Control Room for  15 min. (Note 1)
Indications
* Safety injection actuation AND Any significant transient is in progress, Table 2S-3 RCS activity greater than Technical Specification allowable limits Table 1S-2 Unit 2 Safety System Parameters 1        2      3    4
* Reactor power                                                  SU4.1 None                                    Failed Fuel Iodine radiation monitor 2RITS-4806B
* RCS level
                                                                                                                                                                                                                                > 9.0 E5 cpm
* RCS pressure 4
* CET temperature SU4.2 None                                                              None                                                                                                    RCS sample activity > 1.0 &#xb5;Ci/gm dose equivalent RCS Activity
* Level in at least one S/G                                      I-131 for > 48 hours (Note 1)
* EFW flow to at least one S/G                                      OR RCS sample activity > 60 &#xb5;Ci/gm dose equivalent I-131 OR RCS sample activity > 3100 &#xb5;Ci/gm dose equivalent Xe-133 for > 48 hours (Note 1) to 0CAN031801 Page 21 of 22 GENERAL EMERGENCY            SITE AREA EMERGENCY                                                              ALERT                                                UNUSUAL EVENT RCS leakage for 15 minutes or longer 1        2      3        4 SU5.1 RCS unidentified or pressure boundary leakage 5                                                                                                                                                        > 10 gpm for  15 min. (Note 1)
None                                    None                                                              None RCS                                                                                                                                                            OR Leakage RCS identified leakage > 25 gpm for  15 min. (Note 1)
OR Reactor coolant leakage to a location outside containment > 25 gpm for  15 min. (Note 1)
Inability to shut down the reactor causing a challenge to          Automatic or manual trip fails to shut down the reactor and    Automatic or manual trip fails to shut down the reactor core cooling or RCS heat removal                                    subsequent manual actions taken at the reactor control consolers are not successful in shutting down the reactor 1                                                                1                                                              1 SS6.1                                                              SA6.1                                                          SU6.1 An automatic or manual trip fails to shut down the                An automatic or manual trip fails to shut down the            An automatic trip did not shut down the reactor as reactor as indicated by reactor power > 5%                        reactor as indicated by reactor power > 5%                    indicated by reactor power > 5% after any RPS AND                                                                AND                                                        setpoint is exceeded All actions to shut down the reactor are not                      Manual trip actions taken at the reactor control                  AND successful as indicated by reactor power > 5%                      console (2C03/2C14) (manual reactor trip                      A subsequent automatic trip or manual trip action 6                          AND EITHER                                                      pushbuttons or DSS) are not successful in shutting down the reactor as indicated by reactor power > 5%
taken at the reactor control console (2C03/2C14)
(manual reactor trip pushbuttons or DSS) is None          - CETs >1200&deg;F RPS                                                                                        (Note 8)                                                      successful in shutting down the reactor as indicated Failure                      - RCS heat removal cannot be established                                                                                      by reactor power  5% (Note 8) using steam generators and Once Through                                                                                    SU6.2 cooling initiated A manual trip did not shut down the reactor as S                                                                                                                                                                  indicated by reactor power > 5% after any manual trip action was initiated System                                                                                        Table 2S-4  Communication Methods                                        AND Malfunct.                                                                                                                                                              A subsequent automatic trip or manual trip action System                    Onsite        State / Local      NRC      taken at the reactor control console (2C03/2C14)
(manual reactor trip pushbuttons or DSS) is Station radio system                              X                                      successful in shutting down the reactor as indicated by reactor power  5% (Note 8)
ANO plant phone system                            X                                          Loss of all onsite or offsite communications capabilities None                                                                                                        1        2      3        4 Gaitronics                                        X                                      SU7.1 Loss of all Table 2S-4 onsite communication 7                                                              Telephone Systems:                                                                        methods None
* Commercial                                        None                                OR Loss of Comm.
* Microwave                                                    X            X      Loss of all Table 2S-4 State and local agency communication methods
* Satellite OR
* VOIP Loss of all Table 2S-4 NRC communication methods INFORM Notification System                                            X Failure to isolate containment or loss of containment pressure control Emergency Notification System (ENS)                                                X 1        2      3        4 SU8.1 8                                                                                                                                                        Any penetration is not closed within 15 min. of an None                                    None                                                              None CTMT                                                                                                                                                        CIAS actuation signal Failure                                                                                                                                                        OR Containment pressure > 23.3 psia with < one full train of containment heat removal systems (Note 9) operating per design for  15 min. (Note 1) to 0CAN031801 Page 22 of 22 GENERAL EMERGENCY                    SITE AREA EMERGENCY                                        ALERT                      UNUSUAL EVENT Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode Table 1S-5    Hazardous Events                      1      2      3    4 SA9.1
* Seismic event (earthquake)                          The occurrence of any Table 2S-5 hazardous event
* Internal or external FLOODING event                    AND None 9
* High winds or tornado strike                        Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM S      Hazardous
* FIRE needed for the current operating mode Event
* EXPLOSION                        None                                                                          None System                                                                                        AND EITHER Affecting Malfunct.
* Other events with similar hazard characteristics as    - Event damage has caused indications of Safety determined by the Shift Manager                            degraded performance to the second train of Systems the SAFETY SYSTEM needed for the current operating mode
                                                                                                - Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)
 
Enclosure 6 to 0CAN031801 Supporting Referenced Document Pages
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 Table of Contents Section                                                                                                                            Page
: 1. PURPOSE ............................................................................................................................2
: 2. DEVELOPMENT METHODOLOGY AND BASES................................................................2 2.1  Threshold Limits ..........................................................................................................2 2.2  Effluent Release Points ...............................................................................................5 2.3  Source Term ................................................................................................................8 2.4  Effluent Flow ..............................................................................................................10 2.5  Release Duration .......................................................................................................11 2.6  Meteorology ...............................................................................................................12
: 3. DESIGN INPUTS ................................................................................................................13 3.1  General Constants and Conversion Factors ..............................................................13 3.2  Liquid Effluent ............................................................................................................13 3.3  Gaseous Effluent .......................................................................................................14
: 4. CALCULATIONS ................................................................................................................16 4.1  AU1.1 Liquid Release ................................................................................................16 4.2  AU1.1 Gaseous Release ...........................................................................................17 4.3  AA1.1, AS1.1 and AG1.1 Gaseous Release .............................................................17
: 5. CONCLUSIONS .................................................................................................................18
: 6. REFERENCES ...................................................................................................................18 ATTACHMENTS Attachment 1, AU1.1 Liquid Effluent EAL Calculations .........................................................20 Attachment 2, AU1.1 Gaseous Effluent EAL Calculations.....................................................21 Attachment 3, AA1.1, AS1.1 and AG1.1 URI Gaseous Effluent EAL Calculations................22 Page 1 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0
: 1. PURPOSE The Arkansas Nuclear One (ANO) Emergency Action Level (EAL) Technical Bases Manual contains background information, event declaration thresholds, bases and references for the EAL and Fission Product Barrier (FPB) values used to implement the Nuclear Energy Institute (NEI) 99-01 Revision 6 EAL guidance. This calculation document provides additional technical detail specific to the derivation of the gaseous and liquid radiological effluent EAL values developed in accordance with the guidance in NEI 99-01 Revision 6.
Documentation of the assumptions, calculations and results are provided for the Ax1 series EAL effluent monitor values associated with the following NEI 99-01 Revision 6 EALs:
NEI EAL AU1.1 (gaseous and liquid)
NEI EAL AA1.1 (gaseous and liquid)
NEI EAL AS1.1 (gaseous)
NEI EAL AG1.1 (gaseous)
: 2. DEVELOPMENT METHODOLOGY AND BASES 2.1    Threshold Limits 2.1.1    AU1.1 Liquid Threshold Limits Guidance Criteria AU1 addresses a release of gaseous or liquid radioactivity greater than 2 times the Offsite Dose Calculation Manual (ODCM) limits for 60 minutes or longer.
ANO Bases ODCM Section L 2.3.1 states that the concentration limits for the radioactive liquid effluents released to the discharge canal are as follows:
Less than or equal to the concentrations specified in 10 CFR Part 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases Less than or equal to 2.0E-04 Ci/ml total activity for dissolved and entrained noble gases The site specific AU1.1 liquid effluent EAL threshold values will equate to 2 times the ODCM limit.
Page 2 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 2.1.2 AU1.1 Gaseous Threshold Limits Guidance Criteria AU1 addresses a release of gaseous or liquid radioactivity greater than 2 times the Offsite Dose Calculation Manual (ODCM) limits for 60 minutes or longer.
ANO Bases ODCM Section L 2.4.1 states that the dose rate limits for the radioactive gaseous effluents released from the site to unrestricted areas are as follows:
Less than or equal to 500 mrem/yr to the total body (Noble Gasses)
Less than or equal to 3000 mrem/yr to the skin (Noble Gasses)
Less than or equal to 1500 mrem/yr to any organ (I-131, H-3, and for all radionuclides in particulate form with half-lives greater than 8 days)
ODCM gaseous setpoint calculations are based on the noble gas limits. Organ dose includes inhalation, ingestion and deposition pathways and are applied in unrestricted area site boundary gaseous effluent dose calculations used in the Annual Radioactive Effluent Release Report. Ingestion pathway bases are not compatible or directly comparable with short term event considerations, and are not a significant contribution to the total dose (total body or skin dose limits from noble gas are the major exposure pathway). Thus, the organ dose limit is not applicable for EAL threshold determination.
The site specific AU1.1 gaseous effluent EAL threshold values will equate to 2 times the ODCM limit for the lesser of the total body or skin exposure pathways.
2.1.3 AA1.1 Liquid Threshold Limits Guidance Criteria AA1 addresses a release of radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.
This is based on values at 1% of the EPA Protective Action Guides (PAGs).
Per NEI 99-01, the effluent monitor readings should correspond to the above dose limits at the site-specific dose receptor point (consistent with the calculation methodology employed) for one hour of exposure.
Page 3 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 ANO Bases The liquid effluent limits are based on the water concentration values given in 10 CFR 20 Appendix B Table 2 Column 2 (see Section 2.1.1 above). The 10 CFR 20 values are equivalent to the radionuclide concentrations which, if ingested continuously over the course of a year, would produce a total effective dose equivalent of 0.05 rem (50 mrem).
The EPA PAGs are based on a TEDE dose from immersion, inhalation and deposition.
The 10 CFR 20 limits and the EPA limits do not represent the same type of exposure and thus cannot be compared on a one to one basis.
Thus, the site specific EALs will not contain an AA1.1 liquid effluent monitor threshold value that equates to 1% of the EPA PAG. However, EALs AA1.3 (liquid effluent sample analysis) and AA1.4 (field survey results) will remain applicable for liquid effluent releases that exceed their respective thresholds.
2.1.4 AA1.1 Gaseous Threshold Limits Guidance Criteria AA1 addresses a release of radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.
Per NEI 99-01, the effluent monitor readings are based on values at 1% of the EPA Protective Action Guides (PAGs) at the site-specific dose receptor point (consistent with the calculation methodology employed) for one hour of exposure.
ANO Bases The gaseous effluent limits for AA1.1 are based on values that equate to an offsite dose greater than 10 mrem TEDE or 50 mrem CDE thyroid, which are 1% of the EPA PAGs.
2.1.5 AS1.1 Gaseous Threshold Limits Guidance Criteria AS1 addresses a release of radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE.
This is based on values at 10% of the EPA Protective Action Guides (PAGs) at the site-specific dose receptor point (consistent with the calculation methodology employed) for one hour of exposure.
ANO Bases The gaseous effluent limits for AS1.1 are based on values that equate to an offsite dose greater than 100 mrem TEDE or 500 mrem CDE thyroid, which are 10% of the EPA PAGs.
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Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 2.1.6  AG1.1 Gaseous Threshold Limits Guidance Criteria AG1 addresses a release of radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE.
This is based on values at 100% of the EPA Protective Action Guides (PAGs) at the site-specific dose receptor point (consistent with the calculation methodology employed) for one hour of exposure.
ANO Bases The gaseous effluent limits for AG1.1 are based on values that equate to an offsite dose greater than 1,000 mrem TEDE or 5,000 mrem CDE thyroid, which are 100% of the EPA PAGs.
2.2  Effluent Release Points Note - All effluent release points assume a background reading of zero to conservatively account for all modes of operation applicable to the EALs.
2.2.1  Liquid Release Points Guidance Criteria Per NEI 99-01, the AU1 IC addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways (EAL AU1.1) and planned batch releases from non-continuous release pathways (EAL AU1.2).
Per NEI 99-01, the AA1 IC includes events or conditions involving a radiological release, whether gaseous or liquid, monitored or un-monitored. 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 site-specific monitor list and threshold values should be determined with consideration of the selection of the appropriate installed gaseous and liquid effluent monitors.
ANO Bases There are three monitored liquid effluent lines that discharge to the environment at ANO (ODCM Section 2.1):
ANO-1:      RE-4642 - Liquid Radwaste Monitor ANO-2:      2RE-2330 - Liquid Radwaste Monitor 2RE-4423 - Liquid Radwaste Monitor Page 5 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 2.2.2 Gaseous Release Points Guidance Criteria Per NEI 99-01, the AU1 IC addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways (EAL #1) and planned batch releases from non-continuous release pathways (EAL #2).
Per NEI 99-01, the AA1 IC includes events or conditions involving a radiological release, whether gaseous or liquid, monitored or un-monitored. 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.
Per NEI 99-01, the AS1 and AG1 ICs address monitored and un-monitored releases of gaseous radioactivity. 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 site-specific monitor list and threshold values should include the effluent monitors described in emergency plan and emergency dose assessment procedures.
ANO Bases There are ten monitored gaseous effluent lines that discharge to the environment at ANO (ODCM Section 3.1.2.a):
ANO-1:    RX-9820 (SPING 1) - Unit 1 Containment Purge Exhaust RX-9825 (SPING 2) - Unit 1 Radwaste Area Exhaust (RE-4830 - Waste Gas Holdup System Monitor is upstream to RX-9825)
RX-9830 (SPING 3) - Unit 1 Fuel Handling Area Exhaust RX-9835 (SPING 4) - Unit 1 Penetration Room Exhaust ANO-2:    2RX-9820 (SPING 5) - Unit 2 Containment Purge Exhaust (2RE-8233 -
Containment Building Purge Monitor is upstream to 2RX-9820) 2RX-9825 (SPING 6) - Unit 2 Radwaste Area Exhaust (2RE-2429 -
Waste Gas Holdup System Monitor is upstream to 2RX-9825) 2RX-9830 (SPING 7) - Unit 2 Fuel Handling Area Exhaust 2RX-9835 (SPING 8) - Unit 2 Penetration Room Exhaust 2RX-9845 (SPING 10) - Auxiliary Building Extension Exhaust (ABE)
Per STM 2-47-2, Turbine Building ABE Ventilation, the most probably release of radioactivity through this pathway would be due to a primary-to-secondary leak where radioactivity from the steam generators would be sent to the Start Up / Blowdown DI and possibly released via the Page 6 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 ABE ventilation. However, Operations has administrative controls in place via Abnormal Operating Procedures (AOP) and Emergency Operating Procedures (EOP) to control / limit any release via this pathway due to this type of event.
Radioactivity from the Auxiliary Building Extension (ABE) exhaust is normally below detectable limits. Review of the 2017 Unit 2 gaseous release permits revealed that the weekly analyses of the ABE pathway did not contain any measurable radioactivity from the vent and thus no release permits were required during 2017. Since this pathway does not typically discharge radioactivity above detection limits during normal operations, the pathway does not meet the NEI 99-01 criteria for an EAL threshold: normally occurring continuous radioactivity release or a planned batch release from non-continuous release pathways.
Therefore, no threshold will be developed for EAL AU1.1 for this pathway. EALs AU1.2 and AU1.3 will continue to be valid for a release from the ABE.
2RX-9850 (SPING 11) - Low Level Radwaste Building Exhaust Per U2 SAR, Section 11.5.6.1, Low Level Radioactive Waste Storage Building (LLRWSB), the LLRWSB is designed to provide a controlled environment for receiving and shipping, inspection, equipment sorting, compaction, and decontamination activities associated with on-site storage and off-site shipment of LLRW. The only potential release of radioactivity would occur during compacting operations; however, this process is not currently used.
Radioactivity from the Low Level Radwaste Building exhaust is normally below detectable limits. Review of the 2017 Unit 2 gaseous release permits revealed that the LLRWSB weekly analyses did not contain any measurable radioactivity from the vent and thus no release permits were required during 2017. Since this pathway does not typically discharge radioactivity above detection limits during normal operations, the pathway does not meet the NEI 99-01 criteria for an EAL threshold:
normally occurring continuous radioactivity release or a planned batch release from non-continuous release pathways. Therefore, no threshold will be developed for EAL AU1.1 for this pathway. EALs AU1.2 and AU1.3 will continue to be valid for a release from the LLRWSB.
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Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 2.3  Source Term 2.3.1  AU1.1 Liquid Source Term Guidance Criteria NEI 99-01 does not provide specific guidance for AU1 liquid source term assumptions.
ANO Bases The ODCM setpoint method calls for a sample to be obtained and a gross gamma (Cs-137 equivalent) count and a gamma isotopic analysis performed.
Since liquid releases vary in isotopic composition, Cs-137 is considered a reasonable representative isotope and is used as the assumed source term for the liquid effluent EAL calculations.
2.3.2  AU1.1 Gaseous Source Term Guidance Criteria NEI 99-01 does not provide specific guidance for AU1 gaseous source term assumptions.
ANO Bases The gaseous source term is based upon the NUREG-1940 Table 1-6 noble gas fraction of activity available at shutdown.
2.3.3  AA1.1, AS1.1 and AG1.1 Gaseous Source Terms Guidance Criteria NEI 99-01 specifies that the calculation of monitor readings will require use of an assumed release isotopic mix; the selected mix should be the same for ICs AA1, AS1 and AG1.
ANO Bases The AA1.1, AS1.1 and AG1.1 gaseous EAL thresholds are based upon the ANO URI dose model results using input assumptions applicable to the event, pathway and particular monitor.
The source term used in the URI dose model is taken from NUREG-1940 Table 1.1 (URI Requirements Specification Appendix A Section A.2).
The process reductions used in the URI dose model are taken from NUREG-1228 and NUREG-1465 (URI Requirements Specification Appendix A Sections A.4 and A.5).
Note - HUT is hold-up time.
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Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 URI input assumptions for the gaseous release points are as follows:
Unit 1 Containment CP Filter RCS          HUT < 2 hrs                              CP Exhaust      Env Working Sprays On RX-9820 (SPING 1) is modeled to release path A utilizing an event with fuel clad damage.
Containment Aux Building    RWA Filter RCS      HUT < 2 hrs                                    RWA Exhaust      Env HUT < 2 hrs      Working Sprays On RX-9825 (SPING 2) is modeled to release path D utilizing an event with fuel clad damage.
Fuel Building            FHA Filter SFP                                                    SFA Exhaust      Env HUT < 2 hrs              Working RX-9830 (SPING 3) is modeled to release path M utilizing an event with underwater fuel clad damage.
Containment Aux Building    EPPR Filter RCS      HUT < 2 hrs                                    PPR Exhaust      Env HUT < 2 hrs      Working Sprays On RX-9835 (SPING 4) is modeled to release path C utilizing an event with fuel clad damage.
Unit 2 Containment CP Filter RCS          HUT < 2 hrs                              CP Exhaust      Env Working Sprays On 2RX-9820 (SPING 5) is modeled to release path A utilizing an event with fuel clad damage.
Containment Aux Building    RWA Filter RCS      HUT < 2 hrs                                    RWA Exhaust      Env HUT < 2 hrs      Working Sprays On 2RX-9825 (SPING 6) is modeled to release path D utilizing an event with fuel clad damage.
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Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 Fuel Building            FHA Filter SFP                                                      SFA Exhaust      Env HUT < 2 hrs              Working 2RX-9830 (SPING 7) is modeled to release path M utilizing an event with underwater fuel clad damage.
Containment Aux Building    EPPR Filter RCS      HUT < 2 hrs                                      PPR Exhaust      Env HUT < 2 hrs      Working Sprays On 2RX-9835 (SPING 8) is modeled to release path C utilizing an event with fuel clad damage.
For RCS initiated accidents, 0 time after shutdown (TAS) is used as no credit is taken for source term decay.
For the spent fuel accident, the new fuel age option is used with 80 hours for time after shutdown (TAS).
2.4  Effluent Flow 2.4.1  Effluent Liquid Discharge Flow Guidance Criteria NEI 99-01 does not provide specific guidance for effluent liquid flow assumptions.
ANO Bases Discharge Flow Unit 1 SAR Section 11.1.1 describes the liquid waste processing system for Unit 1. The radioactive waste disposal systems are designed to collect, store, process, monitor, and safely dispose all liquids, gases and solids which are potentially radioactive. U1 SAR Table 11-6 discharge flows are as follows:
Treated Waste Pumps, P-47A/B - 85 gpm Max Flow Rate to Discharge Flume Filtered Waste Pumps P-53A/B - 38 gpm Max Flow Rate to Discharge Flume Laundry Drain Pump, P 50 gpm Max Flow Rate to Discharge Flume A representative discharge flow rate of 85 gpm is used as the input for purposes of the U1 liquid effluent EAL calculations.
Unit 2 SAR Section 11.2.1 describes the liquid waste processing system for Unit 2.
Radioactive liquid wastes which are discharged from the plant are first processed by the Waste Management System (WMS) or the Boron Management System (BMS). The Page 10 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 contents of turbine building sumps and detergent wastes are routinely discharged unprocessed due to their very small potential for radioactive contamination. Discharge flows per U2 SAR are as follows:
Treated Waste Pumps, 2P-47A/B - 50 gpm Max Flow Rate to Discharge Flume (Table 11.2-2)
Treated Waste Pumps, 2P-53A/B - 50 gpm Max Flow Rate to Discharge Flume (Table 11.2-8)
Regenerative Waste Tank Pumps, 2P-135A/B - 100 gpm Max Flow Rate to Discharge Flume (Table 11.2-23)
A representative discharge flow rate of 100 gpm is used as the input for purposes of the U2 liquid effluent EAL calculations.
Dilution Flow Per ODCM Section 2.1.4, dilution volume is the number of circulating water pumps in operation multiplied by the approximate flowrate of a circulating water pump (normally 191,500 gpm) or an indicated flow rate.
A normal dilution flow rate of one circulating water pump (191,500 gpm) is selected for EAL calculations.
2.4.2  Effluent Gaseous Vent Flow Guidance Criteria NEI 99-01 does not provide specific guidance for effluent gaseous vent flow assumptions.
ANO Bases Vent flow values for AU1.1, AA1.1, AS1.1 and AG1.1 use the URI default flow values.
2.5  Release Duration Guidance Criteria Per NEI 99-01, the effluent monitor readings for AA1.1, AS1.1 and AG1.1 gaseous EAL threshold values should correspond to a dose at the site-specific dose receptor point (consistent with the calculation methodology employed) for one hour of exposure.
ANO Bases The effluent monitor readings for AA1.1, AS1.1 and AG1.1 gaseous EAL threshold values are calculated for a release duration of one hour.
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Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 2.6  Meteorology Guidance Criteria The effluent monitor readings should correspond to the applicable dose limit at the site-specific dose receptor point. The site-specific dose receptor point is the distance(s) and/or locations used by the licensee to distinguish between on-site and offsite doses. The selected distance(s) and/or locations should reflect the content of the emergency plan, and the procedural methodology used to determine offsite doses and protective action recommendations. This is typically the boundary of the Owner Controlled Area.
Monitor readings will be calculated using a set of assumed meteorological data or atmospheric dispersion factors; the data or factors selected for use should be the same for ICs AA1, AS1 and AG1.
ANO Bases The site specific meteorology used for the EAL calculation inputs are based upon the FSAR and ODCM as documented below.
2.6.1  ODCM Gaseous Dispersion Factor (U1 SAR 2.3.6.2.5)
The highest annual average X/Q value for a ground level release, derived using the methodology of Regulatory Guide 1.111, is 2.0E-5 sec/m3 in the west-southwest sector at a distance of 0.65 miles.
For purposes of EALs thresholds the SAR historical stability class is used as a basis and any changes in SAR stability results need not require a recalculation of this input.
2.6.2  ODCM Gaseous Dispersion Factor (U1 SAR 2.3.6.2.5)
The predominant stability class of E is determined from the seasonal and annual percent frequency tables.
For purposes of EAL thresholds a long term historical meteorological stability of class E is used as a basis and any changes in seasonal or annual stability results need not require a redetermination of this input.
2.6.3  Wind Speed 190 (elevated) wind speed having the greatest number of intervals for all stability classes is 5 kts or 5.75 mph (U1 SAR Table 2-40).
40 (ground level) wind speed having the greatest number of intervals for all stability classes is 4 mph (U1 SAR Table 2-41).
For purposes of EALs thresholds the SAR historical meteorological wind speeds are used as a basis and any changes in annual predominant wind speed results need not require a recalculation of this input.
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Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 2.6.4  Wind Direction 190 (elevated) wind direction having the greatest number of intervals for all stability classes is sector E (U1 SAR Table 2-40).
40 (elevated) wind direction having the greatest number of intervals for all stability classes is sector E (U1 SAR Table 2-41).
For purposes of EALs thresholds the SAR historical meteorological wind directions are used as a basis and any changes in annual predominant wind direction results need not require a recalculation of this input.
2.6.5  Other Parameters No precipitation is assumed to occur for the duration of the release and plume transport across the EPZ.
: 3. DESIGN INPUTS 3.1  General Constants and Conversion Factors 3.1.1  472 cc/sec per cfm 3.1.2  106 Ci per Ci 3.2  Liquid Effluent 3.2.1  Liquid Effluent Monitor Ranges
: 1)  RE-4642 (STM 1-62 Table 62.2, TDL185 0080/0090) ................... 1E+0 to 1E+8 cpm
: 2)  2RE-2330 (TDW120 2020 Section 1.1.2.1) ................................... 1E+0 to 1E+6 cpm
: 3)  2RE-4423 (TDW120 2020 Section 1.1.2.1) ................................... 1E+0 to 1E+6 cpm 3.2.2  Offset Factor (EMS Report)
: 1)  RE-4642 .............................................................................................. 3.027E+07 cpm
: 2)  2RE-2330 ............................................................................................ 2.054E+06 cpm
: 3)  2RE-4423 ............................................................................................ 2.054E+06 cpm 3.2.3  Slope Factor (EMS Report)
: 1)  RE-4642 ............................................................................. 9.572E-01 cpm per &#xb5;Ci/ml
: 2)  2RE-2330 ........................................................................... 9.178E-01 cpm per &#xb5;Ci/ml
: 3)  2RE-4423 ........................................................................... 9.178E-01 cpm per &#xb5;Ci/ml Page 13 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 3.2.4  Liquid Effluent Dilution Flowrate - DV (ODCM 2.1.4)
: 1)  Minimum Flow ......................................................................................... 191,500 gpm 3.2.5  Liquid Effluent Actual Flowrate - FA
: 1)  RE-4642 Liquid Radwaste Discharge (see section 2.4.1) ............................... 85 gpm
: 2)  2RE-2330 Liquid Radwaste Discharge (see section 2.4.1) ........................... 100 gpm
: 3)  2RE-4423 Liquid Radwaste Discharge (see section 2.4.1) ........................... 100 gpm 3.2.6  10 CFR 20 Appendix B, Table 2, Column 2 Source Term Limit (MPCi)
Cs-137 .............................................................................................................. 1E-6 Ci/ml 3.3  Gaseous Effluent 3.3.1  Gaseous Effluent Monitor Ranges (TDE070 0290)
Note - Containment Purge, Radwaste Area, Fuel Handling Area and Penetration Room SPING monitors have identical ranges.
: 1)  Low Range ............................................................. 1.12E-7 to 3.63E-2 Ci/cc Xe-133
: 2)  Medium Range...................................................... 4.16E-5 to 6.76E+1 Ci/cc Xe-133
: 3)  High Range ........................................................... 4.57E-3 to 5.51E+3 Ci/cc Xe-133 3.3.2  Gaseous Effluent Source Flow (URI default values)
: 1)  Unit 1 RX-9820 (Containment Purge) ...................................................... 1.8E+04 cfm RX-9825 (Radwaste Area) ............................................................ 4.4E+04 cfm RX-9830 (Fuel Handling Area) ...................................................... 4.0E+04 cfm RX-9835 (Penetration Room) ........................................................ 1.8E+03 cfm
: 2)  Unit 2 2RX-9820 (Containment Purge) .................................................. 3.97E+04 cfm 2RX-9825 (Radwaste Area) .......................................................... 5.0E+04 cfm 2RX-9830 (Fuel Handling Area) .................................................... 3.6E+04 cfm 2RX-9835 (Penetration Room) ...................................................... 2.0E+03 cfm 3.3.3  AU1.1 Dispersion Factor (X/Q)
Dispersion Factor (SAR 2.3.6.2.5) ..............................................................2.0E-05 sec/m3 Page 14 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 3.3.4 AU1.1 Gaseous Source Term Fraction (Ai)
NUREG-1940 Table 1-6 noble gas fraction of activity available at shutdown.
Isotopic Fraction Ai (unitless)
Kr-83m        1.83E-02 Kr-85        1.70E-03 Kr-85m        3.71E-02 Kr-87        7.40E-02 Kr-88        1.02E-01 Xe-131m        2.20E-03 Xe-133        3.26E-01 Xe-133m        1.03E-02 Xe-135        8.54E-02 Xe-135m        6.90E-02 Xe-138        2.74E-01 1.00E+00 3.3.5 ODCM Dose Factors (Regulatory Guide 1.109 Table B-1)
Note - RG 1.109 values converted from mRem/yr per Ci/m3 to mRem/yr per &#xb5;Ci/m3.
Total Body Dose        Skin Beta Dose        Gamma Air Dose Factor - Ki          Factor - Li            Factor - Mi (mRem/yr / &#xb5;Ci/m3)    (mRem/yr / &#xb5;Ci/m3)      (mRad/yr / &#xb5;Ci/m3)
Kr-83m        7.56E-02              0.00E+00              1.93E+01 Kr-85      1.61E+01              1.34E+03              1.72E+01 Kr-85m        1.17E+03              1.46E+03              1.23E+03 Kr-87      5.92E+03              9.73E+03              6.17E+03 Kr-88      1.47E+04              2.37E+03              1.52E+04 Xe-131m        9.15E+01              4.76E+02              1.56E+02 Xe-133        2.94E+02              3.06E+02              3.53E+02 Xe-133m        2.51E+02              9.94E+02              3.27E+02 Xe-135        1.81E+03              1.86E+03              1.92E+03 Xe-135m        3.12E+03              7.11E+02              3.36E+03 Xe-138        8.83E+03              4.13E+03              9.21E+03 Page 15 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0
: 4. CALCULATIONS 4.1  AU1.1 Liquid Release 4.1.1  ODCM Liquid Release Limit (ODCM Section 2.1)
                                                              +
                  =    x          x          x                                  +
Where:
ML            Radiation monitor setpoint equivalent to the ODCM limit (cpm)
A            Allocation fraction for the specific unit (1 selected for EAL calculations)
Offset        Detector response for the minimum detectable sample activity calculated from the calibration data (cpm)
SA            Gross gamma (Cs-137 equivalent) activity for the tank (&#xb5;Ci/ml)
(Cs-137 10 CFR 20 limit of 1E-6 Ci/ml selected for EAL calculations)
Slope        Log of the detector response (cpm) / Log of activity concentration (&#xb5;Ci/ml)
DV            Dilution volume flowrate (gpm)
Ci            Concentration of isotope i (&#xb5;Ci/ml) (Cs-137 10 CFR 20 limit of 1E-6 Ci/ml selected for EAL calculations)
MPCi          10 CFR 20 isotope i concentration limit (Ci/ml) (Cs-137 10 CFR 20 limit of 1E-6 Ci/ml selected for EAL calculations)
CTNG          Total concentration of noble gases (&#xb5;Ci/ml) (No noble gas assumed in the liquid discharge for EAL calculations)
MPCTNG        10 CFR 20 Total Noble Gas limit of 2E-4 (Ci/ml)
FA            Actual flowrate (gpm) - maximum flowrate of the discharge pump B            background countrate prior to the release (cpm) (0 cpm selected for EAL calculations) 4.1.2  AU1.1 Liquid Release EAL Threshold AU1.1 liquid is two times (2x) the calculated ODCM limit setpoint.
See Attachment 1 for the spreadsheet calculations that develop the AU1.1 liquid effluent EAL threshold values for each applicable monitor.
Page 16 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 4.2  AU1.1 Gaseous Release 4.2.1  ODCM Gaseous Release Limit 500 Limit total body 472  f    Ai  K i Q i 3000 Limit Skin 472  f    Ai  Li  1.1M i Q i Where:
Limit          radiation monitor reading equivalent to the ODCM limit (Ci/cc) 500/3000      ODCM Limit - 500 total body or 3000 skin (mrem/yr) 472            conversion factor (cc/ft3 per sec/min) f              vent flow (cfm)
X/Q            highest annual average gaseous site boundary dispersion factor (sec/m3)
Ai            isotopic fraction of the mix activity released (unitless)
Ki            total body dose factor (mrem/yr per &#xb5;Ci/m3)
Li + 1.1Mi skin dose factor (mrem/yr per &#xb5;Ci/m3) 4.2.2  AU1.1 Gaseous Release EAL Threshold AU1.1 is two times (2x) the lesser of the calculated total body or skin value ODCM limit setpoint.
See Attachment 2 for the spreadsheet calculations that develop the AU1.1 gaseous effluent EAL threshold values for each applicable monitor.
4.3  AA1.1, AS1.1 and AG1.1 Gaseous Release The AA1.1, AS1.1 and AG1.1 gaseous release EAL threshold are developed using the site specific URI dose assessment models with the inputs described in Section 2 above.
Note - URI calculations were performed for each unit. There was no difference in results between units.
Refer to Attachment 3 for the results of the URI gaseous effluent EAL threshold calculations.
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Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0
: 5. CONCLUSIONS 5.1  Unit 1 Monitor #      Monitor Name            GE        SAE        Alert      UE 4.15E+1    4.15E+0    4.15E-1    1.21E-3 RX-9820    Containment Purge (Ci/cc)  (Ci/cc)    (Ci/cc)    (Ci/cc) 2.67E+1    2.67E+0    2.67E-1    4.94E-4 Gaseous RX-9825    Radwaste Area (Ci/cc)  (Ci/cc)    (Ci/cc)    (Ci/cc) 6.20E+2    6.20E+1    6.20E+0    5.44E-4 RX-9830    Fuel Handling Area (Ci/cc)  (Ci/cc)    (Ci/cc)    (Ci/cc) 6.55E+2    6.55E+1    6.55E+0    1.21E-2 RX-9835    Penetration Room (Ci/cc)  (Ci/cc)    (Ci/cc)    (Ci/cc)
Liquid 2.46E+05 RE-4642    Liquid Radwaste            N/A        N/A        N/A (cpm) 5.2  Unit 2 Monitor #      Monitor Name            GE        SAE        Alert      UE 1.88+01    1.88E+00    1.88E-01    5.48E-4 2RX-9820    Containment Purge (Ci/cc)    (Ci/cc)    (Ci/cc)  (Ci/cc) 2.35+01    2.35E+00    2.35E-01    4.35E-4 Gaseous 2RX-9825    Radwaste Area (Ci/cc)    (Ci/cc)    (Ci/cc)  (Ci/cc) 6.86E+02    6.86E+01    6.86E+00    6.04E-4 2RX-9830    Fuel Handling Area (Ci/cc)    (Ci/cc)    (Ci/cc)  (Ci/cc) 5.88E+02    5.88E+01    5.88E+00    1.09E-2 2RX-9835    Penetration Room (Ci/cc)    (Ci/cc)    (Ci/cc)  (Ci/cc) 2.45E+04 2RE-2330    Liquid Radwaste            N/A        N/A        N/A (cpm)
Liquid                                                                            2.45E+05 2RE-4423    Liquid Radwaste            N/A        N/A        N/A (cpm)
: 6. REFERENCES 6.1    10 CFR Part 20, Appendix B, Table 2, Column 2 6.2    Regulatory Guide 1.109 Table B-1 6.3    NEI 99-01 Revision 6, Methodology for Development of Emergency Action Levels, November 2012 6.4    NUREG-1940, RASCAL 4, Description of Models and Methods, December 2012 6.5    NUREG-1228, Source Term Estimation During Incident Response to Severe Nuclear Power Plant Accidents, October 1988 Page 18 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 6.6  ANO Offsite Dose Calculation Manual (ODCM), Revision 25 6.7  Unified RASCAL Interface Requirement Specification, Draft 051611 6.8  Unified RASCAL Interface Requirement Specification ANO Unit 1 Site Annex, Version 1.1 6.9  Unified RASCAL Interface Requirement Specification ANO Unit 2 Site Annex, Version 1.1 6.10 ANO1 Safety Analysis Report (SAR), Amendment 26 6.11 ANO2 Safety Analysis Report (SAR), Amendment 27 6.12 STM 1-62, Radiation Monitoring, Revision 13 6.13 STM 2-47-2, Turbine Building and Auxiliary Building Extension Ventilation, Revision 15 6.14 TD L185.0080, Operation and Maintenance Samplers, Revision 0 6.15 TD L185 0080.0090, Operation and Maintenance Digital Ratemeter Model DRM-100 and DRM-100S, Revision 4 6.16 TDW120 2020, Installation, Operation, and Maintenance Instructions Switchboard Edgewise Instruments Five Inch Classification 252 Line, Revision 0 6.17 TDE070 0290, Instruction Manual Particulate, Iodine and Noble Gas Air Monitor Model SPING-3A/SPING-4A, Revision 15 6.18 EMS Activity Monitors Report dated 10/07/15 Page 19 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 ATTACHMENT 1 AU1.1 Liquid Effluent EAL Calculations RU1.1 EAL Threshold Actual Flowrate (Fa)
Expected Countrate Monitor Setpoint -
(cpm)
Monitor  Offset        Slope      K=Offset
* S^Slope                              M=A*(K*Fm/Fa)+B      Value (cpm)
RE-4642 3.03E+07      9.57E-01    5.47E+01                85                      1.23E+05 2.46E+05 2RE-2330 2.05E+06      9.18E-01    6.39E+00                100                    1.22E+04 2.45E+04 2RE-4423 2.05E+06      9.18E-01    6.39E+00                100                    1.22E+04 2.45E+04 Gross gamma Cs-137 Equivalent Activity - S (&#xb5;Ci/ml): 1.00E-06 Dilution Volume Flowrate - DV (gpm):                                      1.92E+05 Cs-137 Activity - C (&#xb5;Ci/ml):                                    1.00E-06 Cs-137 10 CFR 20 Limit - MPC (&#xb5;Ci/ml):                                        1.00E-06 Dilution Factor - DF=i(Ci/MPCi) + CTNG/MPCTNG:                                            1.00E+00 Theoretical Release Rate - Fm=DV/DF (gpm):                                        1.92E+05 Allocation Fraction - A:                          100%
Background (cpm):                              0 Page 20 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 ATTACHMENT 2 AU1.1 Gaseous Effluent EAL Calculations Total Body Dose Factor - Ki                                    Gamma Air Dose Factor - Mi Skin Beta Dose Factor - Li Source Term Fraction - Ai Ai x Ki                Ai x (Li + 1.1Mi)
(mRem/yr per &#xb5;Ci/m3)            (mRem/yr per &#xb5;Ci/m3)          (mRad/yr per &#xb5;Ci/m3)                                        (mRem/yr per &#xb5;Ci/m3)    (mRem/yr per &#xb5;Ci/m3)
Kr-83m    7.56E-02                        0.00E+00                      1.93E+01                      1.83E-02                      1.38E-03                3.89E-01 Kr-85  1.61E+01                        1.34E+03                      1.72E+01                      1.70E-03                      2.74E-02                2.31E+00 Kr-85m    1.17E+03                        1.46E+03                      1.23E+03                      3.71E-02                      4.34E+01                1.04E+02 Kr-87  5.92E+03                        9.73E+03                      6.17E+03                      7.40E-02                      4.38E+02                1.22E+03 Kr-88  1.47E+04                        2.37E+03                      1.52E+04                      1.02E-01                      1.50E+03                1.95E+03 Xe-131m    9.15E+01                        4.76E+02                      1.56E+02                      2.20E-03                      2.01E-01                1.42E+00 Xe-133    2.94E+02                        3.06E+02                      3.53E+02                      3.26E-01                      9.59E+01                2.26E+02 Xe-133m    2.51E+02                        9.94E+02                      3.27E+02                      1.03E-02                      2.59E+00                1.39E+01 Xe-135    1.81E+03                        1.86E+03                      1.92E+03                      8.54E-02                      1.55E+02                3.39E+02 Xe-135m    3.12E+03                        7.11E+02                      3.36E+03                      6.90E-02                      2.15E+02                3.04E+02 Xe-138    8.83E+03                        4.13E+03                      9.21E+03                      2.74E-01                      2.42E+03                3.90E+03 1.00E+00                      4.87E+03                8.07E+03 Calculation Constants Total Body-DDE (mRem/yr):                                                            500 Skin Dose-SDE (mRem/yr):                                                            3000 UCF (CFM to cc/sec):                                                            472 X/Q (sec/m3):                                                      2.00E-05 DCF (mRad to mRem):                                                              1.1 Calculation Results Unit 1:                                        RX-9820 RX-9825 RX-9830 RX-9835 Flow (cfm):                                        1.80E+04 4.40E+04 4.00E+04 1.80E+03 Limit-TB (&#xb5;Ci/cc):                                        6.04E-04 2.47E-04 2.72E-04 6.04E-03 Limit-Skin (&#xb5;Ci/cc):                                        2.19E-03 8.95E-04 9.85E-04 2.19E-02 2x ODCM (&#xb5;Ci/cc):                                          1.21E-03 4.94E-04 5.44E-04 1.21E-02 Unit 2:                                    2RX-9820 2RX-9825 2RX-9830 2RX-9835 Flow (cfm):                                    3.97E+04 5.00E+04 3.60E+04 2.00E+03 Limit-TB (&#xb5;Ci/cc):                                    2.74E-04 2.18E-04 3.02E-04 5.44E-03 Limit-Skin (&#xb5;Ci/cc):                                    9.92E-04 7.88E-04 1.09E-03 1.97E-02 2x ODCM (&#xb5;Ci/cc):                                        5.48E-04 4.35E-04 6.04E-04 1.09E-02 Page 21 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 ATTACHMENT 3 AA1.1, AS1.1 and AG1.1 Gaseous Effluent EAL Calculations Page 22 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9820 (SPING 1) Containment Purge Exhaust - Alert Dose Assessment ANO Unit 1                                                                                                                            Wednesday, October 07, 2015 15:52 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <CP Filters> < Env>                                                                                    PRF: 3.00E-03 Containment HUT: = < 2 Hours                        Containment Sprays: = ON                  Purge Filters: = Working                  Steam Gen: = N/A Aux / FHB HUT: = N/A                                Filters: = N/A                            Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                      On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                    Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: CP Gas Conc                                  Readings: 4.15E-01 &#xb5;CI/cc                  Flowrate: 18000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure        External Plume    Inhalation CEDE                      TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)      DDE (mRem)            (mRem)                          (mRem)
(mRem)                  (mRem M
S.B.        8.00E+00            5.32E+00          1.19E+00          6.77E-01    7.19E+00  5.01E+01 0.7        7.44E+00            4.92E+00          1.11E+00          6.66E-01    6.70E+00  4.56E+01 P                          L 1.0        5.36E+00            3.47E+00          8.68E-01          5.91E-01    4.93E+00  3.26E+01                                N      K O
1.5        3.55E+00            2.26E+00          6.52E-01          4.47E-01    3.36E+00  2.35E+01 2.0        2.40E+00            1.52E+00          5.12E-01          3.15E-01    2.35E+00  1.86E+01                                      G                J 3.0        2.14E+00            1.41E+00          3.61E-01          2.20E-01    1.99E+00  1.32E+01 Q    R                H 4.0        1.63E+00            1.05E+00          2.89E-01          1.67E-01    1.50E+00  1.05E+01 U                I 5.0        1.36E+00            8.64E-01          2.53E-01          1.35E-01    1.25E+00  9.29E+00 T
7.0        9.84E-01            6.27E-01          2.01E-01          0.00E+00    8.29E-01  7.67E+00 10.0        5.72E-01            3.56E-01          1.24E-01          0.00E+00    4.80E-01  5.00E+00                                    S Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 155234.UR17                                                                        No PAGs Exceeded Release Rates (Ci/sec)
                    * *
* Classification: Validate against Emergency Action Levels * *
* Particulate                      6.56E-04 (0.0%)
Iodine                          1.61E-02 (0.5%)
Reviewed By:                                                                                                    Noble Gas                      3.53E+00 (99.5%)
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Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9820 (SPING 1) Containment Purge Exhaust - Site Area Emergency Dose Assessment ANO Unit 1                                                                                                                            Wednesday, October 07, 2015 15:52 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <CP Filters> < Env>                                                                                    PRF: 3.00E-03 Containment HUT: = < 2 Hours                      Containment Sprays: = ON                  Purge Filters: = Working                  Steam Gen: = N/A Aux / FHB HUT: = N/A                              Filters: = N/A                            Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                      On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                  Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: CP Gas Conc                                  Readings: 4.15E+00 &#xb5;CI/cc                  Flowrate: 18000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                      TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                          (mRem)
(mRem)                  (mRem M
S.B.        8.00E+01        5.32E+01            1.19E+01          6.77E+00    7.19E+01  5.01E+02 0.7        7.44E+01        4.92E+01            1.11E+01          6.66E+00    6.70E+01  4.56E+02 P                        L 1.0        5.36E+01        3.47E+01            8.68E+00          5.91E+00    4.93E+01  3.26E+02                              N        K O
1.5        3.55E+01        2.26E+01            6.52E+00          4.47E+00    3.36E+01  2.35E+02 2.0        2.40E+01        1.52E+01            5.12E+00          3.15E+00    2.35E+01  1.86E+02                                    G                J 3.0        2.14E+01        1.41E+01            3.61E+00          2.20E+00    1.99E+01  1.32E+02 Q    R                H 4.0        1.63E+01        1.05E+01            2.89E+00          1.67E+00    1.50E+01  1.05E+02 U                I 5.0        1.36E+01        8.64E+00            2.53E+00          1.35E+00    1.25E+01  9.29E+01 T
7.0        9.84E+00        6.27E+00            2.01E+00          9.23E-01    9.21E+00  7.67E+01 10.0        5.72E+00        3.56E+00            1.24E+00          4.53E-01    5.25E+00  5.00E+00                                    S Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 155209.UR17                                                                        No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: Site Area Emergency * *
* Particulate                      6.56E-03 (0.0%)
Iodine                          1.61E-01 (0.5%)
Reviewed By:                                                                                                    Noble Gas                      3.53E+01 (99.5%)
Page 24 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9820 (SPING 1) Containment Purge Exhaust - General Emergency Dose Assessment ANO Unit 1                                                                                                                            Wednesday, October 07, 2015 15:52 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <CP Filters> < Env>                                                                                    PRF: 3.00E-03 Containment HUT: = < 2 Hours                      Containment Sprays: = ON                  Purge Filters: = Working                  Steam Gen: = N/A Aux / FHB HUT: = N/A                              Filters: = N/A                            Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                      On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                  Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: CP Gas Conc                                  Readings: 4.15E+01 &#xb5;CI/cc                  Flowrate: 18000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                      TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                          (mRem)
(mRem)                  (mRem M
S.B.        8.00E+01        5.32E+01            1.19E+01          6.77E+00    7.19E+01  5.01E+02 0.7        7.44E+01        4.92E+01            1.11E+01          6.66E+00    6.70E+01  4.56E+02 P                        L 1.0        5.36E+01        3.47E+01            8.68E+00          5.91E+00    4.93E+01  3.26E+02                              N        K O
1.5        3.55E+01        2.26E+01            6.52E+00          4.47E+00    3.36E+01  2.35E+02 G
2.0        2.40E+01        1.52E+01            5.12E+00          3.15E+00    2.35E+01  1.86E+02                                                      J 3.0        2.14E+01        1.41E+01            3.61E+00          2.20E+00    1.99E+01  1.32E+02 Q    R                  H 4.0        1.63E+01        1.05E+01            2.89E+00          1.67E+00    1.50E+01  1.05E+02 U                I 5.0        1.36E+01        8.64E+00            2.53E+00          1.35E+00    1.25E+01  9.29E+01 T
7.0        9.84E+00        6.27E+00            2.01E+00          9.23E-01    9.21E+00  7.67E+01 10.0        5.72E+00        3.56E+00            1.24E+00          4.53E-01    5.25E+00  5.00E+01                                    S Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 155647.UR17                                                                        No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: General Emergency * *
* Particulate                      6.56E-02 (0.0%)
Iodine                          1.61E+00 (0.5%)
Reviewed By:                                                                                                    Noble Gas                      3.53E+02 (99.5%)
Page 25 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9825 (SPING 2) Radwaste Area Exhaust - Alert Dose Assessment ANO Unit 1                                                                                                                            Wednesday, October 07, 2015 15:59 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <RWA Filters> < Env>                                                                      PRF: 1.20E-03 Containment HUT: = < 2 Hours                        Containment Sprays: = ON                  Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                          Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                    On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                  Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: RWA Gas Conc                                  Readings: 2.67E-01 &#xb5;CI/cc                Flowrate: 44000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure        External Plume    Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)      DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.24E+01            8.31E+00          9.39E-01          7.70E-01    1.00E+01  3.15E+01 0.7        1.16E+01            7.68E+00          9.00E-01          7.78E-01    9.36E+00  2.87E+01 1.0        8.36E+00            5.40E+00          7.60E-01          7.38E-01    6.90E+00  2.06E+01 O
1.5        5.52E+00            3.52E+00          5.92E-01          5.66E-01    4.67E+00  1.49E+01 2.0        3.74E+00            2.38E+00          4.56E-01          3.91E-01    3.22E+00  1.18E+01                                    G 3.0        3.33E+00            2.20E+00          3.23E-01          2.78E-01    2.80E+00  8.30E+00 4.0        2.54E+00            1.64E+00          2.60E-01          2.10E-01    2.11E+00  6.61E+00 5.0        2.12E+00            1.35E+00          2.26E-01          1.68E-01    1.74E+00  5.85E+00 T
7.0        1.54E+00            9.82E-01          1.75E-01          1.09E-01    1.27E+00  4.83E+00 10.0        8.92E-01            5.56E-01          1.03E-01          0.00E+00    6.59E-01  3.15E+00 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 155932.UR17                                                                        No PAGs Exceeded Release Rates (Ci/sec)
                    * *
* Classification: Validate against Emergency Action Levels * *
* Particulate                      4.13E-04 (0.0%)
Iodine                          1.01E-02 (0.2%)
Reviewed By:                                                                                                    Noble Gas                      5.54E+00 (99.8%)
Page 26 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9825 (SPING 2) Radwaste Area Exhaust - Site Area Emergency Dose Assessment ANO Unit 1                                                                                                                          Wednesday, October 07, 2015 15:59 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <RWA Filters> < Env>                                                                      PRF: 1.20E-03 Containment HUT: = < 2 Hours                      Containment Sprays: = ON                  Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                        Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                    On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: RWA Gas Conc                                Readings: 2.67E+00 &#xb5;CI/cc                Flowrate: 44000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.24E+02        8.31E+01            9.39E+00          7.70E+00    1.00E+02  3.15E+02 0.7        1.16E+02        7.68E+01            9.00E+00          7.78E+00    9.36E+01  2.87E+02 1.0        8.36E+01        5.40E+01            7.60E+00          7.38E+00    6.90E+01  2.06E+02 1.5        5.52E+01        3.52E+01            5.92E+00          5.66E+00    4.67E+01  1.49E+02 2.0        3.74E+01        2.38E+01            4.56E+00          3.91E+00    3.22E+01  1.18E+02 3.0        3.33E+01        2.20E+01            3.23E+00          2.78E+00    2.80E+01  8.30E+01 4.0        2.54E+01        1.64E+01            2.60E+00          2.10E+00    2.11E+01  6.61E+01 5.0        2.12E+01        1.35E+01            2.26E+00          1.68E+00    1.74E+01  5.85E+01 7.0        1.54E+01        9.82E+00            1.75E+00          1.09E+00    1.27E+01  4.83E+01 10.0        8.92E+00        5.56E+00            1.03E+00          4.90E+01    7.08E+00  3.15E+01 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 155911.UR17                                                                      No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: Site Area Emergency * *
* Particulate                      4.13E-03 (0.0%)
Iodine                          1.01E-01 (0.2%)
Reviewed By:                                                                                                  Noble Gas                      5.54E+01 (99.8%)
Page 27 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9825 (SPING 2) Radwaste Area Exhaust - General Emergency Dose Assessment ANO Unit 1                                                                                                                          Wednesday, October 07, 2015 15:58 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <RWA Filters> < Env>                                                                      PRF: 1.20E-03 Containment HUT: = < 2 Hours                      Containment Sprays: = ON                  Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                        Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                    On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: RWA Gas Conc                                Readings: 2.67E+01 &#xb5;CI/cc                Flowrate: 44000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.24E+03        8.31E+02            9.39E+01          7.70E+01    1.00E+03  3.15E+03 0.7        1.16E+03        7.68E+02            9.00E+01          7.78E+01    9.36E+02  2.87E+03 1.0        8.36E+02        5.40E+02            7.60E+01          7.38E+01    6.90E+02  2.06E+03 1.5        5.52E+02        3.52E+02            5.92E+01          5.66E+01    4.67E+02  1.49E+03 2.0        3.74E+02        2.38E+02            4.56E+01          3.91E+01    3.22E+02  1.18E+03 3.0        3.33E+02        2.20E+02            3.23E+01          2.78E+01    2.80E+02  8.30E+02 4.0        2.54E+02        1.64E+02            2.60E+01          2.10E+01    2.11E+02  6.61E+02 5.0        2.12E+02        1.35E+02            2.26E+01          1.68E+01    1.74E+02  5.85E+02 7.0        1.54E+02        9.82E+01            1.75E+01          1.09E+01    1.27E+02  4.83E+02 10.0        8.92E+01        5.56E+01            1.03E+01          4.90E+00    7.08E+01  3.15E+02 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 155849.UR17                                                                      No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: General Emergency * *
* Particulate                      4.13E-02 (0.0%)
Iodine                          1.01E+00 (0.2%)
Reviewed By:                                                                                                  Noble Gas                      5.54E+02 (99.8%)
Page 28 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9830 (SPING 3) Spent Fuel Area Exhaust - Alert Dose Assessment ANO Unit 1                                                                                                                            Wednesday, October 07, 2015 16:05 Method: Detailed Assessment - Monitored Release Release Pathway: <SF> <Under Water> <Fuel Bldg> <FHA Filters> < Env>                                                                      PRF: 4.00E-04 Containment HUT: = N/A                              Containment Sprays: = N/A                Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                          Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Spent Fuel Accident - Under Water Damage: 0.560%                                                                                                On Site 57 m Time After S/D (hh:mm): 80:01                                                                                                                Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                    Stability Class: E Precipitation: None Monitor: FH Gas Conc                                  Readings: 6.20E+00 &#xb5;CI/cc                Flowrate: 40000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure        External Plume    Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)      DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.42E+01            9.98E+00          0.00E+00          0.00E+00    9.98E+00  3.89E+00 0.7        1.31E+01            9.20E+00          0.00E+00          0.00E+00    9.20E+00  3.54E+00 1.0        9.60E+00            6.72E+00          0.00E+00          0.00E+00    6.72E+00  2.54E+00 1.5        6.80E+00            4.76E+00          0.00E+00          0.00E+00    4.76E+00  1.84E+00 2.0        5.36E+00            3.75E+00          0.00E+00          0.00E+00    3.75E+00  1.46E+00 3.0        3.69E+00            2.56E+00          0.00E+00          0.00E+00    2.56E+00  1.03E+00 4.0        3.11E+00            2.10E+00          0.00E+00          0.00E+00    2.10E+00  8.19E-01 5.0        2.87E+00            1.92E+00          0.00E+00          0.00E+00    1.92E+00  7.27E-01 7.0        2.54E+00            1.69E+00          0.00E+00          0.00E+00    1.69E+00  6.03E-01 10.0        1.88E+00            1.20E+00          0.00E+00          0.00E+00    1.20E+00  3.95E-01 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 160534.UR17                                                                        No PAGs Exceeded Release Rates (Ci/sec)
                    * *
* Classification: Validate against Emergency Action Levels * *
* Particulate                    9.72E-05 (0.0%)
Iodine                          2.31E-04 (0.0%)
Reviewed By:                                                                                                    Noble Gas                      1.17E+02 (100.0%)
Page 29 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9830 (SPING 3) Spent Fuel Area Exhaust - Site Area Emergency Dose Assessment ANO Unit 1                                                                                                                          Wednesday, October 07, 2015 16:04 Method: Detailed Assessment - Monitored Release Release Pathway: <SF> <Under Water> <Fuel Bldg> <FHA Filters> < Env>                                                                      PRF: 4.00E-04 Containment HUT: = N/A                            Containment Sprays: = N/A                Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                        Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Spent Fuel Accident - Under Water Damage: 0.560%                                                                                              On Site 57 m Time After S/D (hh:mm): 80:00                                                                                                                Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                    Stability Class: E Precipitation: None Monitor: FH Gas Conc                                  Readings: 6.20E+01 &#xb5;CI/cc                Flowrate: 40000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.42E+02        9.98E+01            8.74E-01          2.18E-01    1.01E+02  3.89E+01 0.7        1.31E+02        9.20E+01            7.96E-01          1.98E-01    9.30E+01  3.54E+01 1.0        9.60E+01        6.72E+01            5.72E-01          1.42E-01    6.79E+01  2.54E+01 1.5        6.80E+01        4.76E+01            4.12E-01          1.03E-01    4.81E+01  1.84E+01 2.0        5.36E+01        3.75E+01            3.28E-01          0.00E+00    3.78E+01  1.46E+01 3.0        3.69E+01        2.56E+01            2.30E-01          0.00E+00    2.58E+01  1.03E+01 4.0        3.11E+01        2.10E+01            1.83E-01          0.00E+00    2.12E+01  8.19E+00 5.0        2.87E+01        1.92E+01            1.62E-01          0.00E+00    1.94E+01  7.27E+00 7.0        2.54E+01        1.69E+01            1.34E-01          0.00E+00    1.70E+01  6.03E+00 10.0        1.88E+01        1.20E+01            0.00E+00          0.00E+00    1.20E+01  3.95E+00 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 160416.UR17                                                                      No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: Site Area Emergency * *
* Particulate                    9.72E-04 (0.0%)
Iodine                          2.31E-03 (0.0%)
Reviewed By:                                                                                                  Noble Gas                      1.17E+03 (100.0%)
Page 30 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9830 (SPING 3) Spent Fuel Area Exhaust - General Emergency Dose Assessment ANO Unit 1                                                                                                                          Wednesday, October 07, 2015 16:03 Method: Detailed Assessment - Monitored Release Release Pathway: <SF> <Under Water> <Fuel Bldg> <FHA Filters> < Env>                                                                      PRF: 4.00E-04 Containment HUT: = N/A                            Containment Sprays: = N/A                Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                        Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Spent Fuel Accident - Under Water Damage: 0.560%                                                                                              On Site 57 m Time After S/D (hh:mm): 80:00                                                                                                                Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                    Stability Class: E Precipitation: None Monitor: FH Gas Conc                                  Readings: 6.20E+02 &#xb5;CI/cc                Flowrate: 40000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.42E+03        9.98E+02            8.74E+00          2.18E+00    1.01E+03  3.89E+02 0.7        1.31E+03        9.20E+02            7.96E+00          1.98E+00    9.30E+02  3.54E+02 1.0        9.60E+02        6.72E+02            5.72E+00          1.42E+00    6.79E+02  2.54E+02 1.5        6.80E+02        4.76E+02            4.12E+00          1.03E+00    4.81E+02  1.84E+02 2.0        5.36E+02        3.75E+02            3.28E+00          8.16E-01    3.79E+02  1.46E+02 3.0        3.69E+02        2.56E+02            2.30E+00          5.06E-01    2.58E+02  1.03E+02 4.0        3.11E+02        2.10E+02            1.83E+00          3.93E-01    2.13E+02  8.19E+01 5.0        2.87E+02        1.92E+02            1.62E+00          3.44E-01    1.94E+02  7.27E+01 7.0        2.54E+02        1.69E+02            1.34E+00          2.79E-01    1.70E+02  6.03E+01 10.0        1.88E+02        1.20E+02            8.79E-01          1.75E-01    1.21E+02  3.95E+01 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 160358.UR17                                                                      No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: General Emergency * *
* Particulate                    9.72E-03 (0.0%)
Iodine                          2.31E-02 (0.0%)
Reviewed By:                                                                                                  Noble Gas                      1.17E+04 (100.0%)
Page 31 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9835 (SPING 4) Penetration Room Exhaust - Alert Dose Assessment ANO Unit 1                                                                                                                            Wednesday, October 07, 2015 16:10 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <EPPR Filters> < Env>                                                                      PRF: 1.20E-03 Containment HUT: = < 2 Hours                        Containment Sprays: = ON                  Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                          Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                    On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                  Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: EPPR Gas Conc                                Readings: 6.55E+00 &#xb5;CI/cc                Flowrate: 1800 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure        External Plume    Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)      DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.25E+01            8.35E+00          9.40E-01          7.74E-01    1.01E+01  3.16E+01 0.7        1.16E+01            7.72E+00          9.00E-01          7.83E-01    9.40E+00  2.88E+01 1.0        8.40E+00            5.44E+00          7.64E-01          7.41E-01    6.95E+00  2.06E+01 1.5        5.56E+00            3.54E+00          5.92E-01          5.69E-01    4.70E+00  1.49E+01 2.0        3.75E+00            2.39E+00          4.60E-01          3.93E-01    3.24E+00  1.18E+01 3.0        3.34E+00            2.21E+00          3.24E-01          2.80E-01    2.82E+00  8.31E+00 4.0        2.55E+00            1.64E+00          2.61E-01          2.11E-01    2.12E+00  6.62E+00 5.0        2.13E+00            1.36E+00          2.27E-01          1.69E-01    1.75E+00  5.86E+00 7.0        1.54E+00            9.87E-01          1.76E-01          1.10E-01    1.27E+00  4.84E+00 10.0        8.96E-01            5.59E-01          1.04E-01          0.00E+00    6.62E-01  3.15E+00 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 161015.UR17                                                                        No PAGs Exceeded Release Rates (Ci/sec)
                    * *
* Classification: Validate against Emergency Action Levels * *
* Particulate                      4.14E-04 (0.0%)
Iodine                          1.02E-02 (0.2%)
Reviewed By:                                                                                                    Noble Gas                      5.56E+00 (99.8%)
Page 32 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9835 (SPING 4) Penetration Room Exhaust - Site Area Emergency Dose Assessment ANO Unit 1                                                                                                                          Wednesday, October 07, 2015 16:09 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <EPPR Filters> < Env>                                                                    PRF: 1.20E-03 Containment HUT: = < 2 Hours                      Containment Sprays: = ON                  Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                        Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                    On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: EPPR Gas Conc                                Readings: 6.55E+01 &#xb5;CI/cc                Flowrate: 1800 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.25E+02        8.35E+01            9.40E+00          7.74E+00    1.01E+02  3.16E+02 0.7        1.16E+02        7.72E+01            9.00E+00          7.83E+00    9.40E+01  2.88E+02 1.0        8.40E+01        5.44E+01            7.64E+00          7.41E+00    6.95E+01  2.06E+02 1.5        5.56E+01        3.54E+01            5.92E+00          5.69E+00    4.70E+01  1.49E+02 2.0        3.75E+01        2.39E+01            4.60E+00          3.93E+00    3.24E+01  1.18E+02 3.0        3.34E+01        2.21E+01            3.24E+00          2.80E+00    2.82E+01  8.31E+01 4.0        2.55E+01        1.64E+01            2.61E+00          2.11E+00    2.12E+01  6.62E+01 5.0        2.13E+01        1.36E+01            2.27E+00          1.69E+00    1.75E+01  5.86E+01 7.0        1.54E+01        9.87E+00            1.76E+00          1.10E+00    1.27E+01  4.84E+01 10.0        8.96E+00        5.59E+00            1.04E+00          4.92E-01    6.62E+00  3.15E+01 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 160956.UR17                                                                      No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: Site Area Emergency * *
* Particulate                      4.14E-03 (0.0%)
Iodine                          1.02E-01 (0.2%)
Reviewed By:                                                                                                  Noble Gas                      5.56E+01 (99.8%)
Page 33 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9835 (SPING 4) Penetration Room Exhaust - General Emergency Dose Assessment ANO Unit 1                                                                                                                          Wednesday, October 07, 2015 16:09 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <EPPR Filters> < Env>                                                                    PRF: 1.20E-03 Containment HUT: = < 2 Hours                      Containment Sprays: = ON                  Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                        Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                    On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: EPPR Gas Conc                                Readings: 6.55E+02 &#xb5;CI/cc                Flowrate: 1800 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.25E+03        8.35E+02            9.40E+01          7.74E+01    1.01E+03  3.16E+03 0.7        1.16E+02        7.72E+02            9.00E+01          7.83E+01    9.40E+02  2.88E+03 1.0        8.40E+02        5.44E+02            7.64E+01          7.41E+01    6.95E+02  2.06E+03 1.5        5.56E+02        3.54E+02            5.92E+01          5.69E+01    4.70E+02  1.49E+03 2.0        3.75E+02        2.39E+02            4.60E+01          3.93E+01    3.24E+02  1.18E+03 3.0        3.34E+02        2.21E+02            3.24E+01          2.80E+01    2.82E+02  8.31E+02 4.0        2.55E+02        1.64E+02            2.61E+01          2.11E+01    2.12E+02  6.62E+02 5.0        2.13E+02        1.36E+02            2.27E+01          1.69E+01    1.75E+02  5.86E+02 7.0        1.54E+02        9.87E+01            1.76E+01          1.10E+01    1.27E+02  4.84E+02 10.0        8.96E+01        5.59E+01            1.04E+01          4.92E+00    7.11E+01  3.15E+02 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 160932.UR17                                                                      No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: General Emergency * *
* Particulate                      4.14E-02 (0.0%)
Iodine                          1.02E+00 (0.2%)
Reviewed By:                                                                                                  Noble Gas                      5.56E+02 (99.8%)
Page 34 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9820 (SPING 5) Containment Purge Exhaust - Alert Dose Assessment ANO Unit 2                                                                                                                            Wednesday, October 07, 2015 16:15 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <CP Filters> < Env>                                                                                    PRF: 3.00E-03 Containment HUT: = < 2 Hours                        Containment Sprays: = ON                  Purge Filters: = Working                  Steam Gen: = N/A Aux / FHB HUT: = N/A                                Filters: = N/A                            Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                      On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                  Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: CP Gas Conc                                  Readings: 1.88E-01 &#xb5;CI/cc                  Flowrate: 39700 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure        External Plume    Inhalation CEDE                      TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)      DDE (mRem)            (mRem)                          (mRem)
(mRem)                  (mRem S.B.        8.00E+00            5.32E+00          1.19E+00          6.77E-01    7.19E+00  5.01E+01 0.7        7.44E+00            4.92E+00          1.11E+00          6.66E-01    6.70E+00  4.56E+01 1.0        5.36E+00            3.47E+00          8.68E-01          5.90E-01    4.93E+00  3.26E+01 1.5        3.55E+00            2.26E+00          6.52E-01          4.46E-01    3.35E+00  2.35E+01 2.0        2.40E+00            1.52E+00          5.12E-01          3.15E-01    2.35E+00  1.86E+01 3.0        2.14E+00            1.41E+00          3.61E-01          2.20E-01    1.99E+00  1.32E+01 4.0        1.63E+00            1.05E+00          2.89E-01          1.67E-01    1.50E+00  1.05E+01 5.0        1.36E+00            8.64E-01          2.53E-01          1.35E-01    1.25E+00  9.29E+00 7.0        9.84E-01            6.27E-01          2.01E-01          0.00E+00    8.29E-01  7.67E+00 10.0        5.72E-01            3.56E-01          1.24E-01          0.00E+00    4.80E-01  5.00E+00 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 161518.UR17                                                                        No PAGs Exceeded Release Rates (Ci/sec)
                    * *
* Classification: Validate against Emergency Action Levels * *
* Particulate                      6.56E-04 (0.0%)
Iodine                          1.61E-02 (0.5%)
Reviewed By:                                                                                                    Noble Gas                      3.52E+00 (99.5%)
Page 35 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9820 (SPING 5) Containment Purge Exhaust - Site Area Emergency Dose Assessment ANO Unit 2                                                                                                                            Wednesday, October 07, 2015 16:15 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <CP Filters> < Env>                                                                                  PRF: 3.00E-03 Containment HUT: = < 2 Hours                      Containment Sprays: = ON                  Purge Filters: = Working                  Steam Gen: = N/A Aux / FHB HUT: = N/A                              Filters: = N/A                            Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                    On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                  Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: CP Gas Conc                                  Readings: 1.88E+00 &#xb5;CI/cc                  Flowrate: 39700 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                      TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                          (mRem)
(mRem)                  (mRem S.B.        8.00E+01        5.32E+01            1.19E+01          6.77E+00    7.19E+01  5.01E+02 0.7        7.44E+01        4.92E+01            1.11E+01          6.66E+00    6.70E+01  4.56E+02 1.0        5.36E+01        3.47E+01            8.68E+00          5.90E+00    4.93E+01  3.26E+02 1.5        3.55E+01        2.26E+01            6.52E+00          4.46E+00    3.35E+01  2.35E+02 2.0        2.40E+01        1.52E+01            5.12E+00          3.15E+00    2.35E+01  1.86E+02 3.0        2.14E+01        1.41E+01            3.61E+00          2.20E+00    1.99E+01  1.32E+02 4.0        1.63E+01        1.05E+01            2.89E+00          1.67E+00    1.50E+01  1.05E+02 5.0        1.36E+01        8.64E+00            2.53E+00          1.35E+00    1.25E+01  9.29E+01 7.0        9.84E+00        6.27E+00            2.01E+00          9.22E-01    9.21E+00  7.67E+01 10.0        5.72E+00        3.56E+00            1.24E+00          4.52E-01    5.25E+00  5.00E+01 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 161502.UR17                                                                        No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: Site Area Emergency * *
* Particulate                      6.56E-03 (0.0%)
Iodine                          1.61E-01 (0.5%)
Reviewed By:                                                                                                    Noble Gas                      3.52E+01 (99.5%)
Page 36 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9820 (SPING 5) Containment Purge Exhaust - General Emergency Dose Assessment ANO Unit 2                                                                                                                            Wednesday, October 07, 2015 16:14 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <CP Filters> < Env>                                                                                  PRF: 3.00E-03 Containment HUT: = < 2 Hours                      Containment Sprays: = ON                  Purge Filters: = Working                  Steam Gen: = N/A Aux / FHB HUT: = N/A                              Filters: = N/A                            Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                    On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                  Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: CP Gas Conc                                  Readings: 1.88E+01 &#xb5;CI/cc                  Flowrate: 39700 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                      TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                          (mRem)
(mRem)                  (mRem S.B.        8.00E+02        5.32E+02            1.19E+02          6.77E+01    7.19E+02  5.01E+03 0.7        7.44E+02        4.92E+02            1.11E+02          6.66E+01    6.70E+02  4.56E+03 1.0        5.36E+02        3.47E+02            8.68E+01          5.90E+01    4.93E+02  3.26E+03 1.5        3.55E+02        2.26E+02            6.52E+01          4.46E+01    3.35E+02  2.35E+03 2.0        2.40E+02        1.52E+02            5.12E+01          3.15E+01    2.35E+02  1.86E+03 3.0        2.14E+02        1.41E+02            3.61E+01          2.20E+01    1.99E+02  1.32E+03 4.0        1.63E+02        1.05E+02            2.89E+01          1.67E+01    1.50E+02  1.05E+03 5.0        1.36E+02        8.64E+01            2.53E+01          1.35E+01    1.25E+02  9.29E+02 7.0        9.84E+01        6.27E+01            2.01E+01          9.22E+00    9.21E+01  7.67E+02 10.0        5.72E+01        3.56E+01            1.24E+01          4.52E+00    5.25E+01  5.00E+02 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 161434.UR17                                                                        No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: General Emergency * *
* Particulate                      6.56E-02 (0.0%)
Iodine                          1.61E+00 (0.5%)
Reviewed By:                                                                                                    Noble Gas                      3.52E+02 (99.5%)
Page 37 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9825 (SPING 6) Radwaste Area Exhaust - Alert Dose Assessment ANO Unit 2                                                                                                                            Wednesday, October 07, 2015 16:18 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <RWA Filters> < Env>                                                                      PRF: 1.20E-03 Containment HUT: = < 2 Hours                        Containment Sprays: = ON                  Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                          Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                    On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                  Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: RWA Gas Conc                                  Readings: 2.35E-01 &#xb5;CI/cc                Flowrate: 50000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure        External Plume    Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)      DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.24E+01            8.31E+00          9.39E-01          7.70E-01    1.00E+01  3.15E+01 0.7        1.16E+01            7.68E+00          9.00E-01          7.78E-01    9.36E+00  2.87E+01 1.0        8.36E+00            5.40E+00          7.60E-01          7.38E-01    6.90E+00  2.06E+01 1.5        5.52E+00            3.52E+00          5.92E-01          5.66E-01    4.67E+00  1.49E+01 2.0        3.74E+00            2.38E+00          4.56E-01          3.91E-01    3.22E+00  1.18E+01 3.0        3.33E+00            2.20E+00          3.23E-01          2.78E-01    2.80E+00  8.30E+00 4.0        2.54E+00            1.64E+00          2.60E-01          2.10E-01    2.11E+00  6.61E+00 5.0        2.12E+00            1.35E+00          2.26E-01          1.68E-01    1.74E+00  5.85E+00 7.0        1.54E+00            9.82E-01          1.75E-01          1.09E-01    1.27E+00  4.83E+00 10.0        8.92E-01            5.56E-01          1.03E-01          0.00E+00    6.59E-01  3.15E+00 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 161818.UR17                                                                        No PAGs Exceeded Release Rates (Ci/sec)
                    * *
* Classification: Validate against Emergency Action Levels * *
* Particulate                      4.13E-04 (0.0%)
Iodine                          1.01E-02 (0.2%)
Reviewed By:                                                                                                    Noble Gas                      5.55E+00 (99.8%)
Page 38 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9825 (SPING 6) Radwaste Area Exhaust - Site Area Emergency Dose Assessment ANO Unit 2                                                                                                                          Wednesday, October 07, 2015 16:17 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <RWA Filters> < Env>                                                                      PRF: 1.20E-03 Containment HUT: = < 2 Hours                      Containment Sprays: = ON                  Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                        Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                    On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: RWA Gas Conc                                Readings: 2.35E+00 &#xb5;CI/cc                Flowrate: 50000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.24E+02        8.31E+01            9.39E+00          7.70E+00    1.00E+02  3.15E+02 0.7        1.16E+02        7.68E+01            9.00E+00          7.78E+00    9.36E+01  2.87E+02 1.0        8.36E+01        5.40E+01            7.60E+00          7.38E+00    6.90E+01  2.06E+02 1.5        5.52E+01        3.52E+01            5.92E+00          5.66E+00    4.67E+01  1.49E+02 2.0        3.74E+01        2.38E+01            4.56E+00          3.91E+00    3.22E+01  1.18E+02 3.0        3.33E+01        2.20E+01            3.23E+00          2.78E+00    2.80E+01  8.30E+01 4.0        2.54E+01        1.64E+01            2.60E+00          2.10E+00    2.11E+01  6.61E+01 5.0        2.12E+01        1.35E+01            2.26E+00          1.68E+00    1.74E+01  5.85E+01 7.0        1.54E+01        9.82E+00            1.75E+00          1.09E+00    1.27E+01  4.83E+01 10.0        8.92E+00        5.56E+00            1.03E+00          4.90E-01    7.08E+00  3.15E+01 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 161756.UR17                                                                      No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: Site Area Emergency * *
* Particulate                      4.13E-03 (0.0%)
Iodine                          1.01E-01 (0.2%)
Reviewed By:                                                                                                  Noble Gas                      5.55E+01 (99.8%)
Page 39 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9825 (SPING 6) Radwaste Area Exhaust - General Emergency Dose Assessment ANO Unit 2                                                                                                                          Wednesday, October 07, 2015 16:17 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <RWA Filters> < Env>                                                                      PRF: 1.20E-03 Containment HUT: = < 2 Hours                      Containment Sprays: = ON                  Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                        Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                    On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: RWA Gas Conc                                Readings: 2.35E+01 &#xb5;CI/cc                Flowrate: 50000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.24E+03        8.31E+02            9.39E+01          7.70E+01    1.00E+03  3.15E+03 0.7        1.16E+03        7.68E+02            9.00E+01          7.78E+01    9.36E+02  2.87E+03 1.0        8.36E+02        5.40E+02            7.60E+01          7.38E+01    6.90E+02  2.06E+03 1.5        5.52E+02        3.52E+02            5.92E+01          5.66E+01    4.67E+02  1.49E+03 2.0        3.74E+02        2.38E+02            4.56E+01          3.91E+01    3.22E+02  1.18E+03 3.0        3.33E+02        2.20E+02            3.23E+01          2.78E+01    2.80E+02  8.30E+02 4.0        2.54E+02        1.64E+02            2.60E+01          2.10E+01    2.11E+02  6.61E+02 5.0        2.12E+02        1.35E+02            2.26E+01          1.68E+01    1.74E+02  5.85E+02 7.0        1.54E+02        9.82E+01            1.75E+01          1.09E+01    1.27E+02  4.83E+02 10.0        8.92E+01        5.56E+01            1.03E+01          4.90E+00    7.08E+01  3.15E+02 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 161733.UR17                                                                      No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: General Emergency * *
* Particulate                      4.13E-02 (0.0%)
Iodine                          1.01E+00 (0.2%)
Reviewed By:                                                                                                  Noble Gas                      5.55E+02 (99.8%)
Page 40 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9830 (SPING 7) Spent Fuel Area Exhaust - Alert Dose Assessment ANO Unit 2                                                                                                                            Wednesday, October 07, 2015 16:28 Method: Detailed Assessment - Monitored Release Release Pathway: <SF> <Under Water> <Fuel Bldg> <FHA Filters> < Env>                                                                      PRF: 4.00E-04 Containment HUT: = N/A                              Containment Sprays: = N/A                Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                          Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Spent Fuel Accident - Under Water Damage: 0.560%                                                                                                On Site 57 m Time After S/D (hh:mm): 80:02                                                                                                                Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                    Stability Class: E Precipitation: None Monitor: FH Gas Conc                                  Readings: 6.86E+00 &#xb5;CI/cc                Flowrate: 36000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure        External Plume    Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)      DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.42E+01            9.98E+00          0.00E+00          0.00E+00    9.98E+00  3.89E+00 0.7        1.31E+01            9.20E+00          0.00E+00          0.00E+00    9.20E+00  3.54E+00 1.0        9.60E+00            6.72E+00          0.00E+00          0.00E+00    6.72E+00  2.54E+00 1.5        6.80E+00            4.76E+00          0.00E+00          0.00E+00    4.76E+00  1.84E+00 2.0        5.36E+00            3.75E+00          0.00E+00          0.00E+00    3.75E+00  1.46E+00 3.0        3.69E+00            2.56E+00          0.00E+00          0.00E+00    2.56E+00  1.03E+00 4.0        3.11E+00            2.10E+00          0.00E+00          0.00E+00    2.10E+00  8.19E-01 5.0        2.87E+00            1.92E+00          0.00E+00          0.00E+00    1.92E+00  7.27E-01 7.0        2.54E+00            1.69E+00          0.00E+00          0.00E+00    1.69E+00  6.03E-01 10.0        1.88E+00            1.20E+00          0.00E+00          0.00E+00    1.20E+00  3.95E-01 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 162831.UR17                                                                        No PAGs Exceeded Release Rates (Ci/sec)
                    * *
* Classification: Validate against Emergency Action Levels * *
* Particulate                    9.68E-05 (0.0%)
Iodine                          2.30E-04 (0.0%)
Reviewed By:                                                                                                    Noble Gas                      1.17E+02 (100.0%)
Page 41 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9830 (SPING 7) Spent Fuel Area Exhaust - Site Area Emergency Dose Assessment ANO Unit 2                                                                                                                          Wednesday, October 07, 2015 16:28 Method: Detailed Assessment - Monitored Release Release Pathway: <SF> <Under Water> <Fuel Bldg> <FHA Filters> < Env>                                                                      PRF: 4.00E-04 Containment HUT: = N/A                            Containment Sprays: = N/A                Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                        Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Spent Fuel Accident - Under Water Damage: 0.560%                                                                                              On Site 57 m Time After S/D (hh:mm): 80:02                                                                                                                Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                    Stability Class: E Precipitation: None Monitor: FH Gas Conc                                  Readings: 6.86E+01 &#xb5;CI/cc                Flowrate: 36000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.42E+02        9.98E+01            8.73E-01          2.18E-01    1.01E+02  3.89E+01 0.7        1.31E+02        9.20E+01            7.96E-01          1.98E-01    9.30E+01  3.54E+01 1.0        9.60E+01        6.72E+01            5.68E-01          1.42E-01    6.79E+01  2.54E+01 1.5        6.80E+01        4.76E+01            4.12E-01          1.03E-01    4.81E+01  1.84E+01 2.0        5.36E+01        3.75E+01            3.27E-01          0.00E+00    3.78E+01  1.46E+01 3.0        3.69E+01        2.56E+01            2.29E-01          0.00E+00    2.58E+01  1.03E+01 4.0        3.11E+01        2.10E+01            1.83E-01          0.00E+00    2.12E+01  8.19E+00 5.0        2.87E+01        1.92E+01            1.62E-01          0.00E+00    1.94E+01  7.26E+00 7.0        2.54E+01        1.69E+01            1.34E-01          0.00E+00    1.70E+01  6.03E+00 10.0        1.88E+01        1.20E+01            0.00E+00          0.00E+00    1.20E+01  3.95E+00 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 162808.UR17                                                                      No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: Site Area Emergency * *
* Particulate                    9.68E-04 (0.0%)
Iodine                          2.30E-03 (0.0%)
Reviewed By:                                                                                                  Noble Gas                      1.17E+03 (100.0%)
Page 42 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9830 (SPING 7) Spent Fuel Area Exhaust - General Emergency Dose Assessment ANO Unit 2                                                                                                                          Wednesday, October 07, 2015 16:27 Method: Detailed Assessment - Monitored Release Release Pathway: <SF> <Under Water> <Fuel Bldg> <FHA Filters> < Env>                                                                      PRF: 4.00E-04 Containment HUT: = N/A                            Containment Sprays: = N/A                Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                        Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Spent Fuel Accident - Under Water Damage: 0.560%                                                                                              On Site 57 m Time After S/D (hh:mm): 80:02                                                                                                                Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                    Stability Class: E Precipitation: None Monitor: FH Gas Conc                                  Readings: 6.86E+02 &#xb5;CI/cc                Flowrate: 36000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.42E+03        9.98E+02            8.73E+00          2.18E+00    1.01E+03  3.89E+02 0.7        1.31E+03        9.20E+02            7.96E+00          1.98E+00    9.30E+02  3.54E+02 1.0        9.60E+02        6.72E+02            5.68E+00          1.42E+00    6.79E+02  2.54E+02 1.5        6.80E+02        4.76E+02            4.12E+00          1.03E+00    4.81E+02  1.84E+02 2.0        5.36E+02        3.75E+02            3.27E+00          8.14E-01    3.79E+02  1.46E+02 3.0        3.69E+02        2.56E+02            2.29E+00          5.05E-01    2.58E+02  1.03E+02 4.0        3.11E+02        2.10E+02            1.83E+00          3.93E-01    2.13E+02  8.19E+01 5.0        2.87E+02        1.92E+02            1.62E+00          3.43E-01    1.94E+02  7.26E+01 7.0        2.54E+02        1.69E+02            1.34E+00          2.78E-01    1.70E+02  6.03E+01 10.0        1.88E+02        1.20E+02            8.76E-01          1.75E-01    1.21E+02  3.95E+01 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 162750.UR17                                                                      No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: General Emergency * *
* Particulate                    9.68E-03 (0.0%)
Iodine                          2.30E-02 (0.0%)
Reviewed By:                                                                                                  Noble Gas                      1.17E+04 (100.0%)
Page 43 of 46
 
Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9835 (SPING 8) Penetration Room Exhaust - Alert Dose Assessment ANO Unit 2                                                                                                                            Wednesday, October 07, 2015 16:31 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <EPPR Filters> < Env>                                                                      PRF: 1.20E-03 Containment HUT: = < 2 Hours                        Containment Sprays: = ON                  Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                          Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                    On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                  Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: EPPR Gas Conc                                Readings: 5.88E+00 &#xb5;CI/cc                Flowrate: 2000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure        External Plume    Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)      DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.25E+01            8.32E+00          9.40E-01          7.74E-01    1.01E+01  3.16E+01 0.7        1.16E+01            7.68E+00          9.00E-01          7.83E-01    9.36E+00  2.88E+01 1.0        8.40E+00            5.44E+00          7.60E-01          7.41E-01    6.94E+00  2.06E+01 1.5        5.56E+00            3.53E+00          5.92E-01          5.69E-01    4.69E+00  1.49E+01 2.0        3.74E+00            2.38E+00          4.56E-01          3.93E-01    3.23E+00  1.18E+01 3.0        3.34E+00            2.21E+00          3.24E-01          2.80E-01    2.81E+00  8.31E+00 4.0        2.55E+00            1.64E+00          2.61E-01          2.11E-01    2.11E+00  6.62E+00 5.0        2.12E+00            1.35E+00          2.27E-01          1.69E-01    1.75E+00  5.86E+00 7.0        1.54E+00            9.84E-01          1.75E-01          1.09E-01    1.27E+00  4.84E+00 10.0        8.92E-01            5.57E-01          1.03E-01          0.00E+00    6.60E-01  3.15E+00 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 163140.UR17                                                                        No PAGs Exceeded Release Rates (Ci/sec)
                    * *
* Classification: Validate against Emergency Action Levels * *
* Particulate                      4.13E-04 (0.0%)
Iodine                          1.01E-02 (0.2%)
Reviewed By:                                                                                                    Noble Gas                      5.55E+00 (99.8%)
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Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9835 (SPING 8) Penetration Room Exhaust - Site Area Emergency Dose Assessment ANO Unit 2                                                                                                                          Wednesday, October 07, 2015 16:31 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <EPPR Filters> < Env>                                                                    PRF: 1.20E-03 Containment HUT: = < 2 Hours                      Containment Sprays: = ON                  Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                        Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                    On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: EPPR Gas Conc                                Readings: 5.88E+01 &#xb5;CI/cc                Flowrate: 2000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.25E+02        8.32E+01            9.40E+00          7.74E+00    1.01E+02  3.16E+02 0.7        1.16E+02        7.68E+01            9.00E+00          7.83E+00    9.36E+01  2.88E+02 1.0        8.40E+01        5.44E+01            7.60E+00          7.41E+00    6.94E+01  2.06E+02 1.5        5.56E+01        3.53E+01            5.92E+00          5.69E+00    4.69E+01  1.49E+02 2.0        3.74E+01        2.38E+01            4.56E+00          3.93E+00    3.23E+01  1.18E+02 3.0        3.34E+01        2.21E+01            3.24E+00          2.80E+00    2.81E+01  8.31E+01 4.0        2.55E+01        1.64E+01            2.61E+00          2.11E+00    2.11E+01  6.62E+01 5.0        2.12E+01        1.35E+01            2.27E+00          1.69E+00    1.75E+01  5.86E+01 7.0        1.54E+01        9.84E+00            1.75E+00          1.09E+00    1.27E+01  4.84E+01 10.0        8.92E+00        5.57E+00            1.03E+00          4.92E-01    7.09E+00  3.15E+01 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 163125.UR17                                                                      No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: Site Area Emergency * *
* Particulate                      4.13E-03 (0.0%)
Iodine                          1.01E-01 (0.2%)
Reviewed By:                                                                                                  Noble Gas                      5.55E+01 (99.8%)
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Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9835 (SPING 8) Penetration Room Exhaust - General Emergency Dose Assessment ANO Unit 2                                                                                                                          Wednesday, October 07, 2015 16:31 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <EPPR Filters> < Env>                                                                    PRF: 1.20E-03 Containment HUT: = < 2 Hours                      Containment Sprays: = ON                  Purge Filters: = N/A                      Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours                        Filters: = Working                        Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad                                                                                                                    On Site 57 m Time After S/D (hh:mm): 0:00                                                                                                                Wind: From 270&deg; @ 5.8 mph Release Duration (hh:mm): 1.:00                  ETE (hh:mm): [N/A]                                                                                      Stability Class: E Precipitation: None Monitor: EPPR Gas Conc                                Readings: 5.88E+02 &#xb5;CI/cc                Flowrate: 2000 CFM Deposition                CDE                        Evacuation Areas From 0 to 10 Miles Distance      Exposure      External Plume      Inhalation CEDE                    TEDE Ground DDE                Thyroid (Miles)    Rate (mR/hr)    DDE (mRem)            (mRem)                        (mRem)
(mRem)                (mRem S.B.        1.25E+03        8.32E+02            9.40E+01          7.74E+01    1.00E+03  3.16E+03 0.7        1.16E+02        7.68E+02            9.00E+01          7.83E+01    9.36E+02  2.88E+03 1.0        8.40E+02        5.44E+02            7.60E+01          7.41E+01    6.94E+02  2.06E+03 1.5        5.56E+02        3.53E+02            5.92E+01          5.69E+01    4.69E+02  1.49E+03 2.0        3.74E+02        2.38E+02            4.56E+01          3.93E+01    3.23E+02  1.18E+03 3.0        3.34E+02        2.21E+02            3.24E+01          2.80E+01    2.81E+02  8.31E+02 4.0        2.55E+02        1.64E+02            2.61E+01          2.11E+01    2.11E+02  6.62E+02 5.0        2.12E+02        1.35E+02            2.27E+01          1.69E+01    1.75E+02  5.86E+02 7.0        1.54E+02        9.84E+01            1.75E+01          1.09E+01    1.27E+02  4.84E+02 10.0        8.92E+01        5.57E+01            1.03E+01          4.92E+00    7.09E+01  3.15E+02 Assessment Data Results Save to File:
ANO Unit 1 10Miles Monitored Release 10072015 163106.UR17                                                                      No PAGs Exceeded Release Rates (Ci/sec)
                              * *
* Classification: General Emergency * *
* Particulate                      4.13E-02 (0.0%)
Iodine                          1.01E+00 (0.2%)
Reviewed By:                                                                                                  Noble Gas                      5.55E+02 (99.8%)
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Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 Table of Contents Section                                                                                                                            Page
: 1. PURPOSE ............................................................................................................................2
: 2. DEVELOPMENT METHODOLOGY AND BASES................................................................2 2.1  Fuel Clad Loss .............................................................................................................2 2.2  Reactor Coolant System Loss .....................................................................................4 2.3  Containment Potential Loss .........................................................................................4 2.4  Source Term ................................................................................................................6 2.5  Decay Considerations ..................................................................................................6
: 3. DESIGN INPUTS ..................................................................................................................6 3.1  Constants and Conversion Factors .............................................................................6 3.2  Plant Inputs ..................................................................................................................6 3.3  Source Term ................................................................................................................7
: 4. CALCULATIONS ..................................................................................................................8 4.1  Fuel Clad Damage Estimate Based on 300 &#xb5;Ci/gm DEI-131 ......................................8 4.2  Fission Product Barrier Thresholds .............................................................................9
: 5. CONCLUSIONS .................................................................................................................10
: 6. REFERENCES ...................................................................................................................11 ATTACHMENTS Attachment 1, 300 &#xb5;Ci/gm DEI-131 Equivalent Fuel Clad Damage ......................................12 Attachment 2, Fission Product Barrier Threshold Values ......................................................14 Attachment 3, NUREG-1940 Figure 1-1 PWR Containment Monitor Response ...................15 Page 1 of 15
 
Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0
: 1. PURPOSE The Arkansas Nuclear One (ANO) Emergency Action Level (EAL) Technical Bases Manual contains background information, event declaration thresholds, bases and references for the EAL and Fission Product Barrier (FPB) values used to implement the Nuclear Energy Institute (NEI) 99-01 Revision 6 EAL guidance. This calculation document provides additional technical detail specific to the derivation of the FPB containment high range radiation monitor (CHRRM) readings developed in accordance with the guidance in NEI 99-01 Revision 6.
Documentation of the assumptions, calculations and results are provided for the values associated the NEI 99-01 Revision 6 Table 9-F-3, PWR EAL Fission Product Barrier Table, thresholds listed below.
NEI Fuel Clad Loss 3.A NEI Reactor Coolant Loss 3.A NEI Containment Potential Loss 3.A
: 2. DEVELOPMENT METHODOLOGY AND BASES 2.1  Fuel Clad Loss Guidance Criteria Per NEI 99-01 Revision 6, this radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals 300 &#xb5;Ci/gm dose equivalent I-131 (DEI-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 loss threshold since it indicates a loss of both the fuel clad barrier and the RCS barrier.
The reading should be determined assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory, with RCS radioactivity concentration equal to 300 &#xb5;Ci/gm dose equivalent I-131, into the primary containment atmosphere.
ANO Bases The fuel clad FPB threshold value is based on an instantaneous release of reactor coolant into the containment at a percent fuel clad damage equivalent to 300 &#xb5;Ci/gm DEI-131 RCS activity. That percent fuel clad damage value is ratioed to a containment radiation reading for 100% fuel clad damage to determine the fuel clad FPB threshold value in R/hr.
Page 2 of 15
 
Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 2.2 Reactor Coolant System Loss Guidance Criteria Per NEI 99-01 Revision 6, this radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for fuel clad barrier loss threshold since it indicates a loss of the RCS barrier only.
The reading should be determined assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory, with RCS activity at Technical Specification allowable limits, into the primary containment atmosphere. RCS activity at this level will typically result in primary containment radiation levels that can be more readily detected by primary containment radiation monitors, and more readily differentiated from those caused by piping or component shine sources. If desired, a plant may use a lesser value of RCS activity for determining this value.
In some cases, the site-specific physical location and sensitivity of the containment radiation monitor(s) may be such that radiation from a cloud of released RCS gases cannot be distinguished from radiation emanating from piping and components containing elevated reactor coolant activity. If so, determine if an alternate indication is available.
ANO Bases The ANO technical specification high value for DEI-131 is 60 &#xb5;Ci/gm. This activity would yield a containment radiation monitor reading approximately 5x lower than the fuel clad loss fission product barrier containment radiation reading equivalent to 300 &#xb5;Ci/gm.
NUREG-1940 Figure 1-1 provides estimates for standard plant containment radiation based on spiked RCS activity, which is slightly less than half the value obtained by the 300 &#xb5;Ci/gm to 60 Ci/gm DEI-131 ratio.
NUREG-1940 Figure 1-1 models a spiked RCS activity that is lower than the RCS activity equivalent to 60 &#xb5;Ci/gm DEI-131 described above (the NUREG-1940 graph is based on a release into containment of 100 times the non-noble gas fission products normally found in the coolant). This is the preferred value for the RCS loss threshold as it provides for a containment monitor escalation of approximately one decade between fission product barrier thresholds at the 1 hour point. NEI 99-01 guidance criteria allows the use of a lesser value for RCS activity (see guidance criteria section above).
The ANO RCS FPB threshold value is based on NUREG-1940 standard plant containment radiation readings for an instantaneous release of spiked reactor coolant, which is lower than 60 &#xb5;Ci/gm DEI-131 Technical Specification allowable limits, and is adjusted for the site specific power rating.
Page 3 of 15
 
Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 2.3 Containment Potential Loss Guidance Criteria Per NEI 99-01 Revision 6, this radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that 20% of the fuel cladding has failed. This level of fuel clad failure is well above that used to determine the analogous fuel clad and RCS barrier loss thresholds.
NUREG-1228 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 and the fuel clad barriers. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the classification level to a General Emergency.
NUREG-1228 provides the basis for using the 20% fuel cladding failure value. Unless there is a site-specific analysis justifying a different value, the reading should be determined assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with 20% fuel clad failure into the primary containment atmosphere.
ANO Bases The Containment FPB threshold value is based on an instantaneous release of all reactor coolant into the containment at an equivalent of 20% clad damage.
The ANO FPB containment radiation reading value equivalent to 20% fuel clad damage is obtained by ratio of the 100% fuel clad damage containment radiation reading value to 20% fuel clad damage.
2.4 Source Term Guidance Criteria NEI 99-01 does not specify a basis for the source term activity or the reduction factors.
RG 1.183 provides assumptions for a LOCA used as a reference for FSAR design basis event analysis. Per RG 1.183 Section 1.1.4, Emergency Preparedness Applications:
Requirements for emergency preparedness at nuclear power plants are set forth in 10 CFR 50.47, Emergency Plans. Additional requirements are set forth in Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR Part 50. The planning basis for many of these requirements was published in NUREG-0396, Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants. This joint effort by the Environmental Protection Agency (EPA) and the NRC considered the principal characteristics (such as nuclides released and distances) likely to be involved for a spectrum of design basis and severe (core melt) accidents. No single accident scenario is the basis of the required preparedness. The Page 4 of 15
 
Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 objective of the planning is to provide public protection that would encompass a wide spectrum of possible events with a sufficient basis for extension of response efforts for unanticipated events. These requirements were issued after a long period of involvement by numerous stakeholders, including the Federal Emergency Management Agency, other Federal agencies, local and State governments (and in some cases, foreign governments), private citizens, utilities, and industry groups.
Although the AST provided in this guide was based on a limited spectrum of severe accidents, the particular characteristics have been tailored specifically for DBA analysis use. The AST is not representative of the wide spectrum of possible events that make up the planning basis of emergency preparedness. Therefore, the AST is insufficient by itself as a basis for requesting relief from the emergency preparedness requirements of 10 CFR 50.47 and Appendix E to 10 CFR Part 50.
Thus, RG 1.183 is not used as a basis for the containment radiation monitor thresholds.
Guidance contained in NUREG-1940 is considered representative of the wide spectrum of possible events that make up the emergency preparedness planning basis and provides radiological consequence assessment methods which are acceptable to the NRC.
Additionally, the source term used to develop the effluent EAL thresholds and in the Unified RASCAL Interface/Radiological Assessment System for Consequence Analysis (URI/RASCAL) dose assessment model is from NUREG-1940. Thus, NUREG-1940 has been selected as a source term basis for the fission product barrier containment radiation thresholds for conformance to NRC guidance and consistency with other source term bases used within the Entergy emergency preparedness program.
ANO Bases 2.4.1    The NUREG-1940 source term inputs used for the fission product barrier containment radiation thresholds are as follows:
Fuel Clad Damage Equivalent to 300 &#xb5;Ci/g DEI-131 - NUREG-1940 Table 1-1 equilibrium core activity, in conjunction with the NUREG-1940 Table 1-5 non-noble gas release fraction, is used to develop the site specific iodine source term.
Fuel Clad and Containment Barrier Thresholds - NUREG-1940 Figure 1-1 for cladding failure is used as a basis to establish these thresholds.
RCS Barrier Threshold - NUREG-1940 Figure 1-1 for spiked coolant is used as a basis to establish this threshold.
Note - Source term reduction from containment spray is not included as an assumption for these thresholds.
2.4.2    NUREG-1940 source term is based on a generic plant with a power rating of 3000 MWt.
The ANO site specific source term is derived from the licensed core thermal power output of 2,568 megawatts for Unit 1 and 3,026 megawatts for Unit 2 (SAR Section 1.1).
Page 5 of 15
 
Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 2.4.3    Dose equivalent iodine 131 (DEI-131) dose conversion factors (DCFs) are developed from EPA-400-R-92-001 isotopic DCFs. EPA-400 is the basis for the protective action guidelines and is the appropriate source for DCFs used in emergency preparedness.
The DEI-131 dose conversion factors are not based on the FSAR Chapter 15 or other 10 CFR 20 reference sources as those are not reflective of the exposure assumptions used within the EPA guidance for emergency preparedness use.
2.5  Decay Considerations Guidance Criteria Fission product barrier thresholds and their associated EALs are applicable only when the plant is in Hot Shutdown, Startup, or Power Operation modes (known as the hot operating modes).
The events for these thresholds correspond to an instantaneous release of all reactor coolant mass into the primary containment.
ANO Bases Consistent with the NUREG-1940 graphs, the instantaneous release of the RCS to the containment is assumed to occur one hour after the damage event / reactor scram to account for damage progression, dispersion of activity and decay of the very short half-life isotopes.
: 3. DESIGN INPUTS 3.1  Constants and Conversion Factors None 3.2  Plant Inputs 3.2.1    Rated Power
: 1)  Standard Plant (NUREG-1940 Section 1.2.4) ...........................................3,000 MWt
: 2)  Unit 1 (SAR Section 1.1) ...........................................................................2,568 MWt
: 3)  Unit 2 (SAR Section 1.1) ...........................................................................3,026 MWt 3.2.2    RCS Water Mass at STP (1302.022 Attachment 3 Section 2.3)
: 1)  Unit 1 ...................................................................................................... 2.41E+8 gm
: 2)  Unit 2 ...................................................................................................... 2.14E+8 gm 3.2.3    Standard Plant Containment Radiation Reading (NUREG-1940 Figure 1-1)
: 1)  100% fuel clad damage (spray off) ................... 60,000 R/hr (@ 1 hr after shutdown)
: 2)  100% spiked coolant (spray off) .............................. 50 R/hr (@ 1 hr after shutdown)
Page 6 of 15
 
Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 3.2.4  Monitor Range
: 1)  RE-8060/8061 (TM GO63.0010/TD G063 0020) ............... 1.00E+0 to 1.00E+8 R/hr
: 2)  2RE-8925-1/2RE-8925-2 (TM GO63.0010/TD G063 0020) 1.00E+0 to 1.00E+8 R/hr 3.3  Source Term 3.3.1  Source Term Activity (NUREG-1940 Table 1-1)
Core Activity (Ci/MWt) 1-131      2.67E+04 1-132      3.88E+04 1-133      5.42E+04 1-134      5.98E+04 1-135      5.18E+04 3.3.2  Monitor Range
: 1)  Non-Noble Gasses (I, Cs, Rb) - Fuel Clad Damage .................................. 0.05 (5%)
3.3.3  Release Fractions - RFCore (NUREG-1940 Table 1-5)
Rem/hr per &#xb5;Ci/cc 1-131      1.3E+06 1-132      7.7E+03 1-133      2.2E+05 1-134      1.3E+03 1-135      3.8E+04 Page 7 of 15
 
Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0
: 4. CALCULATIONS 4.1  Fuel Clad Damage Estimate Based on 300 &#xb5;Ci/gm DEI-131 4.1.1  Equivalent Iodine Core Activity 100% Core Activityi(Ci) = Core Activityi(Ci/MWt) x Unit MWt Core Activity (Ci)
Unit 1            Unit 2 1-131    6.86E+07          8.08E+07 1-132    9.96E+07          1.17E+08 1-133    1.39E+08          1.64E+08 1-134    1.54E+08          1.81E+08 1-135    1.33E+08          1.57E+08 Total    5.94E+08          7.00E+08 4.1.2  100% Core Activity Equivalent Reactor Coolant Iodine Concentrations 100% Core RCS Activityi(Ci) x 106 100% Core RCS Activityi(&#xb5;Ci/gm) =
RCS Mass (gm)
RCS Activity (Ci/gm)
Unit 1            Unit 2 1-131    2.85E+05          3.78E+05 1-132    4.13E+05          5.49E+05 1-133    5.78E+05          7.66E+05 1-134    6.37E+05          8.46E+05 1-135    5.52E+05          7.32E+05 Total    2.46E+06          3.27E+06 4.1.3  100% Core Activity Equivalent Reactor Coolant Iodine Concentrations 100% Clad Damage RCS Activityi(&#xb5;Ci/gm) = 100% Core RCS Activityi(&#xb5;Ci/gm) x RFCore RCS Activity (Ci/gm)
Unit 1            Unit 2 1-131    1.42E+04          1.89E+04 1-132    2.07E+04          2.74E+04 1-133    2.89E+04          3.83E+04 1-134    3.19E+04          4.23E+04 1-135    2.76E+04          3.66E+04 Total    1.23E+05          1.64E+05 Page 8 of 15
 
Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 4.1.4    100% Fuel Clad Damage Activity Equivalent Reactor Coolant DEI-131 Concentrations 100% DEI RCS Activityi(&#xb5;Ci/gm) =
                                  =
100% Clad Damage RCS Activityi(&#xb5;Ci/gm) x DEI DCFi Note - The DEI DCF value for each iodine isotope is determined as follows:
EPA - 400 Table 5 - 2 Iodine DCFi(Rem/hr per &#xb5;Ci/cc)
DEI DCFi =
EPA - 400 Table 5 - 2 Iodine DCFI-131(Rem/hr per &#xb5;Ci/cc)
DEI DCF              RCS Activity (Ci/gm)
(unit less)            Unit 1                    Unit 2 1-131        1.00E+00          1.42E+04                  1.89E+04 1-132        5.92E-03          1.22E+02                  1.62E+02 1-133        1.69E-01          4.89E+03                  6.48E+03 1-134        1.00E-03          3.19E+01                  4.23E+01 1-135        2.92E-02          8.07E+02                  1.07E+03 Total                          2.01E+04                  2.66E+04 4.1.5    % Fuel Clad Damage Activity Equivalent Reactor Coolant at 300 &#xb5;Ci/gm DEI-131 300 &#xb5;Ci/gm
          % Clad Damage =
100% DEI RCS Activity(&#xb5;Ci/gm)
U1 300 Ci/gm DEI-131..................................................... 1.49% Fuel Clad Damage U2 300 Ci/gm DEI-131..................................................... 1.13% Fuel Clad Damage See Attachment 1 for the spreadsheet calculations that develop the fuel clad source term activity and the % clad damage.
4.2  Fission Product Barrier Thresholds See Attachment 2 for the spreadsheet calculations that develop the FPB threshold monitor readings.
4.2.1    Containment Potential Loss (20% Fuel Clad Damage Monitor Reading)
MWtUnit Unit20% clad(R/hr) = Std Plant100% clad(R/hr) x 20% x MWtStd Plant U1 Containment Potential Loss Threshold Monitor Reading ........... 1.03E+4 R/hr U2 Containment Potential Loss Threshold Monitor Reading ........... 1.21E+4 R/hr Page 9 of 15
 
Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 4.2.2    Fuel Clad Loss (300 &#xb5;Ci/gm DEI-131 Equivalent Clad Damage Monitor Reading)
MWtU1 Unit1.49% clad(R/hr) = Std Plant100% clad(R/hr) x 1.49% x MWtStd Plant MWtU2 Unit1.13% clad(R/hr) = Std Plant100% clad(R/hr) x 1.13% x MWtStd Plant U1 Fuel Clad Loss Threshold Monitor Reading ................................. 7.68E+2 R/hr U2 Fuel Clad Loss Threshold Monitor Reading ................................. 6.82E+2 R/hr 4.2.3    RCS Loss (Spiked Coolant Monitor Reading)
MWtUnit UnitSpiked(R/hr) = Std Plant100% Spiked(R/hr) x MWtStd Plant U1 RCS Loss Threshold Monitor Reading ......................................... 4.28E+1 R/hr U2 RCS Loss Threshold Monitor Reading ......................................... 5.04E+1 R/hr
: 5. CONCLUSIONS 5.1  300 &#xb5;Ci/gm DEI-131 is equivalent to:
: 1)  Unit 1 .............................................................................. 1.49% fuel clad (gap) damage
: 2)  Unit 2 .............................................................................. 1.13% fuel clad (gap) damage 5.2  Calculated containment high range radiation monitor values are as follows:
Fuel Clad                          RCS                      Containment Loss                            Loss                    Potential Loss Unit 1        7.68E+2 R/hr                    4.28E+1 R/hr                  1.03E+4 R/hr Unit 2        6.82E+2 R/hr                    5.04E+1 R/hr                  1.21E+4 R/hr Based on monitor accuracy/readability and human factors, the EAL Fission Product Barrier thresholds are established as follows:
Fuel Clad                          RCS                      Containment Loss                            Loss                    Potential Loss Unit 1            750 R/hr                        40 R/hr                      10,000 R/hr Unit 2            700 R/hr                        50 R/hr                      12,000 R/hr Page 10 of 15
 
Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0
: 6. REFERENCES 6.1  NEI 99-01 R6, Development of Emergency Action Levels for Non-Passive Reactors, September 2012 6.2  EPA-400-R-92-001, Manual of Protective action Guides and Protective Actions for Nuclear Incidents, May 1992 6.3  NUREG-1940, RASCAL 4: Description of Models and Methods, December 2012 6.4  NUREG-1228, Source Term Estimation During Incident Response to Severe Nuclear Power Plant Accidents, October 1988 6.5  Regulatory Guide 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, July 2000 6.6  ANO1 Safety Analysis Report (SAR)
: 1)  Section 1.1, Introduction, Amendment 20 6.7  ANO2 Safety Analysis Report (SAR)
: 1)  Section 1.1, Introduction, Amendment 17 6.8  ANO1 Technical Specifications
: 1)  Section 3.4.12, RCS Specific Activity, Amendment 243 6.9  ANO2 Technical Specifications
: 1)  Section 3.4.8, RCS Specific Activity, Amendment 293 6.10 1302.022, Core Damage Assessment, Change 5 6.11 TM GO63.00, General Atomic Tech Manual, Revision 2 6.12 TD G063 0020, General Atomic Tech Manual, Revision 2 Page 11 of 15
 
Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 ATTACHMENT 1 300 &#xb5;Ci/gm DEI-131 Equivalent Clad Damage Unit 1 NUREG-1940 Table 1-1                                                                                                                        U1 RCS Activity U1 Core Activity (Ci)
EPA-400 Table 5-2 U1 RCS Activity      U1 RCS Activity        Dose Conversion DEI DCF Factors (Rem/hr per
(&#xb5;Ci/gm 100% Core)    (&#xb5;Ci/gm 100% Clad)
Core Activity (Ci/MWt)                                                                                      &#xb5;Ci/cc)                      (&#xb5;Ci/gm 100% Gap DEI)
I-131    2.67E+04                  6.86E+07                    2.85E+05              1.42E+04                  1.30E+06              1.00E+00    1.42E+04 I-132    3.88E+04                  9.96E+07                    4.13E+05              2.07E+04                  7.70E+03              5.92E-03    1.22E+02 I-133    5.42E+04                  1.39E+08                    5.78E+05              2.89E+04                  2.20E+05              1.69E-01    4.89E+03 I-134    5.98E+04                  1.54E+08                    6.37E+05              3.19E+04                  1.30E+03              1.00E-03    3.19E+01 I-135    5.18E+04                  1.33E+08                    5.52E+05              2.76E+04                  3.80E+04              2.92E-02    8.07E+02 Total    2.31E+04                  5.94E+08                    2.46E+06              1.23E+05                                                    2.01E+04 U1 Rate Power (MWt):                  2568 RCS Liquid Volume (gm):              2.41E+08 Halogen Release Fraction:                5.0%
Target DEI:            3.00E+02
                                                                                                                          %Clad Damage:                  1.49%
Page 12 of 15
 
Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 Unit 2 NUREG-1940 Table 1-1                                                                                                                      U2 RCS Activity U2 Core Activity (Ci)
EPA-400 Table 5-2 U2 RCS Activity      U2 RCS Activity        Dose Conversion DEI DCF Factors (Rem/hr per
(&#xb5;Ci/gm 100% Core)    (&#xb5;Ci/gm 100% Clad)
Core Activity (Ci/MWt)                                                                                    &#xb5;Ci/cc)                      (&#xb5;Ci/gm 100% Gap DEI)
I-131    2.67E+04                  8.08E+07                  3.78E+05              1.89E+04                  1.30E+06              1.00E+00    1.89E+04 I-132    3.88E+04                  1.17E+08                  5.49E+05              2.74E+04                  7.70E+03              5.92E-03    1.62E+02 I-133    5.42E+04                  1.64E+08                  7.66E+05              3.83E+04                  2.20E+05              1.69E-01    6.48E+03 I-134    5.98E+04                  1.81E+08                  8.46E+05              4.23E+04                  1.30E+03              1.00E-03    4.23E+01 I-135    5.18E+04                  1.57E+08                  7.32E+05              3.66E+04                  3.80E+04              2.92E-02    1.07E+03 Total    2.31E+05                  7.00E+08                  3.27E+06              1.64E+05                                                    2.66E+04 U2 Rate Power (MWt):                  3026 RCS Liquid Volume (gm):              2.14E+08 Halogen Release Fraction:                5.0%
Target DEI:            3.00E+02
                                                                                                                          %Clad Damage:                  1.13%
Page 13 of 15
 
Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 ATTACHMENT 2 Fission Product Barrier Threshold Values Reading for 300 Rated Power (MWt)
Reading for 100%          Reading for 20%                                              Reading for Spiked
                                                                                        % Damage for 300 &#xb5;Ci/gm RCS  &#xb5;Ci/gm RCS Activity Clad Failure (R/hr)      Clad Failure (R/hr)      Activity                            RCS Activity (R/hr)
(R/hr)
Unit 1      2568                      5.14E+04                  1.03E+04                1.49%          7.68E+02              4.28E+01 Unit 2      3026                      6.05E+04                  1.21E+04                1.13%          6.82E+02              5.04E+01 NUREG-1940 100% Clad Failure (R/hr):                                  6.00E+04 NUREG-1940 100% Spiked Coolant (R/hr):                                  5.00E+01 Standard Plant (MWt):                            3000 Page 14 of 15
 
Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 ATTACHMENT 3 NUREG-1940 Figure 1-1 PWR Containment Monitor Response Page 15 of 15}}

Latest revision as of 07:22, 3 February 2020

Enclosures 2 - 6: Proposed EAL Technical Basis Document, NEI 99-01. Rev. 6., Proposed EAL Matrix Chart/Review Table and Supporting Referenced Document Pages
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Enclosure 2 to 0CAN031801 Proposed EAL Technical Basis Document (Markup) to 0CAN031801 Page 1 of 255 Table of Contents Section Page

1.0 INTRODUCTION

.................................................................................................................2 2.0 DISCUSSION ......................................................................................................................2 2.1 Background ................................................................................................................2 2.2 Fission Product Barriers .............................................................................................3 2.3 Fission Product Barrier Classification Criteria ............................................................3 2.4 EAL Organization .......................................................................................................4 2.5 Technical Basis Information .......................................................................................5 2.6 Operations Mode Applicability....................................................................................7 3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS ..........................................8 3.1 General Considerations .............................................................................................8 3.2 Classification Methodology ......................................................................................10

4.0 REFERENCES

..................................................................................................................13 4.1 Developmental .........................................................................................................13 4.2 Implementing............................................................................................................13 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS ...........................................................13 5.1 Definitions (ref. 4.1.1 except as noted) ....................................................................13 5.2 Abbreviations/Acronyms ..........................................................................................18 6.0 ANO-TO-NEI 99-01 Rev. 6 EAL CROSS-REFERENCE ..................................................22 7.0 ATTACHMENTS ...............................................................................................................24 7.1 Attachment 1, Emergency Action Level Technical Bases ........................................24 Category A - Abnormal Rad Levels / Rad Effluents ................................................25 Category C - Cold Shutdown / Refueling System Malfunction ................................70 Category E - Independent Spent Fuel Storage Installation (ISFSI) .......................109 Category F - Fission Product Barrier Degradation ................................................112 Table 1[2]F-1, Fission Product Barrier Threshold Matrix & Bases ...119 Category H - Hazards and Other Conditions Affecting Plant Safety .....................164 Category S - System Malfunction ..........................................................................210 7.2 Attachment 2, Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases .....................................................253 to 0CAN031801 Page 2 of 255

1.0 INTRODUCTION

This document provides an explanation and rationale for each Emergency Action Level (EAL) included in the EAL Upgrade Project for Arkansas Nuclear One (ANO). It should be used to facilitate review of the ANO EALs and provide historical documentation for future reference.

Decision-makers responsible for implementation of 1903.010, Emergency Action Level Classification, may use this document as a technical reference in support of EAL interpretation.

This information may assist the Emergency Director in making classifications, particularly those involving judgment or multiple events. The basis information may also be useful in training and for explaining event classifications to off-site officials.

The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases when conditions are present and have been recognized. Use of this document for assistance is not intended to delay the emergency classification.

Because the information in a basis document can affect emergency classification decision-making (e.g., the Emergency Director refers to it during an event), the NRC staff expects that changes to the basis document will be evaluated in accordance with the provisions of 10 CFR 50.54(q).

2.0 DISCUSSION 2.1 Background EALs are the plant-specific indications, conditions or instrument readings that are utilized to classify emergency conditions defined in the ANO Emergency Plan.

In 1992, the NRC endorsed NUMARC/NESP-007 Methodology for Development of Emergency Action Levels as an alternative to NUREG-0654 EAL guidance.

NEI 99-01 (NUMARC/NESP-007) Revisions 4 and 5 were subsequently issued for industry implementation. Enhancements over earlier revisions included:

Consolidating the system malfunction initiating conditions and example emergency action levels which address conditions that may be postulated to occur during plant shutdown conditions.

Initiating conditions and example emergency action levels that fully address conditions that may be postulated to occur at permanently Defueled Stations and Independent Spent Fuel Storage Installations (ISFSIs).

Simplifying the fission product barrier EAL threshold for a Site Area Emergency.

Subsequently, Revision 6 of NEI 99-01 has been issued which incorporates resolutions to numerous implementation issues including the NRC EAL Frequently Asked Questions (FAQs).

Using NEI 99-01 Revision 6, "Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, November 2012 (ref. 4.1.1), ANO conducted an EAL implementation upgrade project that produced the EALs discussed herein.

to 0CAN031801 Page 3 of 255 2.2 Fission Product Barriers Fission product barrier thresholds represent threats to the defense in depth design concept that precludes the release of radioactive fission products to the environment. This concept relies on multiple physical barriers, any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment.

Many of the EALs derived from the NEI methodology are fission product barrier threshold based. That is, the conditions that define the EALs are based upon thresholds that represent the loss or potential loss of one or more of the three fission product barriers. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. A Loss threshold means the barrier no longer assures containment of radioactive materials.

A Potential Loss threshold implies a greater probability of barrier loss and reduced certainty of maintaining the barrier.

The primary fission product barriers are:

A. Fuel Clad Barrier (FCB): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.

B. Reactor Coolant System Barrier (RCB): The Reactor Coolant System Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.

C. Containment Barrier (CNB): The Containment Barrier includes the Reactor Building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the Reactor Building up to and including the outermost secondary side isolation valve.

Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency.

2.3 Fission Product Barrier Classification Criteria The following criteria are the bases for event classification related to fission product barrier loss or potential loss:

Alert:

Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency:

Loss or potential loss of any two barriers General Emergency:

Loss of any two barriers and loss or potential loss of the third barrier to 0CAN031801 Page 4 of 255 2.4 EAL Organization The ANO EAL scheme includes the following features:

Division of the EAL set into three broad groups:

o EALs applicable under any plant operating modes - This group would be reviewed by the EAL-user any time emergency classification is considered.

o EALs applicable only under hot operating modes - This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby, Startup, or Power Operation mode.

o EALs applicable only under cold operating modes - This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refueling or Defueled mode.

The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency.

Within each group, assignment of EALs to categories and subcategories:

Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. The ANO EAL categories are aligned to and represent the NEI 99-01, Recognition Categories. Subcategories are used in the ANO scheme as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The ANO EAL categories and subcategories are listed below.

The primary tool for determining the emergency classification level is the EAL Classification Matrix. The user of the EAL Classification Matrix may (but is not required to) consult the EAL technical bases in order to obtain additional information concerning the EALs under classification consideration. The user should consult Section 3.0 and Attachment 1 of this document for such information.

to 0CAN031801 Page 5 of 255 EAL Groups, Categories and Subcategories EAL Group/Category EAL Subcategory Any Operating Mode:

A - Abnormal Rad Levels / Rad Effluent 1 - Radiological Effluent 2 - Irradiated Fuel Event 3 - Area Radiation Levels H - Hazards and Other Conditions Affecting 1 - Security Plant Safety 2 - Seismic Event 3 - Natural or Technological Hazard 4 - Fire 5 - Hazardous Gas 6 - Control Room Evacuation 7 - Emergency Director Judgment E - Independent Spent Fuel Storage 1 - Confinement Boundary Installation (ISFSI)

Hot Conditions:

S - System Malfunction 1 - Loss of Essential AC Power 2 - Loss of Vital DC Power 3 - Loss of Control Room Indications 4 - RCS Activity 5 - RCS Leakage 6 - RPS Failure 7 - Loss of Communications 8 - Containment Failure 9 - Hazardous Event Affecting Safety Systems F - Fission Product Barrier Degradation None Cold Conditions:

C - Cold Shutdown / Refueling System 1 - RCS Level Malfunction 2 - Loss of Essential AC Power 3 - RCS Temperature 4 - Loss of Vital DC Power 5 - Loss of Communications 6 - Hazardous Event Affecting Safety Systems 2.5 Technical Bases Information EAL technical bases are provided in Attachment 1 for each EAL according to EAL group (Any, Hot, Cold), EAL category (A, C, E, F, H and S) and EAL subcategory. A summary explanation of each category and subcategory is given at the beginning of the technical bases discussions of the EALs included in the category. For each EAL, the following information is provided:

to 0CAN031801 Page 6 of 255 Category Letter & Title Subcategory Number & Title Initiating Condition (IC)

Site-specific description of the generic IC given in NEI 99-01 Rev. 6.

EAL Identifier (enclosed in rectangle)

Each EAL is assigned a unique identifier to support accurate communication of the emergency classification to onsite and offsite personnel. Four characters define each EAL identifier:

1. First character (letter): Corresponds to the EAL category as described above (A, C, E, F, H or S)
2. Second character (letter): The emergency classification (G, S, A or U)

G = General Emergency S = Site Area Emergency A = Alert U = Unusual Event

3. Third character (number): Subcategory number within the given category. Subcategories are sequentially numbered beginning with the number one (1). If a category does not have a subcategory, this character is assigned the number one (1).
4. Fourth character (number): The numerical sequence of the EAL within the EAL subcategory. If the subcategory has only one EAL, it is given the number one (1).

Classification (enclosed in rectangle):

Unusual Event (U), Alert (A), Site Area Emergency (S) or General Emergency (G)

EAL (enclosed in rectangle)

Exact wording of the EAL as it appears in the EAL Classification Matrix. If an ANO Unit 2 EAL threshold value differs from Unit 1, the Unit 2 threshold is enclosed in brackets. For example, in the EAL threshold RVLMS Levels 1 through 8 indicate DRY [RVLMS Levels 1 through 5 indicate DRY], RVLMS Levels 1 through 5 indicate DRY apply only to Unit 2.

Mode Applicability One or more of the following plant operating conditions comprise the mode to which each EAL is applicable: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling, DEF - Defueled, or All. (See Section 2.6 for operating mode definitions).

to 0CAN031801 Page 7 of 255 Definitions:

If the EAL wording contains a defined term, the definition of the term is included in this section. These definitions can also be found in Section 5.1.

Basis:

An EAL basis section that provides ANO-relevant information concerning the EAL as well as a description of the rationale for the EAL as provided in NEI 99-01 Rev. 6.

Reference(s):

Source documentation from which the EAL is derived.

2.6 Operating Mode Applicability Unit 1 (ref. 4.1.6):

1 Power Operation Keff 0.99, reactor power > 5%

2 Startup Keff 0.99, reactor power 5%

3 Hot Standby Keff < 0.99, reactor coolant temperature 280°F 4 Hot Shutdown Keff < 0.99, reactor coolant temperature 280°F > Tavg > 200°F and all reactor vessel head closure bolts fully tensioned 5 Cold Shutdown Keff < 0.99, reactor coolant temperature 200°F and all reactor vessel head closure bolts fully tensioned 6 Refueling One or more reactor vessel head closure bolts less than fully tensioned DEF Defueled All fuel assemblies have been removed from Containment and placed in the spent fuel pool.

to 0CAN031801 Page 8 of 255 Unit 2 (ref. 4.1.6):

1 Power Operation Keff 0.99, reactor power > 5%, average coolant temperature 300°F 2 Startup Keff 0.99, reactor power 5%, average coolant temperature 300°F 3 Hot Standby Keff < 0.99, average coolant temperature 300°F 4 Hot Shutdown Keff < 0.99, average coolant temperature 300°F > Tavg > 200°F 5 Cold Shutdown Keff < 0.99, average coolant temperature 200°F 6 Refueling Keff 0.95, average coolant temperature 140°F, reactor vessel head unbolted or removed, and fuel in the vessel.

DEF Defueled All fuel assemblies have been removed from Containment and placed in the spent fuel pool.

The plant operating mode that exists at the time that the event occurs (prior to any protective system or operator action being initiated in response to the condition) should be compared to the mode applicability of the EALs. If a lower or higher plant operating mode is reached before the emergency classification is made, the declaration shall be based on the mode that existed at the time the event occurred.

3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 3.1 General Considerations When making an emergency classification, the Emergency Director must consider all information having a bearing on the proper assessment of an Initiating Condition (IC). This includes the Emergency Action Level (EAL) plus the associated Operating Mode Applicability, Notes, and the informing basis information. In the Recognition Category F matrices, EALs are based on loss or potential loss of Fission Product Barrier Thresholds.

EAL matrices should be read from left to right, from General Emergency to Unusual Event, and top to bottom. Declaration decisions should be independently verified before declaration is made except when gaining this verification would exceed the 15 minute declaration requirement. Place keeping should be used on all EAL matrices.

to 0CAN031801 Page 9 of 255 3.1.1 Classification Timeliness NRC regulations require the licensee to establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and to promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. The NRC staff has provided guidance on implementing this requirement in NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants" (ref. 4.1.8).

3.1.2 Valid Indications All emergency classification assessments shall be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicators operability, the conditions existence, or the reports accuracy. For example, verification could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by plant personnel.

An indication, report, or condition is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

3.1.3 Imminent Conditions For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the Emergency Director 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. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary.

3.1.4 Planned vs. Unplanned Events A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that: 1) the activity proceeds as planned, and 2) the plant remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain or modify a system or component. In these cases, the controls associated with the planning, preparation and execution of the work will ensure that compliance is maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10 CFR 50.72 (ref. 4.1.4).

3.1.5 Classification Based on Analysis The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., dose assessments, chemistry sampling, RCS leak rate calculation, etc.). For these EALs, the EAL wording or the to 0CAN031801 Page 10 of 255 associated basis discussion will identify the necessary analysis. In these cases, the 15-minute declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available). The NRC expects licensees to establish the capability to initiate and complete EAL-related analyses within a reasonable period of time (e.g., maintain the necessary expertise on-shift).

3.1.6 Emergency Director Judgment While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 EAL scheme provides the Emergency Director with the ability to classify events and conditions based upon judgment using EALs that are consistent with the Emergency Classification Level (ECL) definitions (refer to Category H). The Emergency Director will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.

A similar provision is incorporated in the Fission Product Barrier Tables; judgment may be used to determine the status of a fission product barrier.

3.2 Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e., the relevant plant indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL must be consistent with the related Operating Mode Applicability and Notes. If an EAL has been met or exceeded, the associated IC is likewise met, the emergency classification process clock starts, and the ECL must be declared in accordance with plant procedures no later than fifteen minutes after the process clock started.

When assessing an EAL that specifies a time duration for the off-normal condition, the clock for the EAL time duration runs concurrently with the emergency classification process clock.

For a full discussion of this timing requirement, refer to NSIR/DPR-ISG-01 (ref. 4.1.8).

3.2.1 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared. For example:

If an Alert EAL and a Site Area Emergency EAL are met, whether at one unit or at two units, a Site Area Emergency should be declared.

There is no additive effect from multiple EALs meeting the same ECL. For example:

If two Alert EALs are met, whether at one unit or at two units, an Alert should be declared.

Related guidance concerning classification of rapidly escalating events or conditions is provided in Regulatory Issue Summary (RIS) 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events (ref. 4.1.2).

to 0CAN031801 Page 11 of 255 3.2.2 Consideration of Mode Changes During Classification The mode in effect at the time that an event or condition occurred, and prior to any plant or operator response, is the mode that determines whether or not an IC is applicable. If an event or condition occurs, and results in a mode change before the emergency is declared, the emergency classification level is still based on the mode that existed at the time that the event or condition was initiated (and not when it was declared). Once a different mode is reached, any new event or condition, not related to the original event or condition, requiring emergency classification should be evaluated against the ICs and EALs applicable to the operating mode at the time of the new event or condition.

For events that occur in Cold Shutdown or Refueling, escalation is via EALs that are applicable in the Cold Shutdown or Refueling modes, even if Hot Shutdown (or a higher mode) is entered during the subsequent plant response. In particular, the fission product barrier EALs are applicable only to events that initiate in the Hot Shutdown mode or higher.

3.2.3 Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Director must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Emergency Director, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all emergency classification levels, this approach is particularly important at the higher emergency classification levels since it provides additional time for implementation of protective measures.

3.2.4 Emergency Classification Level Upgrading and Termination An ECL may be terminated when the event or condition that meets the classified IC and EAL no longer exists, and other site-specific termination requirements are met.

As noted above, guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02 (ref. 4.1.2).

3.2.5 Classification of Short-Lived Events Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration. Examples of such events include an earthquake or a failure of the reactor protection system to automatically trip the reactor followed by a successful manual trip.

3.2.6 Classification of Transient Conditions Many of the ICs and/or EALs employ time-based criteria. These criteria will require that the IC/EAL conditions be present for a defined period of time before an emergency declaration is warranted. In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes). The following guidance should be applied to the classification of these conditions.

to 0CAN031801 Page 12 of 255 EAL momentarily met during expected plant response - In instances in which an EAL is briefly met during an expected (normal) plant response, an emergency declaration is not warranted provided that associated systems and components are operating as expected, and operator actions are performed in accordance with procedures.

EAL momentarily met but the condition is corrected prior to an emergency declaration - If an operator takes prompt manual action to address a condition, and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required. For illustrative purposes, consider the following example:

An ATWS occurs and the high pressure ECCS systems fail to automatically start. The plant enters an inadequate core cooling condition (a potential loss of both the Fuel Clad and RCS Barriers). If an operator manually starts a high pressure ECCS system in accordance with an EOP step and clears the inadequate core cooling condition prior to an emergency declaration, then the classification should be based on the ATWS only.

It is important to stress that the 15-minute emergency classification assessment period (process clock) is not a grace period during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event. Emergency classification assessments must be deliberate and timely, with no undue delays. The provision discussed above addresses only those rapidly evolving situations when an operator is able to take a successful corrective action prior to the Emergency Director completing the review and steps necessary to make the emergency declaration. This provision is included to ensure that any public protective actions resulting from the emergency classification are truly warranted by the plant conditions.

3.2.7 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery. This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.

In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022 (ref. 4.1.3) is applicable. Specifically, the event should be reported to the NRC in accordance with 10 CFR § 50.72 (ref. 4.1.4) within one hour of the discovery of the undeclared event or condition. The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.

3.2.8 Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022 (ref. 4.1.3).

to 0CAN031801 Page 13 of 255

4.0 REFERENCES

4.1 Developmental 4.1.1 NEI 99-01 Revision 6, Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, ADAMS Accession Number ML12326A805 4.1.2 RIS 2007-02 Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2, 2007.

4.1.3 NUREG-1022 Event Reporting Guidelines: 10CFR50.72 and 50.73 4.1.4 10 § CFR 50.72 Immediate Notification Requirements for Operating Nuclear Power Reactors 4.1.5 10 § CFR 50.73 License Event Report System 4.1.6 Unit 1[2] Technical Specifications Table 1.1-1[1.1], Modes[Operational Modes]

4.1.7 Arkansas Nuclear One Offsite Dose Calculation Manual (ODCM) 4.1.8 NSIR/DPR-ISG-01 Interim Staff Guidance, Emergency Planning for Nuclear Power Plants 4.1.9 Arkansas Nuclear One Emergency Plan 4.1.10 1015.008 Unit 2 SDC Control 4.2 Implementing 4.2.1 1903.010 Emergency Action Level Classification 4.2.2 NEI 99-01 Rev. 6 to ANO EAL Comparison Matrix 4.2.3 ANO EAL Matrix 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS 5.1 Definitions (ref. 4.1.1 except as noted)

Selected terms used in Initiating Condition, Emergency Action Level statements and EAL bases are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.

Alert 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.

to 0CAN031801 Page 14 of 255 Confinement Boundary The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).

Containment Closure The procedurally defined actions taken to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown existing plant conditions (ref. 4.1.10).

As applied to ANO, Containment Closure must be capable of being set within 30 minutes.

Containment Closure is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

Emergency Action Level (EAL)

A pre-determined, site-specific, observable threshold for an INITIATING CONDITION that, when met or exceeded, places the plant in a given emergency classification level.

Emergency Classification Level (ECL)

One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:

Notification of Unusual Event (NOUE)

Alert Site Area Emergency (SAE)

General Emergency (GE)

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 require a post-event inspection to determine if the attributes of an explosion are present.

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.

to 0CAN031801 Page 15 of 255 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.

Fission Product Barrier Threshold A pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier.

Flooding A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

General Emergency 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 PAG exposure levels offsite for more than the immediate site area.

Hostage A person(s) held as leverage against the station to ensure that demands will be met by the station.

Hostile Action An act toward a NPP ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPPANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

Hostile Force One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

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

to 0CAN031801 Page 16 of 255 Impede(d)

Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

Independent Spent Fuel Storage Installation (ISFSI)

A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

Initiating Condition (IC)

An event or condition that aligns with the definition of one of the four emergency classification levels by virtue of the potential or actual effects or consequences.

Normal Levels As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.

Owner Controlled Area (OCA)

For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line. Access to this area is controlled by the SOCA Personnel Access Control Point (ref. 4.1.9).

Projectile An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

Protected Area An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled (ref. 4.1.9).

RCS Intact The RCS should be considered intact when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams).

Refueling Pathway All the cavities, tubes, canals and pools through which irradiated fuel may be moved, but not including the reactor vessel.

to 0CAN031801 Page 17 of 255 Ruptured The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).

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 (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Security Condition Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A Security Condition does not involve a HOSTILE ACTION.

Site Area Emergency 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 PAG exposure levels beyond the SITE BOUNDARY.

Site Boundary That boundary defined by a 1046 meter (0.65 mile) radius around the plant (ref. 4.1.7).

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.

to 0CAN031801 Page 18 of 255 Unusual Event Events are in progress or have occurred which indicate a potential degradation in 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.

Valid An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Visible Damage Damage to a SAFETY SYSTEM train 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 SAFETY SYSTEM train.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.

5.2 Abbreviations/Acronyms

°F .................................................................................................................... Degrees Fahrenheit

°......................................................................................................................................... Degrees AC ..................................................................................................................... Alternating Current ANO ............................................................................................................ Arkansas Nuclear One AOP .............................................................................................. Abnormal Operating Procedure ATWS.................................................................................... Anticipated Transient Without Scram BMS ................................................................................................... Boron Management System BWST................................................................................................ Borated Water Storage Tank CDE ................................................................................................... Committed Dose Equivalent CET .......................................................................................................... Core Exit Thermocouple CFR................................................................................................... Code of Federal Regulations CIAS.................................................................................. Containment Isolation Actuation Signal CMT, CNTMT, CTMT ..................................................................................................Containment CNB ................................................................................................................ Containment Barrier DBA............................................................................................................. Design Basis Accident DBE......................................................................................................... Design Basis Earthquake to 0CAN031801 Page 19 of 255 DC .............................................................................................................................Direct Current DEF ...................................................................................................................................Defueled D/G....................................................................................................................... Diesel Generator DHR .............................................................................................................. Decay Heat Removal DROPS ............................................................ Diverse Reactor Overpressure Protection System DSC ............................................................................................................. Dry Shielded Canister DSS............................................................................................................ Diverse Scram System EAL .......................................................................................................... Emergency Action Level ECCS ......................................................................................... Emergency Core Cooling System ECL ............................................................................................... Emergency Classification Level DEF ...................................................................................................................................Defueled ENS............................................................................................... Emergency Notification System EOF................................................................................................ Emergency Operations Facility EOP ........................................................................................... Emergency Operating Procedure EPA ............................................................................................ Environmental Protection Agency ERG ............................................................................................ Emergency Response Guideline EPIP ............................................................................. Emergency Plan Implementing Procedure ESAS ........................................................................... Engineered Safeguards Actuation System ESF ...................................................................................................... Engineered Safety Feature ESFAS .................................................................. Engineered Safety Features Actuation System FAA ............................................................................................... Federal Aviation Administration FBI ................................................................................................ Federal Bureau of Investigation FCB ...................................................................................................................... Fuel Clad Barrier FEMA ............................................................................ Federal Emergency Management Agency GE ................................................................................................................... General Emergency HPI ............................................................................................................. High Pressure Injection IC ...................................................................................................................... Initiating Condition IPEEE ............................. Individual Plant Examination of External Events (Generic Letter 88-20)

ISFSI ......................................................................... Independent Spent Fuel Storage Installation Keff ...................................................................................... Effective Neutron Multiplication Factor LCO................................................................................................Limiting Condition of Operation LER .............................................................................................................Licensee Event Report LOCA ...................................................................................................... Loss of Coolant Accident LRW ....................................................................................................................Liquid Rad Waste to 0CAN031801 Page 20 of 255 LTOP............................................................................................ Low Temperature Overpressure LWR ................................................................................................................ Light Water Reactor MCC .............................................................................................................. Motor Control Center MPC ................................................ Maximum Permissible Concentration/Multi-Purpose Canister mR, mRem, mrem, mREM ............................................................ milli-Roentgen Equivalent Man MSL...................................................................................................................... Main Steam Line MTS ................................................................................................................ Margin to Saturation MW.................................................................................................................................. Megawatt NDTT ...................................................................................... Nil Ductility Transition Temperature NEI ............................................................................................................Nuclear Energy Institute NEIC ................................................................................ National Earthquake Information Center NESP ................................................................................ National Environmental Studies Project NORAD ................................................................ North American Aerospace Defense Command NOT .............................................................................................. Normal Operating Temperature (NO)UE ............................................................................................. Notification of Unusual Event NPP................................................................................................................ Nuclear Power Plant NRC ............................................................................................ Nuclear Regulatory Commission NSSS ............................................................................................. Nuclear Steam Supply System OBE ................................................................................................... Operating Basis Earthquake OCA ........................................................................................................... Owner Controlled Area ODCM ........................................................................................ Off-site Dose Calculation Manual ORO ............................................................................................... Offsite Response Organization PA ........................................................................................................................... Protected Area PAG ..................................................................................................... Protective Action Guideline PRA/PSA .................................. Probabilistic Risk Assessment / Probabilistic Safety Assessment P-T .............................................................................................................. Pressure-Temperature PTS ..................................................................................................... Pressurized Thermal Shock PWR..................................................................................................... Pressurized Water Reactor PSIG ............................................................................................ Pounds per Square Inch Gauge R ..................................................................................................................................... Roentgen RB .........................................................................................................................Reactor Building RCC ......................................................................................................... Reactor Control Console RCB ............................................................................................. Reactor Coolant System Barrier RCP ............................................................................................................ Reactor Coolant Pump to 0CAN031801 Page 21 of 255 RCS ......................................................................................................... Reactor Coolant System Rem, rem, REM ..................................................................................... Roentgen Equivalent Man Rep CET ....................................................................... Representative Core Exit Thermocouples RETS ...................................................................... Radiological Effluent Technical Specifications RPS...................................................................................................... Reactor Protection System RV ...........................................................................................................................Reactor Vessel RVLMS........................................................................... Reactor Vessel Level Monitoring System RWT ............................................................................................................. Refueling Water Tank SAR.............................................................................................................Safety Analysis Report SBO ...................................................................................................................... Station Blackout SCBA ................................................................................... Self-Contained Breathing Apparatus SDC ................................................................................................................... Shutdown Cooling SOCA ........................................................................................... Security Owner Controlled Area SG ....................................................................................................................... Steam Generator SI............................................................................................................................ Safety Injection SPDS ........................................................................................ Safety Parameter Display System SPING ..................................................................................... Super Particulate Iodine Noble Gas SRO ......................................................................................................... Senior Reactor Operator TEDE ............................................................................................ Total Effective Dose Equivalent TOAF ................................................................................................................. Top of Active Fuel TSC ........................................................................................................ Technical Support Center USGS .......................................................................................... United States Geological Survey VBS ............................................................................................................ Vehicle Barrier System to 0CAN031801 Page 22 of 255 6.0 ANO-TO-NEI 99-01 REV. 6 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of an ANO EAL within the NEI 99-01 IC/EAL identification scheme. Further information regarding the development of the ANO EALs based on the NEI guidance can be found in the EAL Comparison Matrix.

ANO NEI 99-01 Rev. 6 EAL IC Example EAL AU1.1 AU1 1, 2 AU1.2 AU1 3 AU2.1 AU2 1 AA1.1 AA1 1 AA1.2 AA1 2 AA1.3 AA1 3 AA1.4 AA1 4 AA2.1 AA2 1 AA2.2 AA2 2 AA2.3 AA2 3 AA3.1 AA3 1 AA3.2 AA3 2 AS1.1 AS1 1 AS1.2 AS1 2 AS1.3 AS1 3 AS2.1 AS2 1 AG1.1 AG1 1 AG1.2 AG1 2 AG1.3 AG1 3 AG2.1 AG2 1 CU1.1 CU1 1 CU1.2 CU1 2 CU2.1 CU2 1 CU3.1 CU3 1 CU3.2 CU3 2 CU4.1 CU4 1 to 0CAN031801 Page 23 of 255 ANO NEI 99-01 Rev. 6 EAL IC Example EAL CU5.1 CU5 1, 2, 3 CA1.1 CA1 1 CA1.2 CA1 2 CA2.1 CA2 1 CA3.1 CA3 1, 2 CA6.1 CA6 1 CS1.1 CS1 1 CS1.2 CS1 2 CS1.3 CS1 3 CG1.1 CG1 1 CG1.2 CG1 2 EU1.1 EU1 1 FA1.1 FA1 1 FS1.1 FS1 1 FG1.1 FG1 1 HU1.1 HU1 1, 2, 3 HU2.1 HU2 1 HU3.1 HU3 1 HU3.2 HU3 2 HU3.3 HU3 3 HU3.4 HU3 4 HU4.1 HU4 1 HU4.2 HU4 2 HU4.3 HU4 3 HU4.4 HU4 4 HU7.1 HU7 1 HA1.1 HA1 1, 2 HA5.1 HA5 1 HA6.1 HA6 1 HA7.1 HA7 1 HS1.1 HS1 1 to 0CAN031801 Page 24 of 255 ANO NEI 99-01 Rev. 6 EAL IC Example EAL HS6.1 HS6 1 HS7.1 HS7 1 HG7.1 HG7 1 SU1.1 SU1 1 SU3.1 SU2 1 SU4.1 SU3 1 SU4.2 SU3 2 SU5.1 SU4 1, 2, 3 SU6.1 SU5 1 SU6.2 SU5 2 SU7.1 SU6 1, 2, 3 SU8.1 SU7 1, 2 SA1.1 SA1 1 SA3.1 SA2 1 SA6.1 SA5 1 SA9.1 SA9 1 SS1.1 SS1 1 SS2.1 SS8 1 SS6.1 SS5 1 SG1.1 SG1 1 SG1.2 SG8 1 7.0 ATTACHMENTS 7.1 Attachment 1, Emergency Action Level Technical Bases 7.2 Attachment 2, Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases to 0CAN031801 Page 25 of 255 Attachment 1 - Emergency Action Level Technical Bases Category A - Abnormal Rad Levels / Rad Effluent EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

Many EALs are based on actual or potential degradation of fission product barriers because of the elevated potential for offsite radioactivity release. Degradation of fission product barriers though is not always apparent via non-radiological symptoms. Therefore, direct indication of elevated radiological effluents or area radiation levels are appropriate symptoms for emergency classification.

At lower levels, abnormal radioactivity releases may be indicative of a failure of containment systems or precursors to more significant releases. At higher release rates, offsite radiological conditions may result which require offsite protective actions. Elevated area radiation levels in plant may also be indicative of the failure of containment systems or preclude access to plant vital equipment necessary to ensure plant safety.

Events of this category pertain to the following subcategories:

1. Radiological Effluent Direct indication of effluent radiation monitoring systems provides a rapid assessment mechanism to determine releases in excess of classifiable limits. Projected offsite doses, actual offsite field measurements or measured release rates via sampling indicate doses or dose rates above classifiable limits.
2. Irradiated Fuel Event Conditions indicative of a loss of adequate shielding or damage to irradiated fuel may preclude access to vital plant areas or result in radiological releases that warrant emergency classification.
3. Area Radiation Levels Sustained general area radiation levels which may preclude access to areas requiring continuous occupancy also warrant emergency classification.

to 0CAN031801 Page 26 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:

AU1.1 Unusual Event Reading on any Table 1[2]A-1 effluent radiation monitor > column "UE" for 60 min.

(Notes 1, 2, 3)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: 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.

Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm to 0CAN031801 Page 27 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses a potential decrease reduction 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.

to 0CAN031801 Page 28 of 255 Attachment 1 - Emergency Action Level Technical Bases 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.

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.

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 - This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways .

EAL #2 - This EAL addressesas well as radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit.

This EAL will Such releases are typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).

EAL #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 AA1.

Reference(s):

1. OP-1604.051 Eberline Radiation Monitor System
2. Offsite Dose Calculation Manual
3. EP-CALC-ANO-1701 Radiological Effluent EAL Values
4. NEI 99-01 AU1 to 0CAN031801 Page 29 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:

AU1.2 Unusual Event Sample analysis for a gaseous or liquid release indicates a concentration or release rate 2 x ODCM limits for 60 min. (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

None Basis:

This IC addresses a potential decrease reduction 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.

to 0CAN031801 Page 30 of 255 Attachment 1 - Emergency Action Level Technical Bases 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.

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 - This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways.

EAL #2 - 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).

EAL #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 AA1.

Reference(s):

1. Offsite Dose Calculation Manual
2. NEI 99-01 AU1 to 0CAN031801 Page 31 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.1 Alert Reading on any Table 1[2]A-1 effluent radiation monitor > column "ALERT" for 15 min.

(Notes 1, 2, 3, 4)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: 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.

Note 4 The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm to 0CAN031801 Page 32 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

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.

to 0CAN031801 Page 33 of 255 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

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.

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1604.051 Eberline Radiation Monitor System
2. EP-CALC-ANO-1701 Radiological Effluent EAL Values
3. NEI 99-01 AA1 to 0CAN031801 Page 34 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.2 Alert Dose assessment using actual meteorology indicates doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY. (Note 4)

Note 4: The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

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 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

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.

to 0CAN031801 Page 35 of 255 Attachment 1 - Emergency Action Level Technical Bases Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1904.002 Offsite Dose Projections
2. NEI 99-01 AA1 to 0CAN031801 Page 36 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.3 Alert Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY for 60 min. of exposure. (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

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 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

to 0CAN031801 Page 37 of 255 Attachment 1 - Emergency Action Level Technical Bases 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 EAL is assessed per the ODCM (ref. 2).

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1904.002 Offsite Dose Projections
2. Offsite Dose Calculation Manual
3. NEI 99-01 AA1 to 0CAN031801 Page 38 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.4 Alert Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 10 mR/hr expected to continue for 60 min.

Analyses of field survey samples indicate thyroid CDE > 50 mrem for 60 min. of inhalation.

(Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

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.

to 0CAN031801 Page 39 of 255 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

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.

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1905.002 Offsite Emergency Monitoring
2. NEI 99-01 AA1 to 0CAN031801 Page 40 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

AS1.1 Site Area Emergency Reading on any Table A-1 effluent radiation monitor > column "SAE" for 15 min.

(Notes 1, 2, 3, 4)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: 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.

Note 4: The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm to 0CAN031801 Page 41 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

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.

to 0CAN031801 Page 42 of 255 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

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.

Escalation of the emergency classification level would be via IC AG1.

Reference(s):

1. OP-1604.051 Eberline Radiation Monitor System
2. EP-CALC-ANO-1701 Radiological Effluent EAL Values
3. NEI 99-01 AS1 to 0CAN031801 Page 43 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

AS1.2 Site Area Emergency Dose assessment using actual meteorology indicates doses > 100 mrem TEDE or 500 mrem thyroid CDE at or beyond the SITE BOUNDARY. (Note 4)

Note 4 The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant).

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 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

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.

Escalation of the emergency classification level would be via IC AG1.

to 0CAN031801 Page 44 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1904.002 Offsite Dose Projections
2. NEI 99-01 AS1 to 0CAN031801 Page 45 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

AS1.3 Site Area Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 100 mR/hr expected to continue for 60 min.

Analyses of field survey samples indicate thyroid CDE > 500 mrem for 60 min. of inhalation.

(Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

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 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

to 0CAN031801 Page 46 of 255 Attachment 1 - Emergency Action Level Technical Bases 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.

Escalation of the emergency classification level would be via IC AG1.

Reference(s):

1. OP-1905.002 Offsite Emergency Monitoring
2. NEI 99-01 AS1 to 0CAN031801 Page 47 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

AG1.1 General Emergency Reading on any Table A-1 effluent radiation monitor > column "GE" for 15 min.

(Notes 1, 2, 3, 4)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: 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.

Note 4: The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm to 0CAN031801 Page 48 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

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.

to 0CAN031801 Page 49 of 255 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

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.

Reference(s):

1. OP-1604.051 Eberline Radiation Monitor System
2. EP-CALC-ANO-1701 Radiological Effluent EAL Values
3. NEI 99-01 AG1 to 0CAN031801 Page 50 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

AG1.2 General Emergency Dose assessment using actual meteorology indicates doses > 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)

Note 4 The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant).

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 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

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.

to 0CAN031801 Page 51 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1904.002 Offsite Dose Projections
2. NEI 99-01 AG1 to 0CAN031801 Page 52 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

AG1.3 General Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 1,000 mR/hr expected to continue for 60 min.

Analyses of field survey samples indicate thyroid CDE > 5,000 mrem for 60 min. of inhalation (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

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 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

to 0CAN031801 Page 53 of 255 Attachment 1 - Emergency Action Level Technical Bases 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.

Reference(s):

1. OP-1905.002 Offsite Emergency Monitoring
2. NEI 99-01 AG1 to 0CAN031801 Page 54 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: UNPLANNED loss of water level above irradiated fuel EAL:

AU2.1 Unusual Event UNPLANNED water level drop in the REFUELING PATHWAY as indicated by low water level alarm, visual observation, or BWST[RWT] level drop due to makeup demands AND UNPLANNED rise in corresponding area radiation levels as indicated by any of the following radiation monitors:

Unit 1 o RE-8009 Spent Fuel Area o RE-8017 Fuel Handling Area Unit 2 o 2RE-8914 Spent Fuel Area o 2RE-8915 Spent Fuel Area o 2RE-8916 Spent Fuel Area o 2RE-8912 Containment Incore Instrumentation Mode Applicability:

All Definition(s):

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, but not including the reactor vessel.

to 0CAN031801 Page 55 of 255 Attachment 1 - Emergency Action Level Technical Bases Basis:

This IC addresses a decrease drop 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 decrease drop 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). A significant drop in the water level may also cause an increase a rise in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may increase rise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

Escalation of the emergency classification level would be via IC AA2.

Reference(s):

1. OP-1203.050 Unit 1 Spent Fuel Pool Emergencies
2. OP-2203.002 Spent Fuel Pool Emergencies
3. 1SAR 11.2.5 Area Radiation Monitoring Systems Table 11-15 Area Radiation Monitors
4. 2SAR 12.1.4 Area Radiation Monitoring System
5. NEI 99-01 AU2 to 0CAN031801 Page 56 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

AA2.1 Alert IMMINENT uncovery of irradiated fuel in the REFUELING PATHWAY.

Mode Applicability:

All Definition(s):

CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).

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.

REFUELING PATHWAY - All the cavities, tubes, canals and pools through which irradiated fuel may be moved, but not including the reactor vessel.

Basis:

This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel poolREFUELING PATHWAY (see Developer Notes). 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 to 0CAN031801 Page 57 of 255 Attachment 1 - Emergency Action Level Technical Bases This EAL escalates from AU2 AU2.1 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 an increasea rise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance with Recognition Category C during the Cold Shutdown and Refueling modes.

EAL #2 This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).

EAL #3 Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.

Escalation of the emergency classification level would be via ICs AS1 AS1or AS2 (see AS2 Developer Notes).

Reference(s):

1. NEI 99-01 AA2 to 0CAN031801 Page 58 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

AA2.2 Alert Damage to irradiated fuel resulting in a release of radioactivity AND High alarm on any Table 1[2]A-2 radiation monitor.

Table 1A-2 Unit 1 Fuel Damage Radiation Monitors RE-8009 Spent Fuel Area RE-8017 Fuel Handling RE-8060 Containment High Range Radiation Monitors RE-8061 Containment High Range Radiation Monitors RX-9820 (SPING 1) Containment Purge RX-9825 (SPING 2) Radwaste Area RX-9830 (SPING 3) Fuel Handling Area Table 2A-2 Unit 2 Fuel Damage Radiation Monitors 2RE-8905 Containment Equipment Hatch Area 2RE-8909 Containment Personnel Access Area 2RE-8912 Containment Incore Inst.

2RE-8914 Spent Fuel Area 2RE-8915 Spent Fuel Area 2RE-8916 Spent Fuel Area 2RE-8925-1 Containment High Range Radiation Monitors 2RE-8925-2 Containment High Range Radiation Monitors 2RX-9820 (SPING 5) Containment Purge 2RX-9825 (SPING 6) Radwaste Area 2RX-9830 (SPING 7) Fuel Handling Area to 0CAN031801 Page 59 of 255 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

All Definition(s):

CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC EAL addresses events that have caused imminent or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool (see Developer Notes). 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 EAL 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.

EAL #This EAL escalates from AU2 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 an increase 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.

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 to 0CAN031801 Page 60 of 255 Attachment 1 - Emergency Action Level Technical Bases considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident). EAL #3Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.

Escalation of the emergency classification level would be via ICs AS1 or AS2 (see AS2 Developer Notes).

Reference(s):

1. OP-1203.050 Unit 1 Spent Fuel Pool Emergencies
2. OP-1305.001 Radiation Monitoring System Check and Test
3. OP-2203.002 Spent Fuel Pool Emergencies
4. OP-1604.051 Eberline Radiation Monitoring System
5. OP-2304.133 Containment High Range Radiation Monitor Calibration
6. Offsite Dose Calculation Manual
7. NEI 99-01 AA2 to 0CAN031801 Page 61 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

AA2.3 Alert Lowering of spent fuel pool level to 387.0 ft. [389.5 ft.] (Alarm 2) on LIT-2020-3(4)

[2LIT-2020-1(2)]

Mode Applicability:

All Definition(s):

None Basis:

This IC EAL addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool (see Developer Notes). 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. This EAL escalates from AU2 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 an increase 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.

to 0CAN031801 Page 62 of 255 Attachment 1 - Emergency Action Level Technical Bases 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.

This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).

EAL #3Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.

Escalation of the emergency classification level would be via ICs AS1 or AS2 (see AS2 Developer Notes).

Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).

Reference(s):

1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0
2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0
3. NEI 99-01 AA2 to 0CAN031801 Page 63 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Spent fuel pool level at the top of the fuel racks EAL:

AS2.1 Site Area Emergency Lowering of spent fuel pool level to 377.0 ft. [379.5 ft.] (Alarm 3) on LIT-2020-3(4)

[2LIT-2020-1(2)]

Mode Applicability:

All Definition(s):

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.

Basis:

This IC EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to IMMINENT fuel damage. This condition entails major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

It is recognized that this IC would likely not be met until well after another Site Area Emergency IC was met; however, it is included to provide classification diversity.

Escalation of the emergency classification level would be via IC AG1 or AG2A.

Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).

Reference(s):

1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0
2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0
3. NEI 99-01 AS2 to 0CAN031801 Page 64 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Spent fuel pool level cannot be restored to at least the top of the fuel racks for 60 minutes or longer EAL:

AG2.1 General Emergency Spent fuel pool level cannot be restored to at least 377.0 ft. [379.5 ft.] (Alarm 3) on LIT-2020-3(4) [2LIT-2020-1(2)] for 60 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

All Definition(s):

None Basis:

This IC EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment.

It is recognized that this IC would likely not be met until well after another General Emergency IC was met; however, it is included to provide classification diversity.

Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).

Reference(s):

1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0
2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0
3. NEI 99-01 AG2 to 0CAN031801 Page 65 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 3 - Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

AA3.1 Alert Dose rate > 15 mR/hr in EITHER of the following areas:

Control Room Central Alarm Station (by survey)

Mode Applicability:

All Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

Basis:

Areas that meet this threshold include the Control Room (CR) and the Central Alarm Station (CAS). The Control Room envelope (Unit 1 and Unit 2) is monitored for excessive radiation by five detectors. These radiation detectors are RE-8001, 2RE-8001A, 2RE-8001B, 2RE-8750-1A, and 2RE-8750-1B (ref. 1). The CAS is included in this EAL because of its importance to permitting access to areas required to assure safe plant operations. There are no permanently installed area radiation monitors in CAS that may be used to assess this EAL threshold.

Therefore, this threshold is evaluated using local radiation survey for this area.

This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or IMPEDE personnel from performing actions necessary to maintain normal plant operation, or to perform 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 rise in radiation levels and determine if another IC may be applicable. For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the elevated radiation levels. 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 to 0CAN031801 Page 66 of 255 Attachment 1 - Emergency Action Level Technical Bases affected room/area (e.g., installing temporary shielding, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).

An emergency declaration is not warranted if any of the following conditions apply.

The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation increase 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 A, C or F ICs.

Reference(s):

1. STM 1-62 Radiation Monitoring
2. NEI 99-01 AA3 to 0CAN031801 Page 67 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 3 - Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

AA3.2 Alert An UNPLANNED event results in radiation levels that prohibit or IMPEDE access to any Table 1[2]A-3 room or area (Note 5)

Note 5: 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.

Table 1A-3 Unit 1 Safe Operation & Shutdown Rooms/Areas Room/Area Mode A-4 Switchgear Room 3, 4 Upper North Electrical Penetration Room 3, 4 Lower South Electrical Equipment Room 3, 4 Table 2A-3 Unit 2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux Building 317 Emergency Core Cooling Rooms 3, 4 Aux Building 317 Tendon Gallery Access 3, 4 Aux Building 335 Charging Pumps / MCC 2B-52 3, 4 Aux Building 354 MCC 2B-62 Area 3, 4 Emergency Diesel Generator Corridor 3, 4 Lower South Piping Penetration Room 3, 4 Aux Building 386 Containment Hatch 3, 4 to 0CAN031801 Page 68 of 255 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

3 - Hot Standby, 4 - Hot Shutdown Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

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.

Basis:

This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or IMPEDE personnel from performing actions necessary to maintain normal plant operation, or to perform 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 rise in radiation levels and determine if another IC may be applicable.

For EAL #2 AA3.2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the elevated radiation levels. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased higher 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, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).

An emergency declaration is not warranted if any of the following conditions apply:

The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation increase rise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 43.

The increased higher 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.

to 0CAN031801 Page 69 of 255 Attachment 1 - Emergency Action Level Technical Bases Escalation of the emergency classification level would be via Recognition Category A, C or F ICs.

If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact beyond that already allowed by Technical Specifications at the time of the event.

The list of plant rooms or areas with entry-related mode applicability identified specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations) are not included. In addition, the list specifies the plant mode(s) during which entry would be required for each room or area (ref. 1).

EAL AA3.2 mode applicability has been limited to the mode limitations of Table 1[2]A-3 (Modes 3 and 4 only).

Reference(s):

1. Attachment 2 Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases
2. NEI 99-01 AA3 to 0CAN031801 Page 70 of 255 Attachment 1 - Emergency Action Level Technical Bases Category C - Cold Shutdown / Refueling System Malfunction EAL Group: Cold Conditions (RCS temperature 200°F); EALs in this category are applicable only in one or more cold operating modes.

Category C EALs are directly associated with cold shutdown or refueling system safety functions. Given the variability of plant configurations (e.g., systems out-of-service for maintenance, containment open, reduced AC power redundancy, time since shutdown) during these periods, the consequences of any given initiating event can vary greatly. For example, a loss of decay heat removal capability that occurs at the end of an extended outage has less significance than a similar loss occurring during the first week after shutdown. Compounding these events is the likelihood that instrumentation necessary for assessment may also be inoperable. The cold shutdown and refueling system malfunction EALs are based on performance capability to the extent possible with consideration given to RCS integrity, CONTAINMENT CLOSURE, and fuel clad integrity for the applicable operating modes (5 - Cold Shutdown, 6 - Refueling, DEF - Defueled).

The events of this category pertain to the following subcategories:

1. RCS Level RCS water level is directly related to the status of adequate core cooling and, therefore, fuel clad integrity.
2. Loss of Vital AC Power Loss of vital plant electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite power sources for 4.16 KV vital buses.
3. RCS Temperature Uncontrolled or inadvertent temperature or pressure rises are indicative of a potential loss of safety functions.
4. Loss of Vital DC Power Loss of emergency plant electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of power to or degraded voltage on the 125V DC vital buses.
5. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.
6. Hazardous Event Affecting Safety Systems Certain hazardous natural and technological events may result in VISIBLE DAMAGE to or degraded performance of safety systems warranting classification.

to 0CAN031801 Page 71 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory EAL:

CU1.1 Unusual Event UNPLANNED loss of reactor coolant results in RCS water level less than a required lower limit for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

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.

Basis:

This IC EAL addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor (reactor vessel/RCS

[PWR] or RPV [BWR]) level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.

Refueling evolutions that decreaselower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level decreasinglowering below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.

This EAL #1 recognizes that the minimum required (reactor vessel/RCS [PWR] or RPV [BWR])

level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.

to 0CAN031801 Page 72 of 255 Attachment 1 - Emergency Action Level Technical Bases The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.

EAL #2 addresses a condition where all means to determine (reactor vessel/RCS [PWR] or RPV [BWR]) level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.

Reference(s):

1. OP-1015.002 Decay Heat Removal and LTOP System
2. OP-1015.008 Unit 2 SDC Control
3. NEI 99-01 CU1 to 0CAN031801 Page 73 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory EAL:

CU1.2 Unusual Event RCS level cannot be monitored AND EITHER UNPLANNED rise in any Table 1[2]C-1 sump/tank level due to loss of RCS inventory Visual observation of UNISOLABLE RCS leakage Table 1C-1 Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank Table 2C-1 Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)

Holdup Tank Aux. Building Sump Quench Tank Mode Applicability:

5 - Cold Shutdown, 6 - Refueling to 0CAN031801 Page 74 of 255 Attachment 1 - Emergency Action Level Technical Bases Definition(s):

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.

Basis:

This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor (reactor vessel/RCS [PWR]

or RPV [BWR]) level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.

Refueling evolutions that decrease lower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level decreasing lowering below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.

EAL #1 recognizes that the minimum required (reactor vessel/RCS [PWR] or RPV [BWR]) level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.

The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.

This EAL #2 addresses a condition where all means to determine (reactor vessel/RCS [PWR] or RPV [BWR]) level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels (Table C-1). Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.

Reference(s):

1. OP-1203.039 Excess RCS Leakage
2. OP-2203.016 Excess RCS Leakage
3. NEI 99-01 CU1 to 0CAN031801 Page 75 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Significant Loss of RCS inventory EAL:

CA1.1 Alert Loss of RCS inventory as indicated by EITHER:

RVLMS Levels 1 through 8 [1 through 5] indicate DRY Reactor vessel level 368.5 ft. (LT-1195/LT-1196) [0 in. (L4791/L4792)] (bottom of hot leg)

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

None Basis:

This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.

For this EAL #1, a lowering of RPV water level below (site-specific level) ft the specified level indicates that operator actions have not been successful in restoring and maintaining RCS (reactor vessel/RCS [PWR] or RPV [BWR]) water level. The heat-up rate of the coolant will increase rise as the available water inventory is reduced. A continuing decrease drop in water level will lead to core uncovery.

Although related, this EAL #1 is concerned with the loss of RPV inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Decay Heat Removal suction point). An increase rise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA3.

For EAL #2, the inability to monitor (reactor vessel/RCS [PWR] or RPV [BWR]) level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).

to 0CAN031801 Page 76 of 255 Attachment 1 - Emergency Action Level Technical Bases The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS1 If RCS the (reactor vessel/RCS [PWR] or RPV [BWR]) inventory water level continues to lower, then escalation to Site Area Emergency would be via IC CS1.

The bottom of the RCS hot leg penetration into the reactor vessel is approximately RLVMS Level 8 (Unit 1) or RVLMS Level 5 (Unit 2). However, RVLMS may not be available in the cold shutdown modes. Redundant means of level indication is provided in these modes and included in this EAL. The bottom of the RCS hot leg penetration into the reactor vessel is 368 ft., 0 in. (Unit 1) or 369 ft., 1.5 in. (Unit 2). Below this level, reactor vessel level indication may be lost and loss of suction to decay heat removal systems will occur (ref. 1, 2, 3). Where redundant means of level indication cannot read below this level, the lowest indication that can be read on scale is used for this EAL. The inability to restore and maintain level after reaching this setpoint would be indicative of a failure of the RCS barrier.

Reference(s):

1. OP-1105.008 Inadequate Core Cooling Monitor and Display
2. OP-2105.003 Reactor Vessel Level Monitoring System Operations
3. Calculation No. 90-E-0116-01 ANO-2 EOP Setpoint Basis Document, Setpoints R.3 and R.9
4. NEI 99-01 CA1 to 0CAN031801 Page 77 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Significant Loss of RCS inventory EAL:

CA1.2 Alert RCS level cannot be monitored for 15 min. (Note 1)

AND EITHER UNPLANNED rise in any Table 1[2]C-1 Sump / Tank level due to a loss of RCS inventory Visual observation of UNISOLABLE RCS leakage Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1C-1 Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank Table 2C-1 Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)

Holdup Tank Aux. Building Sump Quench Tank to 0CAN031801 Page 78 of 255 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

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.

Basis:

This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.

For EAL #1, a lowering of water level below (site-specific level) indicates that operator actions have not been successful in restoring and maintaining (reactor vessel/RCS [PWR] or RPV

[BWR]) water level. The heat-up rate of the coolant will increase as the available water inventory is reduced. A continuing decrease in water level will lead to core uncovery.

Although related, EAL #1 is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). An increase in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA3.

For this EAL #2, the inability to monitor RCS (reactor vessel/RCS [PWR] or RPV [BWR]) level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).

The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS1.

If the (reactor vessel/RCS [PWR] or RPV [BWR]) inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS1.

Reference(s):

1. OP-1203.039 Excess RCS Leakage
2. OP-2203.016 Excess RCS Leakage
3. NEI 99-01 CA1 to 0CAN031801 Page 79 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability EAL:

CS1.1 Site Area Emergency CONTAINMENT CLOSURE not established AND RVLMS Levels 1 through 9 [1 through 6] indicate DRY Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

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.

Basis:

This IC addresses a significant and prolonged loss of (reactor vessel/RCS [PWR] or RPV

[BWR]) inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.

The difference in the specified RCS/reactor vessel levels of EALs 1.b and 2.b reflect the fact to 0CAN031801 Page 80 of 255 Attachment 1 - Emergency Action Level Technical Bases that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.

In EAL 3.a, the 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor (reactor vessel/RCS [PWR] or RPV [BWR]) level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).

Thisese EALs addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Escalation of the emergency classification level would be via IC CG1 or AG1.

Reference(s):

1. OP-1105.008 Inadequate Core Cooling Monitor and Display
2. OP-2105.003 Reactor Vessel Level Monitoring System Operations
3. NEI 99-01 CS1 to 0CAN031801 Page 81 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability EAL:

CS1.2 Site Area Emergency

[RVLMS Levels 1 through 7 indicate DRY OR]

RCS level cannot be monitored for 30 min. (Note 1)

AND Core uncovery is indicated by any of the following:

UNPLANNED rise in any Table 1[2]C-1 sump/tank level of sufficient magnitude to indicate core uncovery Containment high range radiation monitor RE-8060/8061 [2RE-8925-1/8925-2] reading

> 10 R/hr Erratic Source Range Monitor indication Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1C-1 Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank to 0CAN031801 Page 82 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2C-1 Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)

Holdup Tank Aux. Building Sump Quench Tank Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

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.

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.

Basis:

When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.

Level 7 DRY on this system is an indication of core uncovery.

This IC addresses a significant and prolonged loss of (reactor vessel/RCS RCS [PWR] or RPV

[BWR]) inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

to 0CAN031801 Page 83 of 255 Attachment 1 - Emergency Action Level Technical Bases Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.

The difference in the specified RCS/reactor vessel levels of EALs 1.b and 2.b CS1.1 and CS1.2 reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.

In EAL 3.a, Tthe 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor (reactor vessel/RCS [PWR] or RPV [BWR]) level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).

These This EALs addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Containment High Range Radiation Monitors RE-8060/8061 [2RE-8925-1/8925-2] are the site-specific radiation monitors that would be indicative of possible core uncovery in the Refueling mode. The dose rate due to core shine when the top of the core becomes uncovered should result in dose rates > 10 R/hr.

Escalation of the emergency classification level would be via IC CG1 or AG1.

Reference(s):

1. OP-1203.039 Excess RCS Leakage
2. OP-2203.016 Excess RCS Leakage
3. OP-2105.003 Reactor Vessel Level Monitoring System Operations
4. 1SAR Table 7-11
5. 2SAR 12.1.4.2
6. NEI 99-01 CS1 to 0CAN031801 Page 84 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL:

CG1.1 General Emergency - UNIT 2 ONLY RVLMS Levels 1 through 7 indicate DRY AND Any Containment Challenge indication, Table 2C-2 Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required.

Table 1[2]C-2 Containment Challenge Indications CONTAINMENT CLOSURE not established (Note 6)

Containment hydrogen concentration > 3%

UNPLANNED rise in containment pressure Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

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.

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.

to 0CAN031801 Page 85 of 255 Attachment 1 - Emergency Action Level Technical Bases Basis:

When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.

Level 7 DRY on this system is an indication of core uncovery.

This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.

In EAL 2.b, tThe 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor (reactor vessel/RCS [PWR] or RPV [BWR]) level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).

to 0CAN031801 Page 86 of 255 Attachment 1 - Emergency Action Level Technical Bases This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Reference(s):

1. OP-1203.039 Excess RCS Leakage
2. OP-2203.016 Excess RCS Leakage
3. OP-2105.003 Reactor Vessel Level Monitoring System Operations
4. 1SAR Table 7-11
5. 2SAR 12.1.4.2
6. Unit 1 SAMG Figure III-1B
7. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart
8. NEI 99-01 CG1 to 0CAN031801 Page 87 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL:

CG1.2 General Emergency RCS level cannot be monitored for 30 min. (Note 1)

AND Core uncovery is indicated by any of the following:

UNPLANNED rise in any Table 1[2]C-1 sump/tank level of sufficient magnitude to indicate core uncovery Containment High Range Radiation Monitor RE-8060/8061 [2RE-8925-1/8925-2]

reading > 10 R/hr Erratic Source Range Monitor indication AND Any Containment Challenge indication, Table 1[2]C-2 Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required.

Table 1C-1 Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank to 0CAN031801 Page 88 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2C-1 Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)

Holdup Tank Aux. Building Sump Quench Tank Table 1[2]C-2 Containment Challenge Indications CONTAINMENT CLOSURE not established (Note 6)

Containment hydrogen concentration > 3%

UNPLANNED rise in containment pressure Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

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.

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.

to 0CAN031801 Page 89 of 255 Attachment 1 - Emergency Action Level Technical Bases Basis:

When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.

Level 7 DRY on this system is an indication of core uncovery.

This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.

In EAL 2.b, tThe 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor (reactor vessel/RCS [PWR] or RPV [BWR]) level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).

to 0CAN031801 Page 90 of 255 Attachment 1 - Emergency Action Level Technical Bases Containment High Range Radiation Monitor RE-8060/8061 [2RE-8925-1/8925-2] are the site-specific radiation monitors that would be indicative of possible core uncovery in the Refueling mode. The dose rate due to core shine when the top of the core becomes uncovered should result in dose rates > 10 R/hr.

This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Reference(s):

1. OP-1203.039 Excess RCS Leakage
2. OP-2203.016 Excess RCS Leakage
3. OP-2105.003 Reactor Vessel Level Monitoring System Operations
4. 1SAR Table 7-11
5. 2SAR 12.1.4.2
6. Unit 1 SAMG Figure III-1B
7. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart
8. NEI 99-01 CG1 to 0CAN031801 Page 91 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 2 - Loss of Vital AC Power Initiating Condition: Loss of all but one AC power source to vital buses for 15 minutes or longer EAL:

CU2.1 Unusual Event AC power capability, Table 1[2]C-3, to vital 4.16 KV buses A3 [2A3] and A4 [2A4] reduced to a single power source for 15 min. (Note 1)

AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1C-3 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite DG1 DG2 AAC Gen to 0CAN031801 Page 92 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2C-3 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)

Onsite 2DG1 2DG2 AAC Gen Mode Applicability:

5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):

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 (as defined in 10 CFR 50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

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

When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the increased greater time available to restore another power source to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.

to 0CAN031801 Page 93 of 255 Attachment 1 - Emergency Action Level Technical Bases An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to a vital bus. Some examples of this condition are presented below.

A loss of all offsite power with a concurrent failure of all but one emergency vital power source (e.g., an onsite diesel generator).

A loss of all offsite power and loss of all emergency vital power sources (e.g., onsite diesel generators) with a single train of emergency vital buses being back-fed from the unit main generator.

A loss of emergency vital power sources (e.g., onsite diesel generators) with a single train of emergency vital buses being back-fed from an offsite power source.

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

The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA2.

This EAL is the cold condition equivalent of the hot condition EAL SA1.1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram
2. OP-1202.007 Degraded Power
3. OP-1202.008 Blackout
4. OP-2104.037 Alternate AC Diesel Generator Operations
5. 2SAR Figure 8.3-1 Station Single Line Diagram
6. OP-2202.007 Loss of Off-Site Power
7. OP-2202.008 Station Blackout
8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
9. NEI 99-01 CU2 to 0CAN031801 Page 94 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 2 - Loss of Vital AC Power Initiating Condition: Loss of all offsite and all onsite AC power to vital buses for 15 minutes or longer EAL:

CA2.1 Alert Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3 [2A3] and A4 [2A4] for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):

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 (as defined in 10 CFR 50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Although the AAC may be considered available, it will not prevent declaration of this EAL unless it is powering a vital bus within the 15-minute time period of the EAL.

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.

Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in to 0CAN031801 Page 95 of 255 Attachment 1 - Emergency Action Level Technical Bases accordance with abnormal or emergency operating procedures, or beyond design basis accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems.

When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased greater time available to restore an emergency vital bus to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.

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

Escalation of the emergency classification level would be via IC CS1 or AS1.

This EAL is the cold condition equivalent of the hot condition EAL SS1.1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram
2. OP-1202.007 Degraded Power
3. OP-1202.008 Blackout
4. OP-2104.037 Alternate AC Diesel Generator Operations
5. 2SAR Figure 8.3-1 Station Single Line Diagram
6. OP-2202.007 Loss of Off-Site Power
7. OP-2202.008 Station Blackout
8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
9. NEI 99-01 CU2 to 0CAN031801 Page 96 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: UNPLANNED rise in RCS temperature EAL:

CU3.1 Unusual Event UNPLANNED rise in RCS temperature to > 200°F due to loss of decay heat removal capability Mode Applicability:

5 - Cold Shutdown, 6 - Refueling° Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

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.

Basis:

This IC addresses an UNPLANNED increase rise in RCS temperature above the Technical Specification cold shutdown temperature limit or the inability to determine RCS temperature and level,and represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to IC EAL CA3.1.

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

EAL #1This EALThis EAL involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

to 0CAN031801 Page 97 of 255 Attachment 1 - Emergency Action Level Technical Bases During an outage, the level in the reactor vessel will normally be maintained at or above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at loweredreduced inventory may result in a rapid increase rise in reactor coolant temperature depending on the time after shutdown.

EAL #2 reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

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

Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria.

Reference(s):

1. Unit 1 and Unit 2 Technical Specifications Table 1.1-1
2. NEI 99-01 CU3 to 0CAN031801 Page 98 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: UNPLANNED rise in RCS temperature EAL:

CU3.2 Unusual Event Loss of all RCS temperature and RCS level indication for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

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.

Basis:

This IC EALEAL addresses an UNPLANNED increase in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level, andand represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to IC EAL CA3.1.

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

EAL #1 involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be to 0CAN031801 Page 99 of 255 Attachment 1 - Emergency Action Level Technical Bases maintained below the cold shutdown temperature limit specified in Technical Specifications.

During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

During an outage, the level in the reactor vessel will normally be maintained above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at reduced inventory may result in a rapid increase in reactor coolant temperature depending on the time after shutdown.

EAL #2This EAL reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

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

Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria.

Reference(s):

1. NEI 99-01 CU3 to 0CAN031801 Page 100 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: Inability to maintain plant in cold shutdown EAL:

CA3.1 Alert UNPLANNED rise in RCS temperature to > 200°F for > Table 1[2]C-4 duration (Note 1)

OR UNPLANNED RCS pressure rise > 10 psig due to a loss of RCS cooling (this EAL does not apply during water-solid plant conditions)

Note 1: 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 is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1[2]C-4 RCS Heat-up Duration Thresholds CONTAINMENT RCS Status Heat-up Duration CLOSURE Status Intact (but not lowered inventory) N/A 60 min.*

Not intact established 20 min.*

OR lowered inventory not established 0 min.

  • If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

to 0CAN031801 Page 101 of 255 Attachment 1 - Emergency Action Level Technical Bases As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

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.

Basis:

In the absence of reliable RCS temperature indication caused by the loss of decay heat removal capability, classification should be based on the RCS pressure rise criteria when the RCS is intact in Mode 5 or based on time to boil data when in Mode 6 or the RCS is not intact in Mode 5.

This IC EAL addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant.

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

The RCS Heat-up Duration Thresholds table addresses an increasea rise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact, or RCS inventory is reduced (e.g., lowered inventory operationmid-loop operation in PWRs). The 20-minute criterion was included to allow time for operator action to address the temperature increaserise.

The RCS Heat-up Duration Thresholds table also addresses an increasea rise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release.

The 60-minute time frame should allow sufficient time to address the temperature increase rise without a substantial degradation in plant safety.

Finally, in the case where there is an increase rise in RCS temperature, the RCS is not intact or is at loweredreduced inventory [PWR], and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) the evaporated reactor coolant may be released directly into the containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel.

EAL #2The RCS pressure rise threshold provides a pressure-based indication of RCS heat-up in the absence of RCS temperature monitoring capability.

Escalation of the emergency classification level would be via IC CS1 or AS1.

Reference(s):

1. Unit 1 and Unit 2 Technical Specifications Table 1.1-1
2. NEI 99-01 CA3 to 0CAN031801 Page 102 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 4 - Loss of Vital DC Power Initiating Condition: Loss of Vital DC power for 15 minutes or longer EAL:

CU4.1 Unusual Event Indicated voltage is < 105 VDC on vital 125 VDC buses for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC.

This IC addresses a loss of vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions increase raise the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant.

to 0CAN031801 Page 103 of 255 Attachment 1 - Emergency Action Level Technical Bases As used in this EAL, required means the vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment. For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification.

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

Depending upon the event, escalation of the emergency classification level would be via IC CA1 or CA3, or an IC in Recognition Category A.

This EAL is the cold condition equivalent of the hot condition EAL SS2.1.

Reference(s):

1. 1SAR 8.3.2.1.1 Batteries
2. 2SAR 8.3.2.1.1 Batteries
3. NEI 99-01 CU4 to 0CAN031801 Page 104 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 5 - Loss of Communications Initiating Condition: Loss of all onsite or offsite communications capabilities EAL:

CU5.1 Unusual Event Loss of all Table 1[2]C-5 onsite communication methods OR Loss of all Table 1[2]C-5 State and local agency communication methods OR Loss of all Table 1[2]C-5 NRC communication methods Table 1[2]C-5 Communication Methods System Onsite ORO NRC Station radio system X ANO plant phone system X Gaitronics X Telephone Systems:

Commercial Microwave X X Satellite VOIP INFORM Notification System X Emergency Notification System (ENS) X Mode Applicability:

5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):

None to 0CAN031801 Page 105 of 255 Attachment 1 - Emergency Action Level Technical Bases Basis:

This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to State and local agenciesOROs and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

EAL #1The first EAL condition addresses a total loss of the communications methods used in support of routine plant operations.

EAL #2The second EAL condition addresses a total loss of the communications methods used to notify all State and local agenciesOROs of an emergency declaration. The State and local agenciesOROs referred to here are the Arkansas Department of Health, Arkansas Department of Emergency Management, Pope, Yell, Johnson, and Logan County offsite agencies (see Developer Notes).

EAL #3The third EAL addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

This EAL is the cold condition equivalent of the hot condition EAL SU7.1.

Reference(s):

1. OP-1903.062 Communications System Operating Procedure
2. NEI 99-01 CU5 to 0CAN031801 Page 106 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 6 - Hazardous Event Affecting Safety Systems Initiating Condition: Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode EAL:

CA6.1 Alert The occurrence of any Table 1[2]C-6 hazardous event AND Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode AND EITHER:

Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)

Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted.

Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

Table 1[2]C-6 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 to 0CAN031801 Page 107 of 255 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

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 require a post-event inspection to determine if the attributes of an explosion are present.

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.

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

VISIBLE DAMAGE - Damage to a SAFETY SYSTEM train 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 SAFETY SYSTEM train.

Basis:

This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS needed for the current operating mode. In order to provide the appropriate context for consideration of an ALERT classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues. Note that this second SAFETY SYSTEM to 0CAN031801 Page 108 of 255 Attachment 1 - Emergency Action Level Technical Bases train is from the same SAFETY SYSTEM that has indications of degraded performance; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events.

Indications of degraded performance addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

VISIBLE DAMAGE addresses damage to a SAFETY SYSTEM train that is not in service/operation and that potentially could cause performance issues. 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.

This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, needed 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.

EAL 1.b.1 addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

EAL 1.b.2 addresses damage to a SAFETY SYSTEM component that is not in service/operation or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level would be via IC CS1 or AS1.

This EAL is the cold condition equivalent of the hot condition EAL SA9.1.

Reference(s):

1. EP FAQ 2016-002
2. NEI 99-01 CA6 to 0CAN031801 Page 109 of 255 Attachment 1 - Emergency Action Level Technical Bases Category E - Independent Spent Fuel Storage Installation (ISFSI)

EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

An independent spent fuel storage installation (ISFSI) is a complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. A significant amount of the radioactive material contained within a canister must escape its packaging and enter the biosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel.

An Unusual Event is declared on the basis of the occurrence of an event of sufficient magnitude that a loaded cask CONFINEMENT BOUNDARY is damaged or violated.

The ANO ISFSI is located wholly within the plant PROTECTED AREA. Therefore any security event related to the ISFSI is classified under Category H1 security event related EALs.

to 0CAN031801 Page 110 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: E - ISFSI Subcategory: Confinement Boundary Initiating Condition: Damage to a loaded cask CONFINEMENT BOUNDARY EAL:

EU1.1 Unusual Event Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading on the surface of a loaded spent fuel cask (VSC-24 VCC or HI-STORM overpack) > any Table 1[2]-E-1 value Table 1[2]E-1 ISFSI Dose Rates VSC-24 VCC HI-STORM 200 mrem/hr on the sides 60 mrem/hr (gamma + neutron) on the top or outlet vent 400 mrem/hr on the top 600 mrem/hr (gamma + neutron on 700 mrem/hr at the air inlet the side of the side of the overpack 200 mrem/hr at the air outlet (excluding inlet and outlet ducts)

Mode Applicability:

All Definition(s):

CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) - A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

Basis:

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the to 0CAN031801 Page 111 of 255 Attachment 1 - Emergency Action Level Technical Bases creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of damage is determined by radiological survey. The specified EAL threshold values correspond to 2 times the cask technical specification values (ref. 1, 2). The technical specification (licensing bases document) multiple of 2 times, which is also used in Recognition Category A IC AU1, is used here to distinguish between non-emergency and emergency conditions. The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the on-contact dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.

Security-related events for ISFSIs are covered under ICs HU1 and HA1.

Reference(s):

1. Certificate of Compliance Appendix A Technical Specifications for the HI-STORM 100 Cask System Section 5.7.4
2. VSC-24 Storage Cask Final Safety Analysis Report Section 1.2.4 Maximum External Surface Dose Rate
3. NEI 99-01 E-HU1 to 0CAN031801 Page 112 of 255 Attachment 1 - Emergency Action Level Technical Bases Category F - Fission Product Barrier Degradation EAL Group: Hot Conditions (RCS temperature > 200°F); EALs in this category are applicable only in one or more hot operating modes.

EALs in this category represent threats to the defense in depth design concept that precludes the release of highly radioactive fission products to the environment. This concept relies on multiple physical barriers any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment. The primary fission product barriers are:

A. Fuel Clad Barrier (FCB): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.

B. Reactor Coolant System Barrier (RCB): The RCS Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.

C. Containment Barrier (CNB): The Containment Barrier includes the Reactor Building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the Reactor Building up to and including the outermost secondary side isolation valve.

Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency.

The EALs in this category require evaluation of the loss and potential loss thresholds listed in the fission product barrier matrix of Table F-1. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. Loss means the barrier no longer assures containment of radioactive materials. Potential Loss means integrity of the barrier is threatened and could be lost if conditions continue to degrade. The number of barriers that are lost or potentially lost and the following criteria determine the appropriate emergency classification level:

Alert:

Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency:

Loss or potential loss of any two barriers General Emergency:

Loss of any two barriers and loss or potential loss of third barrier to 0CAN031801 Page 113 of 255 Attachment 1 - Emergency Action Level Technical Bases The logic used for emergency classification based on fission product barrier monitoring should reflect the following considerations:

The Fuel Clad Barrier and the RCS Barrier are weighted more heavily than the Containment Barrier.

Unusual Event ICs associated with RCS and Fuel Clad Barriers are addressed under System Malfunction ICs.

For accident conditions involving a radiological release, evaluation of the fission product barrier thresholds will need to be performed in conjunction with dose assessments to ensure correct and timely escalation of the emergency classification. For example, an evaluation of the fission product barrier thresholds may result in a Site Area Emergency classification while a dose assessment may indicate that an EAL for General Emergency IC AG1 has been exceeded.

The fission product barrier thresholds specified within a scheme reflect plant-specific ANO design and operating characteristics.

As used in this category, the term RCS leakage encompasses not just those types defined in Technical Specifications but also includes the loss of RCS mass to any location - inside the containment, an interfacing system, or outside of the containment.

The release of liquid or steam mass from the RCS due to the as-designed/expected operation of a relief valve is not considered to be RCS leakage.

At the Site Area Emergency level, EAL users should maintain cognizance of how far present conditions are from meeting a threshold that would require a General Emergency declaration. For example, if the Fuel Clad and RCS fission product barriers were both lost, then there should be frequent assessments of containment radioactive inventory and integrity. Alternatively, if both the Fuel Clad and RCS fission product barriers were potentially lost, the Emergency Director would have more assurance that there was no immediate need to escalate to a General Emergency.

to 0CAN031801 Page 114 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: F - Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Any loss or any potential loss of either Fuel Clad or RCS EAL:

FA1.1 Alert Any loss or any potential loss of either Fuel Clad or RCS barrier (Table 1[2]F-1)

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.

At the Alert classification level, Fuel Clad and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Clad 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 Clad or RCS barrier results in declaration of a Site Area Emergency under EAL FS1.1.

Reference(s):

1. NEI 99-01 FA1 to 0CAN031801 Page 115 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: F - Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Loss or potential loss of any two barriers EAL:

FS1.1 Site Area Emergency Loss or potential loss of any two barriers (Table 1[2]F-1)

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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.

Basis:

Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.

At the Site Area Emergency classification level, each barrier is weighted equally. A Site Area Emergency is therefore appropriate for any combination of the following conditions:

One barrier loss and a second barrier loss (i.e., loss - loss)

One barrier loss and a second barrier potential loss (i.e., loss - potential loss)

One barrier potential loss and a second barrier potential loss (i.e., potential loss -

potential loss)

At the Site Area Emergency classification level, the ability to dynamically assess the proximity of present conditions with respect to the threshold for a General Emergency is important. For example, the existence of Fuel Clad and RCS Barrier loss thresholds in addition to offsite dose assessments would require continual assessments of radioactive inventory and Containment integrity in anticipation of reaching a General Emergency classification. Alternatively, if both Fuel Clad and RCS potential loss thresholds existed, the Emergency Director would have greater assurance that escalation to a General Emergency is less IMMINENT.

Reference(s):

1. NEI 99-01 FS1 to 0CAN031801 Page 116 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: F - Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Loss of any two barriers and loss or potential loss of third barrier EAL:

FG1.1 General Emergency Loss of any two barriers AND Loss or potential loss of the third barrier (Table 1[2]F-1)

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.

At the General Emergency classification level each barrier is weighted equally. A General Emergency is therefore appropriate for any combination of the following conditions:

Loss of Fuel Clad, RCS and Containment Barriers Loss of Fuel Clad and RCS Barriers with potential loss of Containment Barrier Loss of RCS and Containment Barriers with potential loss of Fuel Clad Barrier Loss of Fuel Clad and Containment Barriers with potential loss of RCS Barrier Reference(s):

1. NEI 99-01 FG1 to 0CAN031801 Page 117 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1 Fission Product Barrier Threshold Matrix & Bases Table 1[2]F-1 lists the threshold conditions that define the Loss and Potential Loss of the three fission product barriers (Fuel Clad, Reactor Coolant System, and Containment). The table is structured so that each of the three barriers occupies adjacent columns. Each fission product barrier column is further divided into two columns; one for Loss thresholds and one for Potential Loss thresholds.

The first column of the table (to the left of the Fuel Clad Loss column) lists the categories (types) of fission product barrier thresholds. The fission product barrier categories are:

A. RCS or S/G Tube Leakage B. Inadequate Heat removal C. Containment Radiation / RCS Activity D. Containment Integrity or Bypass E. Emergency Director Judgment Each category occupies a row in Table 1[2]F-1 thus forming a matrix defined by the categories.

The intersection of each row with each Loss/Potential Loss column forms a cell in which one or more fission product barrier thresholds appear. If NEI 99-01 does not define a threshold for a barrier Loss/Potential Loss, the word None is entered in the cell.

Thresholds are assigned sequential numbers within each barrier column beginning with number one (ex., FCB1, FCB2FCB9).

If a cell in Table 1[2]F-1 contains more than one numbered threshold, each of the numbered thresholds, if exceeded, signifies a Loss or Potential Loss of the barrier. It is not necessary to exceed all of the thresholds in a category before declaring a barrier Loss/Potential Loss.

Subdivision of Table 1[2]F-1 by category facilitates association of plant conditions to the applicable fission product barrier Loss and Potential Loss thresholds. This structure promotes a systematic approach to assessing the classification status of the fission product barriers.

When equipped with knowledge of plant conditions related to the fission product barriers, the EAL-user first scans down the category column of Table 1[2]F-1, locates the likely category and then reads across the fission product barrier Loss and Potential Loss thresholds in that category to determine if a threshold has been exceeded. If a threshold has not been exceeded, the EAL-user proceeds to the next likely category and continues review of the thresholds in the new category.

If the EAL-user determines that any threshold has been exceeded, by definition, the barrier is lost or potentially lost - even if multiple thresholds in the same barrier column are exceeded, only that one barrier is lost or potentially lost. The EAL-user must examine each of the three fission product barriers to determine if other barrier thresholds in the category are lost or potentially lost. For example, if containment radiation is sufficiently high, a Loss of the Fuel to 0CAN031801 Page 118 of 255 Attachment 1 - Emergency Action Level Technical Bases Clad and RCS Barriers and a Potential Loss of the Containment Barrier can occur. Barrier Losses and Potential Losses are then applied to the algorithms given in EALs FG1.1, FS1.1, and FA1.1 to determine the appropriate emergency classification.

In the remainder of this Attachment, the Fuel Clad Barrier threshold bases appear first, followed by the RCS Barrier and finally the Containment Barrier threshold bases. In each barrier, the bases are given according category Loss followed by category Potential Loss beginning with Category A, then B,, E.

to 0CAN031801 Page 119 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1 Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FCB) Reactor Coolant System Barrier (RCB) Containment Barrier (CNB)

Category Loss Potential Loss Loss Potential Loss Loss Potential Loss RCB2 UNISOLABLE RCS leakage or S/G tube leakage > 50[44] gpm excluding normal reductions in RCS inventory (e.g.,

letdown, RCP seal leakoff)

RCB3 RCB1 Unit 1: PTS limits apply (RT14) CNB1 A An automatic or manual AND A S/G that is leaking >

FCB1 ESAS [ESFAS] actuation 50[44] gpm (excluding normal RCS or S/G required by EITHER: RCS pressure and temperature are left None RVLMS Levels 1 through 9 reductions in RCS inventory) or None of the NDTT/LTOP limit lines on EOP Tube [1 through 7] indicate DRY UNISOLABLE RCS Figure 3 (Note 12) that is RUPTURED is also Leakage leakage Unit 2: Uncontrolled RCS cooldown (50°F FAULTED outside of S/G tube RUPTURE containment step change which is below 500°F from NOT)

AND RCS pressure and temperature are to the left of line B (200 degrees MTS),

Standard Attachment 1, P-T Limits (Note 12)

FCB3 CETs > 700°F B FCB4 RCB4 CNB2 RCS heat removal cannot be established using CETs > 1200°F Inadequate FCB2 RCS heat removal cannot be established using steam None steam generators None AND Heat CETs > 1200°F generators AND Restoration procedures not effective Removal AND HPI [Once Through] cooling initiated within 15 min. (Note 1)

HPI [Once Through] cooling initiated FCB5 Containment High C Range Radiation RCB5 Monitor RE-8060/8061 CNB3 CTMT [2RE-8925-1/ 8925-2] Containment High Range None None None Containment High Range Radiation Radiation / > 750 [700] R/hr Radiation Monitor RE-Monitor RE-8060/8061 [2RE-8925-8060/8061 [2RE-8925-RCS FCB6 1/8925-2] > 40 [50] R/hr 1/8925-2] > 10,000 [12,000] R/hr Activity Coolant activity

> 300 Ci/gm dose equivalent I-131 to 0CAN031801 Page 120 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1 Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FCB) Reactor Coolant System Barrier (RCB) Containment Barrier (CNB)

Category Loss Potential Loss Loss Potential Loss Loss Potential Loss CNB4 Containment isolation is CNB6 required Containment pressure > 73.7 psia AND EITHER:

CNB7 Containment integrity D has been lost based on Containment hydrogen concentration Emergency Director > 3%

CTMT None None None None judgment CNB8 Integrity or UNISOLABLE pathway Containment pressure > 44.7 psia Bypass from Containment to the [23.3 psia] with < one full train of environment exists containment heat removal systems CNB5 (Note 9) operating per design for 15 min. (Note 1)

Indications of RCS leakage outside of Containment FCB7 E Any condition in the FCB8 RCB6 RCB7 CNB9 CNB10 Any condition in the opinion of Any condition in the opinion Any condition in the opinion of Any condition in the opinion of the Emergency opinion of the the Emergency Director that of the Emergency Director Any condition in the opinion of the Emergency the Emergency Director that Emergency Director that indicates Director Emergency Director Director that indicates potential loss of the RCS indicates potential loss of the that indicates loss of the RCS indicates loss of the potential loss of the Containment that indicates loss of barrier Judgment the Fuel Clad barrier Fuel Clad barrier barrier Containment barrier barrier to 0CAN031801 Page 121 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: A - RCS or S/G Tube Leakage Degradation Threat: Loss Threshold:

None to 0CAN031801 Page 122 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: A - RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

FCB1 RVLMS Levels 1 through 9 [1 through 7] indicate DRY Definition(s):

None Basis:

This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage.

There is no Fuel Clad Barrier Loss threshold associated with RCS or S/G Tube Leakage.

Reference(s):

1. ULD-1-SYS-24 Unit 1 Inadequate Core Cooling System
2. Calculation 84-EQ-0080-02 Loop Error Analysis for Reactor Vessel Level Monitoring System
3. ULD-2-SYS-24 Unit 2 Inadequate Core Cooling Monitoring System
4. Calculation 90-E-0116-01 Unit 2 EOP Setpoint Document, Setpoint R.3
5. NEI 99-01 RCS or SG Tube Leakage Potential Loss 1.A to 0CAN031801 Page 123 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: B - Inadequate Heat Removal Degradation Threat: Loss Threshold:

FCB2 CETs > 1200°F Definition(s):

None Basis:

This reading indicates temperatures within the core are sufficient to cause significant superheating of reactor coolant.

Reference(s):

1. NEI 99-01 Inadequate Heat Removal Loss 2.A to 0CAN031801 Page 124 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: B - Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

FCB3 CETs > 700°F Definition(s):

None Basis:

This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage.

Reference(s):

1. NEI 99-01 Inadequate Heat Removal Potential Loss 2.A to 0CAN031801 Page 125 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: B - Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

FCB4 RCS heat removal cannot be established using steam generators AND HPI [Once Through] cooling initiated Definition(s):

None Basis:

This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using this threshold is not warranted.

In combination with Potential Loss RCB4, meeting this threshold results in a Site Area Emergency.

Reference(s):

1. OP-1202.004 Overheating
2. OP-1202.013 Figure 4, Core Exit Thermocouple for Inadequate Core Cooling
3. OP-2202.006 Loss of Feedwater
4. OP-2202.009 Functional Recovery, Safety Function Status Check 5
5. NEI 99-01 Inadequate Heat Removal Potential Loss 2.B to 0CAN031801 Page 126 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: C - CTMT Radiation / RCS Activity Degradation Threat: Loss Threshold:

FCB5 Containment High Range Radiation Monitor RE-8060/8061 [2RE-8925-1/8925-2]

> 750 [700] R/hr Definition(s):

None Basis:

The containment radiation monitor reading (768[682] R/hr rounded to 750[700] R/hr for readability) corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals 300 µCi/gm dose equivalent I-131.

Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to 51.49[1.13]an approximate range of 2% to 3% 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 Loss threshold C.1RCB5 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 ECL to a Site Area Emergency.

There is no Potential Loss threshold associated with CTMT Radiation/RCS Activity

/Containment Radiation.

Basis Reference(s):

1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values
2. NEI 99-01 RCS Activity/Containment Radiation FC Loss 3.A to 0CAN031801 Page 127 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: C - CTMT Radiation / RCS Activity Degradation Threat: Loss Threshold:

FCB6 Coolant activity > 300 Ci/gm dose equivalent I-131 Definition(s):

None Basis:

This threshold indicates that RCS radioactivity concentration is greater than 300 µCi/gm dose equivalent I-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.

It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications.

There is no Potential Loss threshold associated with CTMT Radiation/RCS Activity

/Containment Radiation.

Reference(s):

1. NEI 99-01 RCS Activity/Containment Radiation Fuel Clad Loss 3.B to 0CAN031801 Page 128 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: C - CTMT Radiation / RCS Activity Degradation Threat: Potential Loss Threshold:

None to 0CAN031801 Page 129 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: D - CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

None to 0CAN031801 Page 130 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

None to 0CAN031801 Page 131 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: E - Emergency Director Judgment Degradation Threat: Loss Threshold:

FCB7 Any condition in the opinion of the Emergency Director that indicates loss of the Fuel Clad barrier Definition(s):

None Basis:

This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad barrier is lost.

Reference(s):

1. NEI 99-01 Emergency Director Judgment Fuel Clad Loss 6.A to 0CAN031801 Page 132 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: E - Emergency Director Judgment Degradation Threat: Potential Loss Threshold:

FCB8 Any condition in the opinion of the Emergency Director that indicates potential loss of the Fuel Clad barrier Definition(s):

None Basis:

This threshold addresses any other factors that are to 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.

Reference(s):

1. NEI 99-01 Emergency Director Judgment Potential Fuel Clad Loss 6.A to 0CAN031801 Page 133 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: A - RCS or S/G Tube Leakage Degradation Threat: Loss Threshold:

RCB1 An automatic or manual ESAS [ESFAS] actuation required by EITHER:

UNISOLABLE RCS leakage S/G tube RUPTURE Definition(s):

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.

RUPTURED - The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

Basis:

Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

This 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 Loss threshold 1.ACNB1 will also be met.

to 0CAN031801 Page 134 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1202.010 ESAS
2. OP-2202.003 Loss of Coolant Accident
3. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Loss 1.A to 0CAN031801 Page 135 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: A - RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

RCB2 UNISOLABLE RCS leakage or S/G tube leakage > 50[44] gpm excluding normal reductions in RCS inventory (e.g., letdown, RCP seal leakoff)

Definition(s):

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.

Basis:

Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

This 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 makeup [charging]

(makeup) pump, but an ECCS (SI)ESAS [ESFAS] actuation has not occurred. The threshold is met when letdown has been isolated and an operating procedure, or operating crew supervision, directs that a standby charging (makeup)makeup [charging] pump be placed in service to restore and maintain pressurizer level.

This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system.

The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold 1.ACNB1 will also be met.

to 0CAN031801 Page 136 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. 1SAR 9.1 Makeup and Purification System
2. 2SAR 9.3.4 Chemical and Volume Control System
3. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.A to 0CAN031801 Page 137 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: A - RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

RCB3 Unit 1:

PTS limits apply (RT14)

AND RCS pressure and temperature are left of the NDTT/LTOP limit lines, on EOP Figure 3 (Note 12)

Unit 2:

Uncontrolled RCS cooldown (50°F step change which is below 500°F from NOT)

AND RCS pressure and temperature are to the left of line B (200 degrees MTS), Standard Attachment 1, P-T Limits (Note 12)

Note 12: Once PTS limits are first invoked, if RCS temperature and pressure are not brought within the limits within 15 minutes, this threshold is met and an immediate declaration is warranted. This threshold is met immediately upon exceeding the limits after this initial 15 minute period until PTS limits no longer apply.

Definition(s):

None 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).

to 0CAN031801 Page 138 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1202.012 Repetitive Task 14 Control RCS Pressure
2. OP-1202.013 EOP Figures, Figure 3 RCS Pressure vs Temperature Limits
3. OP-1202.011 HPI Cooldown
4. Calculation No: 90-E-0116-01 ANO- EOP Setpoint Basis Document OP Setpoint P.2, RCS Pressure-Temperature
5. OP-2202.010 Standard Attachments, Attachment 1, P-T Limits
6. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.B to 0CAN031801 Page 139 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: B - Inadequate Heat Removal Degradation Threat: Loss Threshold:

None to 0CAN031801 Page 140 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: B - Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

RCB4 RCS heat removal cannot be established using steam generators AND HPI [Once Through] cooling initiated Definition(s):

None Basis:

This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using this threshold is not warranted.

In combination with Potential Loss FCB4, meeting this threshold results in a Site Area Emergency.

Meeting this threshold results in a Site Area Emergency because this threshold is identical to Fuel Clad Barrier Potential Loss threshold 2.BFCB4; 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 increaseraise RCS pressure to the point where mass will be lost from the system.

There is no RCS barrier Loss threshold associated with Inadequate Heat Removal.

Reference(s):

1. OP-1202.004 Overheating
2. OP-1202.013 Figure 4, Core Exit Thermocouple for Inadequate Core Cooling
3. OP-2202.006 Loss of Feedwater
4. OP-2202.009 Functional Recovery, Safety Function Status Check 5
5. NEI 99-01 Inadequate Heat Removal RCS Potential Loss 2.B to 0CAN031801 Page 141 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: C - CTMT Radiation/ RCS Activity Degradation Threat: Loss Threshold:

RCB5 Containment High Range Radiation Monitor RE-8060/8061 [2RE-8925-1/8925-2] > 40 [50] R/hr Definition(s):

None Basis:

NRC Information Notice 97-045, Supplement 1, identifies the potential for erratic indications from the high range radiation monitors (HRRMs) as a result of thermally induced currents (TIC) which may cause the HRRM to read falsely high (for approximately 15 minutes) on a rapid temperature rise, and fail low intermittently on a rapid temperature fall. Because of this phenomenon, any trends or alarms on the HRRMs should be validated by comparison to the containment low range/area radiation monitors and Air Monitoring Systems trends before actions are taken.

The containment radiation monitor reading (42.8[50.4] R/hr rounded to 40[50] R/hr for readability) 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 Loss threshold 3.AFCB5 since it indicates a loss of the RCS Barrier only.

There is no Potential Loss threshold associated with RCS Activity / ContainmentCTMT Radiation/RCS Activity.

Reference(s):

1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values
2. NEI 99-01 CMT Radiation / RCS Activity RCS Loss 3.A to 0CAN031801 Page 142 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: B - CTMT Radiation/ RCS Activity Degradation Threat: Potential Loss Threshold:

None to 0CAN031801 Page 143 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: D - CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

None to 0CAN031801 Page 144 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

None to 0CAN031801 Page 145 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: E - Emergency Director Judgment Degradation Threat: Loss Threshold:

RCB6 Any condition in the opinion of the Emergency Director that indicates loss of the RCS barrier Definition(s):

None Basis:

This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is lost.

Reference(s):

1. NEI 99-01 Emergency Director Judgment RCS Loss 6.A to 0CAN031801 Page 146 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: E - Emergency Director Judgment Degradation Threat: Potential Loss Threshold:

RCB7 Any condition in the opinion of the Emergency Director that indicates potential loss of the RCS barrier Definition(s):

None Basis:

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

Reference(s):

1. NEI 99-01 Emergency Director Judgment RCS Potential Loss 6.A to 0CAN031801 Page 147 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: A - RCS or S/G Tube Leakage Degradation Threat: Loss Threshold:

CNB1 A S/G that is leaking > 50[44] gpm (excluding normal reductions in RCS inventory) or that is RUPTURED S/G is also FAULTED outside of containment Definition(s):

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.

RUPTURED - The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).

Basis:

This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAULTED outside of containment. The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the thresholds for RCS Barrier Potential Loss 1.A RCB2 and Loss 1.ARCB1, 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 droppecreasing 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 SU4 for the fuel clad barrier (i.e., RCS activity values) and IC SU5 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 sustained release of radioactive to 0CAN031801 Page 148 of 255 Attachment 1 - Emergency Action Level Technical Bases 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 A ICs.

The emergency classification levelECLs 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?

P-to-S Leak Rate Yes No Less than or equal to 25 gpm No classification No classification Unusual Event per Unusual Event per Greater than 25 gpm SU4SU5.1 SU4SU5.1 Greater than 50[44] gpm (RCS Site Area Emergency per Alert per FA1.1 Barrier Potential Loss) FS1.1 Requires an automatic or manual Site Area Emergency per ESAS [ESFAS]ECCS (SIAS) Alert per FA1.1 FS1.1 actuation (RCS Barrier Loss)

There is no Potential Loss threshold associated with RCS or S/G Tube Leakage.

Reference(s):

1. NEI 99-01 RCS or SG Tube Leakage Containment Loss 1.A to 0CAN031801 Page 149 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: A - RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

None to 0CAN031801 Page 150 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: B - Inadequate Heat Removal Degradation Threat: Loss Threshold:

None to 0CAN031801 Page 151 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: B - Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

CNB2 CETs > 1200°F AND Restoration procedures not effective within 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Definition(s):

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.

Basis:

The restoration procedure is considered effective if core exit thermocouple readings are droppdecreasing and/or if reactor vessel level is risincreasing. 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.

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.

Severe accident analyses (e.g., NUREG-1150) 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.

Reference(s):

1. NEI 99-01 Inadequate Heat Removal Containment Potential Loss 2.A to 0CAN031801 Page 152 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: C - CTMT Radiation/RCS Activity Degradation Threat: Loss Threshold:

None to 0CAN031801 Page 153 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: C - CTMT Radiation/RCS Activity Degradation Threat: Potential Loss Threshold:

CNB3 Containment High Range Radiation Monitor RE-8060/8061 [2RE-8925-1/8925-2]

> 10,000 [12,000] R/hr Definition(s):

None Basis:

The containment radiation monitor reading (10,300[12,100] R/hr rounded to 10,000[12,000] R/hr for readability) 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 levelECL to a General Emergency.

There is no Loss threshold associated with RCS Activity/ContainmentCTMT Radiation/RCS Activity.

Reference(s):

1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values
2. NEI 99-01 CTMT Radiation / RCS Activity Containment Potential Loss 3.A to 0CAN031801 Page 154 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

CNB4 Containment isolation is required AND EITHER:

Containment integrity has been lost based on Emergency Director judgment UNISOLABLE pathway from Containment to the environment exists Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

Basis:

Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

The status of the containment barrier during an event involving steam generator tube leakage is assessed using Loss Threshold 1.ACNB1.

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 bulleted thresholds 4.A.1 and 4.A.2.

4.A.1First Threshold - 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.).

to 0CAN031801 Page 155 of 255 Attachment 1 - Emergency Action Level Technical Bases Refer to the middle piping run of Figure 9-F-41. 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 A ICs.

4.A.2Second Threshold - 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-41. In this simplified example, the inboard and outboard isolation valves remained open after a containment isolation was required (i.e.,

containment isolation was not successful). There is now an UNISOLABLE pathway from the containment to the environment.

The existence of a filter is not considered in the threshold assessment. Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.

Leakage between two interfacing liquid systems, by itself, does not meet this threshold.

Refer to the bottom piping run of Figure 9-F-41. 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 developed a leak that allowed steam/water to enter the Auxiliary Building, then second threshold 4.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 the first threshold 4.A.1 to be met as well.

to 0CAN031801 Page 156 of 255 Attachment 1 - Emergency Action Level Technical Bases Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable 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 an enclosed system.

These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A ICs.

Reference(s):

1. NEI 99-01 CTMT Integrity or Bypass Containment Loss 4.A to 0CAN031801 Page 157 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

CNB5 Indications of RCS leakage outside of Containment Definition(s):

None Basis:

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 Loss RCB1 and/or Potential Loss RCB2 threshold 1.A to be met.

The status of the containment barrier during an event involving steam generator tube leakage is assessed using Containment Loss Threshold CNB1.

Containment sump, temperature, pressure and/or radiation levels will riincrease if reactor coolant mass is leaking into the containment. If these parameters have not risenincreased, then the reactor coolant mass may be leaking outside of containment (i.e., a containment bypass sequence). RiIncreases 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 riincrease 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-41. In this simplified example, a leak has occurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause threshold CNB4 to be met as well.

Reference(s):

1. NEI 99-01 CTMT Integrity or Bypass Containment Loss 4.B to 0CAN031801 Page 158 of 255 Attachment 1 - Emergency Action Level Technical Bases Figure 1: Containment Integrity or Bypass Examples nd 2 Threshold - Airborne release from pathway Effluent Inside Auxiliary Monitor Reactor Building Building Damper Area Monitor Open valve Open valve Damper st Penetration 1 Threshold -

Airborne Airborne Monitor nd Open valve Open valve 2 Threshold -

st RCS leakage Interface 1 Threshold - Airborne outside AB leakage release from penetration Process Monitor Closed Cooling Open valve Open valve Pump RCP Seal Cooling to 0CAN031801 Page 159 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

CNB6 Containment pressure > 73.7 psia Definition(s):

None Basis:

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.

Reference(s):

1. 1SAR 1.4.43 Criterion 50 - Containment Design Basis
2. 2SAR Table 6.2-7 Principle Containment Design Parameters
3. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.A to 0CAN031801 Page 160 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

CNB7 Containment hydrogen concentration > 3%

Definition(s):

None Basis:

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a potential loss of the Containment Barrier.

Reference(s):

1. Unit 1 SAMG Figure III-1B
2. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart
3. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.B to 0CAN031801 Page 161 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

CNB8 Containment pressure > 44.7 psia [23.3 psia] with < one full train of containment heat removal systems (Note 9) operating per design for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 9: One full train of containment heat removal systems consists of one train of RB [Containment]

Spray and one train of RB [Containment] Cooling System.

Definition(s):

None Basis:

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.

Reference(s):

1. 1SAR 6.2 Reactor Building Spray System
2. 1SAR 6.3 Reactor Building Cooling System
3. OP-2202.003 Loss of Coolant Accident
4. OP-2202.010 Standard Attachments, Attachment 22
5. 2SAR 6.2.2 Containment Heat Removal Systems
6. 2SAR 7.3.1.1.11.2 Containment Spray System
7. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.C to 0CAN031801 Page 162 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: E - Emergency Director Judgment Degradation Threat: Loss Threshold:

CNB9 Any condition in the opinion of the Emergency Director that indicates loss of the Containment barrier Definition(s):

None Basis:

This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is lost.

Reference(s):

1. NEI 99-01 Emergency Director Judgment Containment Loss 6.A to 0CAN031801 Page 163 of 255 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: E - Emergency Director Judgment Degradation Threat: Potential Loss Threshold:

CNB10 Any condition in the opinion of the Emergency Director that indicates potential loss of the Containment barrier Definition(s):

None Basis:

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

Reference(s):

1. NEI 99-01 Emergency Director Judgment Containment Potential Loss 6.A to 0CAN031801 Page 164 of 255 Attachment 1 - Emergency Action Level Technical Bases Category H - Hazards and Other Conditions Affecting Plant Safety EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

Hazards are non-plant, system-related events that can directly or indirectly affect plant operation, reactor plant safety or personnel safety.

1. Security Unauthorized entry attempts into the PROTECTED AREA, bomb threats, sabotage attempts, and actual security compromises threatening loss of physical control of the plant.
2. Seismic Event Natural events such as earthquakes have potential to cause plant structure or equipment damage of sufficient magnitude to threaten personnel or plant safety.
3. Natural or Technological Hazard Other natural and non-naturally occurring events that can cause damage to plant facilities include tornados, FLOODING, hazardous material releases and events restricting site access warranting classification.
4. Fire FIRES can pose significant hazards to personnel and reactor safety. Appropriate for classification are FIRES within the plant PROTECTED AREA or which may affect operability of equipment needed for safe shutdown.
5. Hazardous Gas Toxic, corrosive, asphyxiant or flammable gas leaks can affect normal plant operations or preclude access to plant areas required to safely shutdown the plant.
6. Control Room Evacuation Events that are indicative of loss of Control Room habitability. If the Control Room must be evacuated, additional support for monitoring and controlling plant functions is necessary through the emergency response facilities.
7. Emergency Director Judgment The EALs defined in other categories specify the predetermined symptoms or events that are indicative of emergency or potential emergency conditions and thus warrant classification.

While these EALs have been developed to address the full spectrum of possible emergency conditions which may warrant classification and subsequent implementation of the Emergency Plan, a provision for classification of emergencies based on operator/management experience and judgment is still necessary. The EALs of this category provide the Emergency Director the latitude to classify emergency conditions consistent with the established classification criteria based upon Emergency Director judgment.

to 0CAN031801 Page 165 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards Subcategory: 1 - Security Initiating Condition: Confirmed SECURITY CONDITION or threat EAL:

HU1.1 Unusual Event A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by ANO Security Shift Supervision OR Notification of a credible security threat directed at the site OR A validated notification from the NRC providing information of an aircraft threat Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.

Access to this area is controlled by the SOCA Personnel Access Control Point.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

to 0CAN031801 Page 166 of 255 Attachment 1 - Emergency Action Level Technical Bases PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

SECURITY CONDITION - Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A security condition does not involve a HOSTILE ACTION.

Basis:

This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, and HS1 and HG1.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and Offsite Response Organizations.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

The first threshold EAL #1 references the Security Shift Supervision (site-specific security shift supervision)because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR 2.39 information.

The second threshold EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with OP-1203.048 Security Event (site-specific procedure).

to 0CAN031801 Page 167 of 255 Attachment 1 - Emergency Action Level Technical Bases The third threshold EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with 11-S-82-1 Security Contingency Events (ref. 2)(site-specific procedure).

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).

Escalation of the emergency classification level would be via IC HA1.

Reference(s):

1. ANO Security Plan
2. OP-1203.048 Security Event
3. NEI 99-01 HU1 to 0CAN031801 Page 168 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards Subcategory: 1 - Security Initiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes EAL:

HA1.1 Alert A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by ANO Security Shift Supervision OR A validated notification from NRC of an aircraft attack threat within 30 min. of the site Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

HOSTILE FORCE - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.

Access to this area is controlled by the SOCA Personnel Access Control Point.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

to 0CAN031801 Page 169 of 255 Attachment 1 - Emergency Action Level Technical Bases PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

Basis:

This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations (OROs), allowing them to be better prepared should it be necessary to consider further actions.

This IC EAL does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.

Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.

The first threshold EAL #1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA.

The second threshold EAL #2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with OP-1203.048 Security Event (ref. 2)(site-specific procedure).

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRC.

In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The to 0CAN031801 Page 170 of 255 Attachment 1 - Emergency Action Level Technical Bases emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).

Escalation of the emergency classification level would be via IC HS1.

Reference(s):

1. ANO Security Plan
2. OP-1203.048 Security Event
3. NEI 99-01 HA1 to 0CAN031801 Page 171 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards Subcategory: 1 - Security Initiating Condition: HOSTILE ACTION within the PROTECTED AREA EAL:

HS1.1 Site Area Emergency A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by ANO Security Shift Supervision Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

HOSTILE FORCE - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.

Access to this area is controlled by the SOCA Personnel Access Control Point.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

to 0CAN031801 Page 172 of 255 Attachment 1 - Emergency Action Level Technical Bases Basis:

This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event (ref. 1, 2).

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Site Area Emergency declaration will mobilize Offsite Response Organization (ORO) resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.

This IC EAL does not apply to a HOSTILE ACTION directed at an ISFSI Protected Area located outside the PROTECTED AREA; such an attack should be assessed using IC HA1. It also does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).

Escalation of the emergency classification level would be via IC HG1.

Reference(s):

1. ANO Security Plan
2. OP-1203.048 Security Event
3. NEI 99-01 HS1 to 0CAN031801 Page 173 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 2 - Seismic Event Initiating Condition: Seismic event greater than OBE levels EAL:

HU2.1 Unusual Event Seismic event > OBE as indicated by annunciation of the 0.10 g acceleration alarm Mode Applicability:

All Definition(s):

None Basis:

This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (OBE). An earthquake greater than an OBE but less than a Safe Shutdown Earthquake (SSE)Design Basis Earthquake (DBE) should have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections). Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety of the plant.

Event verification with external sources should not be necessary during or following an OBE.

Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., lateral accelerations in excess of 0.08g1g). The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA6 or SA9.

Two strong motion triaxial accelerometers, ACS-8001 and ACS-8003, located at the base slab provide alarms to the Unit 1 control room via the seismic network control center, C529-NCC.

One alarm from C529-NCC is triggered when a setpoint of 0.01g has been exceeded. This alarm indicates that an earthquake has occurred and the seismic monitoring system is recording seismic data. Another alarm from C529-NCC is triggered when the pre-determined value of 0.1g, indicating the OBE has been exceeded (ref. 2, 3).

to 0CAN031801 Page 174 of 255 Attachment 1 - Emergency Action Level Technical Bases To avoid inappropriate emergency classification resulting from spurious actuation of the seismic instrumentation or felt motion not attributable to seismic activity, an offsite agency (USGS, National Earthquake Information Center (NEIC)) can confirm that an earthquake has occurred in the area of the plant. Such confirmation should not, however, preclude a timely emergency declaration based on receipt of the OBE alarm. If requested, provide the analyst with the following ANO coordinates: 35º 18' 36" north latitude, 93º 13' 53" west longitude (ref. 4).

Alternatively, near real-time seismic activity can be accessed via the NEIC website:

Reference(s):

1. 1SAR 2.2.1 Location
2. 1SAR 2.7.2 Site Seismic Evaluation
3. 1SAR 2.7.6 Time-History Accelerograph
4. OP-1203.025 Natural Emergencies
5. OP-2203.008 Natural Emergencies
6. NEI 99-01 HU2 to 0CAN031801 Page 175 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.1 Unusual Event A tornado strike within the PROTECTED AREA Mode Applicability:

All Definition(s):

PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

This EALEAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA.

EAL #2 addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns. Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.

EAL #3 addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.

EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.

Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.

This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.

to 0CAN031801 Page 176 of 255 Attachment 1 - Emergency Action Level Technical Bases EAL #5 addresses (site-specific description).

Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.

If damage is confirmed visually or by other in-plant indications, the event may be escalated to an Alert under EAL CA6.1 or SA9.1.

A tornado striking (touching down) within the PROTECTED AREA warrants declaration of an Unusual Event regardless of the measured wind speed at the meteorological tower. A tornado is defined as a violently rotating column of air in contact with the ground and extending from the base of a thunderstorm.

Reference(s):

1. OP-1203.025 Natural Emergencies
2. OP-2203.008 Natural Emergencies
3. NEI 99-01 HU3 to 0CAN031801 Page 177 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.2 Unusual Event 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 Mode Applicability:

All Definition(s):

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

EAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA.

This EAL addresses FLOODING of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.

Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To to 0CAN031801 Page 178 of 255 Attachment 1 - Emergency Action Level Technical Bases warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.

EAL #3 addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.

EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.

Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.

This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.

EAL #5 addresses (site-specific description).

Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.

Refer to EAL CA6.1 or SA9.1 for internal FLOODING affecting more than one SAFETY SYSTEM train.

Reference(s):

1. OP-1203.025 Natural Emergencies
2. OP-2203.008 Natural Emergencies
3. NEI 99-01 HU3 to 0CAN031801 Page 179 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.3 Unusual Event Movement of personnel within the PROTECTED AREA is IMPEDED due to an event external to the PROTECTED AREA involving hazardous materials (e.g., an offsite chemical spill or toxic gas release)

Mode Applicability:

All Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

This EAL EAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA.

This EAL addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns. Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.

EAL #3 addresses a hazardous materials event originating at an offsite location outside the PROTECTED AREA and of sufficient magnitude to IMPEDE the movement of personnel within the PROTECTED AREA.

EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.

to 0CAN031801 Page 180 of 255 Attachment 1 - Emergency Action Level Technical Bases Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.

This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.

EAL #5 addresses (site-specific description).

Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.

Reference(s):

1. NEI 99-01 HU3 to 0CAN031801 Page 181 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.4 Unusual Event A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles (Note 7)

Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

Mode Applicability:

All Definition(s):

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant. EAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA.

This EAL addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns. Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.

EAL #3 addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.

This EAL EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of such an event include site FLOODING caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.

to 0CAN031801 Page 182 of 255 Attachment 1 - Emergency Action Level Technical Bases This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the FLOODING around the Cooper Station during the Midwest floods of 1993, or the FLOODING around Ft. Calhoun Station in 2011.

EAL #5 addresses (site-specific description). Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.

Reference(s):

1. NEI 99-01 HU3 to 0CAN031801 Page 183 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.1 Unusual Event A FIRE is not extinguished within 15 min. of any of the following FIRE detection indications (Note 1):

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 The FIRE is located within any Table 1[2]H-1 area Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1H-1 Unit 1 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Penthouse/MSIV Room Exceptions:

Boric Acid Mix Tank Room (Chem Add Area), 404 (157-B), EDG Exhaust Fan area on 386 (1-E and 2-E)

Turbine Building All elevations including: Pipechase under ICW Coolers, CRD Pump Pit/T-28 Room/Area under ICW Pumps Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)

Manholes adjacent to Intake Structure (MH-05/MH-06)

Intake Structure (354 and 366)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10) to 0CAN031801 Page 184 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2H-1 Unit 2 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Aux Extension Turbine Building All elevations Outside Areas Intake Structure (354 and 366)

Concrete Manhole East, NE of intake (2MH-01)

Concrete Manhole East of Turbine Building next to train bay (2MH-03)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)

Mode Applicability:

All Definition(s):

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.

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

EAL #1 The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.

to 0CAN031801 Page 185 of 255 Attachment 1 - Emergency Action Level Technical Bases Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report. EAL #2 This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.

If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.

EAL #3 In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.

This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA. [Sentence for plants with an ISFSI outside the plant Protected Area]

EAL #4 If a FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area]

PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish. Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.

Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part:

to 0CAN031801 Page 186 of 255 Attachment 1 - Emergency Action Level Technical Bases Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."

When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.

Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC EAL CA6.1 or SA9SA9.1.

The 15 minute requirement begins with a credible notification that a FIRE is occurring, or receipt of multiple VALID fire detection system alarms or field validation of a single fire alarm. The alarm is to be validated using available Control Room indications or alarms to prove that it is not spurious, or by reports from the field.

Table 1[2]H-1 Fire Areas are those areas that contain equipment necessary for safe operation and shutdown of the plant (ref. 1, 2).

Reference(s):

1. OP-1203.049 Fires in Areas Affecting Safe Shutdown
2. OP- 2203.049 Fires in Areas Affecting Safe Shutdown
3. NEI 99-01 HU4 to 0CAN031801 Page 187 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.2 Unusual Event Receipt of a single fire alarm (i.e., no other indications of a FIRE)

AND The fire alarm is indicating a FIRE within any Table 1[2]H-1 area AND The existence of a FIRE is not verified within 30 min. of alarm receipt (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1H-1 Unit 1 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Penthouse/MSIV Room Exceptions:

Boric Acid Mix Tank Room (Chem Add Area), 404 (157-B), EDG Exhaust Fan area on 386 (1-E and 2-E)

Turbine Building All elevations including: Pipechase under ICW Coolers, CRD Pump Pit/T-28 Room/Area under ICW Pumps Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)

Manholes adjacent to Intake Structure (MH-05/MH-06)

Intake Structure (354 and 366)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10) to 0CAN031801 Page 188 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2H-1 Unit 2 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Aux Extension Turbine Building All elevations Outside Areas Intake Structure (354 and 366)

Concrete Manhole East, NE of intake (2MH-01)

Concrete Manhole East of Turbine Building next to train bay (2MH-03)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)

Mode Applicability:

All Definition(s):

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.

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

EAL #1 The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.

to 0CAN031801 Page 189 of 255 Attachment 1 - Emergency Action Level Technical Bases Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report.

EAL #2 This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.

If an actual FIRE is verified by a report from the field, then HU4.1 EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted. EAL #3 In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.

This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA. [Sentence for plants with an ISFSI outside the plant Protected Area]

EAL #4 Basis-Related Fire Protection Requirements from Appendix R Appendix R to 10 CFR 50, states in part:

Criterion 3 of 10 CFR 50, Appendix A, states, in part:

Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.

In this respect, noncombustible and heat resistant materials are used wherever practical throughout the unit, particularly in locations such as the containment and Control Room. Fire detection and fighting systems of appropriate capacity and capability are provided and designed to minimize the adverse effects of fires on SSCs important to safety. Firefighting systems are to 0CAN031801 Page 190 of 255 Attachment 1 - Emergency Action Level Technical Bases designed to assure that the rupture or inadvertent operation of a fire system does not significantly impair the safety capability of these structures, systems, and components.

When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.

Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train is employed(G.2.c). As used in HU4.2EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC EAL CA6.1 or SA9SA9.1.

The 30-minute requirement begins upon receipt of a single VALID fire detection system alarm.

The alarm is to be validated using available Control Room indications or alarms to prove that it is not spurious, or by reports from the field. Actual field reports must be made within the 30-minute time limit or a classification must be made. If a fire is verified to be occurring by field report, classification shall be made based on EAL HU4.1, with the 15-minute requirement beginning with the verification of the fire by field report.

Table 1[2]H-1 Fire Areas are those areas that contain equipment necessary for safe operation and shutdown of the plant (ref. 1, 2).

Reference(s):

1. OP-1203.049 Fires in Areas Affecting Safe Shutdown
2. OP- 2203.049 Fires in Areas Affecting Safe Shutdown
3. NEI 99-01 HU4 to 0CAN031801 Page 191 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.3 Unusual Event A FIRE within the PROTECTED AREA not extinguished within 60 min. of the initial report, alarm or indication (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

All Definition(s):

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

EAL #1 The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.

Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report.

to 0CAN031801 Page 192 of 255 Attachment 1 - Emergency Action Level Technical Bases EAL #2 This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.

If an actual FIRE is verified by a report from the field, then HU4.1 EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted. EAL #3 In addition to a FIRE addressed by EAL HU4.1 #1 or HU4.2EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.

This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA. [Sentence for plants with an ISFSI outside the plant Protected Area]

EAL #4 If a FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area]

PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish. Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.

Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part:

Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."

to 0CAN031801 Page 193 of 255 Attachment 1 - Emergency Action Level Technical Bases When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.

Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC EAL CA6.1 or SA9SA8.1.

Reference(s):

1. NEI 99-01 HU4 to 0CAN031801 Page 194 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.4 Unusual Event A FIRE within the PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish Mode Applicability:

All Definition(s):

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

EAL #1 The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.

Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report.

EAL #2 to 0CAN031801 Page 195 of 255 Attachment 1 - Emergency Action Level Technical Bases This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.

If an actual FIRE is verified by a report from the field, then HU4.1 EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted. EAL #3 In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.

This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA. [Sentence for plants with an ISFSI outside the plant Protected Area]

EAL #4 If a FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area]

PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish. Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.

Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part:

Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."

When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.

Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not to 0CAN031801 Page 196 of 255 Attachment 1 - Emergency Action Level Technical Bases per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC EAL CA6.1 or SA9SA9.1.

Reference(s):

1. NEI 99-01 HU4 to 0CAN031801 Page 197 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 5 - Hazardous Gas Initiating Condition: Gaseous release IMPEDING access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

HA5.1 Alert Release of a toxic, corrosive, asphyxiant or flammable gas into any Table 1[2]H-2 room or area AND Entry into the room or area is prohibited or IMPEDED (Note 5)

Note 5: 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.

Table 1H-2 Unit 1 Safe Operation & Shutdown Rooms/Areas Room/Area Mode A-4 Switchgear Room 3, 4 Upper North Electrical Penetration Room 3, 4 Lower South Electrical Equipment Room 3, 4 Table 2H-2 Unit 2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux Building 317 Emergency Core Cooling Rooms 3, 4 Aux Building 317 Tendon Gallery Access 3, 4 Aux Building 335 Charging Pumps / MCC 2B-52 3, 4 Aux Building 354 MCC 2B-62 Area 3, 4 Emergency Diesel Generator Corridor 3, 4 Lower South Piping Penetration Room 3, 4 Aux Building 386 Containment Hatch 3, 4 to 0CAN031801 Page 198 of 255 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

3 - Hot Standby, 4 - Hot Shutdown Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

Basis:

This IC addresses an event involving a release of a hazardous gas that precludes or IMPEDES access to equipment necessary to maintain normal plant operation, or required for a normal plant cooldown and shutdown. This condition represents an actual or potential substantial degradation of the level of safety of the plant.

An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.

Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Directors judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly IMPEDE procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards.

Access should be considered as IMPEDED if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

An emergency declaration is not warranted if any of the following conditions apply:

The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release). For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.

The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).

The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

to 0CAN031801 Page 199 of 255 Attachment 1 - Emergency Action Level Technical Bases The access control measures are of a conservative or precautionary nature, and would not actually prevent or IMPEDE a required action.

If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact 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.

This EAL does not apply to firefighting activities that generate smoke and that automatically or manually activate a fire suppression system in an area , or to intentional inerting of containment.

(BWR only).

The list of plant rooms or areas with entry-related mode applicability identified specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations) are not included. In addition, the list specifies the plant mode(s) during which entry would be required for each room or area (ref. 1).

Escalation of the emergency classification level would be via Recognition Category A, C or F ICs.

EAL HA5.1 mode applicability has been limited to the mode limitations of Table 1[2]H-2 (Modes 3 and 4 only).

Reference(s):

1. Attachment 2 Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases
2. NEI 99-01 HA5 to 0CAN031801 Page 200 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 6 - Control Room Evacuation Initiating Condition: Control Room evacuation resulting in transfer of plant control to alternate locations EAL:

HA6.1 Alert An event has resulted in plant control being transferred from the Control Room to alternate locations Mode Applicability:

All Definition(s):

None Basis:

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety.

Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations. The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel. Activation of the ERO and emergency response facilities will assist in responding to these challenges.

Transfer of plant control begins when the last licensed operator leaves the Control Room.

Escalation of the emergency classification level would be via IC HS6.

Reference(s):

1. OP-1203.002 Alternate Shutdown
2. OP- 2203.014 Alternate Shutdown
3. NEI 99-01 HA6 to 0CAN031801 Page 201 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 6 - Control Room Evacuation Initiating Condition: Inability to control a key safety function from outside the Control Room EAL:

HS6.1 Site Area Emergency An event has resulted in plant control being transferred from the Control Room to alternate locations AND Control of any of the following key safety functions is not re-established within 15 min. (Note 1):

Reactivity (Modes 1, 2 and 3 only)

Core cooling RCS heat removal Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling Definition(s):

None Basis:

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plant control to alternate locations is a precursor to a challenge to one or more fission product barriers within a relatively short period of time.

The determination of whether or not control is established at the remote safe shutdown location(s) is based on Emergency Director judgment. The Emergency Director is expected to make a reasonable, informed judgment within 15 (the site-specific time for transfer) minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).

to 0CAN031801 Page 202 of 255 Attachment 1 - Emergency Action Level Technical Bases Transfer of plant control and the time period to establish control begins when the last licensed operator leaves the Control Room.

Escalation of the emergency classification level would be via IC FG1 or CG1 Reference(s):

1. OP-1203.002 Alternate Shutdown
2. OP-2203.014 Alternate Shutdown
3. NEI 99-01 HS6 to 0CAN031801 Page 203 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - Emergency Director Judgment Initiating Condition: Other conditions exist that in the judgment of the Emergency Director warrant declaration of a UE EAL:

HU7.1 Unusual Event 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.

Mode Applicability:

All Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an UNUSUAL EVENTNOUE.

Reference(s):

1. NEI 99-01 HU7 to 0CAN031801 Page 204 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - Emergency Director Judgment Initiating Condition: Other conditions exist that in the judgment of the Emergency Director warrant declaration of an ALERT EAL:

HA7.1 Alert 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.

Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.

Access to this area is controlled by the SOCA Personnel Access Control Point.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

to 0CAN031801 Page 205 of 255 Attachment 1 - Emergency Action Level Technical Bases Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an ALERT.

Reference(s):

1. NEI 99-01 HA7 to 0CAN031801 Page 206 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - Emergency Director Judgment Initiating Condition: Other conditions exist that in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY EAL:

HS7.1 Site Area Emergency 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.

Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.

Access to this area is controlled by the SOCA Personnel Access Control Point.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

to 0CAN031801 Page 207 of 255 Attachment 1 - Emergency Action Level Technical Bases PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a SITE AREA EMERGENCY.

Reference(s):

1. NEI 99-01 HS7 to 0CAN031801 Page 208 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - Emergency Director Judgment Initiating Condition: Other conditions exist that in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY EAL:

HG7.1 General Emergency Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

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.

OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.

Access to this area is controlled by the SOCA Personnel Access Control Point.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

to 0CAN031801 Page 209 of 255 Attachment 1 - Emergency Action Level Technical Bases PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a GENERAL EMERGENCY.

Reference(s):

1. NEI 99-01 HG7 to 0CAN031801 Page 210 of 255 Attachment 1 - Emergency Action Level Technical Bases Category S - System Malfunction EAL Group: Hot Conditions (RCS temperature > 200°F); EALs in this category are applicable only in one or more hot operating modes.

Numerous system-related equipment failure events that warrant emergency classification have been identified in this category. They may pose actual or potential threats to plant safety.

The events of this category pertain to the following subcategories:

1. Loss of Vital AC Power Loss of vital electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite sources for vital 4.16 KV buses.
2. Loss of Vital DC Power Loss of emergency electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of vital plant 125V DC power sources.
3. Loss of Control Room Indications Certain events that degrade plant operator ability to effectively assess plant conditions within the plant warrant emergency classification. Losses of indicators are in this subcategory.
4. RCS Activity During normal operation, reactor coolant fission product activity is very low. Small concentrations of fission products in the coolant are primarily from the fission of tramp uranium in the fuel clad or minor perforations in the clad itself. Any significant rise from these base-line levels (2% - 5% clad failures) is indicative of fuel failures and is covered under the Fission Product Barrier Degradation category. However, lesser amounts of clad damage may result in coolant activity exceeding Technical Specification limits. These fission products will be circulated with the reactor coolant and can be detected by coolant sampling.
5. RCS Leakage The reactor vessel provides a volume for the coolant that covers the reactor core. The reactor pressure vessel and associated pressure piping (reactor coolant system) together provide a barrier to limit the release of radioactive material should the reactor fuel clad integrity fail. Excessive RCS leakage greater than Technical Specification limits indicates potential pipe cracks that may propagate to an extent threatening fuel clad, RCS and containment integrity.

to 0CAN031801 Page 211 of 255 Attachment 1 - Emergency Action Level Technical Bases

6. RPS Failure This subcategory includes events related to failure of the Reactor Protection System (RPS) to initiate and complete reactor trips. In the plant licensing basis, postulated failures of the RPS to complete a reactor trip comprise a specific set of analyzed events referred to as Anticipated Transient Without Scram (ATWS) events. For EAL classification, however, ATWS is intended to mean any trip failure event that does not achieve reactor shutdown. If RPS actuation fails to assure reactor shutdown, positive control of reactivity is at risk and could cause a threat to fuel clad, RCS and containment integrity.
7. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.
8. Containment Failure Failure of containment isolation capability (under conditions in which the containment is not currently challenged) warrants emergency classification. Failure of containment pressure control capability also warrants emergency classification.
9. Hazardous Event Affecting Safety Systems Various natural and technological events that result in degraded plant safety system performance or significant VISIBLE DAMAGE warrant emergency classification under this subcategory.

to 0CAN031801 Page 212 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Loss of all offsite AC power capability to vital buses for 15 minutes or longer EAL:

SU1.1 Unusual Event Loss of all offsite AC power capability, Table 1[2]S-1, to vital 4.16 KV buses A3 [2A3] and A4 [2A4] for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1S-1 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite Unit Auxiliary Transformer (main generator via main transformer)

DG1 DG2 AAC Gen to 0CAN031801 Page 213 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2S-1 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)

Onsite Unit Auxiliary Transformer (main generator via main transformer) 2DG1 2DG2 AAC Gen Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None 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 vital 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 vital buses, whether or not the buses are powered from it.

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

Escalation of the emergency classification level would be via IC SA1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram
2. OP-1202.007 Degraded Power
3. OP-1202.008 Blackout
4. OP-2104.037 Alternate AC Diesel Generator Operations to 0CAN031801 Page 214 of 255 Attachment 1 - Emergency Action Level Technical Bases
5. 2SAR Figure 8.3-1 Station Single Line Diagram
6. OP-2202.007 Loss of Off-Site Power
7. OP-2202.008 Station Blackout
8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
9. NEI 99-01 SU1 to 0CAN031801 Page 215 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Loss of all but one AC power source to vital buses for 15 minutes or longer EAL:

SA1.1 Alert AC power capability, Table 1[2]S-1, to vital 4.16 KV buses A3 [2A3] and A4 [2A4] reduced to a single power source for 15 min. (Note 1)

AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1S-1 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite Unit Auxiliary Transformer (main generator via main transformer)

DG1 DG2 AAC Gen to 0CAN031801 Page 216 of 255 Attachment 1 - Emergency Action Level Technical Bases Table 2S-1 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)

Onsite Unit Auxiliary Transformer (main generator via main transformer) 2DG1 2DG2 AAC Gen Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

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 SU1.

An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to a emergency vital bus. Some examples of this condition are presented below.

to 0CAN031801 Page 217 of 255 Attachment 1 - Emergency Action Level Technical Bases 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 vital emergency power sources (e.g., onsite diesel generators) with a single train of emergency vital buses being back-fed from the unit main generator.

A loss of vital emergency power sources (e.g., onsite diesel generators) with a single train of vital 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 SS1.

This EAL is the hot condition equivalent of the cold condition EAL CU2.1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram
2. OP-1202.007 Degraded Power
3. OP-1202.008 Blackout
4. OP-2104.037 Alternate AC Diesel Generator Operations
5. 2SAR Figure 8.3-1 Station Single Line Diagram
6. OP-2202.007 Loss of Off-Site Power
7. OP-2202.008 Station Blackout
8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
9. NEI 99-01 SA1 to 0CAN031801 Page 218 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Loss of all offsite power and all onsite AC power to vital buses for 15 minutes or longer EAL:

SS1.1 Site Area Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3 [2A3] and A4 [2A4] for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Although the AAC may be considered available, it will not prevent declaration of this EAL unless it is powering a vital bus within the 15 minute time period of the EAL.

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.

Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or emergency operating procedures, or beyond design basis to 0CAN031801 Page 219 of 255 Attachment 1 - Emergency Action Level Technical Bases accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.

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

Escalation of the emergency classification level would be via ICs AG1, FG1 or SG1.

This EAL is the hot condition equivalent of the cold condition EAL CA2.1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram
2. OP-1202.007 Degraded Power
3. OP-1202.008 Blackout
4. OP-2104.037 Alternate AC Diesel Generator Operations
5. 2SAR Figure 8.3-1 Station Single Line Diagram
6. OP-2202.007 Loss of Off-Site Power
7. OP-2202.008 Station Blackout
8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
9. NEI 99-01 SS1 to 0CAN031801 Page 220 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Prolonged loss of all offsite and all onsite AC power to vital buses EAL:

SG1.1 General Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3 [2A3] and A4 [2A4]

AND EITHER:

Restoration of at least one vital 4.16 KV 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 (Note 1)

CETs > 1200°F Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC addresses a prolonged loss of all power sources to AC emergency vital buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or to 0CAN031801 Page 221 of 255 Attachment 1 - Emergency Action Level Technical Bases emergency operating procedures, or beyond design basis accident response guidelines (e.g.,

FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. A prolonged loss of these buses will lead to a loss of one or more 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 vital 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 greater likelihood of challenges to multiple fission product barriers. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the site-specific SBO coping analysis time (ref. 4, 5).

The estimate for restoring at least one emergency vital bus should be based on a realistic appraisal of the situation. Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public.

The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.

Reference(s):

1. OP-1202.005 Inadequate Core Cooling
2. OP-2202.009 Functional Recovery
3. OP-2202.011 Lower Mode Functional Recovery
4. Unit 1 Calculation 85-E-0072-02 Time from Loss of All AC Power to Loss of Subcooling
5. Unit 2 Calculation 85-E-0072-01 Time from Loss of All AC Power to Loss of Subcooling
6. 1SAR Figure 8-1 Station Single Line Diagram
7. OP-1202.007 Degraded Power
8. OP-1202.008 Blackout
9. OP-2104.037 Alternate AC Diesel Generator Operations
10. 2SAR Figure 8.3-1 Station Single Line Diagram
11. OP-2202.007 Loss of Off-Site Power
12. OP-2202.008 Station Blackout
13. OP-2107.006 Backfeed of Unit Auxiliary Transformer
14. NEI 99-01 SG1 to 0CAN031801 Page 222 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Loss of all vital AC and vital DC power sources for 15 minutes or longer EAL:

SG1.2 General Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3 [2A3] and A4 [2A4] for 15 min. (Note 1)

AND Indicated voltage is < 105 VDC on D01 [2D01] and D02 [2D02] vital 125 VDC buses for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC (ref. 9, 10).

This IC addresses a concurrent and prolonged loss of both vital AC and Vital DC power. A loss of all vital AC power compromises the performance of all SAFETY SYSTEMS requiring electric to 0CAN031801 Page 223 of 255 Attachment 1 - Emergency Action Level Technical Bases power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or emergency operating procedures, or beyond design basis accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. A loss of vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both vital AC and vital 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 both EAL thresholds are met.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram
2. OP-1202.007 Degraded Power
3. OP-1202.008 Blackout
4. OP-2104.037 Alternate AC Diesel Generator Operations
5. 2SAR Figure 8.3-1 Station Single Line Diagram
6. OP-2202.007 Loss of Off-Site Power
7. OP-2202.008 Station Blackout
8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
9. 1SAR 8.3.2.1.1 Batteries
10. 2SAR 8.3.2.1.1 Batteries
11. OP-1203.036 Loss of 125V DC
12. OP-2203.037 Loss of 125V DC
13. 2SAR Figure 8.3-6 Low Voltage Safety System Power Supplies
14. NEI 99-01 SG8 to 0CAN031801 Page 224 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 2 - Loss of Vital DC Power Initiating Condition: Loss of all vital DC power for 15 minutes or longer EAL:

SS2.1 Site Area Emergency Indicated voltage is < 105 VDC on D01 [2D01] and D02 [2D02] vital 125 VDC buses for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC (ref. 2, 3).

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 AG1, FG1 or SG1SG8.

to 0CAN031801 Page 225 of 255 Attachment 1 - Emergency Action Level Technical Bases This EAL is the hot condition equivalent of the cold condition EAL CU4.1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram
2. 1SAR 8.3.2.1.1 Batteries
3. 2SAR 8.3.2.1.1 Batteries
4. OP-1203.036 Loss of 125V DC
5. OP-2203.037 Loss of 125V DC
6. 2SAR Figure 8.3-6 Low Voltage Safety System Power Supplies
7. NEI 99-01 SS8 to 0CAN031801 Page 226 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 3 - Loss of Control Room Indications Initiating Condition: UNPLANNED loss of Control Room indications for 15 minutes or longer EAL:

SU3.1 Unusual Event An UNPLANNED event results in the inability to monitor one or more Table 1[2]S-2 parameters from within the Control Room for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1[2]S-2 Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one S/G EFW flow to at least one S/G Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

to 0CAN031801 Page 227 of 255 Attachment 1 - Emergency Action Level Technical Bases 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.

Basis:

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 one or more of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.

An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling [PWR] / RPV level [BWR] and RCS heat removal.

The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level [PWR] / RPV water level [BWR] cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.

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

Escalation of the emergency classification level would be via IC EAL SA3.1SA2.

Reference(s):

1. 1SAR 7.5 Safety-Related Display Instrumentation
2. 2SAR 7.5 Safety-Related Display Instrumentation
3. NEI 99-01 SU2 to 0CAN031801 Page 228 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 3 - Loss of Control Room Indications Initiating Condition: UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress EAL:

SA3.1 Alert An UNPLANNED event results in the inability to monitor one or more Table 1[2]S-2 parameters from within the Control Room for 15 min. (Note 1)

AND Any significant transient is in progress, Table 1[2]S-3 Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1[2]S-2 Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one S/G EFW flow to at least one S/G Table 1[2]S-3 Significant Transients Reactor trip Runback > 25% thermal power Electrical load rejection > 25% electrical load Safety injection actuation Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown to 0CAN031801 Page 229 of 255 Attachment 1 - Emergency Action Level Technical Bases Definition(s):

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 (as defined in 10 CFR 50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

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.

Basis:

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 one or more of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.

An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling [PWR] / RPV level [BWR] and RCS heat removal.

The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level [PWR] / RPV water level [BWR] cannot be determined from the to 0CAN031801 Page 230 of 255 Attachment 1 - Emergency Action Level Technical Bases 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 AS1.

Reference(s):

1. 1SAR 7.1.3 Engineered Safeguards Actuation System
2. 2SAR 7.3 Engineered Safety Features Systems
3. NEI 99-01 SA2 to 0CAN031801 Page 231 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 4 - RCS Activity Initiating Condition: RCS activity greater than Technical Specification allowable limits EAL:

SU4.1 Unusual Event Failed Fuel Iodine radiation monitor RI-1237S [2RITS-4806B] > 9.0 E5 cpm Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None 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.

Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category A ICs.

Unit 1 RE-1237S, Failed Fuel Monitor, is in the letdown system to monitor the letdown line for evidence of fuel damage.

Unit 2 specific activity monitor 2RITS-4806B monitors the Letdown fluid for the presence of Iodine-131.

A monitor reading corresponding to the instantaneous dose equivalent I-131 value of 60 uCi/gm is determined by multiplying by 30 the monitor reading listed in the table in OP-1203.019[OP-2203.020] that represents a projected 2.0 uCi/gm I-131 RCS activity in order to correlate to a Tech Spec instantaneous limit of 60 uCi/gm dose equivalent I-131 for the EAL (ref. 2, 5). This yields values of 3.1E6 cpm for Unit 1 and 3.9E6 cpm for Unit 2. The top of scale of the monitor is 1E6. The EAL value is set at 9.0 E5 cpm for both units which is 90% of the top of the scale.

to 0CAN031801 Page 232 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. 1SAR Table 11-7
2. OP-1203-019 High Activity in Reactor Coolant
3. Unit 1 Technical Specifications LCO 3.4.12 RCS Specific Activity
4. 2SAR 9.3.5 Failed Fuel Detection System
5. OP-2203.020 High Activity in RCS
6. OP- 2203.012L ANNUNCIATOR 2K12 CORRECTIVE ACTION, A-1
7. Unit 2 Technical Specifications LCO 3.4.8 Reactor Coolant System Specific Activity
8. NEI 99-01 SU3 to 0CAN031801 Page 233 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 4 - RCS Activity Initiating Condition: RCS activity greater than Technical Specification allowable limits EAL:

SU4.2 Unusual Event RCS sample activity > 1.0 µCi/gm dose equivalent I-131 for > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (Note 1)

OR RCS sample activity > 60 µCi/gm dose equivalent I-131 OR RCS sample activity > 2200[3100] µCi/gm dose equivalent Xe-133 for > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None 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.

Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category A ICs.

Reference(s):

1. Unit 1 Technical Specifications LCO 3.4.12 RCS Specific Activity
2. Unit 2 Technical Specifications LCO 3.4.8 Reactor Coolant System Specific Activity
3. NEI 99-01 SU3 to 0CAN031801 Page 234 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 5 - RCS Leakage Initiating Condition: RCS leakage for 15 minutes or longer EAL:

SU5.1 Unusual Event RCS unidentified or pressure boundary leakage > 10 gpm for 15 min. (Note 1)

OR RCS identified leakage > 25 gpm for 15 min. (Note 1)

OR Reactor coolant leakage to a location outside containment > 25 gpm for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

Basis:

Failure to isolate the leak (from the Control Room or locally) within 15 minutes, or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

Steam generator tube leakage is identified RCS leakage.

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.

The first and second EAL conditions EAL #1 and EAL #2 are focused on a loss of mass from the RCS due to unidentified leakage", "pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications). The third condition EAL

  1. 3 addresses an RCS mass loss caused by an UNISOLABLE leak through an interfacing to 0CAN031801 Page 235 of 255 Attachment 1 - Emergency Action Level Technical Bases system. These conditions EALs thus apply to leakage into the containment, a secondary-side system (e.g., steam generator tube leakage in a PWR) or a location outside of containment.

The leak rate values for each condition 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). The first condition 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. For PWRs, aAn 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). For BWRs, a stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is not applicable to this EAL.

The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible.

Escalation of the emergency classification level would be via ICs of Recognition Category A or F.

Reference(s):

1. Unit 1 and Unit 2 Technical Specifications Section 1.1 Definitions
2. NEI 99-01 SU4 to 0CAN031801 Page 236 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 6 - RPS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor EAL:

SU6.1 Unusual Event An automatic trip did not shut down the reactor as indicated by reactor power > 5% after any RPS setpoint is exceeded AND A subsequent automatic trip or manual trip action taken at the reactor control console (C03

[2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) is successful in shutting down the reactor as indicated by reactor power 5% (Note 8)

Note 8: 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.

Mode Applicability:

1 - Power Operation Definition(s):

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.

Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor (trip [PWR] / scram [BWR]) that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic (trip [PWR] / scram [BWR])

is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.

In the event that the operator identifies a reactor trip is IMMINENT and initiates a successful manual reactor trip before the automatic trip setpoint is reached, no declaration is required. The successful manual trip of the reactor before it reaches its automatic trip setpoint or reactor trip signals caused by instrumentation channel failures do not lead to a potential fission product barrier loss.

Following the failure onf an automatic reactor (trip[PWR] / scram [BWR]), operators will promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor (trip[PWR] / scram [BWR])). If these manual actions are successful in shutting to 0CAN031801 Page 237 of 255 Attachment 1 - Emergency Action Level Technical Bases down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.

If an initial manual reactor (trip [PWR] / scram [BWR]) is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor (trip[PWR] / scram [BWR])) using a different switch).

Depending upon several factors, the initial or subsequent effort to manually (trip [PWR] / scram

[BWR]) the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor (trip [PWR] / scram [BWR]) signal. If a subsequent manual or automatic (trip [PWR] /

scram [BWR]) is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.

A manual action at the reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor (trip[PWR] / scram [BWR])). This action does not include manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the reactor control consoles.Taking the Reactor Mode Switch to SHUTDOWN is considered to be a manual scram action. [BWR]

The plant response to the failure of an automatic or manual reactor (trip [PWR] / scram [BWR])

will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the reactor control consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC SA5SA6. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC SA5 SA6 or FA1, an Unusual Event declaration is appropriate for this event.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Should a reactor (trip [PWR] / scram [BWR]) 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 results in a condition that should have included an automatic reactor trip [PWR] / scram [BWR]) and the RPS fails to automatically shutdown the reactor, then this IC and associated the EALs are applicable, and should be evaluated.

If the signal generated as a result of plant work does not cause a plant transient and the (trip [PWR] / scram [BWR]) failure is determined through other means (e.g., assessment of test results), then this IC and associated the EALs are not applicable and no classification is warranted.

to 0CAN031801 Page 238 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
4. OP-1202.001 Reactor Trip
5. OP-2202.001 Standard Post Trip Actions
6. NEI 99-01 SU5 to 0CAN031801 Page 239 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 6 - RPS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor EAL:

SU6.2 Unusual Event A manual trip did not shut down the reactor as indicated by reactor power > 5% after any manual trip action was initiated AND A subsequent automatic trip or manual trip action taken at the reactor control console (C03

[2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) is successful in shutting down the reactor as indicated by reactor power 5% (Note 8)

Note 8: A manual scram 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.

Mode Applicability:

1 - Power Operation Definition(s):

None Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor (trip [PWR] / scram [BWR]) that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic (trip [PWR] / scram [BWR])

is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.

This EAL addresses a failure of a manually initiated trip in the absence of having exceeded an automatic RPS trip setpoint and a subsequent automatic or manual trip is successful in shutting down the reactor.

Following the failure on an automatic reactor (trip [PWR] / scram [BWR]), operators will promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor (trip [PWR] / scram [BWR])). 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 plants decay heat removal systems.

to 0CAN031801 Page 240 of 255 Attachment 1 - Emergency Action Level Technical Bases If an initial manual reactor (trip [PWR] / scram [BWR]) is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor (trip [PWR] / scram [BWR])) using a different switch).

Depending upon several factors, the initial or subsequent effort to manually (trip [PWR] / scram

[BWR]) the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor (trip [PWR] / scram [BWR]) signal. If a subsequent manual or automatic (trip [PWR] /

scram [BWR]) is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.

A manual action at the reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor (trip

[PWR] / scram [BWR])). This action does not include manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the reactor control consoles.

Taking the Reactor Mode Switch to SHUTDOWN is considered to be a manual scram action.

[BWR]

The plant response to the failure of an automatic or manual reactor (trip [PWR] / scram [BWR])

will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the reactor control consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC SA5SA6. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC SA5 SA6 or FA1, an Unusual Event declaration is appropriate for this event.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Should a reactor (trip [PWR] / scram [BWR]) 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 results in a condition that should have included an automatic reactor (trip [PWR] / scram [BWR]) and the RPS fails to automatically shutdown the reactor, then this IC and associated the EALs are applicable, and should be evaluated.

If the signal generated as a result of plant work does not cause a plant transient and the (trip [PWR] / scram [BWR]) failure is determined through other means (e.g., assessment of test results), then this IC and associated the EALs are not applicable and no classification is warranted.

to 0CAN031801 Page 241 of 255 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
4. OP-1202.001 Reactor Trip
5. OP-2202.001 Standard Post Trip Actions
6. NEI 99-01 SU5 to 0CAN031801 Page 242 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 6 - RPS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor EAL:

SA6.1 Alert An automatic or manual trip fails to shut down the reactor as indicated by reactor power > 5%

AND Manual trip actions taken at the reactor control console (C03 [2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) are not successful in shutting down the reactor as indicated by reactor power > 5% (Note 8)

Note 8: 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.

Mode Applicability:

1 - Power Operation Definition(s):

None Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor (trip [PWR] / scram [BWR]) 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 reactor control console 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

[PWR] / scram [BWR])). 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 to 0CAN031801 Page 243 of 255 Attachment 1 - Emergency Action Level Technical Bases the Control Room, or any location outside the Control Room, are not considered to be at the reactor control consoles.

Taking the Reactor Mode Switch to SHUTDOWN is considered to be a manual scram action.

[BWR]

The plant response to the failure of an automatic or manual reactor (trip [PWR] / scram [BWR])

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 shut down the reactor is prolonged enough to cause a challenge to the core cooling [PWR] / RPV water level [BWR] or RCS RCS heat removal safety functions, the emergency classification level will escalate to a Site Area Emergency via IC SS65. Depending upon plant responses and symptoms, escalation is also possible via IC FS1.

Absent the plant conditions needed to meet either IC SS65 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.

Reference(s):

1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
4. OP-1202.001 Reactor Trip
5. OP-2202.001 Standard Post Trip Actions
6. NEI 99-01 SA5 to 0CAN031801 Page 244 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 6 - RPS Failure Initiating Condition: Inability to shut down the reactor causing a challenge to core cooling or RCS heat removal EAL:

SS6.1 Site Area Emergency An automatic or manual trip fails to shut down the reactor as indicated by reactor power > 5%

AND All actions to shut down the reactor are not successful as indicated by reactor power > 5%

AND EITHER:

CETs >1200°F RCS heat removal cannot be established using steam generators and HPI [Once Through] cooling initiated.

Mode Applicability:

1 - Power Operation Definition(s):

None Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor (trip [PWR] / scram [BWR]) that results in a reactor shutdown, all subsequent operator actions to manually shutdown the reactor are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.

In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs. This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shut down 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.

to 0CAN031801 Page 245 of 255 Attachment 1 - Emergency Action Level Technical Bases Escalation of the emergency classification level would be via IC AG1 or FG1.

Reference(s):

1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
4. OP-1202.001 Reactor Trip
5. OP-2202.001 Standard Post Trip Actions
6. OP-1202.004 Overheating
7. OP-2202.006 Loss of Feedwater
8. OP-1202.013 Figure 1, Saturation and Adequate SCM
9. Calculation 90-E-0116-07 Unit 1 EOP Setpoint Document, Setpoint B.19
10. OP-2202.009 Functional Recovery
11. Calculation 90-E-0116-01 Unit 2 EOP Setpoint Document
12. NEI 99-01 SS5 to 0CAN031801 Page 246 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 7 - Loss of Communications Initiating Condition: Loss of all onsite or offsite communications capabilities EAL:

SU7.1 Unusual Event Loss of all Table 1[2]S-4 onsite communication methods OR Loss of all Table 1[2]S-4 State and local agency communication methods OR Loss of all Table 1[2]S-4 NRC communication methods Table 1[2]S-4 Communication Methods System Onsite State / Local NRC Station radio system X ANO plant phone system X Gaitronics X Telephone Systems:

Commercial Microwave X X Satellite VOIP INFORM Notification System X Emergency Notification System (ENS) X Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown to 0CAN031801 Page 247 of 255 Attachment 1 - Emergency Action Level Technical Bases Definition(s):

None Basis:

This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to OROs State and local agencies and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

EAL #1The first EAL condition addresses a total loss of the communications methods used in support of routine plant operations.

EAL #2The second EAL condition addresses a total loss of the communications methods used to notify all OROs State and local agencies of an emergency declaration. The OROs State and local agencies referred to here are the Arkansas Department of Health, Arkansas Department of Emergency Management, Pope, Yell, Johnson, and Logan County agencies.(see Developer Notes)

EAL #3The third EAL addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

This EAL is the hot condition equivalent of the cold condition EAL CU5.1.

Reference(s):

1. OP-1903.062 Communications System Operating Procedure
2. NEI 99-01 SU6 to 0CAN031801 Page 248 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 8 - Containment Failure Initiating Condition: Failure to isolate containment or loss of containment pressure control EAL:

SU8.1 Unusual Event Any penetration is not closed within 15 min. of an ESAS [CIAS] actuation signal OR Containment pressure > 44.7 psia [23.3 psia] with < one full train of containment heat removal systems (Note 9) operating per design for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 9: One full train of containment heat removal systems consists of one train of RB [Containment]

Spray and one train of RB [Containment] Cooling System.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

A penetration is closed for this EAL if either side of the penetration has a closed valve or a check valve is intact (for penetrations that only have one automatic valve and a check valve).

This IC EAL addresses a failure of one or more containment penetrations to automatically isolate (close) when required by an actuation signal. It also addresses an event that results in high containment pressure with a concurrent failure of containment pressure control systems.

Absent challenges to another fission product barrier, either condition represents potential degradation of the level of safety of the plant.

For EAL #1the first condition, the containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); a failure resulting from testing or maintenance does not warrant classification. The determination of containment and penetration status - isolated or not isolated - should be made in accordance with the appropriate criteria contained in the plant AOPs and EOPs. The 15-minute to 0CAN031801 Page 249 of 255 Attachment 1 - Emergency Action Level Technical Bases criterion is included to allow operators time to manually isolate the required penetrations, if possible.

EAL #2The second condition addresses a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. The inability to start the required equipment indicates that containment heat removal/depressurization systems (e.g., containment sprays or ice condenser fans) are either lost or performing in a degraded manner.

This event would escalate to a Site Area Emergency in accordance with IC FS1 if there were a concurrent loss or potential loss of either the Fuel Clad or RCS fission product barriers.

Reference(s):

1. OP-1202.010 ESAS
2. 1SAR 6.2 Reactor Building Spray System
3. 1SAR 6.3 Reactor Building Cooling System
4. OP-2202.003 Loss of Coolant Accident
5. OP-2202.010 Standard Attachments, Attachment 22
6. 2SAR 6.2.2 Containment Heat Removal Systems
7. 2SAR 7.3.1.1.11.2 Containment Spray System
8. NEI 99-01 SU7 to 0CAN031801 Page 250 of 255 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 9 - Hazardous Event Affecting Safety Systems Initiating Condition: Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode EAL:

SA9.1 Alert The occurrence of any Table 1[2]S-5 hazardous event AND Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode AND EITHER:

Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)

Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted.

Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

Table 1[2]S-5 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 to 0CAN031801 Page 251 of 255 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 require a post-event inspection to determine if the attributes of an explosion are present.

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.

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

VISIBLE DAMAGE - Damage to a SAFETY SYSTEM train 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 SAFETY SYSTEM train.

Basis:

This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS needed for the current operating mode. In order to provide the appropriate context for consideration of an ALERT classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues.

to 0CAN031801 Page 252 of 255 Attachment 1 - Emergency Action Level Technical Bases Note that this second SAFETY SYSTEM train is from the same SAFETY SYSTEM that has indications of degraded performance; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events.

Indications of degraded performance addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

VISIBLE DAMAGE addresses damage to a SAFETY SYSTEM train that is not in service/operation and that potentially could cause performance issues. Operators will make a determination of VISIBLE DAMAGE 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. This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, needed 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.

EAL 1.b.1 addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

EAL 1.b.2 addresses damage to a SAFETY SYSTEM component that is not in service/operation or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level would be via IC FS1 or AS1.

This EAL is the hot condition equivalent of the cold condition EAL CA6.1.

Reference(s):

1. EP FAQ 2016-002
2. NEI 99-01 SA9 to 0CAN031801 Page 253 of 255 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases

Background

NEI 99-01 Revision 6 ICs AA3 and HA5 prescribe declaration of an Alert based on impeded access to rooms or areas (due to either area radiation levels or hazardous gas concentrations) where equipment necessary for normal plant operations, cooldown or shutdown is located.

These areas are intended to be plant operating mode dependent. Specifically the Developers Notes for AA3 and HA5 states:

The site-specific list of plant rooms or areas with entry-related mode applicability identified should specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Do not include rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations). In addition, the list should specify the plant mode(s) during which entry would be required for each room or area.

The list should 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).

Further, as specified in IC HA5:

The list need not include the Control Room if adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas. Such features may include, but are not limited to, capability to draw air from multiple air intakes at different and separate locations, inner and outer atmospheric boundaries, or the capability to acquire and maintain positive pressure within the Control Room envelope.

to 0CAN031801 Page 254 of 255 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases ANO Table 1[2]A-3 and 1[2]H-2 Bases A review of station operating procedures identified the following mode dependent in-plant actions and associated areas that are required for normal plant operation, cooldown or shutdown:

Unit 1 AREA MODES PURPOSE REFERENCE Core flood tank valves, OP-1102.010 A-4 Switchgear Room 3, 4 decay heat removal (DHR) OP-1104.004 Upper North Electrical 3, 4 DHR alignment OP-1104.004 Penetration Room Lower South Electrical 3, 4 DHR alignment OP-1104.004 Equipment Room Unit 2 AREA MODES PURPOSE REFERENCE Aux Building 317 Emergency Shutdown Cooling (SDC) 3, 4 OP-2104.004 Core Cooling Rooms venting and alignment Aux Building 317 Tendon 3, 4 SDC alignment OP-2104.004 Gallery Access Aux Building 335 Charging Charging low pressure OP-2102.010 Pumps / Motor Control Center 3, 4 operation, T-Hot injection (MCC) 2B-52 valves, and SDC alignment OP-2104.004 SDC alignment and T-Hot OP-2102.010 Auxiliary Building 354 3, 4 injection valves at MCC 2B-62 Area OP-2104.004 MCC 2B-62 Close Safety Injection Tank (SIT) valves and SDC / Low Emergency Diesel Generator 3, 4 Temperature Overpressure OP-2102.010 Corridor (LTOP) valve alignment at MCC 2B-51 Lower South Piping 3, 4 SDC alignment OP-2104.004 Penetration Room Aux Building 386 Close SIT valves at 3, 4 OP-2102.010 Containment Hatch MCC 2B-61 Mode 3 is included above for DHR- and SDC-related activities because the procedures begin alignment in Mode 3; however, these actions could be delayed until Mode 4, if necessary. In order to ensure adequate guidance to emergency response personnel, the above areas are added to the EAL in order to provide prompt operator guidance for EAL declaration.

to 0CAN031801 Page 255 of 255 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases Both ANO-1 and ANO-2 Control Room ventilation systems have adequate engineered safety/design features in place to preclude a Control Room evacuation due to the release of a hazardous gas. Therefore the Control Room is not included in this assessment or in Tables 1[2]H-2.

Table 1[2]A-3 & 1[2]H-2 Results Table 1[2]A-3 & 1[2]H-2 Safe Operation & Shutdown Rooms/Areas Unit 1 Room/Area Mode Applicability A-4 Switchgear Room 3, 4 Upper North Electrical Penetration Room 3, 4 Lower South Electrical Equipment Room 3, 4 Unit 2 Room/Area Mode Applicability Aux Building 317 Emergency Core Cooling Rooms 3, 4 Aux Building 317 Tendon Gallery Access 3, 4 Aux Building 335 Charging Pumps / MCC 2B-52 3, 4 Auxiliary Building 354 MCC 2B-62 Area 3, 4 Emergency Diesel Generator Corridor 3, 4 Lower South Piping Penetration Room 3, 4 Aux Building 386 Containment Hatch 3, 4

Enclosure 3 to 0CAN031801 Proposed EAL Technical Basis Document (Clean) to 0CAN031801 Page 1 of 240 Table of Contents Section Page

1.0 INTRODUCTION

.................................................................................................................2 2.0 DISCUSSION ......................................................................................................................2 2.1 Background ................................................................................................................2 2.2 Fission Product Barriers .............................................................................................3 2.3 Fission Product Barrier Classification Criteria ............................................................3 2.4 EAL Organization .......................................................................................................4 2.5 Technical Basis Information .......................................................................................5 2.6 Operations Mode Applicability....................................................................................7 3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS ..........................................8 3.1 General Considerations .............................................................................................8 3.2 Classification Methodology ......................................................................................10

4.0 REFERENCES

..................................................................................................................13 4.1 Developmental .........................................................................................................13 4.2 Implementing............................................................................................................13 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS ...........................................................13 5.1 Definitions (ref. 4.1.1 except as noted) ....................................................................13 5.2 Abbreviations/Acronyms ..........................................................................................18 6.0 ANO-TO-NEI 99-01 Rev. 6 EAL CROSS-REFERENCE ..................................................21 7.0 ATTACHMENTS ...............................................................................................................24 7.1 Attachment 1, Emergency Action Level Technical Bases ........................................24 Category A - Abnormal Rad Levels / Rad Effluents ................................................25 Category C - Cold Shutdown / Refueling System Malfunction ................................65 Category E - Independent Spent Fuel Storage Installation (ISFSI) .......................104 Category F - Fission Product Barrier Degradation ................................................107 Table 1[2]F-1, Fission Product Barrier Threshold Matrix & Bases ...114 Category H - Hazards and Other Conditions Affecting Plant Safety .....................158 Category S - System Malfunction ..........................................................................196 7.2 Attachment 2, Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases .....................................................238 to 0CAN031801 Page 2 of 240

1.0 INTRODUCTION

This document provides an explanation and rationale for each Emergency Action Level (EAL) included in the EAL Upgrade Project for Arkansas Nuclear One (ANO). It should be used to facilitate review of the ANO EALs and provide historical documentation for future reference.

Decision-makers responsible for implementation of 1903.010, Emergency Action Level Classification, may use this document as a technical reference in support of EAL interpretation.

This information may assist the Emergency Director in making classifications, particularly those involving judgment or multiple events. The basis information may also be useful in training and for explaining event classifications to off-site officials.

The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present. Use of this document for assistance is not intended to delay the emergency classification.

Because the information in a basis document can affect emergency classification decision-making (e.g., the Emergency Director refers to it during an event), the NRC staff expects that changes to the basis document will be evaluated in accordance with the provisions of 10 CFR 50.54(q).

2.0 DISCUSSION 2.1 Background EALs are the plant-specific indications, conditions or instrument readings that are utilized to classify emergency conditions defined in the ANO Emergency Plan.

In 1992, the NRC endorsed NUMARC/NESP-007 Methodology for Development of Emergency Action Levels as an alternative to NUREG-0654 EAL guidance.

NEI 99-01 (NUMARC/NESP-007) Revisions 4 and 5 were subsequently issued for industry implementation. Enhancements over earlier revisions included:

Consolidating the system malfunction initiating conditions and example emergency action levels which address conditions that may be postulated to occur during plant shutdown conditions.

Initiating conditions and example emergency action levels that fully address conditions that may be postulated to occur at permanently Defueled Stations and Independent Spent Fuel Storage Installations (ISFSIs).

Simplifying the fission product barrier EAL threshold for a Site Area Emergency.

Subsequently, Revision 6 of NEI 99-01 has been issued which incorporates resolutions to numerous implementation issues including the NRC EAL Frequently Asked Questions (FAQs).

Using NEI 99-01 Revision 6, "Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, November 2012 (ref. 4.1.1), ANO conducted an EAL implementation upgrade project that produced the EALs discussed herein.

to 0CAN031801 Page 3 of 240 2.2 Fission Product Barriers Fission product barrier thresholds represent threats to the defense in depth design concept that precludes the release of radioactive fission products to the environment. This concept relies on multiple physical barriers, any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment.

Many of the EALs derived from the NEI methodology are fission product barrier threshold based. That is, the conditions that define the EALs are based upon thresholds that represent the loss or potential loss of one or more of the three fission product barriers. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. A Loss threshold means the barrier no longer assures containment of radioactive materials.

A Potential Loss threshold implies a greater probability of barrier loss and reduced certainty of maintaining the barrier.

The primary fission product barriers are:

A. Fuel Clad Barrier (FCB): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.

B. Reactor Coolant System Barrier (RCB): The Reactor Coolant System Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.

C. Containment Barrier (CNB): The Containment Barrier includes the Reactor Building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the Reactor Building up to and including the outermost secondary side isolation valve.

Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency.

2.3 Fission Product Barrier Classification Criteria The following criteria are the bases for event classification related to fission product barrier loss or potential loss:

Alert:

Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency:

Loss or potential loss of any two barriers General Emergency:

Loss of any two barriers and loss or potential loss of the third barrier to 0CAN031801 Page 4 of 240 2.4 EAL Organization The ANO EAL scheme includes the following features:

Division of the EAL set into three broad groups:

o EALs applicable under any plant operating modes - This group would be reviewed by the EAL-user any time emergency classification is considered.

o EALs applicable only under hot operating modes - This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby, Startup, or Power Operation mode.

o EALs applicable only under cold operating modes - This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refueling or Defueled mode.

The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency.

Within each group, assignment of EALs to categories and subcategories:

Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. The ANO EAL categories are aligned to and represent the NEI 99-01, Recognition Categories. Subcategories are used in the ANO scheme as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The ANO EAL categories and subcategories are listed below.

The primary tool for determining the emergency classification level is the EAL Classification Matrix. The user of the EAL Classification Matrix may (but is not required to) consult the EAL technical bases in order to obtain additional information concerning the EALs under classification consideration. The user should consult Section 3.0 and Attachment 1 of this document for such information.

to 0CAN031801 Page 5 of 240 EAL Groups, Categories and Subcategories EAL Group/Category EAL Subcategory Any Operating Mode:

A - Abnormal Rad Levels / Rad Effluent 1 - Radiological Effluent 2 - Irradiated Fuel Event 3 - Area Radiation Levels H - Hazards and Other Conditions Affecting 1 - Security Plant Safety 2 - Seismic Event 3 - Natural or Technological Hazard 4 - Fire 5 - Hazardous Gas 6 - Control Room Evacuation 7 - Emergency Director Judgment E - Independent Spent Fuel Storage 1 - Confinement Boundary Installation (ISFSI)

Hot Conditions:

S - System Malfunction 1 - Loss of Essential AC Power 2 - Loss of Vital DC Power 3 - Loss of Control Room Indications 4 - RCS Activity 5 - RCS Leakage 6 - RPS Failure 7 - Loss of Communications 8 - Containment Failure 9 - Hazardous Event Affecting Safety Systems F - Fission Product Barrier Degradation None Cold Conditions:

C - Cold Shutdown / Refueling System 1 - RCS Level Malfunction 2 - Loss of Essential AC Power 3 - RCS Temperature 4 - Loss of Vital DC Power 5 - Loss of Communications 6 - Hazardous Event Affecting Safety Systems 2.5 Technical Bases Information EAL technical bases are provided in Attachment 1 for each EAL according to EAL group (Any, Hot, Cold), EAL category (A, C, E, F, H and S) and EAL subcategory. A summary explanation of each category and subcategory is given at the beginning of the technical bases discussions of the EALs included in the category. For each EAL, the following information is provided:

to 0CAN031801 Page 6 of 240 Category Letter & Title Subcategory Number & Title Initiating Condition (IC)

Site-specific description of the generic IC given in NEI 99-01 Rev. 6.

EAL Identifier (enclosed in rectangle)

Each EAL is assigned a unique identifier to support accurate communication of the emergency classification to onsite and offsite personnel. Four characters define each EAL identifier:

1. First character (letter): Corresponds to the EAL category as described above (A, C, E, F, H or S)
2. Second character (letter): The emergency classification (G, S, A or U)

G = General Emergency S = Site Area Emergency A = Alert U = Unusual Event

3. Third character (number): Subcategory number within the given category. Subcategories are sequentially numbered beginning with the number one (1). If a category does not have a subcategory, this character is assigned the number one (1).
4. Fourth character (number): The numerical sequence of the EAL within the EAL subcategory. If the subcategory has only one EAL, it is given the number one (1).

Classification (enclosed in rectangle):

Unusual Event (U), Alert (A), Site Area Emergency (S) or General Emergency (G)

EAL (enclosed in rectangle)

Exact wording of the EAL as it appears in the EAL Classification Matrix. If an ANO Unit 2 EAL threshold value differs from Unit 1, the Unit 2 threshold is enclosed in brackets. For example, in the EAL threshold RVLMS Levels 1 through 8 indicate DRY [RVLMS Levels 1 through 5 indicate DRY], RVLMS Levels 1 through 5 indicate DRY apply only to Unit 2.

Mode Applicability One or more of the following plant operating conditions comprise the mode to which each EAL is applicable: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling, DEF - Defueled, or Any. (See Section 2.6 for operating mode definitions).

to 0CAN031801 Page 7 of 240 Definitions:

If the EAL wording contains a defined term, the definition of the term is included in this section. These definitions can also be found in Section 5.1.

Basis:

An EAL basis section that provides ANO-relevant information concerning the EAL as well as a description of the rationale for the EAL as provided in NEI 99-01 Rev. 6.

Reference(s):

Source documentation from which the EAL is derived.

2.6 Operating Mode Applicability Unit 1 (ref. 4.1.6):

1 Power Operation Keff 0.99, reactor power > 5%

2 Startup Keff 0.99, reactor power 5%

3 Hot Standby Keff < 0.99, reactor coolant temperature 280°F 4 Hot Shutdown Keff < 0.99, reactor coolant temperature 280°F > Tavg > 200°F and all reactor vessel head closure bolts fully tensioned 5 Cold Shutdown Keff < 0.99, reactor coolant temperature 200°F and all reactor vessel head closure bolts fully tensioned 6 Refueling One or more reactor vessel head closure bolts less than fully tensioned DEF Defueled All fuel assemblies have been removed from Containment and placed in the spent fuel pool.

to 0CAN031801 Page 8 of 240 Unit 2 (ref. 4.1.6):

1 Power Operation Keff 0.99, reactor power > 5%, average coolant temperature 300°F 2 Startup Keff 0.99, reactor power 5%, average coolant temperature 300°F 3 Hot Standby Keff < 0.99, average coolant temperature 300°F 4 Hot Shutdown Keff < 0.99, average coolant temperature 300°F > Tavg > 200°F 5 Cold Shutdown Keff < 0.99, average coolant temperature 200°F 6 Refueling Keff 0.95, average coolant temperature 140°F, reactor vessel head unbolted or removed, and fuel in the vessel.

DEF Defueled All fuel assemblies have been removed from Containment and placed in the spent fuel pool.

The plant operating mode that exists at the time that the event occurs (prior to any protective system or operator action being initiated in response to the condition) should be compared to the mode applicability of the EALs. If a lower or higher plant operating mode is reached before the emergency classification is made, the declaration shall be based on the mode that existed at the time the event occurred.

3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 3.1 General Considerations When making an emergency classification, the Emergency Director must consider all information having a bearing on the proper assessment of an Initiating Condition (IC). This includes the Emergency Action Level (EAL) plus the associated Operating Mode Applicability, Notes, and the informing basis information. In the Recognition Category F matrices, EALs are based on loss or potential loss of Fission Product Barrier Thresholds.

EAL matrices shall be read from left to right, from General Emergency to Unusual Event, and top to bottom. Declaration decisions shall be independently verified before declaration is made except when gaining this verification would exceed the 15 minute declaration requirement.

Place keeping shall be used on all EAL matrices.

to 0CAN031801 Page 9 of 240 3.1.1 Classification Timeliness NRC regulations require the licensee to establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and to promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. The NRC staff has provided guidance on implementing this requirement in NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants" (ref. 4.1.8).

3.1.2 Valid Indications All emergency classification assessments shall be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicators operability, the conditions existence, or the reports accuracy. For example, verification could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by plant personnel.

An indication, report, or condition is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

3.1.3 Imminent Conditions For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the Emergency Director 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. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary.

3.1.4 Planned vs. Unplanned Events A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that: 1) the activity proceeds as planned, and 2) the plant remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain or modify a system or component. In these cases, the controls associated with the planning, preparation and execution of the work will ensure that compliance is maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10 CFR 50.72 (ref. 4.1.4).

3.1.5 Classification Based on Analysis The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., dose assessments, chemistry sampling, RCS leak rate calculation, etc.). For these EALs, the EAL wording or the to 0CAN031801 Page 10 of 240 associated basis discussion will identify the necessary analysis. In these cases, the 15-minute declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available). The NRC expects licensees to establish the capability to initiate and complete EAL-related analyses within a reasonable period of time (e.g., maintain the necessary expertise on-shift).

3.1.6 Emergency Director Judgment While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 EAL scheme provides the Emergency Director with the ability to classify events and conditions based upon judgment using EALs that are consistent with the Emergency Classification Level (ECL) definitions (refer to Category H). The Emergency Director will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.

A similar provision is incorporated in the Fission Product Barrier Tables; judgment may be used to determine the status of a fission product barrier.

3.2 Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e., the relevant plant indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL must be consistent with the related Operating Mode Applicability and Notes. If an EAL has been met or exceeded, the associated IC is likewise met, the emergency classification process clock starts, and the ECL must be declared in accordance with plant procedures no later than fifteen minutes after the process clock started.

When assessing an EAL that specifies a time duration for the off-normal condition, the clock for the EAL time duration runs concurrently with the emergency classification process clock.

For a full discussion of this timing requirement, refer to NSIR/DPR-ISG-01 (ref. 4.1.8).

3.2.1 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared. For example:

If an Alert EAL and a Site Area Emergency EAL are met, whether at one unit or at two units, a Site Area Emergency should be declared.

There is no additive effect from multiple EALs meeting the same ECL. For example:

If two Alert EALs are met, whether at one unit or at two units, an Alert should be declared.

3.2.2 Consideration of Mode Changes During Classification The mode in effect at the time that an event or condition occurred, and prior to any plant or operator response, is the mode that determines whether or not an IC is applicable. If an event or condition occurs, and results in a mode change before the emergency is declared, the emergency classification level is still based on the mode that existed at the time that the event to 0CAN031801 Page 11 of 240 or condition was initiated (and not when it was declared). Once a different mode is reached, any new event or condition, not related to the original event or condition, requiring emergency classification should be evaluated against the ICs and EALs applicable to the operating mode at the time of the new event or condition.

For events that occur in Cold Shutdown or Refueling, escalation is via EALs that are applicable in the Cold Shutdown or Refueling modes, even if Hot Shutdown (or a higher mode) is entered during the subsequent plant response. In particular, the fission product barrier EALs are applicable only to events that initiate in the Hot Shutdown mode or higher.

3.2.3 Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Director must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Emergency Director, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all emergency classification levels, this approach is particularly important at the higher emergency classification levels since it provides additional time for implementation of protective measures.

3.2.4 Emergency Classification Level Upgrading and Termination An ECL may be terminated when the event or condition that meets the classified IC and EAL no longer exists, and other site-specific termination requirements are met.

3.2.5 Classification of Short-Lived Events Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration. Examples of such events include an earthquake or a failure of the reactor protection system to automatically trip the reactor followed by a successful manual trip.

3.2.6 Classification of Transient Conditions Many of the ICs and/or EALs employ time-based criteria. These criteria will require that the IC/EAL conditions be present for a defined period of time before an emergency declaration is warranted. In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes). The following guidance should be applied to the classification of these conditions.

EAL momentarily met during expected plant response - In instances in which an EAL is briefly met during an expected (normal) plant response, an emergency declaration is not warranted provided that associated systems and components are operating as expected, and operator actions are performed in accordance with procedures.

to 0CAN031801 Page 12 of 240 EAL momentarily met but the condition is corrected prior to an emergency declaration - If an operator takes prompt manual action to address a condition, and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required. For illustrative purposes, consider the following example:

An ATWS occurs and the high pressure ECCS systems fail to automatically start. The plant enters an inadequate core cooling condition (a potential loss of both the Fuel Clad and RCS Barriers). If an operator manually starts a high pressure ECCS system in accordance with an EOP step and clears the inadequate core cooling condition prior to an emergency declaration, then the classification should be based on the ATWS only.

It is important to stress that the 15-minute emergency classification assessment period (process clock) is not a grace period during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event. Emergency classification assessments must be deliberate and timely, with no undue delays. The provision discussed above addresses only those rapidly evolving situations when an operator is able to take a successful corrective action prior to the Emergency Director completing the review and steps necessary to make the emergency declaration. This provision is included to ensure that any public protective actions resulting from the emergency classification are truly warranted by the plant conditions.

3.2.7 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery. This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.

In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022 (ref. 4.1.3) is applicable. Specifically, the event should be reported to the NRC in accordance with 10 CFR § 50.72 (ref. 4.1.4) within one hour of the discovery of the undeclared event or condition. The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.

3.2.8 Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022 (ref. 4.1.3).

to 0CAN031801 Page 13 of 240

4.0 REFERENCES

4.1 Developmental 4.1.1 NEI 99-01 Revision 6, Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, ADAMS Accession Number ML12326A805 4.1.2 RIS 2007-02 Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2, 2007.

4.1.3 NUREG-1022 Event Reporting Guidelines: 10CFR50.72 and 50.73 4.1.4 10 § CFR 50.72 Immediate Notification Requirements for Operating Nuclear Power Reactors 4.1.5 10 § CFR 50.73 License Event Report System 4.1.6 Unit 1[2] Technical Specifications Table 1.1-1[1.1], Modes[Operational Modes]

4.1.7 Arkansas Nuclear One Offsite Dose Calculation Manual (ODCM) 4.1.8 NSIR/DPR-ISG-01 Interim Staff Guidance, Emergency Planning for Nuclear Power Plants 4.1.9 Arkansas Nuclear One Emergency Plan 4.1.10 1015.008 Unit 2 SDC Control 4.2 Implementing 4.2.1 1903.010 Emergency Action Level Classification 4.2.2 NEI 99-01 Rev. 6 to ANO EAL Comparison Matrix 4.2.3 ANO EAL Matrix 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS 5.1 Definitions (ref. 4.1.1 except as noted)

Selected terms used in Initiating Condition, Emergency Action Level statements and EAL bases are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.

Alert 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.

to 0CAN031801 Page 14 of 240 Confinement Boundary The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).

Containment Closure The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions (ref. 4.1.10).

As applied to ANO, Containment Closure must be capable of being set within 30 minutes.

Containment Closure is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

Emergency Action Level (EAL)

A pre-determined, site-specific, observable threshold for an INITIATING CONDITION that, when met or exceeded, places the plant in a given emergency classification level.

Emergency Classification Level (ECL)

One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:

Unusual Event (UE)

Alert Site Area Emergency (SAE)

General Emergency (GE)

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 require a post-event inspection to determine if the attributes of an explosion are present.

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.

to 0CAN031801 Page 15 of 240 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.

Fission Product Barrier Threshold A pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier.

Flooding A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

General Emergency 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 PAG exposure levels offsite for more than the immediate site area.

Hostage A person(s) held as leverage against the station to ensure that demands will be met by the station.

Hostile Action An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

Hostile Force One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

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

to 0CAN031801 Page 16 of 240 Impede(d)

Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

Independent Spent Fuel Storage Installation (ISFSI)

A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

Initiating Condition (IC)

An event or condition that aligns with the definition of one of the four emergency classification levels by virtue of the potential or actual effects or consequences.

Owner Controlled Area (OCA)

For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line. Access to this area is controlled by the SOCA Personnel Access Control Point (ref. 4.1.9).

Projectile An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

Protected Area An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled (ref. 4.1.9).

RCS Intact The RCS should be considered intact when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams).

Refueling Pathway All the cavities, tubes, canals and pools through which irradiated fuel may be moved, but not including the reactor vessel.

Ruptured The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).

to 0CAN031801 Page 17 of 240 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 (as defined in 10 CFR 50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Security Condition Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A Security Condition does not involve a HOSTILE ACTION.

Site Area Emergency 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 PAG exposure levels beyond the SITE BOUNDARY.

Site Boundary That boundary defined by a 1046 meter (0.65 mile) radius around the plant (ref. 4.1.7).

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.

Unusual Event Events are in progress or have occurred which indicate a potential degradation in 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.

to 0CAN031801 Page 18 of 240 Valid An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Visible Damage Damage to a SAFETY SYSTEM train 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 SAFETY SYSTEM train.

5.2 Abbreviations/Acronyms

°F .................................................................................................................... Degrees Fahrenheit

°......................................................................................................................................... Degrees AC ..................................................................................................................... Alternating Current ANO ............................................................................................................ Arkansas Nuclear One AOP .............................................................................................. Abnormal Operating Procedure ATWS.................................................................................... Anticipated Transient Without Scram BMS ................................................................................................... Boron Management System BWST................................................................................................ Borated Water Storage Tank CDE ................................................................................................... Committed Dose Equivalent CET .......................................................................................................... Core Exit Thermocouple CFR................................................................................................... Code of Federal Regulations CIAS.................................................................................. Containment Isolation Actuation Signal CMT, CNTMT, CTMT ..................................................................................................Containment CNB ................................................................................................................ Containment Barrier DBA............................................................................................................. Design Basis Accident DBE......................................................................................................... Design Basis Earthquake DC .............................................................................................................................Direct Current DEF ...................................................................................................................................Defueled D/G....................................................................................................................... Diesel Generator DHR .............................................................................................................. Decay Heat Removal DROPS ............................................................ Diverse Reactor Overpressure Protection System DSC ............................................................................................................. Dry Shielded Canister to 0CAN031801 Page 19 of 240 DSS............................................................................................................ Diverse Scram System EAL .......................................................................................................... Emergency Action Level ECCS ......................................................................................... Emergency Core Cooling System ECL ............................................................................................... Emergency Classification Level DEF ...................................................................................................................................Defueled ENS............................................................................................... Emergency Notification System EOF................................................................................................ Emergency Operations Facility EOP ........................................................................................... Emergency Operating Procedure EPA ............................................................................................ Environmental Protection Agency ERG ............................................................................................ Emergency Response Guideline EPIP ............................................................................. Emergency Plan Implementing Procedure ESAS ........................................................................... Engineered Safeguards Actuation System ESF ...................................................................................................... Engineered Safety Feature ESFAS .................................................................. Engineered Safety Features Actuation System FAA ............................................................................................... Federal Aviation Administration FBI ................................................................................................ Federal Bureau of Investigation FCB ...................................................................................................................... Fuel Clad Barrier FEMA ............................................................................ Federal Emergency Management Agency GE ................................................................................................................... General Emergency HPI ............................................................................................................. High Pressure Injection IC ...................................................................................................................... Initiating Condition IPEEE ............................. Individual Plant Examination of External Events (Generic Letter 88-20)

ISFSI ......................................................................... Independent Spent Fuel Storage Installation Keff ...................................................................................... Effective Neutron Multiplication Factor LCO................................................................................................Limiting Condition of Operation LER .............................................................................................................Licensee Event Report LOCA ...................................................................................................... Loss of Coolant Accident LRW ....................................................................................................................Liquid Rad Waste LTOP............................................................................................ Low Temperature Overpressure LWR ................................................................................................................ Light Water Reactor MCC .............................................................................................................. Motor Control Center MPC ................................................ Maximum Permissible Concentration/Multi-Purpose Canister mR, mRem, mrem, mREM ............................................................ milli-Roentgen Equivalent Man MSL...................................................................................................................... Main Steam Line to 0CAN031801 Page 20 of 240 MTS ................................................................................................................ Margin to Saturation MW.................................................................................................................................. Megawatt NDTT ...................................................................................... Nil Ductility Transition Temperature NEI ............................................................................................................Nuclear Energy Institute NEIC ................................................................................ National Earthquake Information Center NESP ................................................................................ National Environmental Studies Project NORAD ................................................................ North American Aerospace Defense Command NOT .............................................................................................. Normal Operating Temperature (NO)UE ............................................................................................. Notification of Unusual Event NPP................................................................................................................ Nuclear Power Plant NRC ............................................................................................ Nuclear Regulatory Commission NSSS ............................................................................................. Nuclear Steam Supply System OBE ................................................................................................... Operating Basis Earthquake OCA ........................................................................................................... Owner Controlled Area ODCM ........................................................................................ Off-site Dose Calculation Manual ORO ............................................................................................... Offsite Response Organization PA ........................................................................................................................... Protected Area PAG ..................................................................................................... Protective Action Guideline PRA/PSA .................................. Probabilistic Risk Assessment / Probabilistic Safety Assessment P-T .............................................................................................................. Pressure-Temperature PTS ..................................................................................................... Pressurized Thermal Shock PWR..................................................................................................... Pressurized Water Reactor PSIG ............................................................................................ Pounds per Square Inch Gauge R ..................................................................................................................................... Roentgen RB .........................................................................................................................Reactor Building RCC ......................................................................................................... Reactor Control Console RCB ............................................................................................. Reactor Coolant System Barrier RCP ............................................................................................................ Reactor Coolant Pump RCS ......................................................................................................... Reactor Coolant System Rem, rem, REM ..................................................................................... Roentgen Equivalent Man Rep CET ....................................................................... Representative Core Exit Thermocouples RETS ...................................................................... Radiological Effluent Technical Specifications RPS...................................................................................................... Reactor Protection System RV ...........................................................................................................................Reactor Vessel to 0CAN031801 Page 21 of 240 RVLMS........................................................................... Reactor Vessel Level Monitoring System RWT ............................................................................................................. Refueling Water Tank SAR.............................................................................................................Safety Analysis Report SBO ...................................................................................................................... Station Blackout SCBA ................................................................................... Self-Contained Breathing Apparatus SDC ................................................................................................................... Shutdown Cooling SOCA ........................................................................................... Security Owner Controlled Area SG ....................................................................................................................... Steam Generator SI............................................................................................................................ Safety Injection SPDS ........................................................................................ Safety Parameter Display System SPING ..................................................................................... Super Particulate Iodine Noble Gas SRO ......................................................................................................... Senior Reactor Operator TEDE ............................................................................................ Total Effective Dose Equivalent TOAF ................................................................................................................. Top of Active Fuel TSC ........................................................................................................ Technical Support Center USGS .......................................................................................... United States Geological Survey VBS ............................................................................................................ Vehicle Barrier System 6.0 ANO-TO-NEI 99-01 REV. 6 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of an ANO EAL within the NEI 99-01 IC/EAL identification scheme. Further information regarding the development of the ANO EALs based on the NEI guidance can be found in the EAL Comparison Matrix.

ANO NEI 99-01 Rev. 6 EAL IC Example EAL AU1.1 AU1 1, 2 AU1.2 AU1 3 AU2.1 AU2 1 AA1.1 AA1 1 AA1.2 AA1 2 AA1.3 AA1 3 AA1.4 AA1 4 AA2.1 AA2 1 to 0CAN031801 Page 22 of 240 ANO NEI 99-01 Rev. 6 EAL IC Example EAL AA2.2 AA2 2 AA2.3 AA2 3 AA3.1 AA3 1 AA3.2 AA3 2 AS1.1 AS1 1 AS1.2 AS1 2 AS1.3 AS1 3 AS2.1 AS2 1 AG1.1 AG1 1 AG1.2 AG1 2 AG1.3 AG1 3 AG2.1 AG2 1 CU1.1 CU1 1 CU1.2 CU1 2 CU2.1 CU2 1 CU3.1 CU3 1 CU3.2 CU3 2 CU4.1 CU4 1 CU5.1 CU5 1, 2, 3 CA1.1 CA1 1 CA1.2 CA1 2 CA2.1 CA2 1 CA3.1 CA3 1, 2 CA6.1 CA6 1 CS1.1 CS1 1 CS1.2 CS1 2 CS1.3 CS1 3 CG1.1 CG1 1 CG1.2 CG1 2 EU1.1 EU1 1 FA1.1 FA1 1 to 0CAN031801 Page 23 of 240 ANO NEI 99-01 Rev. 6 EAL IC Example EAL FS1.1 FS1 1 FG1.1 FG1 1 HU1.1 HU1 1, 2, 3 HU2.1 HU2 1 HU3.1 HU3 1 HU3.2 HU3 2 HU3.3 HU3 3 HU3.4 HU3 4 HU4.1 HU4 1 HU4.2 HU4 2 HU4.3 HU4 3 HU4.4 HU4 4 HU7.1 HU7 1 HA1.1 HA1 1, 2 HA5.1 HA5 1 HA6.1 HA6 1 HA7.1 HA7 1 HS1.1 HS1 1 HS6.1 HS6 1 HS7.1 HS7 1 HG7.1 HG7 1 SU1.1 SU1 1 SU3.1 SU2 1 SU4.1 SU3 1 SU4.2 SU3 2 SU5.1 SU4 1, 2, 3 SU6.1 SU5 1 SU6.2 SU5 2 SU7.1 SU6 1, 2, 3 SU8.1 SU7 1, 2 SA1.1 SA1 1 to 0CAN031801 Page 24 of 240 ANO NEI 99-01 Rev. 6 EAL IC Example EAL SA3.1 SA2 1 SA6.1 SA5 1 SA9.1 SA9 1 SS1.1 SS1 1 SS2.1 SS8 1 SS6.1 SS5 1 SG1.1 SG1 1 SG1.2 SG8 1 7.0 ATTACHMENTS 7.1 Attachment 1, Emergency Action Level Technical Bases 7.2 Attachment 2, Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases to 0CAN031801 Page 25 of 240 Attachment 1 - Emergency Action Level Technical Bases Category A - Abnormal Rad Levels / Rad Effluent EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

Many EALs are based on actual or potential degradation of fission product barriers because of the elevated potential for offsite radioactivity release. Degradation of fission product barriers though is not always apparent via non-radiological symptoms. Therefore, direct indication of elevated radiological effluents or area radiation levels are appropriate symptoms for emergency classification.

At lower levels, abnormal radioactivity releases may be indicative of a failure of containment systems or precursors to more significant releases. At higher release rates, offsite radiological conditions may result which require offsite protective actions. Elevated area radiation levels in plant may also be indicative of the failure of containment systems or preclude access to plant vital equipment necessary to ensure plant safety.

Events of this category pertain to the following subcategories:

1. Radiological Effluent Direct indication of effluent radiation monitoring systems provides a rapid assessment mechanism to determine releases in excess of classifiable limits. Projected offsite doses, actual offsite field measurements or measured release rates via sampling indicate doses or dose rates above classifiable limits.
2. Irradiated Fuel Event Conditions indicative of a loss of adequate shielding or damage to irradiated fuel may preclude access to vital plant areas or result in radiological releases that warrant emergency classification.
3. Area Radiation Levels Sustained general area radiation levels which may preclude access to areas requiring continuous occupancy also warrant emergency classification.

to 0CAN031801 Page 26 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:

AU1.1 Unusual Event Reading on any Table 1[2]A-1 effluent radiation monitor > column "UE" for 60 min.

(Notes 1, 2, 3)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: 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.

Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm to 0CAN031801 Page 27 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses a potential reduction 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.

to 0CAN031801 Page 28 of 240 Attachment 1 - Emergency Action Level Technical Bases 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.

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.

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways as well as radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit.

Such releases are typically associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).

Escalation of the emergency classification level would be via IC AA1.

Reference(s):

1. OP-1604.051 Eberline Radiation Monitor System
2. Offsite Dose Calculation Manual
3. EP-CALC-ANO-1701 Radiological Effluent EAL Values
4. NEI 99-01 AU1 to 0CAN031801 Page 29 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:

AU1.2 Unusual Event Sample analysis for a gaseous or liquid release indicates a concentration or release rate 2 x ODCM limits for 60 min. (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

None Basis:

This IC addresses a potential reduction 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.

to 0CAN031801 Page 30 of 240 Attachment 1 - Emergency Action Level Technical Bases Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

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 AA1.

Reference(s):

1. Offsite Dose Calculation Manual
2. NEI 99-01 AU1 to 0CAN031801 Page 31 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.1 Alert Reading on any Table 1[2]A-1 effluent radiation monitor > column "ALERT" for 15 min.

(Notes 1, 2, 3, 4)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: 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.

Note 4 The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm to 0CAN031801 Page 32 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

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.

to 0CAN031801 Page 33 of 240 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1604.051 Eberline Radiation Monitor System
2. EP-CALC-ANO-1701 Radiological Effluent EAL Values
3. NEI 99-01 AA1 to 0CAN031801 Page 34 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.2 Alert Dose assessment using actual meteorology indicates doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)

Note 4: The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

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 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1904.002 Offsite Dose Projections
2. NEI 99-01 AA1 to 0CAN031801 Page 35 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.3 Alert Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY for 60 min. of exposure (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

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 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

This EAL is assessed per the ODCM (ref. 2).

Escalation of the emergency classification level would be via IC AS1.

to 0CAN031801 Page 36 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1904.002 Offsite Dose Projections
2. Offsite Dose Calculation Manual
3. NEI 99-01 AA1 to 0CAN031801 Page 37 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.4 Alert Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 10 mR/hr expected to continue for 60 min.

Analyses of field survey samples indicate thyroid CDE > 50 mrem for 60 min. of inhalation (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

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.

to 0CAN031801 Page 38 of 240 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1905.002 Offsite Emergency Monitoring
2. NEI 99-01 AA1 to 0CAN031801 Page 39 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

AS1.1 Site Area Emergency Reading on any Table A-1 effluent radiation monitor > column "SAE" for 15 min.

(Notes 1, 2, 3, 4)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: 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.

Note 4: The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm to 0CAN031801 Page 40 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

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.

to 0CAN031801 Page 41 of 240 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

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.

Escalation of the emergency classification level would be via IC AG1.

Reference(s):

1. OP-1604.051 Eberline Radiation Monitor System
2. EP-CALC-ANO-1701 Radiological Effluent EAL Values
3. NEI 99-01 AS1 to 0CAN031801 Page 42 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

AS1.2 Site Area Emergency Dose assessment using actual meteorology indicates doses > 100 mrem TEDE or 500 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)

Note 4 The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant).

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 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC AG1.

Reference(s):

1. OP-1904.002 Offsite Dose Projections
2. NEI 99-01 AS1 to 0CAN031801 Page 43 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

AS1.3 Site Area Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 100 mR/hr expected to continue for 60 min.

Analyses of field survey samples indicate thyroid CDE > 500 mrem for 60 min. of inhalation (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

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 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC AG1.

to 0CAN031801 Page 44 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1905.002 Offsite Emergency Monitoring
2. NEI 99-01 AS1 to 0CAN031801 Page 45 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

AG1.1 General Emergency Reading on any Table A-1 effluent radiation monitor > column "GE" for 15 min.

(Notes 1, 2, 3, 4)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: 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.

Note 4: The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm to 0CAN031801 Page 46 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

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.

to 0CAN031801 Page 47 of 240 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

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.

Reference(s):

1. OP-1604.051 Eberline Radiation Monitor System
2. EP-CALC-ANO-1701 Radiological Effluent EAL Values
3. NEI 99-01 AG1 to 0CAN031801 Page 48 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

AG1.2 General Emergency Dose assessment using actual meteorology indicates doses > 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)

Note 4 The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant).

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 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Reference(s):

1. OP-1904.002 Offsite Dose Projections
2. NEI 99-01 AG1 to 0CAN031801 Page 49 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

AG1.3 General Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 1,000 mR/hr expected to continue for 60 min.

Analyses of field survey samples indicate thyroid CDE > 5,000 mrem for 60 min. of inhalation (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

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 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

to 0CAN031801 Page 50 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1905.002 Offsite Emergency Monitoring
2. NEI 99-01 AG1 to 0CAN031801 Page 51 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: UNPLANNED loss of water level above irradiated fuel EAL:

AU2.1 Unusual Event UNPLANNED water level drop in the REFUELING PATHWAY as indicated by low water level alarm, visual observation, or BWST[RWT] level drop due to makeup demands AND UNPLANNED rise in corresponding area radiation levels as indicated by any of the following radiation monitors:

Unit 1 o RE-8009 Spent Fuel Area o RE-8017 Fuel Handling Area Unit 2 o 2RE-8914 Spent Fuel Area o 2RE-8915 Spent Fuel Area o 2RE-8916 Spent Fuel Area o 2RE-8912 Containment Incore Instrumentation Mode Applicability:

All Definition(s):

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, but not including the reactor vessel.

to 0CAN031801 Page 52 of 240 Attachment 1 - Emergency Action Level Technical Bases Basis:

This IC addresses a drop 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 drop 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). A significant drop in the water level may also cause a rise in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may rise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

Escalation of the emergency classification level would be via IC AA2.

Reference(s):

1. OP-1203.050 Unit 1 Spent Fuel Pool Emergencies
2. OP-2203.002 Spent Fuel Pool Emergencies
3. 1SAR 11.2.5 Area Radiation Monitoring Systems Table 11-15 Area Radiation Monitors
4. 2SAR 12.1.4 Area Radiation Monitoring System
5. NEI 99-01 AU2 to 0CAN031801 Page 53 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

AA2.1 Alert IMMINENT uncovery of irradiated fuel in the REFUELING PATHWAY.

Mode Applicability:

All Definition(s):

CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).

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.

REFUELING PATHWAY - All the cavities, tubes, canals and pools through which irradiated fuel may be moved, but not including the reactor vessel.

Basis:

This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the REFUELING PATHWAY. 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 EU1.

This EAL escalates from AU2.1 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.

to 0CAN031801 Page 54 of 240 Attachment 1 - Emergency Action Level Technical Bases While an area radiation monitor could detect a rise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance with Recognition Category C during the Cold Shutdown and Refueling modes.

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. NEI 99-01 AA2 to 0CAN031801 Page 55 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

AA2.2 Alert Damage to irradiated fuel resulting in a release of radioactivity AND High alarm on any Table 1[2]A-2 radiation monitor.

Table 1A-2 Unit 1 Fuel Damage Radiation Monitors RE-8009 Spent Fuel Area RE-8017 Fuel Handling RE-8060 Containment High Range Radiation Monitors RE-8061 Containment High Range Radiation Monitors RX-9820 (SPING 1) Containment Purge RX-9825 (SPING 2) Radwaste Area RX-9830 (SPING 3) Fuel Handling Area Table 2A-2 Unit 2 Fuel Damage Radiation Monitors 2RE-8905 Containment Equipment Hatch Area 2RE-8909 Containment Personnel Access Area 2RE-8912 Containment Incore Inst.

2RE-8914 Spent Fuel Area 2RE-8915 Spent Fuel Area 2RE-8916 Spent Fuel Area 2RE-8925-1 Containment High Range Radiation Monitors 2RE-8925-2 Containment High Range Radiation Monitors 2RX-9820 (SPING 5) Containment Purge 2RX-9825 (SPING 6) Radwaste Area 2RX-9830 (SPING 7) Fuel Handling Area to 0CAN031801 Page 56 of 240 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

All Definition(s):

CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This EAL addresses events that have caused actual damage to an irradiated fuel assembly.

These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

This EAL 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 EU1.

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 classification level would be via IC AS1.

Reference(s):

1. OP-1203.050 Unit 1 Spent Fuel Pool Emergencies
2. OP-1305.001 Radiation Monitoring System Check and Test
3. OP-2203.002 Spent Fuel Pool Emergencies
4. OP-1604.051 Eberline Radiation Monitoring System
5. OP-2304.133 Containment High Range Radiation Monitor Calibration
6. Offsite Dose Calculation Manual
7. NEI 99-01 AA2 to 0CAN031801 Page 57 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

AA2.3 Alert Lowering of spent fuel pool level to 387.0 ft.[389.5 ft.] (Alarm 2) on LIT-2020-3(4)

[2LIT-2020-1(2)]

Mode Applicability:

All Definition(s):

None Basis:

This EAL addresses events that have caused a significant lowering of water level within the spent fuel pool. 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.

Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.

Escalation of the emergency classification level would be via IC AS1 or AS2.

Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).

Reference(s):

1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0
2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0
3. NEI 99-01 AA2 to 0CAN031801 Page 58 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Spent fuel pool level at the top of the fuel racks EAL:

AS2.1 Site Area Emergency Lowering of spent fuel pool level to 377.0 ft.[379.5 ft.] (Alarm 3) on LIT-2020-3(4)

[2LIT-2020-1(2)]

Mode Applicability:

All Definition(s):

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.

Basis:

This EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to IMMINENT fuel damage. This condition entails major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

It is recognized that this IC would likely not be met until well after another Site Area Emergency IC was met; however, it is included to provide classification diversity.

Escalation of the emergency classification level would be via IC AG1 or AG2.

Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).

Reference(s):

1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0
2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0
3. NEI 99-01 AS2 to 0CAN031801 Page 59 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Spent fuel pool level cannot be restored to at least the top of the fuel racks for 60 minutes or longer EAL:

AG2.1 General Emergency Spent fuel pool level cannot be restored to at least 377.0 ft.[379.5 ft.] (Alarm 3) on LIT-2020-3(4)[2LIT-2020-1(2)] for 60 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

All Definition(s):

None Basis:

This EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment.

It is recognized that this IC would likely not be met until well after another General Emergency IC was met; however, it is included to provide classification diversity.

Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).

Reference(s):

1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0
2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0
3. NEI 99-01 AG2 to 0CAN031801 Page 60 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 3 - Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

AA3.1 Alert Dose rate > 15 mR/hr in EITHER of the following areas:

Control Room Central Alarm Station (by survey)

Mode Applicability:

All Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

Basis:

Areas that meet this threshold include the Control Room (CR) and the Central Alarm Station (CAS). The Control Room envelope (Unit 1 and Unit 2) is monitored for excessive radiation by five detectors. These radiation detectors are RE-8001, 2RE-8001A, 2RE-8001B, 2RE-8750-1A, and 2RE-8750-1B (ref. 1). The CAS is included in this EAL because of its importance to permitting access to areas required to assure safe plant operations. There are no permanently installed area radiation monitors in CAS that may be used to assess this EAL threshold.

Therefore, this threshold is evaluated using local radiation survey for this area.

This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or IMPEDE personnel from performing actions necessary to maintain normal plant operation, or to perform 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 rise in radiation levels and determine if another IC may be applicable.

Escalation of the emergency classification level would be via Recognition Category A, C or F ICs.

to 0CAN031801 Page 61 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. STM 1-62 Radiation Monitoring
2. NEI 99-01 AA3 to 0CAN031801 Page 62 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 3 - Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

AA3.2 Alert An UNPLANNED event results in radiation levels that prohibit or IMPEDE access to any Table 1[2]A-3 room or area (Note 5)

Note 5: 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.

Table 1A-3 Unit 1 Safe Operation & Shutdown Rooms/Areas Room/Area Mode A-4 Switchgear Room 3, 4 Upper North Electrical Penetration Room 3, 4 Lower South Electrical Equipment Room 3, 4 Table 2A-3 Unit 2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux Building 317 Emergency Core Cooling Rooms 3, 4 Aux Building 317 Tendon Gallery Access 3, 4 Aux Building 335 Charging Pumps / MCC 2B-52 3, 4 Aux Building 354 MCC 2B-62 Area 3, 4 Emergency Diesel Generator Corridor 3, 4 Lower South Piping Penetration Room 3, 4 Aux Building 386 Containment Hatch 3, 4 to 0CAN031801 Page 63 of 240 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

3 - Hot Standby, 4 - Hot Shutdown Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

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.

Basis:

This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or IMPEDE personnel from performing actions necessary to maintain normal plant operation, or to perform 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 rise in radiation levels and determine if another IC may be applicable.

For AA3.2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the elevated radiation levels. The emergency classification is not contingent upon whether entry is actually necessary at the time of the higher 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, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).

An emergency declaration is not warranted if any of the following conditions apply:

The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation rise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 3.

The higher 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 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 A, C or F ICs.

to 0CAN031801 Page 64 of 240 Attachment 1 - Emergency Action Level Technical Bases If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact beyond that already allowed by Technical Specifications at the time of the event.

The list of plant rooms or areas with entry-related mode applicability identified specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations) are not included. In addition, the list specifies the plant mode(s) during which entry would be required for each room or area (ref. 1).

EAL AA3.2 mode applicability has been limited to the mode limitations of Table 1[2]A-3 (Modes 3 and 4 only).

Reference(s):

1. Attachment 2 Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases
2. NEI 99-01 AA3 to 0CAN031801 Page 65 of 240 Attachment 1 - Emergency Action Level Technical Bases Category C - Cold Shutdown / Refueling System Malfunction EAL Group: Cold Conditions (RCS temperature 200°F); EALs in this category are applicable only in one or more cold operating modes.

Category C EALs are directly associated with cold shutdown or refueling system safety functions. Given the variability of plant configurations (e.g., systems out-of-service for maintenance, containment open, reduced AC power redundancy, time since shutdown) during these periods, the consequences of any given initiating event can vary greatly. For example, a loss of decay heat removal capability that occurs at the end of an extended outage has less significance than a similar loss occurring during the first week after shutdown. Compounding these events is the likelihood that instrumentation necessary for assessment may also be inoperable. The cold shutdown and refueling system malfunction EALs are based on performance capability to the extent possible with consideration given to RCS integrity, CONTAINMENT CLOSURE, and fuel clad integrity for the applicable operating modes (5 - Cold Shutdown, 6 - Refueling, DEF - Defueled).

The events of this category pertain to the following subcategories:

1. RCS Level RCS water level is directly related to the status of adequate core cooling and, therefore, fuel clad integrity.
2. Loss of Vital AC Power Loss of vital plant electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite power sources for 4.16 KV vital buses.
3. RCS Temperature Uncontrolled or inadvertent temperature or pressure rises are indicative of a potential loss of safety functions.
4. Loss of Vital DC Power Loss of emergency plant electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of power to or degraded voltage on the 125V DC vital buses.
5. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.
6. Hazardous Event Affecting Safety Systems Certain hazardous natural and technological events may result in VISIBLE DAMAGE to or degraded performance of safety systems warranting classification.

to 0CAN031801 Page 66 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory EAL:

CU1.1 Unusual Event UNPLANNED loss of reactor coolant results in RCS water level less than a required lower limit for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

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.

Basis:

This EAL addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.

Refueling evolutions that lower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level lowering below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.

This EAL recognizes that the minimum required RCS level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.

to 0CAN031801 Page 67 of 240 Attachment 1 - Emergency Action Level Technical Bases The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.

Reference(s):

1. OP-1015.002 Decay Heat Removal and LTOP System
2. OP-1015.008 Unit 2 SDC Control
3. NEI 99-01 CU1 to 0CAN031801 Page 68 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory EAL:

CU1.2 Unusual Event RCS level cannot be monitored AND EITHER UNPLANNED rise in any Table 1[2]C-1 sump/tank level due to loss of RCS inventory Visual observation of UNISOLABLE RCS leakage Table 1C-1 Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank Table 2C-1 Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)

Holdup Tank Aux. Building Sump Quench Tank Mode Applicability:

5 - Cold Shutdown, 6 - Refueling to 0CAN031801 Page 69 of 240 Attachment 1 - Emergency Action Level Technical Bases Definition(s):

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.

Basis:

This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.

Refueling evolutions that lower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level lowering below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.

This EAL addresses a condition where all means to determine RCS level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels (Table C-1). Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.

Reference(s):

1. OP-1203.039 Excess RCS Leakage
2. OP-2203.016 Excess RCS Leakage
3. NEI 99-01 CU1 to 0CAN031801 Page 70 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Significant Loss of RCS inventory EAL:

CA1.1 Alert Loss of RCS inventory as indicated by EITHER:

RVLMS Levels 1 through 8[1 through 5] indicate DRY Reactor vessel level 368.5 ft. (LT-1195/LT-1196)[0 in. (L4791/L4792)] (bottom of hot leg)

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

None Basis:

This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.

For this EAL, a lowering of RPV water level below the specified level indicates that operator actions have not been successful in restoring and maintaining RCS water level. The heat-up rate of the coolant will rise as the available water inventory is reduced. A continuing drop in water level will lead to core uncovery.

Although related, this EAL is concerned with the loss of RPV inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Decay Heat Removal suction point). A rise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA3.

If water level continues to lower, then escalation to Site Area Emergency would be via IC CS1.

The bottom of the RCS hot leg penetration into the reactor vessel is approximately RLVMS Level 8 (Unit 1) or RVLMS Level 5 (Unit 2). However, RVLMS may not be available in the cold shutdown modes. Redundant means of level indication is provided in these modes and included in this EAL. The bottom of the RCS hot leg penetration into the reactor vessel is 368 ft., 0 in. (Unit 1) or 369 ft., 1.5 in. (Unit 2). Below this level, reactor vessel level indication may be lost and loss of suction to decay heat removal systems will occur (ref. 1, 2, 3). Where to 0CAN031801 Page 71 of 240 Attachment 1 - Emergency Action Level Technical Bases redundant means of level indication cannot read below this level, the lowest indication that can be read on scale is used for this EAL. The inability to restore and maintain level after reaching this setpoint would be indicative of a failure of the RCS barrier.

Reference(s):

1. OP-1105.008 Inadequate Core Cooling Monitor and Display
2. OP-2105.003 Reactor Vessel Level Monitoring System Operations
3. Calculation No. 90-E-0116-01 ANO-2 EOP Setpoint Basis Document, Setpoints R.3 and R.9
4. NEI 99-01 CA1 to 0CAN031801 Page 72 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Significant Loss of RCS inventory EAL:

CA1.2 Alert RCS level cannot be monitored for 15 min. (Note 1)

AND EITHER UNPLANNED rise in any Table 1[2]C-1 sump/tank level due to a loss of RCS inventory Visual observation of UNISOLABLE RCS leakage Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1C-1 Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank Table 2C-1 Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)

Holdup Tank Aux. Building Sump Quench Tank to 0CAN031801 Page 73 of 240 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

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.

Basis:

This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.

For this EAL, the inability to monitor RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.

The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS1.

If the RCS inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS1.

Reference(s):

1. OP-1203.039 Excess RCS Leakage
2. OP-2203.016 Excess RCS Leakage
3. NEI 99-01 CA1 to 0CAN031801 Page 74 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability EAL:

CS1.1 Site Area Emergency CONTAINMENT CLOSURE not established AND RVLMS Levels 1 through 9[1 through 6] indicate DRY Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

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.

Basis:

This IC addresses a significant and prolonged loss of RCS inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.

to 0CAN031801 Page 75 of 240 Attachment 1 - Emergency Action Level Technical Bases This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Escalation of the emergency classification level would be via IC CG1 or AG1.

Reference(s):

1. OP-1105.008 Inadequate Core Cooling Monitor and Display
2. OP-2105.003 Reactor Vessel Level Monitoring System Operations
3. NEI 99-01 CS1 to 0CAN031801 Page 76 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability EAL:

CS1.2 Site Area Emergency

[RVLMS Levels 1 through 7 indicate DRY OR]

RCS level cannot be monitored for 30 min. (Note 1)

AND Core uncovery is indicated by any of the following:

UNPLANNED rise in any Table 1[2]C-1 sump/tank level of sufficient magnitude to indicate core uncovery Containment high range radiation monitor RE-8060/8061[2RE-8925-1/8925-2] reading

> 10 R/hr Erratic Source Range Monitor indication Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1C-1 Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank to 0CAN031801 Page 77 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2C-1 Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)

Holdup Tank Aux. Building Sump Quench Tank Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

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.

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.

Basis:

When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.

Level 7 DRY on this system is an indication of core uncovery.

This IC addresses a significant and prolonged loss of reactor vessel/RCS inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

to 0CAN031801 Page 78 of 240 Attachment 1 - Emergency Action Level Technical Bases Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.

The difference in the specified RCS levels of EALs CS1.1 and CS1.2 reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.

The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.

This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Containment High Range Radiation Monitors RE-8060/8061 [2RE-8925-1/8925-2] are the site-specific radiation monitors that would be indicative of possible core uncovery in the Refueling mode. The dose rate due to core shine when the top of the core becomes uncovered should result in dose rates > 10 R/hr.

Escalation of the emergency classification level would be via IC CG1 or AG1.

Reference(s):

1. OP-1203.039 Excess RCS Leakage
2. OP-2203.016 Excess RCS Leakage
3. OP-2105.003 Reactor Vessel Level Monitoring System Operations
4. 1SAR Table 7-11
5. 2SAR 12.1.4.2
6. NEI 99-01 CS1 to 0CAN031801 Page 79 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL:

CG1.1 General Emergency - UNIT 2 ONLY RVLMS Levels 1 through 7 indicate DRY AND Any Containment Challenge indication, Table 2C-2 Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required.

Table 1[2]C-2 Containment Challenge Indications CONTAINMENT CLOSURE not established (Note 6)

Containment hydrogen concentration > 3%

UNPLANNED rise in containment pressure Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

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.

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.

to 0CAN031801 Page 80 of 240 Attachment 1 - Emergency Action Level Technical Bases Basis:

When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.

Level 7 DRY on this system is an indication of core uncovery.

This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS level cannot be restored, fuel damage is probable.

With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.

This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

to 0CAN031801 Page 81 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1203.039 Excess RCS Leakage
2. OP-2203.016 Excess RCS Leakage
3. OP-2105.003 Reactor Vessel Level Monitoring System Operations
4. 1SAR Table 7-11
5. 2SAR 12.1.4.2
6. Unit 1 SAMG Figure III-1B
7. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart
8. NEI 99-01 CG1 to 0CAN031801 Page 82 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL:

CG1.2 General Emergency RCS level cannot be monitored for 30 min. (Note 1)

AND Core uncovery is indicated by any of the following:

UNPLANNED rise in any Table 1[2]C-1 sump/tank level of sufficient magnitude to indicate core uncovery Containment High Range Radiation Monitor RE-8060/8061[2RE-8925-1/8925-2]

reading > 10 R/hr Erratic Source Range Monitor indication AND Any Containment Challenge indication, Table 1[2]C-2 Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required.

Table 1C-1 Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank to 0CAN031801 Page 83 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2C-1 Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)

Holdup Tank Aux. Building Sump Quench Tank Table 1[2]C-2 Containment Challenge Indications CONTAINMENT CLOSURE not established (Note 6)

Containment hydrogen concentration > 3%

UNPLANNED rise in containment pressure Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

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.

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.

to 0CAN031801 Page 84 of 240 Attachment 1 - Emergency Action Level Technical Bases Basis:

When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.

Level 7 DRY on this system is an indication of core uncovery.

This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS level cannot be restored, fuel damage is probable.

With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.

The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.

to 0CAN031801 Page 85 of 240 Attachment 1 - Emergency Action Level Technical Bases Containment High Range Radiation Monitor RE-8060/8061 [2RE-8925-1/8925-2] are the site-specific radiation monitors that would be indicative of possible core uncovery in the Refueling mode. The dose rate due to core shine when the top of the core becomes uncovered should result in dose rates > 10 R/hr.

This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Reference(s):

1. OP-1203.039 Excess RCS Leakage
2. OP-2203.016 Excess RCS Leakage
3. OP-2105.003 Reactor Vessel Level Monitoring System Operations
4. 1SAR Table 7-11
5. 2SAR 12.1.4.2
6. Unit 1 SAMG Figure III-1B
7. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart
8. NEI 99-01 CG1 to 0CAN031801 Page 86 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 2 - Loss of Vital AC Power Initiating Condition: Loss of all but one AC power source to vital buses for 15 minutes or longer EAL:

CU2.1 Unusual Event AC power capability, Table 1[2]C-3, to vital 4.16 KV buses A3[2A3] and A4[2A4] reduced to a single power source for 15 min. (Note 1)

AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1C-3 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite DG1 DG2 AAC Gen to 0CAN031801 Page 87 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2C-3 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)

Onsite 2DG1 2DG2 AAC Gen Mode Applicability:

5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):

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 (as defined in 10 CFR 50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

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

When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the greater time available to restore another power source to service.

Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.

to 0CAN031801 Page 88 of 240 Attachment 1 - Emergency Action Level Technical Bases An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to a vital bus. Some examples of this condition are presented below.

A loss of all offsite power with a concurrent failure of all but one vital power source.

A loss of all offsite power and loss of all vital power sources with a single train of vital buses being back-fed from the unit main generator.

A loss of vital power sources (e.g., onsite diesel generators) with a single train of vital buses being back-fed from an offsite power source.

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

The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA2.

This EAL is the cold condition equivalent of the hot condition EAL SA1.1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram
2. OP-1202.007 Degraded Power
3. OP-1202.008 Blackout
4. OP-2104.037 Alternate AC Diesel Generator Operations
5. 2SAR Figure 8.3-1 Station Single Line Diagram
6. OP-2202.007 Loss of Off-Site Power
7. OP-2202.008 Station Blackout
8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
9. NEI 99-01 CU2 to 0CAN031801 Page 89 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 2 - Loss of Vital AC Power Initiating Condition: Loss of all offsite and all onsite AC power to vital buses for 15 minutes or longer EAL:

CA2.1 Alert Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3[2A3] and A4[2A4] for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):

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 (as defined in 10 CFR 50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Although the AAC may be considered available, it will not prevent declaration of this EAL unless it is powering a vital bus within the 15-minute time period of the EAL.

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.

Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in to 0CAN031801 Page 90 of 240 Attachment 1 - Emergency Action Level Technical Bases accordance with abnormal or emergency operating procedures, or beyond design basis accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems.

When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the greater time available to restore a vital bus to service.

Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.

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

Escalation of the emergency classification level would be via IC CS1 or AS1.

This EAL is the cold condition equivalent of the hot condition EAL SS1.1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram
2. OP-1202.007 Degraded Power
3. OP-1202.008 Blackout
4. OP-2104.037 Alternate AC Diesel Generator Operations
5. 2SAR Figure 8.3-1 Station Single Line Diagram
6. OP-2202.007 Loss of Off-Site Power
7. OP-2202.008 Station Blackout
8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
9. NEI 99-01 CU2 to 0CAN031801 Page 91 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: UNPLANNED rise in RCS temperature EAL:

CU3.1 Unusual Event UNPLANNED rise in RCS temperature to > 200°F due to loss of decay heat removal capability Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

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.

Basis:

This IC addresses an UNPLANNED rise in RCS temperature above the Technical Specification cold shutdown temperature limit and represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to EAL CA3.1.

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

This EAL involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications.

During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

to 0CAN031801 Page 92 of 240 Attachment 1 - Emergency Action Level Technical Bases During an outage, the level in the reactor vessel will normally be maintained at or above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at lowered inventory may result in a rapid rise in reactor coolant temperature depending on the time after shutdown.

Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria.

Reference(s):

1. Unit 1 and Unit 2 Technical Specifications Table 1.1-1
2. NEI 99-01 CU3 to 0CAN031801 Page 93 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: UNPLANNED rise in RCS temperature EAL:

CU3.2 Unusual Event Loss of all RCS temperature and RCS level indication for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

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.

Basis:

This EAL addresses the inability to determine RCS temperature and level, and represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to EAL CA3.1.

This EAL reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

to 0CAN031801 Page 94 of 240 Attachment 1 - Emergency Action Level Technical Bases Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria.

Reference(s):

1. NEI 99-01 CU3 to 0CAN031801 Page 95 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: Inability to maintain plant in cold shutdown EAL:

CA3.1 Alert UNPLANNED rise in RCS temperature to > 200°F for > Table 1[2]C-4 duration (Note 1)

OR UNPLANNED RCS pressure rise > 10 psig due to a loss of RCS cooling (this EAL does not apply during water-solid plant conditions)

Note 1: 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 is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1[2]C-4 RCS Heat-up Duration Thresholds CONTAINMENT RCS Status Heat-up Duration CLOSURE Status Intact (but not lowered inventory) N/A 60 min.*

Not intact established 20 min.*

OR lowered inventory not established 0 min.

  • If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

to 0CAN031801 Page 96 of 240 Attachment 1 - Emergency Action Level Technical Bases As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

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.

Basis:

In the absence of reliable RCS temperature indication caused by the loss of decay heat removal capability, classification should be based on the RCS pressure rise criteria when the RCS is intact in Mode 5 or based on time to boil data when in Mode 6 or the RCS is not intact in Mode 5.

This EAL addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant.

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact, or RCS inventory is reduced (e.g., lowered inventory operation). The 20-minute criterion was included to allow time for operator action to address the temperature rise.

The RCS Heat-up Duration Thresholds table also addresses a rise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature rise without a substantial degradation in plant safety.

Finally, in the case where there is a rise in RCS temperature, the RCS is not intact or is at lowered inventory and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) the evaporated reactor coolant may be released directly into the containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel.

The RCS pressure rise threshold provides a pressure-based indication of RCS heat-up in the absence of RCS temperature monitoring capability.

Escalation of the emergency classification level would be via IC CS1 or AS1.

Reference(s):

1. Unit 1 and Unit 2 Technical Specifications Table 1.1-1
2. NEI 99-01 CA3 to 0CAN031801 Page 97 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 4 - Loss of Vital DC Power Initiating Condition: Loss of Vital DC power for 15 minutes or longer EAL:

CU4.1 Unusual Event Indicated voltage is < 105 VDC on vital 125 VDC buses for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC.

This IC addresses a loss of vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions raise the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant.

to 0CAN031801 Page 98 of 240 Attachment 1 - Emergency Action Level Technical Bases As used in this EAL, required means the vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment. For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification.

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

Depending upon the event, escalation of the emergency classification level would be via IC CA1 or CA3, or an IC in Recognition Category A.

This EAL is the cold condition equivalent of the hot condition EAL SS2.1.

Reference(s):

1. 1SAR 8.3.2.1.1 Batteries
2. 2SAR 8.3.2.1.1 Batteries
3. NEI 99-01 CU4 to 0CAN031801 Page 99 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 5 - Loss of Communications Initiating Condition: Loss of all onsite or offsite communications capabilities EAL:

CU5.1 Unusual Event Loss of all Table 1[2]C-5 onsite communication methods OR Loss of all Table 1[2]C-5 State and local agency communication methods OR Loss of all Table 1[2]C-5 NRC communication methods Table 1[2]C-5 Communication Methods System Onsite ORO NRC Station radio system X ANO plant phone system X Gaitronics X Telephone Systems:

Commercial Microwave X X Satellite VOIP INFORM Notification System X Emergency Notification System (ENS) X Mode Applicability:

5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):

None to 0CAN031801 Page 100 of 240 Attachment 1 - Emergency Action Level Technical Bases Basis:

This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to State and local agencies and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

The first EAL condition addresses a total loss of the communications methods used in support of routine plant operations.

The second EAL condition addresses a total loss of the communications methods used to notify all State and local agencies of an emergency declaration. The State and local agencies referred to here are the Arkansas Department of Health, Arkansas Department of Emergency Management, Pope, Yell, Johnson, and Logan County offsite agencies.

The third EAL addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

This EAL is the cold condition equivalent of the hot condition EAL SU7.1.

Reference(s):

1. OP-1903.062 Communications System Operating Procedure
2. NEI 99-01 CU5 to 0CAN031801 Page 101 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 6 - Hazardous Event Affecting Safety Systems Initiating Condition: Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode EAL:

CA6.1 Alert The occurrence of any Table 1[2]C-6 hazardous event AND Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode AND EITHER:

Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)

Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted.

Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

Table 1[2]C-6 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 to 0CAN031801 Page 102 of 240 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

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 require a post-event inspection to determine if the attributes of an explosion are present.

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.

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

VISIBLE DAMAGE - Damage to a SAFETY SYSTEM train 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 SAFETY SYSTEM train.

Basis:

This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS needed for the current operating mode. In order to provide the appropriate context for consideration of an ALERT classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues. Note that this second SAFETY SYSTEM to 0CAN031801 Page 103 of 240 Attachment 1 - Emergency Action Level Technical Bases train is from the same SAFETY SYSTEM that has indications of degraded performance; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events.

Indications of degraded performance addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

VISIBLE DAMAGE addresses damage to a SAFETY SYSTEM train that is not in service/operation and that potentially could cause performance issues. 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.

This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

Escalation of the emergency classification level would be via IC CS1 or AS1.

This EAL is the cold condition equivalent of the hot condition EAL SA9.1.

Reference(s):

1. EP FAQ 2016-002
2. NEI 99-01 CA6 to 0CAN031801 Page 104 of 240 Attachment 1 - Emergency Action Level Technical Bases Category E - Independent Spent Fuel Storage Installation (ISFSI)

EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

An independent spent fuel storage installation (ISFSI) is a complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. A significant amount of the radioactive material contained within a canister must escape its packaging and enter the biosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel.

An Unusual Event is declared on the basis of the occurrence of an event of sufficient magnitude that a loaded cask CONFINEMENT BOUNDARY is damaged or violated.

The ANO ISFSI is located wholly within the plant PROTECTED AREA. Therefore any security event related to the ISFSI is classified under Category H1 security event related EALs.

to 0CAN031801 Page 105 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: E - ISFSI Subcategory: Confinement Boundary Initiating Condition: Damage to a loaded cask CONFINEMENT BOUNDARY EAL:

EU1.1 Unusual Event Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading on the surface of a loaded spent fuel cask (VSC-24 VCC or HI-STORM overpack) > any Table 1[2]E-1 value Table 1[2]E-1 ISFSI Dose Rates VSC-24 VCC HI-STORM 200 mrem/hr on the sides 60 mrem/hr (gamma + neutron) on the top or outlet vent 400 mrem/hr on the top 600 mrem/hr (gamma + neutron on 700 mrem/hr at the air inlet the side of the side of the overpack 200 mrem/hr at the air outlet (excluding inlet and outlet ducts)

Mode Applicability:

All Definition(s):

CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) - A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

Basis:

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the to 0CAN031801 Page 106 of 240 Attachment 1 - Emergency Action Level Technical Bases creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of damage is determined by radiological survey. The specified EAL threshold values correspond to 2 times the cask technical specification values (ref. 1, 2). The technical specification (licensing bases document) multiple of 2 times, which is also used in Recognition Category A IC AU1, is used here to distinguish between non-emergency and emergency conditions. The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the on-contact dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.

Security-related events for ISFSIs are covered under ICs HU1 and HA1.

Reference(s):

1. Certificate of Compliance Appendix A Technical Specifications for the HI-STORM 100 Cask System Section 5.7.4
2. VSC-24 Storage Cask Final Safety Analysis Report Section 1.2.4 Maximum External Surface Dose Rate
3. NEI 99-01 E-HU1 to 0CAN031801 Page 107 of 240 Attachment 1 - Emergency Action Level Technical Bases Category F - Fission Product Barrier Degradation EAL Group: Hot Conditions (RCS temperature > 200°F); EALs in this category are applicable only in one or more hot operating modes.

EALs in this category represent threats to the defense in depth design concept that precludes the release of highly radioactive fission products to the environment. This concept relies on multiple physical barriers any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment. The primary fission product barriers are:

A. Fuel Clad Barrier (FCB): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.

B. Reactor Coolant System Barrier (RCB): The RCS Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.

C. Containment Barrier (CNB): The Containment Barrier includes the Reactor Building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the Reactor Building up to and including the outermost secondary side isolation valve.

Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency.

The EALs in this category require evaluation of the loss and potential loss thresholds listed in the fission product barrier matrix of Table F-1. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. Loss means the barrier no longer assures containment of radioactive materials. Potential Loss means integrity of the barrier is threatened and could be lost if conditions continue to degrade. The number of barriers that are lost or potentially lost and the following criteria determine the appropriate emergency classification level:

Alert:

Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency:

Loss or potential loss of any two barriers General Emergency:

Loss of any two barriers and loss or potential loss of third barrier to 0CAN031801 Page 108 of 240 Attachment 1 - Emergency Action Level Technical Bases The logic used for emergency classification based on fission product barrier monitoring should reflect the following considerations:

The Fuel Clad Barrier and the RCS Barrier are weighted more heavily than the Containment Barrier.

Unusual Event ICs associated with RCS and Fuel Clad Barriers are addressed under System Malfunction ICs.

For accident conditions involving a radiological release, evaluation of the fission product barrier thresholds will need to be performed in conjunction with dose assessments to ensure correct and timely escalation of the emergency classification. For example, an evaluation of the fission product barrier thresholds may result in a Site Area Emergency classification while a dose assessment may indicate that an EAL for General Emergency IC AG1 has been exceeded.

The fission product barrier thresholds specified within a scheme reflect plant-specific ANO design and operating characteristics.

As used in this category, the term RCS leakage encompasses not just those types defined in Technical Specifications but also includes the loss of RCS mass to any location - inside the containment, an interfacing system, or outside of the containment.

The release of liquid or steam mass from the RCS due to the as-designed/expected operation of a relief valve is not considered to be RCS leakage.

At the Site Area Emergency level, EAL users should maintain cognizance of how far present conditions are from meeting a threshold that would require a General Emergency declaration. For example, if the Fuel Clad and RCS fission product barriers were both lost, then there should be frequent assessments of containment radioactive inventory and integrity. Alternatively, if both the Fuel Clad and RCS fission product barriers were potentially lost, the Emergency Director would have more assurance that there was no immediate need to escalate to a General Emergency.

to 0CAN031801 Page 109 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: F - Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Any loss or any potential loss of either Fuel Clad or RCS EAL:

FA1.1 Alert Any loss or any potential loss of either Fuel Clad or RCS barrier (Table 1[2]F-1)

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.

At the Alert classification level, Fuel Clad and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Clad 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 Clad or RCS barrier results in declaration of a Site Area Emergency under EAL FS1.1.

Reference(s):

1. NEI 99-01 FA1 to 0CAN031801 Page 110 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: F - Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Loss or potential loss of any two barriers EAL:

FS1.1 Site Area Emergency Loss or potential loss of any two barriers (Table 1[2]F-1)

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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.

Basis:

Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.

At the Site Area Emergency classification level, each barrier is weighted equally. A Site Area Emergency is therefore appropriate for any combination of the following conditions:

One barrier loss and a second barrier loss (i.e., loss - loss)

One barrier loss and a second barrier potential loss (i.e., loss - potential loss)

One barrier potential loss and a second barrier potential loss (i.e., potential loss -

potential loss)

At the Site Area Emergency classification level, the ability to dynamically assess the proximity of present conditions with respect to the threshold for a General Emergency is important. For example, the existence of Fuel Clad and RCS Barrier loss thresholds in addition to offsite dose assessments would require continual assessments of radioactive inventory and Containment integrity in anticipation of reaching a General Emergency classification. Alternatively, if both Fuel Clad and RCS potential loss thresholds existed, the Emergency Director would have greater assurance that escalation to a General Emergency is less IMMINENT.

Reference(s):

1. NEI 99-01 FS1 to 0CAN031801 Page 111 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: F - Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Loss of any two barriers and loss or potential loss of third barrier EAL:

FG1.1 General Emergency Loss of any two barriers AND Loss or potential loss of the third barrier (Table 1[2]F-1)

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.

At the General Emergency classification level each barrier is weighted equally. A General Emergency is therefore appropriate for any combination of the following conditions:

Loss of Fuel Clad, RCS and Containment Barriers Loss of Fuel Clad and RCS Barriers with potential loss of Containment Barrier Loss of RCS and Containment Barriers with potential loss of Fuel Clad Barrier Loss of Fuel Clad and Containment Barriers with potential loss of RCS Barrier Reference(s):

1. NEI 99-01 FG1 to 0CAN031801 Page 112 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1 Fission Product Barrier Threshold Matrix & Bases Table 1[2]F-1 lists the threshold conditions that define the Loss and Potential Loss of the three fission product barriers (Fuel Clad, Reactor Coolant System, and Containment). The table is structured so that each of the three barriers occupies adjacent columns. Each fission product barrier column is further divided into two columns; one for Loss thresholds and one for Potential Loss thresholds.

The first column of the table (to the left of the Fuel Clad Loss column) lists the categories (types) of fission product barrier thresholds. The fission product barrier categories are:

A. RCS or S/G Tube Leakage B. Inadequate Heat removal C. Containment Radiation / RCS Activity D. Containment Integrity or Bypass E. Emergency Director Judgment Each category occupies a row in Table 1[2]F-1 thus forming a matrix defined by the categories.

The intersection of each row with each Loss/Potential Loss column forms a cell in which one or more fission product barrier thresholds appear. If NEI 99-01 does not define a threshold for a barrier Loss/Potential Loss, the word None is entered in the cell.

Thresholds are assigned sequential numbers within each barrier column beginning with number one (ex., FCB1, FCB2FCB9).

If a cell in Table 1[2]F-1 contains more than one numbered threshold, each of the numbered thresholds, if exceeded, signifies a Loss or Potential Loss of the barrier. It is not necessary to exceed all of the thresholds in a category before declaring a barrier Loss/Potential Loss.

Subdivision of Table 1[2]F-1 by category facilitates association of plant conditions to the applicable fission product barrier Loss and Potential Loss thresholds. This structure promotes a systematic approach to assessing the classification status of the fission product barriers.

When equipped with knowledge of plant conditions related to the fission product barriers, the EAL-user first scans down the category column of Table 1[2]F-1, locates the likely category and then reads across the fission product barrier Loss and Potential Loss thresholds in that category to determine if a threshold has been exceeded. If a threshold has not been exceeded, the EAL-user proceeds to the next likely category and continues review of the thresholds in the new category.

If the EAL-user determines that any threshold has been exceeded, by definition, the barrier is lost or potentially lost - even if multiple thresholds in the same barrier column are exceeded, only that one barrier is lost or potentially lost. The EAL-user must examine each of the three fission product barriers to determine if other barrier thresholds in the category are lost or potentially lost. For example, if containment radiation is sufficiently high, a Loss of the Fuel to 0CAN031801 Page 113 of 240 Attachment 1 - Emergency Action Level Technical Bases Clad and RCS Barriers and a Potential Loss of the Containment Barrier can occur. Barrier Losses and Potential Losses are then applied to the algorithms given in EALs FG1.1, FS1.1, and FA1.1 to determine the appropriate emergency classification.

In the remainder of this Attachment, the Fuel Clad Barrier threshold bases appear first, followed by the RCS Barrier and finally the Containment Barrier threshold bases. In each barrier, the bases are given according category Loss followed by category Potential Loss beginning with Category A, then B,, E.

to 0CAN031801 Page 114 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1 Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FCB) Reactor Coolant System Barrier (RCB) Containment Barrier (CNB)

Category Loss Potential Loss Loss Potential Loss Loss Potential Loss RCB2 UNISOLABLE RCS leakage or S/G tube leakage > 50[44] gpm excluding normal reductions in RCS inventory (e.g.,

letdown, RCP seal leakoff)

RCB3 RCB1 Unit 1: PTS limits apply (RT14) CNB1 A An automatic or manual AND A S/G that is leaking FCB1 ESAS [ESFAS] actuation > 50[44] gpm (excluding RCS or S/G required by EITHER: RCS pressure and temperature are left None RVLMS Levels 1 through 9 normal reductions in RCS None of the NDTT/LTOP limit lines on EOP Tube [1 through 7] indicate DRY UNISOLABLE RCS Figure 3 (Note 12) inventory) or that is Leakage leakage Unit 2: Uncontrolled RCS cooldown (50°F RUPTURED is also FAULTED S/G tube RUPTURE outside of containment step change which is below 500°F from NOT)

AND RCS pressure and temperature are to the left of line B (200 degrees MTS),

Standard Attachment 1, P-T Limits (Note 12)

FCB3 CETs > 700°F B FCB4 RCB4 CNB2 RCS heat removal cannot be established using CETs > 1200°F Inadequate FCB2 RCS heat removal cannot be established using steam None steam generators None AND Heat CETs > 1200°F generators AND Restoration procedures not effective Removal AND HPI [Once Through] cooling initiated within 15 min. (Note 1)

HPI [Once Through] cooling initiated FCB5 Containment High C Range Radiation RCB5 Monitor RE-8060/8061 CNB3 CTMT [2RE-8925-1/ 8925-2] Containment High Range None None None Containment High Range Radiation Radiation / > 750 [700] R/hr Radiation Monitor RE-Monitor RE-8060/8061 [2RE-8925-1/

8060/8061 [2RE-8925-1/

RCS FCB6 8925-2] > 40[50] R/hr 8925-2] > 10,000[12,000] R/hr Activity Coolant activity

> 300 Ci/gm dose equivalent I-131 to 0CAN031801 Page 115 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1 Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FCB) Reactor Coolant System Barrier (RCB) Containment Barrier (CNB)

Category Loss Potential Loss Loss Potential Loss Loss Potential Loss CNB4 Containment isolation is CNB6 required Containment pressure > 73.7 psia AND EITHER:

CNB7 Containment integrity D has been lost based on Containment hydrogen concentration Emergency Director > 3%

CTMT None None None None judgment CNB8 Integrity or UNISOLABLE pathway Containment pressure > 44.7 psia Bypass from Containment to the [23.3 psia] with < one full train of environment exists containment heat removal systems CNB5 (Note 9) operating per design for 15 min. (Note 1)

Indications of RCS leakage outside of Containment FCB7 E Any condition in the FCB8 RCB6 RCB7 CNB9 CNB10 Any condition in the opinion of Any condition in the opinion Any condition in the opinion of Any condition in the opinion of the Emergency opinion of the the Emergency Director that of the Emergency Director Any condition in the opinion of the Emergency the Emergency Director that Emergency Director that indicates Director Emergency Director Director that indicates potential loss of the RCS indicates potential loss of the that indicates loss of the RCS indicates loss of the potential loss of the Containment that indicates loss of barrier Judgment the Fuel Clad barrier Fuel Clad barrier barrier Containment barrier barrier to 0CAN031801 Page 116 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: A - RCS or S/G Tube Leakage Degradation Threat: Loss Threshold:

None to 0CAN031801 Page 117 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: A - RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

FCB1 RVLMS Levels 1 through 9[1 through 7] indicate DRY Definition(s):

None Basis:

This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage.

There is no Fuel Clad Barrier Loss threshold associated with RCS or S/G Tube Leakage.

Reference(s):

1. ULD-1-SYS-24 Unit 1 Inadequate Core Cooling System
2. Calculation 84-EQ-0080-02 Loop Error Analysis for Reactor Vessel Level Monitoring System
3. ULD-2-SYS-24 Unit 2 Inadequate Core Cooling Monitoring System
4. Calculation 90-E-0116-01 Unit 2 EOP Setpoint Document, Setpoint R.3
5. NEI 99-01 RCS or SG Tube Leakage Potential Loss 1.A to 0CAN031801 Page 118 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: B - Inadequate Heat Removal Degradation Threat: Loss Threshold:

FCB2 CETs > 1200°F Definition(s):

None Basis:

This reading indicates temperatures within the core are sufficient to cause significant superheating of reactor coolant.

Reference(s):

1. NEI 99-01 Inadequate Heat Removal Loss 2.A to 0CAN031801 Page 119 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: B - Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

FCB3 CETs > 700°F Definition(s):

None Basis:

This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage.

Reference(s):

1. NEI 99-01 Inadequate Heat Removal Potential Loss 2.A to 0CAN031801 Page 120 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: B - Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

FCB4 RCS heat removal cannot be established using steam generators AND HPI[Once Through] cooling initiated Definition(s):

None Basis:

This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using this threshold is not warranted.

In combination with Potential Loss RCB4, meeting this threshold results in a Site Area Emergency.

Reference(s):

1. OP-1202.004 Overheating
2. OP-1202.013 Figure 4, Core Exit Thermocouple for Inadequate Core Cooling
3. OP-2202.006 Loss of Feedwater
4. OP-2202.009 Functional Recovery, Safety Function Status Check 5
5. NEI 99-01 Inadequate Heat Removal Potential Loss 2.B to 0CAN031801 Page 121 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: C - CTMT Radiation / RCS Activity Degradation Threat: Loss Threshold:

FCB5 Containment High Range Radiation Monitor RE-8060/8061[2RE-8925-1/8925-2]

> 750[700] R/hr Definition(s):

None Basis:

The containment radiation monitor reading (768[682] R/hr rounded to 750[700] R/hr for readability) corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals 300 µCi/gm dose equivalent I-131.

Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to 1.49[1.13]% 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 Loss threshold RCB5 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 ECL to a Site Area Emergency.

There is no Potential Loss threshold associated with CTMT Radiation/RCS Activity.

Reference(s):

1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values
2. NEI 99-01 RCS Activity/Containment Radiation FC Loss 3.A to 0CAN031801 Page 122 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: C - CTMT Radiation / RCS Activity Degradation Threat: Loss Threshold:

FCB6 Coolant activity > 300 µCi/gm dose equivalent I-131 Definition(s):

None Basis:

This threshold indicates that RCS radioactivity concentration is greater than 300 µCi/gm dose equivalent I-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.

It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications.

There is no Potential Loss threshold associated with CTMT Radiation/RCS Activity.

Reference(s):

1. NEI 99-01 RCS Activity/Containment Radiation Fuel Clad Loss 3.B to 0CAN031801 Page 123 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: C - CTMT Radiation / RCS Activity Degradation Threat: Potential Loss Threshold:

None to 0CAN031801 Page 124 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: D - CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

None to 0CAN031801 Page 125 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

None to 0CAN031801 Page 126 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: E - Emergency Director Judgment Degradation Threat: Loss Threshold:

FCB7 Any condition in the opinion of the Emergency Director that indicates loss of the Fuel Clad barrier Definition(s):

None Basis:

This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad barrier is lost.

Reference(s):

1. NEI 99-01 Emergency Director Judgment Fuel Clad Loss 6.A to 0CAN031801 Page 127 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: E - Emergency Director Judgment Degradation Threat: Potential Loss Threshold:

FCB8 Any condition in the opinion of the Emergency Director that indicates potential loss of the Fuel Clad barrier Definition(s):

None Basis:

This threshold addresses any other factors that are to 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.

Reference(s):

1. NEI 99-01 Emergency Director Judgment Potential Fuel Clad Loss 6.A to 0CAN031801 Page 128 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: A - RCS or S/G Tube Leakage Degradation Threat: Loss Threshold:

RCB1 An automatic or manual ESAS[ESFAS] actuation required by EITHER:

UNISOLABLE RCS leakage S/G tube RUPTURE Definition(s):

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.

RUPTURED - The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

Basis:

Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

This 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 Loss threshold CNB1 will also be met.

to 0CAN031801 Page 129 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1202.010 ESAS
2. OP-2202.003 Loss of Coolant Accident
3. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Loss 1.A to 0CAN031801 Page 130 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: A - RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

RCB2 UNISOLABLE RCS leakage or S/G tube leakage > 50[44] gpm excluding normal reductions in RCS inventory (e.g., letdown, RCP seal leakoff)

Definition(s):

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.

Basis:

Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

This 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 makeup [charging]

pump, but an ESAS [ESFAS] actuation has not occurred.

This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system.

The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold CNB1 will also be met.

Reference(s):

1. 1SAR 9.1 Makeup and Purification System
2. 2SAR 9.3.4 Chemical and Volume Control System
3. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.A to 0CAN031801 Page 131 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: A - RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

RCB3 Unit 1:

PTS limits apply (RT14)

AND RCS pressure and temperature are left of the NDTT/LTOP limit lines, on EOP Figure 3 (Note 12)

Unit 2:

Uncontrolled RCS cooldown (50°F step change which is below 500°F from NOT)

AND RCS pressure and temperature are to the left of line B (200 degrees MTS), Standard Attachment 1, P-T Limits (Note 12)

Note 12: Once PTS limits are first invoked, if RCS temperature and pressure are not brought within the limits within 15 minutes, this threshold is met and an immediate declaration is warranted. This threshold is met immediately upon exceeding the limits after this initial 15 minute period until PTS limits no longer apply.

Definition(s):

None 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).

to 0CAN031801 Page 132 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1202.012 Repetitive Task 14 Control RCS Pressure
2. OP-1202.013 EOP Figures, Figure 3 RCS Pressure vs Temperature Limits
3. OP-1202.011 HPI Cooldown
4. Calculation No: 90-E-0116-01 ANO- EOP Setpoint Basis Document OP Setpoint P.2, RCS Pressure-Temperature
5. OP-2202.010 Standard Attachments, Attachment 1, P-T Limits
6. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.B to 0CAN031801 Page 133 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: B - Inadequate Heat Removal Degradation Threat: Loss Threshold:

None to 0CAN031801 Page 134 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: B - Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

RCB4 RCS heat removal cannot be established using steam generators AND HPI[Once Through] cooling initiated Definition(s):

None Basis:

This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using this threshold is not warranted.

In combination with Potential Loss FCB4, meeting this threshold results in a Site Area Emergency.

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 raise RCS pressure to the point where mass will be lost from the system.

There is no RCS barrier Loss threshold associated with Inadequate Heat Removal.

Reference(s):

1. OP-1202.004 Overheating
2. OP-1202.013 Figure 4, Core Exit Thermocouple for Inadequate Core Cooling
3. OP-2202.006 Loss of Feedwater
4. OP-2202.009 Functional Recovery, Safety Function Status Check 5
5. NEI 99-01 Inadequate Heat Removal RCS Potential Loss 2.B to 0CAN031801 Page 135 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: C - CTMT Radiation/ RCS Activity Degradation Threat: Loss Threshold:

RCB5 Containment High Range Radiation Monitor RE-8060/8061[2RE-8925-1/8925-2] > 40[50] R/hr Definition(s):

None Basis:

NRC Information Notice 97-045, Supplement 1, identifies the potential for erratic indications from the high range radiation monitors (HRRMs) as a result of thermally induced currents (TIC) which may cause the HRRM to read falsely high (for approximately 15 minutes) on a rapid temperature rise, and fail low intermittently on a rapid temperature fall. Because of this phenomenon, any trends or alarms on the HRRMs should be validated by comparison to the containment low range/area radiation monitors and Air Monitoring Systems trends before actions are taken.

The containment radiation monitor reading (42.8[50.4] R/hr rounded to 40[50] R/hr for readability) 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 Loss threshold FCB5 since it indicates a loss of the RCS Barrier only.

There is no Potential Loss threshold associated with CTMT Radiation/RCS Activity.

Reference(s):

1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values
2. NEI 99-01 CMT Radiation / RCS Activity RCS Loss 3.A to 0CAN031801 Page 136 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: B - CTMT Radiation/ RCS Activity Degradation Threat: Potential Loss Threshold:

None to 0CAN031801 Page 137 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: D - CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

None to 0CAN031801 Page 138 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

None to 0CAN031801 Page 139 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: E - Emergency Director Judgment Degradation Threat: Loss Threshold:

RCB6 Any condition in the opinion of the Emergency Director that indicates loss of the RCS barrier Definition(s):

None Basis:

This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is lost.

Reference(s):

1. NEI 99-01 Emergency Director Judgment RCS Loss 6.A to 0CAN031801 Page 140 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: E - Emergency Director Judgment Degradation Threat: Potential Loss Threshold:

RCB7 Any condition in the opinion of the Emergency Director that indicates potential loss of the RCS barrier Definition(s):

None Basis:

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

Reference(s):

1. NEI 99-01 Emergency Director Judgment RCS Potential Loss 6.A to 0CAN031801 Page 141 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: A - RCS or S/G Tube Leakage Degradation Threat: Loss Threshold:

CNB1 A S/G that is leaking > 50[44] gpm (excluding normal reductions in RCS inventory) or that is RUPTURED is also FAULTED outside of containment Definition(s):

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.

RUPTURED - The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).

Basis:

This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAULTED outside of containment. The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the thresholds for RCS Barrier Potential Loss RCB2 and Loss RCB1, 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 dropping 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 SU4 for the fuel clad barrier (i.e., RCS activity values) and IC SU5 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. These types of conditions will result in a significant and 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.

to 0CAN031801 Page 142 of 240 Attachment 1 - Emergency Action Level Technical Bases 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 a 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 A ICs.

The ECLs 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?

P-to-S Leak Rate Yes No Less than or equal to 25 gpm No classification No classification Greater than 25 gpm Unusual Event per SU5.1 Unusual Event per SU5.1 Greater than 50[44] gpm (RCS Site Area Emergency per Alert per FA1.1 Barrier Potential Loss) FS1.1 Requires an automatic or manual Site Area Emergency per ESAS[ESFAS] actuation (RCS Alert per FA1.1 FS1.1 Barrier Loss)

There is no Potential Loss threshold associated with RCS or S/G Tube Leakage.

Reference(s):

1. NEI 99-01 RCS or SG Tube Leakage Containment Loss 1.A to 0CAN031801 Page 143 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: A - RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

None to 0CAN031801 Page 144 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: B - Inadequate Heat Removal Degradation Threat: Loss Threshold:

None to 0CAN031801 Page 145 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: B - Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

CNB2 CETs > 1200°F AND Restoration procedures not effective within 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Definition(s):

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.

Basis:

The restoration procedure is considered effective if core exit thermocouple readings are dropping and/or if reactor vessel level is rising. 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.

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.

Severe accident analyses (e.g., NUREG-1150) 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.

Reference(s):

1. NEI 99-01 Inadequate Heat Removal Containment Potential Loss 2.A to 0CAN031801 Page 146 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: C - CTMT Radiation/RCS Activity Degradation Threat: Loss Threshold:

None to 0CAN031801 Page 147 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: C - CTMT Radiation/RCS Activity Degradation Threat: Potential Loss Threshold:

CNB3 Containment High Range Radiation Monitor RE-8060/8061[2RE-8925-1/8925-2]

> 10,000[12,000] R/hr Definition(s):

None Basis:

The containment radiation monitor reading (10,300[12,100] R/hr rounded to 10,000[12,000] R/hr for readability) 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 ECL to a General Emergency.

There is no Loss threshold associated with CTMT Radiation/RCS Activity.

Reference(s):

1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values
2. NEI 99-01 CTMT Radiation / RCS Activity Containment Potential Loss 3.A to 0CAN031801 Page 148 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

CNB4 Containment isolation is required AND EITHER:

Containment integrity has been lost based on Emergency Director judgment UNISOLABLE pathway from Containment to the environment exists Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

Basis:

Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

The status of the containment barrier during an event involving steam generator tube leakage is assessed using Loss Threshold CNB1.

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 bulleted thresholds.

First Threshold - 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.).

to 0CAN031801 Page 149 of 240 Attachment 1 - Emergency Action Level Technical Bases Refer to the middle piping run of Figure 1. Two simplified examples are provided. One is leakage from a penetration and the other is leakage from an in-service system valve.

Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure.

Another example would be a loss or potential loss of the RCS barrier, and the simultaneous occurrence of two FAULTED locations on a steam generator where one fault is located inside containment (e.g., on a steam or feedwater line) and the other outside of containment. In this case, the associated steam line provides a pathway for the containment atmosphere to escape to an area outside the containment.

Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A ICs.

Second Threshold - 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 1. In this simplified example, the inboard and outboard isolation valves remained open after a containment isolation was required (i.e., containment isolation was not successful). There is now an UNISOLABLE pathway from the containment to the environment.

The existence of a filter is not considered in the threshold assessment. Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.

Leakage between two interfacing liquid systems, by itself, does not meet this threshold.

Refer to the bottom piping run of Figure 1. In this simplified example, leakage in an RCP seal cooler is allowing radioactive material to enter the Auxiliary Building. The radioactivity would be detected by the Process Monitor. If there is no leakage from the closed water cooling system to the Auxiliary Building, then no threshold has been met. If the pump developed a leak that allowed steam/water to enter the Auxiliary Building, then second threshold 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 the first threshold to be met as well.

to 0CAN031801 Page 150 of 240 Attachment 1 - Emergency Action Level Technical Bases Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable 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 an enclosed system.

These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A ICs.

Reference(s):

1. NEI 99-01 CTMT Integrity or Bypass Containment Loss 4.A to 0CAN031801 Page 151 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

CNB5 Indications of RCS leakage outside of Containment Definition(s):

None Basis:

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 Loss RCB1 and/or Potential Loss RCB2 threshold to be met.

The status of the containment barrier during an event involving steam generator tube leakage is assessed using Containment Loss Threshold CNB1.

Containment sump, temperature, pressure and/or radiation levels will rise if reactor coolant mass is leaking into the containment. If these parameters have not risen, then the reactor coolant mass may be leaking outside of containment (i.e., a containment bypass sequence).

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

Unexpected elevated readings and alarms on radiation monitors with detectors outside containment should be corroborated with other available indications to confirm that the source is a loss of RCS mass outside of containment. If the fuel clad barrier has not been lost, radiation monitor readings outside of containment may not rise significantly; however, other unexpected changes in sump levels, area temperatures or pressures, 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 1. In this simplified example, a leak has occurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause threshold CNB4 to be met as well.

Reference(s):

1. NEI 99-01 CTMT Integrity or Bypass Containment Loss 4.B to 0CAN031801 Page 152 of 240 Attachment 1 - Emergency Action Level Technical Bases Figure 1: Containment Integrity or Bypass Examples nd 2 Threshold - Airborne release from pathway Effluent Inside Auxiliary Monitor Reactor Building Building Damper Area Monitor Open valve Open valve Damper st Penetration 1 Threshold -

Airborne Airborne Monitor nd Open valve Open valve 2 Threshold -

st RCS leakage Interface 1 Threshold - Airborne outside AB leakage release from penetration Process Monitor Closed Cooling Open valve Open valve Pump RCP Seal Cooling to 0CAN031801 Page 153 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

CNB6 Containment pressure > 73.7 psia Definition(s):

None Basis:

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.

Reference(s):

1. 1SAR 1.4.43 Criterion 50 - Containment Design Basis
2. 2SAR Table 6.2-7 Principle Containment Design Parameters
3. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.A to 0CAN031801 Page 154 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

CNB7 Containment hydrogen concentration > 3%

Definition(s):

None Basis:

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a potential loss of the Containment Barrier.

Reference(s):

1. Unit 1 SAMG Figure III-1B
2. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart
3. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.B to 0CAN031801 Page 155 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

CNB8 Containment pressure > 44.7 psia[23.3 psia] with < one full train of containment heat removal systems (Note 9) operating per design for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 9: One full train of containment heat removal systems consists of one train of RB [Containment]

Spray and one train of RB [Containment] Cooling System.

Definition(s):

None Basis:

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 but not including containment venting strategies) are either lost or performing in a degraded manner.

Reference(s):

1. 1SAR 6.2 Reactor Building Spray System
2. 1SAR 6.3 Reactor Building Cooling System
3. OP-2202.003 Loss of Coolant Accident
4. OP-2202.010 Standard Attachments, Attachment 22
5. 2SAR 6.2.2 Containment Heat Removal Systems
6. 2SAR 7.3.1.1.11.2 Containment Spray System
7. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.C to 0CAN031801 Page 156 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: E - Emergency Director Judgment Degradation Threat: Loss Threshold:

CNB9 Any condition in the opinion of the Emergency Director that indicates loss of the Containment barrier Definition(s):

None Basis:

This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is lost.

Reference(s):

1. NEI 99-01 Emergency Director Judgment Containment Loss 6.A to 0CAN031801 Page 157 of 240 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: E - Emergency Director Judgment Degradation Threat: Potential Loss Threshold:

CNB10 Any condition in the opinion of the Emergency Director that indicates potential loss of the Containment barrier Definition(s):

None Basis:

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

Reference(s):

1. NEI 99-01 Emergency Director Judgment Containment Potential Loss 6.A to 0CAN031801 Page 158 of 240 Attachment 1 - Emergency Action Level Technical Bases Category H - Hazards and Other Conditions Affecting Plant Safety EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

Hazards are non-plant, system-related events that can directly or indirectly affect plant operation, reactor plant safety or personnel safety.

1. Security Unauthorized entry attempts into the PROTECTED AREA, bomb threats, sabotage attempts, and actual security compromises threatening loss of physical control of the plant.
2. Seismic Event Natural events such as earthquakes have potential to cause plant structure or equipment damage of sufficient magnitude to threaten personnel or plant safety.
3. Natural or Technological Hazard Other natural and non-naturally occurring events that can cause damage to plant facilities include tornados, FLOODING, hazardous material releases and events restricting site access warranting classification.
4. Fire FIRES can pose significant hazards to personnel and reactor safety. Appropriate for classification are FIRES within the plant PROTECTED AREA or which may affect operability of equipment needed for safe shutdown.
5. Hazardous Gas Toxic, corrosive, asphyxiant or flammable gas leaks can affect normal plant operations or preclude access to plant areas required to safely shutdown the plant.
6. Control Room Evacuation Events that are indicative of loss of Control Room habitability. If the Control Room must be evacuated, additional support for monitoring and controlling plant functions is necessary through the emergency response facilities.
7. Emergency Director Judgment The EALs defined in other categories specify the predetermined symptoms or events that are indicative of emergency or potential emergency conditions and thus warrant classification.

While these EALs have been developed to address the full spectrum of possible emergency conditions which may warrant classification and subsequent implementation of the Emergency Plan, a provision for classification of emergencies based on operator/management experience and judgment is still necessary. The EALs of this category provide the Emergency Director the latitude to classify emergency conditions consistent with the established classification criteria based upon Emergency Director judgment.

to 0CAN031801 Page 159 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards Subcategory: 1 - Security Initiating Condition: Confirmed SECURITY CONDITION or threat EAL:

HU1.1 Unusual Event A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by ANO Security Shift Supervision OR Notification of a credible security threat directed at the site OR A validated notification from the NRC providing information of an aircraft threat Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.

Access to this area is controlled by the SOCA Personnel Access Control Point.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

to 0CAN031801 Page 160 of 240 Attachment 1 - Emergency Action Level Technical Bases PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

SECURITY CONDITION - Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A security condition does not involve a HOSTILE ACTION.

Basis:

This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1 and HS1.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and Offsite Response Organizations.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

The first threshold references the Security Shift Supervision because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR 2.39 information.

The second threshold addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with OP-1203.048 Security Event .

to 0CAN031801 Page 161 of 240 Attachment 1 - Emergency Action Level Technical Bases The third threshold addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC.

Validation of the threat is performed in accordance with 11-S-82-1 Security Contingency Events (ref. 2).

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).

Escalation of the emergency classification level would be via IC HA1.

Reference(s):

1. ANO Security Plan
2. OP-1203.048 Security Event
3. NEI 99-01 HU1 to 0CAN031801 Page 162 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards Subcategory: 1 - Security Initiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes EAL:

HA1.1 Alert A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by ANO Security Shift Supervision OR A validated notification from NRC of an aircraft attack threat within 30 min. of the site Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

HOSTILE FORCE - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.

Access to this area is controlled by the SOCA Personnel Access Control Point.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

to 0CAN031801 Page 163 of 240 Attachment 1 - Emergency Action Level Technical Bases Basis:

This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations (OROs), allowing them to be better prepared should it be necessary to consider further actions.

This EAL does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.

Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.

The first threshold is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA.

The second threshold addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with OP-1203.048 Security Event (ref. 2).

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRC.

In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.

to 0CAN031801 Page 164 of 240 Attachment 1 - Emergency Action Level Technical Bases Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).

Escalation of the emergency classification level would be via IC HS1.

Reference(s):

1. ANO Security Plan
2. OP-1203.048 Security Event
3. NEI 99-01 HA1 to 0CAN031801 Page 165 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards Subcategory: 1 - Security Initiating Condition: HOSTILE ACTION within the PROTECTED AREA EAL:

HS1.1 Site Area Emergency A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by ANO Security Shift Supervision Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

HOSTILE FORCE - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.

Access to this area is controlled by the SOCA Personnel Access Control Point.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

to 0CAN031801 Page 166 of 240 Attachment 1 - Emergency Action Level Technical Bases Basis:

This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event (ref. 1, 2).

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Site Area Emergency declaration will mobilize Offsite Response Organization (ORO) resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.

This EAL does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.

Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).

Reference(s):

1. ANO Security Plan
2. OP-1203.048 Security Event
3. NEI 99-01 HS1 to 0CAN031801 Page 167 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 2 - Seismic Event Initiating Condition: Seismic event greater than OBE levels EAL:

HU2.1 Unusual Event Seismic event > OBE as indicated by annunciation of the 0.10 g acceleration alarm Mode Applicability:

All Definition(s):

None Basis:

This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (OBE). An earthquake greater than an OBE but less than a Design Basis Earthquake (DBE) should have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections). Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety of the plant.

Event verification with external sources should not be necessary during or following an OBE.

Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., lateral accelerations in excess of 0.1g). The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA6 or SA9.

Two strong motion triaxial accelerometers, ACS-8001 and ACS-8003, located at the base slab provide alarms to the Unit 1 control room via the seismic network control center, C529-NCC.

One alarm from C529-NCC is triggered when a setpoint of 0.01g has been exceeded. This alarm indicates that an earthquake has occurred and the seismic monitoring system is recording seismic data. Another alarm from C529-NCC is triggered when the pre-determined value of 0.1g, indicating the OBE has been exceeded (ref. 2, 3).

to 0CAN031801 Page 168 of 240 Attachment 1 - Emergency Action Level Technical Bases To avoid inappropriate emergency classification resulting from spurious actuation of the seismic instrumentation or felt motion not attributable to seismic activity, an offsite agency (USGS, National Earthquake Information Center (NEIC)) can confirm that an earthquake has occurred in the area of the plant. Such confirmation should not, however, preclude a timely emergency declaration based on receipt of the OBE alarm. If requested, provide the analyst with the following ANO coordinates: 35º 18' 36" north latitude, 93º 13' 53" west longitude (ref. 4).

Alternatively, near real-time seismic activity can be accessed via the NEIC website:

Reference(s):

1. 1SAR 2.2.1 Location
2. 1SAR 2.7.2 Site Seismic Evaluation
3. 1SAR 2.7.6 Time-History Accelerograph
4. OP-1203.025 Natural Emergencies
5. OP-2203.008 Natural Emergencies
6. NEI 99-01 HU2 to 0CAN031801 Page 169 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.1 Unusual Event A tornado strike within the PROTECTED AREA Mode Applicability:

All Definition(s):

PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

This EAL addresses a tornado striking (touching down) within the PROTECTED AREA.

Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.

If damage is confirmed visually or by other in-plant indications, the event may be escalated to an Alert under EAL CA6.1 or SA9.1.

A tornado striking (touching down) within the PROTECTED AREA warrants declaration of an Unusual Event regardless of the measured wind speed at the meteorological tower. A tornado is defined as a violently rotating column of air in contact with the ground and extending from the base of a thunderstorm.

Reference(s):

1. OP-1203.025 Natural Emergencies
2. OP-2203.008 Natural Emergencies
3. NEI 99-01 HU3 to 0CAN031801 Page 170 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.2 Unusual Event 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 Mode Applicability:

All Definition(s):

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

This EAL addresses FLOODING of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.

Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.

to 0CAN031801 Page 171 of 240 Attachment 1 - Emergency Action Level Technical Bases Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.

Refer to EAL CA6.1 or SA9.1 for internal FLOODING affecting more than one SAFETY SYSTEM train.

Reference(s):

1. OP-1203.025 Natural Emergencies
2. OP-2203.008 Natural Emergencies
3. NEI 99-01 HU3 to 0CAN031801 Page 172 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.3 Unusual Event Movement of personnel within the PROTECTED AREA is IMPEDED due to an event external to the PROTECTED AREA involving hazardous materials (e.g., an offsite chemical spill or toxic gas release)

Mode Applicability:

All Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

This EAL addresses a hazardous materials event originating at a location outside the PROTECTED AREA and of sufficient magnitude to IMPEDE the movement of personnel within the PROTECTED AREA.

Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.

Reference(s):

1. NEI 99-01 HU3 to 0CAN031801 Page 173 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.4 Unusual Event A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles (Note 7)

Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

Mode Applicability:

All Definition(s):

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

This EAL addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.

Examples of such an event include site FLOODING caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.

This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the FLOODING around the Cooper Station during the Midwest floods of 1993, or the FLOODING around Ft. Calhoun Station in 2011.

Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.

Reference(s):

1. NEI 99-01 HU3 to 0CAN031801 Page 174 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.1 Unusual Event A FIRE is not extinguished within 15 min. of any of the following FIRE detection indications (Note 1):

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 The FIRE is located within any Table 1[2]H-1 area Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1H-1 Unit 1 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Penthouse/MSIV Room Exceptions:

Boric Acid Mix Tank Room (Chem Add Area), 404 (157-B), EDG Exhaust Fan area on 386 (1-E and 2-E)

Turbine Building All elevations including: Pipechase under ICW Coolers, CRD Pump Pit/T-28 Room/Area under ICW Pumps Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)

Manholes adjacent to Intake Structure (MH-05/MH-06)

Intake Structure (354 and 366)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10) to 0CAN031801 Page 175 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2H-1 Unit 2 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Aux Extension Turbine Building All elevations Outside Areas Intake Structure (354 and 366)

Concrete Manhole East, NE of intake (2MH-01)

Concrete Manhole East of Turbine Building next to train bay (2MH-03)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)

Mode Applicability:

All Definition(s):

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.

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.

to 0CAN031801 Page 176 of 240 Attachment 1 - Emergency Action Level Technical Bases Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via EAL CA6.1 or SA9.1.

The 15 minute requirement begins with a credible notification that a FIRE is occurring, or receipt of multiple VALID fire detection system alarms or field validation of a single fire alarm. The alarm is to be validated using available Control Room indications or alarms to prove that it is not spurious, or by reports from the field.

Table 1[2]H-1 Fire Areas are those areas that contain equipment necessary for safe operation and shutdown of the plant (ref. 1, 2).

Reference(s):

1. OP-1203.049 Fires in Areas Affecting Safe Shutdown
2. OP- 2203.049 Fires in Areas Affecting Safe Shutdown
3. NEI 99-01 HU4 to 0CAN031801 Page 177 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.2 Unusual Event Receipt of a single fire alarm (i.e., no other indications of a FIRE)

AND The fire alarm is indicating a FIRE within any Table 1[2]H-1 area AND The existence of a FIRE is not verified within 30 min. of alarm receipt (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1H-1 Unit 1 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Penthouse/MSIV Room Exceptions:

Boric Acid Mix Tank Room (Chem Add Area), 404 (157-B), EDG Exhaust Fan area on 386 (1-E and 2-E)

Turbine Building All elevations including: Pipechase under ICW Coolers, CRD Pump Pit/T-28 Room/Area under ICW Pumps Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)

Manholes adjacent to Intake Structure (MH-05/MH-06)

Intake Structure (354 and 366)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10) to 0CAN031801 Page 178 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2H-1 Unit 2 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Aux Extension Turbine Building All elevations Outside Areas Intake Structure (354 and 366)

Concrete Manhole East, NE of intake (2MH-01)

Concrete Manhole East of Turbine Building next to train bay (2MH-03)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)

Mode Applicability:

All Definition(s):

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.

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

to 0CAN031801 Page 179 of 240 Attachment 1 - Emergency Action Level Technical Bases A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.

If an actual FIRE is verified by a report from the field, then HU4.1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report.

If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.

Basis-Related Fire Protection Requirements Criterion 3 of 10 CFR 50, Appendix A, states, in part:

Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.

In this respect, noncombustible and heat resistant materials are used wherever practical throughout the unit, particularly in locations such as the containment and Control Room. Fire detection and fighting systems of appropriate capacity and capability are provided and designed to minimize the adverse effects of fires on SSCs important to safety. Firefighting systems are designed to assure that the rupture or inadvertent operation of a fire system does not significantly impair the safety capability of these structures, systems, and components.

In addition, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train is employed. As used in HU4.2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via EAL CA6.1 or SA9.1.

The 30-minute requirement begins upon receipt of a single VALID fire detection system alarm.

The alarm is to be validated using available Control Room indications or alarms to prove that it is not spurious, or by reports from the field. Actual field reports must be made within the 30-minute time limit or a classification must be made. If a fire is verified to be occurring by field report, classification shall be made based on EAL HU4.1, with the 15-minute requirement beginning with the verification of the fire by field report.

Table 1[2]H-1 Fire Areas are those areas that contain equipment necessary for safe operation and shutdown of the plant (ref. 1, 2).

to 0CAN031801 Page 180 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1203.049 Fires in Areas Affecting Safe Shutdown
2. OP- 2203.049 Fires in Areas Affecting Safe Shutdown
3. NEI 99-01 HU4 to 0CAN031801 Page 181 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.3 Unusual Event A FIRE within the PROTECTED AREA not extinguished within 60 min. of the initial report, alarm or indication (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

All Definition(s):

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

In addition to a FIRE addressed by EAL HU4.1 or HU4.2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via EAL CA6.1 or SA8.1.

Reference(s):

1. NEI 99-01 HU4 to 0CAN031801 Page 182 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.4 Unusual Event A FIRE within the PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish Mode Applicability:

All Definition(s):

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

If a FIRE within the plant PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish. Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via EAL CA6.1 or SA9.1.

Reference(s):

1. NEI 99-01 HU4 to 0CAN031801 Page 183 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 5 - Hazardous Gas Initiating Condition: Gaseous release IMPEDING access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

HA5.1 Alert Release of a toxic, corrosive, asphyxiant or flammable gas into any Table 1[2]H-2 room or area AND Entry into the room or area is prohibited or IMPEDED (Note 5)

Note 5: 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.

Table 1H-2 Unit 1 Safe Operation & Shutdown Rooms/Areas Room/Area Mode A-4 Switchgear Room 3, 4 Upper North Electrical Penetration Room 3, 4 Lower South Electrical Equipment Room 3, 4 Table 2H-2 Unit 2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux Building 317 Emergency Core Cooling Rooms 3, 4 Aux Building 317 Tendon Gallery Access 3, 4 Aux Building 335 Charging Pumps / MCC 2B-52 3, 4 Aux Building 354 MCC 2B-62 Area 3, 4 Emergency Diesel Generator Corridor 3, 4 Lower South Piping Penetration Room 3, 4 Aux Building 386 Containment Hatch 3, 4 to 0CAN031801 Page 184 of 240 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

3 - Hot Standby, 4 - Hot Shutdown Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

Basis:

This IC addresses an event involving a release of a hazardous gas that precludes or IMPEDES access to equipment necessary to maintain normal plant operation, or required for a normal plant cooldown and shutdown. This condition represents an actual or potential substantial degradation of the level of safety of the plant.

An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.

Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Directors judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly IMPEDE procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards.

Access should be considered as IMPEDED if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

An emergency declaration is not warranted if any of the following conditions apply:

The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release). For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.

The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).

The access control measures are of a conservative or precautionary nature, and would not actually prevent or IMPEDE a required action.

to 0CAN031801 Page 185 of 240 Attachment 1 - Emergency Action Level Technical Bases If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact 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.

This EAL does not apply to firefighting activities that generate smoke and that automatically or manually activate a fire suppression system in an area.

The list of plant rooms or areas with entry-related mode applicability identified specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations) are not included. In addition, the list specifies the plant mode(s) during which entry would be required for each room or area (ref. 1).

Escalation of the emergency classification level would be via Recognition Category A, C or F ICs.

EAL HA5.1 mode applicability has been limited to the mode limitations of Table 1[2]H-2 (Modes 3 and 4 only).

Reference(s):

1. Attachment 2 Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases
2. NEI 99-01 HA5 to 0CAN031801 Page 186 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 6 - Control Room Evacuation Initiating Condition: Control Room evacuation resulting in transfer of plant control to alternate locations EAL:

HA6.1 Alert An event has resulted in plant control being transferred from the Control Room to alternate locations Mode Applicability:

All Definition(s):

None Basis:

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety.

Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations. The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel. Activation of the ERO and emergency response facilities will assist in responding to these challenges.

Transfer of plant control begins when the last licensed operator leaves the Control Room.

Escalation of the emergency classification level would be via IC HS6.

Reference(s):

1. OP-1203.002 Alternate Shutdown
2. OP-2203.014 Alternate Shutdown
3. NEI 99-01 HA6 to 0CAN031801 Page 187 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 6 - Control Room Evacuation Initiating Condition: Inability to control a key safety function from outside the Control Room EAL:

HS6.1 Site Area Emergency An event has resulted in plant control being transferred from the Control Room to alternate locations AND Control of any of the following key safety functions is not re-established within 15 min. (Note 1):

Reactivity (Modes 1, 2 and 3 only)

Core cooling RCS heat removal Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling Definition(s):

None Basis:

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plant control to alternate locations is a precursor to a challenge to one or more fission product barriers within a relatively short period of time.

The determination of whether or not control is established at the remote safe shutdown location(s) is based on Emergency Director judgment. The Emergency Director is expected to make a reasonable, informed judgment within 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).

to 0CAN031801 Page 188 of 240 Attachment 1 - Emergency Action Level Technical Bases Transfer of plant control and the time period to establish control begins when the last licensed operator leaves the Control Room.

Escalation of the emergency classification level would be via IC FG1 or CG1 Reference(s):

1. OP-1203.002 Alternate Shutdown
2. OP-2203.014 Alternate Shutdown
3. NEI 99-01 HS6 to 0CAN031801 Page 189 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - Emergency Director Judgment Initiating Condition: Other conditions exist that in the judgment of the Emergency Director warrant declaration of a UE EAL:

HU7.1 Unusual Event 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.

Mode Applicability:

All Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an UNUSUAL EVENT.

Reference(s):

1. NEI 99-01 HU7 to 0CAN031801 Page 190 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - Emergency Director Judgment Initiating Condition: Other conditions exist that in the judgment of the Emergency Director warrant declaration of an ALERT EAL:

HA7.1 Alert 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.

Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.

Access to this area is controlled by the SOCA Personnel Access Control Point.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

to 0CAN031801 Page 191 of 240 Attachment 1 - Emergency Action Level Technical Bases Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an ALERT.

Reference(s):

1. NEI 99-01 HA7 to 0CAN031801 Page 192 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - Emergency Director Judgment Initiating Condition: Other conditions exist that in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY EAL:

HS7.1 Site Area Emergency 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.

Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.

Access to this area is controlled by the SOCA Personnel Access Control Point.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

to 0CAN031801 Page 193 of 240 Attachment 1 - Emergency Action Level Technical Bases PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a SITE AREA EMERGENCY.

Reference(s):

1. NEI 99-01 HS7 to 0CAN031801 Page 194 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - Emergency Director Judgment Initiating Condition: Other conditions exist that in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY EAL:

HG7.1 General Emergency Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

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.

OWNER CONTROLLED AREA - For the purposes of classification this is the Security Owner Controlled Area (SOCA). The SOCA is demarcated as a Vehicle Barrier System (VBS) and a detection fence on the outside and a delay fence on the inside of the passive and active barriers. The SOCA is the area inside the SOCA VBS up to the PROTECTED AREA fence line.

Access to this area is controlled by the SOCA Personnel Access Control Point.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

to 0CAN031801 Page 195 of 240 Attachment 1 - Emergency Action Level Technical Bases PROTECTED AREA - An area encompassed by physical barriers (i.e., the security fence) and to which access is controlled.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a GENERAL EMERGENCY.

Reference(s):

1. NEI 99-01 HG7 to 0CAN031801 Page 196 of 240 Attachment 1 - Emergency Action Level Technical Bases Category S - System Malfunction EAL Group: Hot Conditions (RCS temperature > 200°F); EALs in this category are applicable only in one or more hot operating modes.

Numerous system-related equipment failure events that warrant emergency classification have been identified in this category. They may pose actual or potential threats to plant safety.

The events of this category pertain to the following subcategories:

1. Loss of Vital AC Power Loss of vital electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite sources for vital 4.16 KV buses.
2. Loss of Vital DC Power Loss of emergency electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of vital plant 125V DC power sources.
3. Loss of Control Room Indications Certain events that degrade plant operator ability to effectively assess plant conditions within the plant warrant emergency classification. Losses of indicators are in this subcategory.
4. RCS Activity During normal operation, reactor coolant fission product activity is very low. Small concentrations of fission products in the coolant are primarily from the fission of tramp uranium in the fuel clad or minor perforations in the clad itself. Any significant rise from these base-line levels (2% - 5% clad failures) is indicative of fuel failures and is covered under the Fission Product Barrier Degradation category. However, lesser amounts of clad damage may result in coolant activity exceeding Technical Specification limits. These fission products will be circulated with the reactor coolant and can be detected by coolant sampling.
5. RCS Leakage The reactor vessel provides a volume for the coolant that covers the reactor core. The reactor pressure vessel and associated pressure piping (reactor coolant system) together provide a barrier to limit the release of radioactive material should the reactor fuel clad integrity fail. Excessive RCS leakage greater than Technical Specification limits indicates potential pipe cracks that may propagate to an extent threatening fuel clad, RCS and containment integrity.

to 0CAN031801 Page 197 of 240 Attachment 1 - Emergency Action Level Technical Bases

6. RPS Failure This subcategory includes events related to failure of the Reactor Protection System (RPS) to initiate and complete reactor trips. In the plant licensing basis, postulated failures of the RPS to complete a reactor trip comprise a specific set of analyzed events referred to as Anticipated Transient Without Scram (ATWS) events. For EAL classification, however, ATWS is intended to mean any trip failure event that does not achieve reactor shutdown. If RPS actuation fails to assure reactor shutdown, positive control of reactivity is at risk and could cause a threat to fuel clad, RCS and containment integrity.
7. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.
8. Containment Failure Failure of containment isolation capability (under conditions in which the containment is not currently challenged) warrants emergency classification. Failure of containment pressure control capability also warrants emergency classification.
9. Hazardous Event Affecting Safety Systems Various natural and technological events that result in degraded plant safety system performance or significant VISIBLE DAMAGE warrant emergency classification under this subcategory.

to 0CAN031801 Page 198 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Loss of all offsite AC power capability to vital buses for 15 minutes or longer EAL:

SU1.1 Unusual Event Loss of all offsite AC power capability, Table 1[2]S-1, to vital 4.16 KV buses A3[2A3] and A4[2A4] for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1S-1 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite Unit Auxiliary Transformer (main generator via main transformer)

DG1 DG2 AAC Gen to 0CAN031801 Page 199 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2S-1 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)

Onsite Unit Auxiliary Transformer (main generator via main transformer) 2DG1 2DG2 AAC Gen Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None 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 vital 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 vital buses, whether or not the buses are powered from it.

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

Escalation of the emergency classification level would be via IC SA1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram
2. OP-1202.007 Degraded Power
3. OP-1202.008 Blackout
4. OP-2104.037 Alternate AC Diesel Generator Operations to 0CAN031801 Page 200 of 240 Attachment 1 - Emergency Action Level Technical Bases
5. 2SAR Figure 8.3-1 Station Single Line Diagram
6. OP-2202.007 Loss of Off-Site Power
7. OP-2202.008 Station Blackout
8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
9. NEI 99-01 SU1 to 0CAN031801 Page 201 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Loss of all but one AC power source to vital buses for 15 minutes or longer EAL:

SA1.1 Alert AC power capability, Table 1[2]S-1, to vital 4.16 KV buses A3[2A3] and A4[2A4] reduced to a single power source for 15 min. (Note 1)

AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1S-1 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite Unit Auxiliary Transformer (main generator via main transformer)

DG1 DG2 AAC Gen to 0CAN031801 Page 202 of 240 Attachment 1 - Emergency Action Level Technical Bases Table 2S-1 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)

Onsite Unit Auxiliary Transformer (main generator via main transformer) 2DG1 2DG2 AAC Gen Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

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 SU1.

to 0CAN031801 Page 203 of 240 Attachment 1 - Emergency Action Level Technical Bases An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to a vital bus. Some examples of this condition are presented below.

A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).

A loss of all offsite power and loss of all vital power sources (e.g., onsite diesel generators) with a single train of vital buses being back-fed from the unit main generator.

A loss of vital power sources (e.g., onsite diesel generators) with a single train of vital 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 SS1.

This EAL is the hot condition equivalent of the cold condition EAL CU2.1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram
2. OP-1202.007 Degraded Power
3. OP-1202.008 Blackout
4. OP-2104.037 Alternate AC Diesel Generator Operations
5. 2SAR Figure 8.3-1 Station Single Line Diagram
6. OP-2202.007 Loss of Off-Site Power
7. OP-2202.008 Station Blackout
8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
9. NEI 99-01 SA1 to 0CAN031801 Page 204 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Loss of all offsite power and all onsite AC power to vital buses for 15 minutes or longer EAL:

SS1.1 Site Area Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3[2A3] and A4[2A4] for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Although the AAC may be considered available, it will not prevent declaration of this EAL unless it is powering a vital bus within the 15 minute time period of the EAL.

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.

Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or emergency operating procedures, or beyond design basis to 0CAN031801 Page 205 of 240 Attachment 1 - Emergency Action Level Technical Bases accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.

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

Escalation of the emergency classification level would be via IC AG1, FG1 or SG1.

This EAL is the hot condition equivalent of the cold condition EAL CA2.1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram
2. OP-1202.007 Degraded Power
3. OP-1202.008 Blackout
4. OP-2104.037 Alternate AC Diesel Generator Operations
5. 2SAR Figure 8.3-1 Station Single Line Diagram
6. OP-2202.007 Loss of Off-Site Power
7. OP-2202.008 Station Blackout
8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
9. NEI 99-01 SS1 to 0CAN031801 Page 206 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Prolonged loss of all offsite and all onsite AC power to vital buses EAL:

SG1.1 General Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3[2A3] and A4[2A4]

AND EITHER:

Restoration of at least one vital 4.16 KV 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 (Note 1)

CETs > 1200°F Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC addresses a prolonged loss of all power sources to AC vital buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or to 0CAN031801 Page 207 of 240 Attachment 1 - Emergency Action Level Technical Bases emergency operating procedures, or beyond design basis accident response guidelines (e.g.,

FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. A prolonged loss of these buses will lead to a loss of one or more 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 vital 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 a greater likelihood of challenges to multiple fission product barriers. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the site-specific SBO coping analysis time (ref. 4, 5).

The estimate for restoring at least one vital bus should be based on a realistic appraisal of the situation. Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public.

The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.

Reference(s):

1. OP-1202.005 Inadequate Core Cooling
2. OP-2202.009 Functional Recovery
3. OP-2202.011 Lower Mode Functional Recovery
4. Unit 1 Calculation 85-E-0072-02 Time from Loss of All AC Power to Loss of Subcooling
5. Unit 2 Calculation 85-E-0072-01 Time from Loss of All AC Power to Loss of Subcooling
6. 1SAR Figure 8-1 Station Single Line Diagram
7. OP-1202.007 Degraded Power
8. OP-1202.008 Blackout
9. OP-2104.037 Alternate AC Diesel Generator Operations
10. 2SAR Figure 8.3-1 Station Single Line Diagram
11. OP-2202.007 Loss of Off-Site Power
12. OP-2202.008 Station Blackout
13. OP-2107.006 Backfeed of Unit Auxiliary Transformer
14. NEI 99-01 SG1 to 0CAN031801 Page 208 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Loss of all vital AC and vital DC power sources for 15 minutes or longer EAL:

SG1.2 General Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3[2A3] and A4[2A4] for 15 min. (Note 1)

AND Indicated voltage is < 105 VDC on D01[2D01] and D02[2D02] vital 125 VDC buses for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC (ref. 9, 10).

This IC addresses a concurrent and prolonged loss of both vital AC and Vital DC power. A loss of all vital AC power compromises the performance of all SAFETY SYSTEMS requiring electric to 0CAN031801 Page 209 of 240 Attachment 1 - Emergency Action Level Technical Bases power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or emergency operating procedures, or beyond design basis accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. A loss of vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both vital AC and vital 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 both EAL thresholds are met.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram
2. OP-1202.007 Degraded Power
3. OP-1202.008 Blackout
4. OP-2104.037 Alternate AC Diesel Generator Operations
5. 2SAR Figure 8.3-1 Station Single Line Diagram
6. OP-2202.007 Loss of Off-Site Power
7. OP-2202.008 Station Blackout
8. OP-2107.006 Backfeed of Unit Auxiliary Transformer
9. 1SAR 8.3.2.1.1 Batteries
10. 2SAR 8.3.2.1.1 Batteries
11. OP-1203.036 Loss of 125V DC
12. OP-2203.037 Loss of 125V DC
13. 2SAR Figure 8.3-6 Low Voltage Safety System Power Supplies
14. NEI 99-01 SG8 to 0CAN031801 Page 210 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 2 - Loss of Vital DC Power Initiating Condition: Loss of all vital DC power for 15 minutes or longer EAL:

SS2.1 Site Area Emergency Indicated voltage is < 105 VDC on D01[2D01] and D02[2D02] vital 125 VDC buses for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC (ref. 2, 3).

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 IC AG1, FG1 or SG1.

This EAL is the hot condition equivalent of the cold condition EAL CU4.1.

to 0CAN031801 Page 211 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram
2. 1SAR 8.3.2.1.1 Batteries
3. 2SAR 8.3.2.1.1 Batteries
4. OP-1203.036 Loss of 125V DC
5. OP-2203.037 Loss of 125V DC
6. 2SAR Figure 8.3-6 Low Voltage Safety System Power Supplies
7. NEI 99-01 SS8 to 0CAN031801 Page 212 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 3 - Loss of Control Room Indications Initiating Condition: UNPLANNED loss of Control Room indications for 15 minutes or longer EAL:

SU3.1 Unusual Event An UNPLANNED event results in the inability to monitor one or more Table 1[2]S-2 parameters from within the Control Room for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1[2]S-2 Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one S/G EFW flow to at least one S/G Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

to 0CAN031801 Page 213 of 240 Attachment 1 - Emergency Action Level Technical Bases 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.

Basis:

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 one or more of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.

An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level 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 EAL SA3.1.

Reference(s):

1. 1SAR 7.5 Safety-Related Display Instrumentation
2. 2SAR 7.5 Safety-Related Display Instrumentation
3. NEI 99-01 SU2 to 0CAN031801 Page 214 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 3 - Loss of Control Room Indications Initiating Condition: UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress EAL:

SA3.1 Alert An UNPLANNED event results in the inability to monitor one or more Table 1[2]S-2 parameters from within the Control Room for 15 min. (Note 1)

AND Any significant transient is in progress, Table 1[2]S-3 Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1[2]S-2 Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one S/G EFW flow to at least one S/G Table 1[2]S-3 Significant Transients Reactor trip Runback > 25% thermal power Electrical load rejection > 25% electrical load Safety injection actuation to 0CAN031801 Page 215 of 240 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 (as defined in 10 CFR 50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

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.

Basis:

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 one or more of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.

An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be to 0CAN031801 Page 216 of 240 Attachment 1 - Emergency Action Level Technical Bases more significant than simply a reportable condition. In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level 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 FS1 or AS1.

Reference(s):

1. 1SAR 7.1.3 Engineered Safeguards Actuation System
2. 2SAR 7.3 Engineered Safety Features Systems
3. NEI 99-01 SA2 to 0CAN031801 Page 217 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 4 - RCS Activity Initiating Condition: RCS activity greater than Technical Specification allowable limits EAL:

SU4.1 Unusual Event Failed Fuel Iodine radiation monitor RI-1237S[2RITS-4806B] > 9.0 E5 cpm Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None 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.

Escalation of the emergency classification level would be via IC FA1 or the Recognition Category A ICs.

Unit 1 RE-1237S, Failed Fuel Monitor, is in the letdown system to monitor the letdown line for evidence of fuel damage.

Unit 2 specific activity monitor 2RITS-4806B monitors the Letdown fluid for the presence of Iodine-131.

A monitor reading corresponding to the instantaneous dose equivalent I-131 value of 60 uCi/gm is determined by multiplying by 30 the monitor reading listed in the table in OP-1203.019[OP-2203.020] that represents a projected 2.0 uCi/gm I-131 RCS activity(ref. 2, 5).

This yields values of 3.1E6 cpm for Unit 1 and 3.9E6 cpm for Unit 2. The top of scale of the monitor is 1E6. The EAL value is set at 9.0 E5 cpm for both units which is 90% of the top of the scale.

to 0CAN031801 Page 218 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. 1SAR Table 11-7
2. OP-1203-019 High Activity in Reactor Coolant
3. Unit 1 Technical Specifications LCO 3.4.12 RCS Specific Activity
4. 2SAR 9.3.5 Failed Fuel Detection System
5. OP-2203.020 High Activity in RCS
6. OP- 2203.012L ANNUNCIATOR 2K12 CORRECTIVE ACTION, A-1
7. Unit 2 Technical Specifications LCO 3.4.8 Reactor Coolant System Specific Activity
8. NEI 99-01 SU3 to 0CAN031801 Page 219 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 4 - RCS Activity Initiating Condition: RCS activity greater than Technical Specification allowable limits EAL:

SU4.2 Unusual Event RCS sample activity > 1.0 µCi/gm dose equivalent I-131 for > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (Note 1)

OR RCS sample activity > 60 µCi/gm dose equivalent I-131 OR RCS sample activity > 2200[3100] µCi/gm dose equivalent Xe-133 for > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None 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.

Escalation of the emergency classification level would be via IC FA1 or the Recognition Category A ICs.

Reference(s):

1. Unit 1 Technical Specifications LCO 3.4.12 RCS Specific Activity
2. Unit 2 Technical Specifications LCO 3.4.8 Reactor Coolant System Specific Activity
3. NEI 99-01 SU3 to 0CAN031801 Page 220 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 5 - RCS Leakage Initiating Condition: RCS leakage for 15 minutes or longer EAL:

SU5.1 Unusual Event RCS unidentified or pressure boundary leakage > 10 gpm for 15 min. (Note 1)

OR RCS identified leakage > 25 gpm for 15 min. (Note 1)

OR Reactor coolant leakage to a location outside containment > 25 gpm for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

Basis:

Failure to isolate the leak (from the Control Room or locally) within 15 minutes, or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

Steam generator tube leakage is identified RCS leakage.

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.

The first and second EAL conditions 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). The third condition addresses an RCS mass loss caused by an UNISOLABLE leak through an interfacing system. These conditions thus apply to leakage into the containment, a secondary-side system (e.g., steam generator tube leakage) or a location outside of containment.

to 0CAN031801 Page 221 of 240 Attachment 1 - Emergency Action Level Technical Bases The leak rate values for each condition 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). The first condition 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 A or F.

Reference(s):

1. Unit 1 and Unit 2 Technical Specifications Section 1.1 Definitions
2. NEI 99-01 SU4 to 0CAN031801 Page 222 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 6 - RPS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor EAL:

SU6.1 Unusual Event An automatic trip did not shut down the reactor as indicated by reactor power > 5% after any RPS setpoint is exceeded AND A subsequent automatic trip or manual trip action taken at the reactor control console (C03

[2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) is successful in shutting down the reactor as indicated by reactor power 5% (Note 8)

Note 8: 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.

Mode Applicability:

1 - Power Operation Definition(s):

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.

Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic trip is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.

In the event that the operator identifies a reactor trip is IMMINENT and initiates a successful manual reactor trip before the automatic trip setpoint is reached, no declaration is required. The successful manual trip of the reactor before it reaches its automatic trip setpoint or reactor trip signals caused by instrumentation channel failures do not lead to a potential fission product barrier loss.

to 0CAN031801 Page 223 of 240 Attachment 1 - Emergency Action Level Technical Bases Following the failure of 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 plants decay heat removal systems.

If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles 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 plants decay heat removal systems.

A manual action at the reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor 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 reactor control consoles.

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 reactor control consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC SA6. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC SA6 or FA1, an Unusual Event declaration is appropriate for this event.

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 results in a condition that should have included an automatic reactor trip and the RPS fails to automatically shutdown the reactor, then this IC and associated EALs are applicable, and should be evaluated.

If the signal generated as a result of plant work does not cause a plant transient and the trip failure is determined through other means (e.g., assessment of test results), then this IC and associated EALs are not applicable and no classification is warranted.

to 0CAN031801 Page 224 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
4. OP-1202.001 Reactor Trip
5. OP-2202.001 Standard Post Trip Actions
6. NEI 99-01 SU5 to 0CAN031801 Page 225 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 6 - RPS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor EAL:

SU6.2 Unusual Event A manual trip did not shut down the reactor as indicated by reactor power > 5% after any manual trip action was initiated AND A subsequent automatic trip or manual trip action taken at the reactor control console (C03

[2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) is successful in shutting down the reactor as indicated by reactor power 5% (Note 8)

Note 8: A manual scram 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.

Mode Applicability:

1 - Power Operation Definition(s):

None Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic trip is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.

This EAL addresses a failure of a manually initiated trip in the absence of having exceeded an automatic RPS trip setpoint and a subsequent automatic or manual trip is successful in shutting down the reactor.

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 plants decay heat removal systems.

to 0CAN031801 Page 226 of 240 Attachment 1 - Emergency Action Level Technical Bases If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles 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 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 plants decay heat removal systems.

A manual action at the reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor 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 reactor control consoles.

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 reactor control consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC SA6. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC SA6 or FA1, an Unusual Event declaration is appropriate for this event.

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 results in a condition that should have included an automatic reactor trip and the RPS fails to automatically shutdown the reactor, then this IC and associated EALs are applicable, and should be evaluated.

If the signal generated as a result of plant work does not cause a plant transient and the trip failure is determined through other means (e.g., assessment of test results), then this IC and associated EALs are not applicable and no classification is warranted.

Reference(s):

1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
4. OP-1202.001 Reactor Trip
5. OP-2202.001 Standard Post Trip Actions
6. NEI 99-01 SU5 to 0CAN031801 Page 227 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 6 - RPS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor EAL:

SA6.1 Alert An automatic or manual trip fails to shut down the reactor as indicated by reactor power > 5%

AND Manual trip actions taken at the reactor control console (C03[2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) are not successful in shutting down the reactor as indicated by reactor power > 5% (Note 8)

Note 8: 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.

Mode Applicability:

1 - Power Operation Definition(s):

None 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 reactor control console 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 console (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 console.

to 0CAN031801 Page 228 of 240 Attachment 1 - Emergency Action Level Technical Bases 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 shut down the reactor is prolonged enough to cause a challenge to the core cooling or RCS heat removal safety functions, the emergency classification level will escalate to a Site Area Emergency via IC SS6. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC SS6 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.

Reference(s):

1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
4. OP-1202.001 Reactor Trip
5. OP-2202.001 Standard Post Trip Actions
6. NEI 99-01 SA5 to 0CAN031801 Page 229 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 6 - RPS Failure Initiating Condition: Inability to shut down the reactor causing a challenge to core cooling or RCS heat removal EAL:

SS6.1 Site Area Emergency An automatic or manual trip fails to shut down the reactor as indicated by reactor power > 5%

AND All actions to shut down the reactor are not successful as indicated by reactor power > 5%

AND EITHER:

CETs > 1200°F RCS heat removal cannot be established using steam generators and HPI[Once Through] cooling initiated.

Mode Applicability:

1 - Power Operation Definition(s):

None 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 actions to manually shutdown the reactor are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.

In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs. This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor.

Escalation of the emergency classification level would be via IC AG1 or FG1.

to 0CAN031801 Page 230 of 240 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation
2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation
3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes
4. OP-1202.001 Reactor Trip
5. OP-2202.001 Standard Post Trip Actions
6. OP-1202.004 Overheating
7. OP-2202.006 Loss of Feedwater
8. OP-1202.013 Figure 1, Saturation and Adequate SCM
9. Calculation 90-E-0116-07 Unit 1 EOP Setpoint Document, Setpoint B.19
10. OP-2202.009 Functional Recovery
11. Calculation 90-E-0116-01 Unit 2 EOP Setpoint Document
12. NEI 99-01 SS5 to 0CAN031801 Page 231 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 7 - Loss of Communications Initiating Condition: Loss of all onsite or offsite communications capabilities EAL:

SU7.1 Unusual Event Loss of all Table 1[2]S-4 onsite communication methods OR Loss of all Table 1[2]S-4 State and local agency communication methods OR Loss of all Table 1[2]S-4 NRC communication methods Table 1[2]S-4 Communication Methods System Onsite State / Local NRC Station radio system X ANO plant phone system X Gaitronics X Telephone Systems:

Commercial Microwave X X Satellite VOIP INFORM Notification System X Emergency Notification System (ENS) X Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown to 0CAN031801 Page 232 of 240 Attachment 1 - Emergency Action Level Technical Bases Definition(s):

None Basis:

This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to State and local agencies and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

The first EAL condition addresses a total loss of the communications methods used in support of routine plant operations.

The second EAL condition addresses a total loss of the communications methods used to notify all State and local agencies of an emergency declaration. The State and local agencies referred to here are the Arkansas Department of Health, Arkansas Department of Emergency Management, Pope, Yell, Johnson, and Logan County agencies.

The third EAL addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

This EAL is the hot condition equivalent of the cold condition EAL CU5.1.

Reference(s):

1. OP-1903.062 Communications System Operating Procedure
2. NEI 99-01 SU6 to 0CAN031801 Page 233 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 8 - Containment Failure Initiating Condition: Failure to isolate containment or loss of containment pressure control EAL:

SU8.1 Unusual Event Any penetration is not closed within 15 min. of an ESAS[CIAS] actuation signal OR Containment pressure > 44.7 psia[23.3 psia] with < one full train of containment heat removal systems (Note 9) operating per design for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 9: One full train of containment heat removal systems consists of one train of RB [Containment]

Spray and one train of RB [Containment] Cooling System.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

A penetration is closed for this EAL if either side of the penetration has a closed valve or a check valve is intact (for penetrations that only have one automatic valve and a check valve).

This EAL addresses a failure of one or more containment penetrations to automatically isolate (close) when required by an actuation signal. It also addresses an event that results in high containment pressure with a concurrent failure of containment pressure control systems.

Absent challenges to another fission product barrier, either condition represents potential degradation of the level of safety of the plant.

For the first condition, the containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); a failure resulting from testing or maintenance does not warrant classification. The determination of containment and penetration status - isolated or not isolated - should be made in accordance with the appropriate criteria contained in the plant AOPs and EOPs. The 15-minute criterion is included to allow operators time to manually isolate the required penetrations, if possible.

to 0CAN031801 Page 234 of 240 Attachment 1 - Emergency Action Level Technical Bases The second condition addresses a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. The inability to start the required equipment indicates that containment heat removal/depressurization systems (e.g., containment sprays) are either lost or performing in a degraded manner.

This event would escalate to a Site Area Emergency in accordance with IC FS1 if there were a concurrent loss or potential loss of either the Fuel Clad or RCS fission product barriers.

Reference(s):

1. OP-1202.010 ESAS
2. 1SAR 6.2 Reactor Building Spray System
3. 1SAR 6.3 Reactor Building Cooling System
4. OP-2202.003 Loss of Coolant Accident
5. OP-2202.010 Standard Attachments, Attachment 22
6. 2SAR 6.2.2 Containment Heat Removal Systems
7. 2SAR 7.3.1.1.11.2 Containment Spray System
8. NEI 99-01 SU7 to 0CAN031801 Page 235 of 240 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 9 - Hazardous Event Affecting Safety Systems Initiating Condition: Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode EAL:

SA9.1 Alert The occurrence of any Table 1[2]S-5 hazardous event AND Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode AND EITHER:

Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)

Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted.

Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

Table 1[2]S-5 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 to 0CAN031801 Page 236 of 240 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

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 require a post-event inspection to determine if the attributes of an explosion are present.

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.

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

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 (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

VISIBLE DAMAGE - Damage to a SAFETY SYSTEM train 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 SAFETY SYSTEM train.

Basis:

This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS needed for the current operating mode. In order to provide the appropriate context for consideration of an ALERT classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues.

to 0CAN031801 Page 237 of 240 Attachment 1 - Emergency Action Level Technical Bases Note that this second SAFETY SYSTEM train is from the same SAFETY SYSTEM that has indications of degraded performance; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events.

Indications of degraded performance addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

VISIBLE DAMAGE addresses damage to a SAFETY SYSTEM train that is not in service/operation and that potentially could cause performance issues. Operators will make a determination of VISIBLE DAMAGE 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. This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

Escalation of the emergency classification level would be via IC FS1 or AS1.

This EAL is the hot condition equivalent of the cold condition EAL CA6.1.

Reference(s):

1. EP FAQ 2016-002
2. NEI 99-01 SA9 to 0CAN031801 Page 238 of 240 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases

Background

NEI 99-01 Revision 6 ICs AA3 and HA5 prescribe declaration of an Alert based on impeded access to rooms or areas (due to either area radiation levels or hazardous gas concentrations) where equipment necessary for normal plant operations, cooldown or shutdown is located.

These areas are intended to be plant operating mode dependent. Specifically the Developers Notes for AA3 and HA5 states:

The site-specific list of plant rooms or areas with entry-related mode applicability identified should specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Do not include rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations). In addition, the list should specify the plant mode(s) during which entry would be required for each room or area.

The list should 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).

Further, as specified in IC HA5:

The list need not include the Control Room if adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas. Such features may include, but are not limited to, capability to draw air from multiple air intakes at different and separate locations, inner and outer atmospheric boundaries, or the capability to acquire and maintain positive pressure within the Control Room envelope.

to 0CAN031801 Page 239 of 240 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases ANO Table 1[2]A-3 and 1[2]H-2 Bases A review of station operating procedures identified the following mode dependent in-plant actions and associated areas that are required for normal plant operation, cooldown or shutdown:

Unit 1 AREA MODES PURPOSE REFERENCE Core flood tank valves, OP-1102.010 A-4 Switchgear Room 3, 4 decay heat removal (DHR) OP-1104.004 Upper North Electrical 3, 4 DHR alignment OP-1104.004 Penetration Room Lower South Electrical 3, 4 DHR alignment OP-1104.004 Equipment Room Unit 2 AREA MODES PURPOSE REFERENCE Aux Building 317 Emergency Shutdown Cooling (SDC) 3, 4 OP-2104.004 Core Cooling Rooms venting and alignment Aux Building 317 Tendon 3, 4 SDC alignment OP-2104.004 Gallery Access Aux Building 335 Charging Charging low pressure OP-2102.010 Pumps / Motor Control Center 3, 4 operation, T-Hot injection (MCC) 2B-52 valves, and SDC alignment OP-2104.004 SDC alignment and T-Hot OP-2102.010 Auxiliary Building 354 3, 4 injection valves at MCC 2B-62 Area OP-2104.004 MCC 2B-62 Close Safety Injection Tank (SIT) valves and SDC / Low Emergency Diesel Generator 3, 4 Temperature Overpressure OP-2102.010 Corridor (LTOP) valve alignment at MCC 2B-51 Lower South Piping 3, 4 SDC alignment OP-2104.004 Penetration Room Aux Building 386 Close SIT valves at 3, 4 OP-2102.010 Containment Hatch MCC 2B-61 Mode 3 is included above for DHR- and SDC-related activities because the procedures begin alignment in Mode 3; however, these actions could be delayed until Mode 4, if necessary. In order to ensure adequate guidance to emergency response personnel, the above areas are added to the EAL in order to provide prompt operator guidance for EAL declaration.

to 0CAN031801 Page 240 of 240 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases Both ANO-1 and ANO-2 Control Room ventilation systems have adequate engineered safety/design features in place to preclude a Control Room evacuation due to the release of a hazardous gas. Therefore the Control Room is not included in this assessment or in Tables 1[2]H-2.

Table 1[2]A-3 & 1[2]H-2 Results Table 1[2]A-3 & 1[2]H-2 Safe Operation & Shutdown Rooms/Areas Unit 1 Room/Area Mode Applicability A-4 Switchgear Room 3, 4 Upper North Electrical Penetration Room 3, 4 Lower South Electrical Equipment Room 3, 4 Unit 2 Room/Area Mode Applicability Aux Building 317 Emergency Core Cooling Rooms 3, 4 Aux Building 317 Tendon Gallery Access 3, 4 Aux Building 335 Charging Pumps / MCC 2B-52 3, 4 Auxiliary Building 354 MCC 2B-62 Area 3, 4 Emergency Diesel Generator Corridor 3, 4 Lower South Piping Penetration Room 3, 4 Aux Building 386 Containment Hatch 3, 4

Enclosure 4 to 0CAN031801 NEI 99-01, Rev. 6, Deviations and Differences, ANO Units 1 and 2 to 0CAN031801 Page 1 of 120 Table of Contents Section Page Introduction ------------------------------------------------------------------------------------------------------------ 2 Comparison Matrix Format ---------------------------------------------------------------------------------------- 2 EAL Wording ---------------------------------------------------------------------------------------------------------- 2 EAL Emphasis Techniques ---------------------------------------------------------------------------------------- 2 Global Differences --------------------------------------------------------------------------------------------------- 3 Differences and Deviations ---------------------------------------------------------------------------------------- 5 Category A - Abnormal Rad Levels / Rad Effluent -------------------------------------------------------- 17 Category C - Cold Shutdown / Refueling System Malfunction ----------------------------------------- 38 Category D - Permanently Defueled Station Malfunction ----------------------------------------------- 61 Category E -Independent Spent Fuel Storage Installation (ISFSI) ----------------------------------- 62 Category F - Fission Product Barrier Degradation -------------------------------------------------------- 63 Category H - Hazards and Other Conditions Affecting Plant Safety --------------------------------- 76 Category S - System Malfunction ----------------------------------------------------------------------------- 95 Table 1 - ANO EAL Categories/Subcategories -------------------------------------------------------------- 8 Table 2 - NEI / ANO EAL Identification Cross-Reference ------------------------------------------------- 9 Table 3 - Summary of Deviations ----------------------------------------------------------------------------- 14 to 0CAN031801 Page 2 of 120 Introduction This document provides a line-by-line comparison of the Initiating Conditions (ICs), Mode Applicability, and Emergency Action Levels (EALs) in NEI 99-01, Rev. 6, Final, Development of Emergency Action Levels for Non-Passive Reactors, ADAMS Accession Number ML12326A805, and Arkansas Nuclear One (ANO) Initiating Conditions (ICs), Mode Applicability, and EALs. This document provides a means of assessing ANO differences and deviations from the NRC endorsed guidance given in NEI 99-01. Discussion of ANO EAL bases and lists of source document references are given in the EAL Technical Bases Document. It is, therefore, advisable to reference the EAL Technical Bases Document for background information while using this document.

Comparison Matrix Format The ICs and EALs discussed in this document are grouped according to NEI 99-01 Recognition Categories. Within each Recognition Category, the ICs and EALs are listed in tabular format according to the order in which they are given in NEI 99-01. Generally, each row of the comparison matrix provides the following information:

NEI EAL/IC identifier NEI EAL/IC wording ANO EAL/IC identifier ANO EAL/IC wording Description of any differences or deviations EAL Wording In Section 4.1, NEI recommends the following: The guidance in NEI 99-01 is not intended to be applied to plants as-is; however, developers should attempt to keep their site-specific schemes as close to the generic guidance as possible. The goal is to meet the intent of the generic Initiating Conditions (ICs) and Emergency Action Levels (EALs) within the context of site-specific characteristics - locale, plant design, operating features, terminology, etc. Meeting this goal will result in a shorter and less cumbersome NRC review and approval process, closer alignment with the schemes of other nuclear power plant sites and better positioning to adopt future industry-wide scheme enhancements.

To assist the Emergency Director (ED), the ANO EALs have been written in a clear and concise style (to the extent that the differences from the NEI EAL wording could be reasonably documented and justified). This supports timely and accurate classification in the tense atmosphere of an emergency event. The EAL differences introduced to reduce reading burden comprise almost all of the differences justified in this document.

EAL Emphasis Techniques Due to the width of the table columns and table formatting constraints in this document, line breaks and indentation may differ slightly from the appearance of comparable wording in the source documents. NEI 99-01 is the source document for the NEI EALs; the ANO EAL Technical Bases Document for the ANO EALs.

to 0CAN031801 Page 3 of 120 Development of the ANO IC/EAL wording has attempted to minimize inconsistencies and apply sound human factors principles. As a result, differences occur between NEI and ANO ICs/EALs for these reasons alone. When such difference may infer a technical difference in the associated NEI IC/EAL, the difference is identified and a justification provided.

The print and paragraph formatting conventions summarized below guide presentation of the ANO EALs in accordance with the EAL writing criteria. Space restrictions in the EAL table of this document sometimes override this criteria in cases when following the criteria would introduce undesirable complications in the EAL layout.

Upper case-bold print is used for the logic terms AND, OR, and EITHER.

Bold font is used for certain logic terms, negative terms (not, cannot, etc.), any, all.

Upper case print is reserved for defined terms, acronyms, system abbreviations, logic terms (and, or, etc. when not used as a conjunction), annunciator window engravings.

Three or more items in a list are normally introduced with Any of the following... or All of the following... Items of the list begin with bullets when a priority or sequence is not inferred.

The use of AND/OR logic within the same EAL has been avoided when possible. When such logic cannot be avoided, indentation and separation of subordinate contingent phrases is employed.

Global Differences The differences listed below generally apply throughout the set of EALs and are not repeated in the Justification sections of this document. The global differences do not decrease the effectiveness of the intent of NEI 99-01.

1. The NEI phrase Notification of Unusual Event has been changed to Unusual Event or abbreviated "UE" to reduce EAL-user reading burden.
2. NEI 99-01 IC Example EALs are implemented in separate plant EALs to improve clarity and readability. For example, NEI lists all IC HU3 Example EALs under one IC. The corresponding ANO EALs appear as unique EALs (e.g., HU3.1 through HU3.4).
3. Mode applicability identifiers (numbers/letter) modify the NEI 99-01 mode applicability names as follows: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling, DEF - Defueled. NEI 99-01defines Defueled as follows: Reactor Vessel contains no irradiated fuel (full core off-load during refueling or extended outage).
4. NEI 99-01 uses the terms greater than, less than, greater than or equal to, etc., in the wording of some example EALs. For consistency and to reduce EAL-user reading burden, ANO has adopted use of boolean symbols in place of the NEI 99-01 text modifiers within the EAL wording.

to 0CAN031801 Page 4 of 120

5. min. is the standard abbreviation for minutes and is used to reduce EAL user reading burden.
6. Wherever the generic bracketed PWR term reactor vessel/RCS is provided, ANO uses the term RCS as the site-specific nomenclature.
7. IC/EAL identification:

NEI 99-01 defines the thresholds requiring emergency classification (example EALs) and assigns them to ICs which, in turn, are grouped in Recognition Categories.

ANO endeavors to optimize the NEI EAL organization and identification scheme to enhance usability of the plant-specific EAL set. To this end, the ANO IC/EAL scheme includes the following features:

a. Division of the NEI EAL set into three groups:

o EALs applicable under all plant operating modes - This group would be reviewed by the EAL-user any time emergency classification is considered.

o EALs applicable only under hot operating modes - This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby, Startup, or Power Operation mode.

o EALs applicable only under cold operating modes - This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refueling, or Defueled mode.

The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency.

b. Within each of the above three groups, EALs are assigned to categories and subcategories. Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. Subcategories are used as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The ANO EAL categories/subcategories and their relationship to NEI Recognition Categories are listed in Table 1.

to 0CAN031801 Page 5 of 120

c. Unique identification of each EAL - Four characters comprise the EAL identifier as illustrated in Figure 1.

Figure 1 - EAL Identifier EAL Identifier XXX.X Category (A, H, E, S, F, C) Sequential number within subcategory/classification Emergency classification (G, S, A, U) Subcategory number (1 if no subcategory)

The first character is a letter associated with the category in which the EAL is located. The second character is a letter associated with the emergency classification level (G for General Emergency, S for Site Area Emergency, A for Alert, and U for Notification of Unusual Event). The third character is a number associated with one or more subcategories within a given category.

Subcategories are sequentially numbered beginning with the number 1. If a category does not have a subcategory, this character is assigned the number

1. The fourth character is a number preceded by a period for each EAL within a subcategory. EALs are sequentially numbered within the emergency classification level of a subcategory beginning with the number 1.

The EAL identifier is designed to fulfill the following objectives:

o Uniqueness - The EAL identifier ensures that there can be no confusion over which EAL is driving the need for emergency classification.

o Speed in locating the EAL of concern - When the EALs are displayed in a matrix format, knowledge of the EAL identifier alone can lead the EAL-user to the location of the EAL within the classification matrix. The identifier conveys the category, subcategory and classification level. This assists Emergency Response Organization (ERO) responders (who may not be in the same facility as the ED) to find the EAL of concern in a timely manner without the need for a word description of the classification threshold.

o Possible classification upgrade - The category/subcategory/identifier scheme helps the EAL-user find higher emergency classification EALs that may become active if plant conditions worsen.

Table 2 lists the ANO ICs and EALs that correspond to the NEI ICs/Example EALs when the above EAL/IC organization and identification scheme is implemented.

Differences and Deviations In accordance NRC Regulatory Issue Summary (RIS) 2003-18 Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels Supplements 1 and 2, a difference is an EAL change in which the basis scheme guidance differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the ANO EAL. A deviation is an EAL change in which the basis to 0CAN031801 Page 6 of 120 scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the ANO proposed EAL.

Administrative changes that do not actually change the textual content are neither differences nor deviations. Likewise, any format change that does not alter the wording of the IC or EAL is considered neither a difference nor a deviation.

The following are examples of differences:

Choosing the applicable EAL based upon plant type (i.e., BWR vs. PWR).

Using a numbering scheme other than that provided in NEI 99-01 that does not change the intent of the overall scheme.

Where the NEI 99-01 guidance specifically provides an option to not include an EAL, if equipment for the EAL does not exist at ANO (e.g., automatic real-time dose assessment capability).

Pulling information from the bases section up to the actual EAL that does not change the intent of the EAL.

Choosing to state ALL Operating Modes are applicable instead of stating N/A, or listing each mode individually under the Abnormal Rad Level/Radiological Effluent and Hazard and Other Conditions Affecting Plant Safety sections.

Using synonymous wording (e.g., greater than or equal to vs. at or above, less than or equal vs. at or below, greater than or less than vs. above or below, etc.)

Adding ANO equipment/instrument identification and/or noun names to EALs.

Combining like ICs that are exactly the same, but have different operating modes as long as the intent of each IC is maintained and the overall progression of the EAL scheme is not affected.

Any change to the IC and/or EAL, and/or basis wording, as stated in NEI 99-01, that does not alter the intent of the IC and/or EAL, i.e., the IC and/or EAL continues to:

o Classify at the correct classification level.

o Logically integrate with other EALs in the EAL scheme.

o Ensure that the resulting EAL scheme is complete (i.e., classifies all potential emergency conditions).

The following are examples of deviations:

Use of altered mode applicability.

Altering key words or time limits.

to 0CAN031801 Page 7 of 120 Changing words of physical reference (protected area, safety-related equipment, etc.).

Eliminating an IC. This includes the removal of an IC from the Fission Product Barrier Degradation category as this impacts the logic of Fission Product Barrier ICs.

Changing a Fission Product Barrier from a Loss to a Potential Loss or vice-versa.

Not using NEI 99-01definitions as the intent is for all NEI 99-01 users to have a standard set of defined terms as defined in NEI 99-01. Differences due to plant types are permissible (BWR or PWR). Verbatim compliance to the wording in NEI 99-01 is not necessary as long as the intent of the defined word is maintained. Use of the wording provided in NEI 99-01 is encouraged since the intent is for all users to have a standard set of defined terms as defined in NEI 99-01.

Any change to the IC and/or EAL, and/or basis wording as stated in NEI 99-01 that does alter the intent of the IC and/or EAL, i.e., the IC and/or EAL:

o Does not classify at the classification level consistent with NEI 99-01.

o Is not logically integrated with other EALs in the EAL scheme.

o Results in an incomplete EAL scheme (i.e., does not classify all potential emergency conditions).

The Difference/Deviation Justification columns in the remaining sections of this document identify each difference between the NEI 99-01 IC/EAL wording and the ANO IC/EAL wording.

An explanation that justifies the reason for each difference is then provided. If the difference is determined to be a deviation, a statement is made to that affect and explanation is given that states why classification may be different from the NEI 99-01 IC/EAL and the reason for its acceptability. In all cases, however, the differences and deviations do not decrease the effectiveness of the intent of NEI 99-01. A summary list of ANO EAL deviations from NEI 99-01 is given in Table 3.

to 0CAN031801 Page 8 of 120 Table 1 - ANO EAL Categories/Subcategories ANO EALs NEI Category Subcategory Recognition Category Group: Any Operating Mode:

1 - Radiological Effluent A - Abnormal Rad Levels/Rad Effluent 2 - Irradiated Fuel Event Abnormal Rad Levels/Radiological Effluent 3 - Area Radiation Levels ICs/EALs H - Hazards and Other Conditions Affecting 1 - Security Hazards and Other Conditions Affecting Plant Safety 2 - Seismic Event Plant Safety ICs/EALs 3 - Natural or Technological Hazard 4 - Fire 5 - Hazardous Gas 6 - Control Room Evacuation 7 - Emergency Director Judgment E - ISFSI 1 - Confinement Boundary ISFSI ICs/EALs Group: Hot Conditions:

1 - Loss of Vital AC Power 2 - Loss of Vital DC Power 3 - Loss of Control Room Indications 4 - RCS Activity S - System Malfunction 5 - RCS Leakage System Malfunction ICs/EALs 6 - RPS Failure 7 - Loss of Communications 8 - Containment Failure 9 - Hazardous Event Affecting Safety Systems F - Fission Product Barrier None Fission Product Barrier ICs/EALs Group: Cold Conditions:

1 - RCS Level 2 - Loss of Vital AC Power C - Cold Shutdown/Refueling System 3 - RCS Temperature Cold Shutdown./ Refueling System Malfunction 4 - Loss of Vital DC Power Malfunction ICs/EALs 5 - Loss of Communications 6 - Hazardous Event Affecting Safety Systems to 0CAN031801 Page 9 of 120 Table 2 - NEI / ANO EAL Identification Cross-Reference NEI ANO Example IC Category and Subcategory EAL EAL AU1 1 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AU1.1 AU1 2 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AU1.1 AU1 3 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AU1.2 AU2 1 A - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event AU2.1 AA1 1 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AA1.1 AA1 2 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AA1.2 AA1 3 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AA1.3 AA1 4 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AA1.4 AA2 1 A - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event AA2.1 AA2 2 A - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event AA2.2 AA2 3 A - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event AA2.3 AA3 1 A - Abnormal Rad Levels / Rad Effluent, 3 - Area Radiation Levels AA3.1 AA3 2 A - Abnormal Rad Levels / Rad Effluent, 3 - Area Radiation Levels AA3.2 AS1 1 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AS1.1 AS1 2 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AS1.2 AS1 3 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AS1.3 to 0CAN031801 Page 10 of 120 NEI ANO Example IC Category and Subcategory EAL EAL AS2 1 A - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event AS2.1 AG1 1 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AG1.1 AG1 2 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AG1.2 AG1 3 A - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent AG1.3 AG2 1 A - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event AG2.1 CU1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CU1.1 CU1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CU1.2 CU2 1 C - Cold SD/ Refueling System Malfunction, 2 - Loss of Vital AC Power CU2.1 CU3 1 C - Cold SD/ Refueling System Malfunction, 3 - RCS Temperature CU3.1 CU3 2 C - Cold SD/ Refueling System Malfunction, 3 - RCS Temperature CU3.2 CU4 1 C - Cold SD/ Refueling System Malfunction, 4 - Loss of Vital DC Power CU4.1 CU5 1, 2, 3 C - Cold SD/ Refueling System Malfunction, 5 - Loss of Communications CU5.1 CA1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CA1.1 CA1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CA1.2 CA2 1 C - Cold SD/ Refueling System Malfunction, 1 - Loss of Vital AC Power CA2.1 CA3 1, 2 C - Cold SD/ Refueling System Malfunction, 3 - RCS Temperature CA3.1 CA6 1 C - Cold SD/ Refueling System Malfunction, 6 - Hazardous Event Affecting Safety Systems HA4.1 CS1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CS1.1 to 0CAN031801 Page 11 of 120 NEI ANO Example IC Category and Subcategory EAL EAL CS1 2 N/A N/A CS1 3 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CS1.2 CG1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CG1.1 CG1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CG1.2 E-HU1 1 E - ISFSI EU1.1 FA1 1 F - Fission Product Barrier Degradation FA1.1 FS1 1 F - Fission Product Barrier Degradation FS1.1 FG1 1 F - Fission Product Barrier Degradation FG1.1 HU1 1, 2, 3 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HU1.1 HU2 1 H - Hazards and Other Conditions Affecting Plant Safety, 2 - Seismic Event HU2.1 HU3 1 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.1 HU3 2 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.2 HU3 3 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.3 HU3 4 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.4 HU3 5 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard N/A HU4 1 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.1 HU4 2 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.2 HU4 3 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.3 to 0CAN031801 Page 12 of 120 NEI ANO Example IC Category and Subcategory EAL EAL HU4 4 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.4 HU7 1 H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HU7.1 HA1 1, 2 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HA1.1 HA5 1 H - Hazards and Other Conditions Affecting Plant Safety, 5 - Hazardous Gases HA5.1 HA6 1 H - Hazards and Other Conditions Affecting Plant Safety, 6 - Control Room Evacuation HA6.1 HA7 1 H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HA7.1 HS1 1 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HS1.1 HS6 1 H - Hazards and Other Conditions Affecting Plant Safety, 6 - Control Room Evacuation HS6.1 HS7 1 H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HS7.1 HG1 1 N/A N/A HG7 2 H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HG7.1 SU1 1 S - System Malfunction, 1 - Loss of Emergency AC Power SU1.1 SU2 1 S - System Malfunction, 3 - Loss of Control Room Indications SU3.1 SU3 1 S - System Malfunction, 4 - RCS Activity SU4.1 SU3 2 S - System Malfunction, 4 - RCS Activity SU4.2 SU4 1, 2, 3 S - System Malfunction, 5 - RCS Leakage SU5.1 SU5 1 S - System Malfunction, 6 - RPS Failure SU6.1 SU5 2 S - System Malfunction, 6 - RPS Failure SU6.2 to 0CAN031801 Page 13 of 120 NEI ANO Example IC Category and Subcategory EAL EAL SU6 1, 2, 3 S - System Malfunction, 7 -Loss of Communications SU7.1 SU7 1, 2 S - System Malfunction, 8 -Containment Failure SU8.1 SA1 1 S - System Malfunction, 1 - Loss of Emergency AC Power SA1.1 SA2 1 S - System Malfunction, 3 - Loss of Control Room Indications SA3.1 SA5 1 S - System Malfunction, 6 - RPS Failure SA6.1 SA9 1 S - Hazardous Event Affecting Safety Systems SA9.1 SS1 1 S - System Malfunction, 1 - Loss of Emergency AC Power SS1.1 SS5 1 S - System Malfunction, 6 - RPS Failure SS6.1 SS8 1 S - System Malfunction, 2 - Loss of Vital DC Power SS2.1 SG1 1 S - System Malfunction, 1 - Loss of Emergency AC Power SG1.1 SG8 2 S - System Malfunction, 1 - Loss of Emergency AC Power SG1.2 to 0CAN031801 Page 14 of 120 Table 3 - Summary of Deviations NEI ANO Description IC Example EAL EAL HG1 1 N/A IC HG1 and associated example EAL not implemented in the ANO scheme.

There are several other ICs that are redundant with this IC, and are better suited to ensure timely and effective emergency declarations. In addition, the development of new spent fuel pool level EALs, as a result of NRC Order EA-12-051, clarified the intended emergency classification level for spent fuel pool level events. This deviation is justified because:

1. Hostile Action in the Protected Area is bounded by ICs HS1 and HS7. Hostile Action resulting in a loss of physical control is bound by EAL HG7, as well as any event that may lead to radiological releases to the public in excess of Environmental Protection Agency (EPA)

Protective Action Guides (PAGs).

a. If, for whatever reason, the Control Room must be evacuated, and control of safety functions (e.g., reactivity control, core cooling, and RCS heat removal) cannot be reestablished, then IC HS6 would apply, as well as IC HS7 if desired by the EAL decision-maker.
b. Also, as stated above, any event (including Hostile Action) that could reasonably be expected to have a release exceeding EPA PAGs would be bound by IC HG7.
c. From a Hostile Action perspective, ICs HS1, HS7 and HG7 are appropriate, and therefore, make this part of HG1 redundant and unnecessary.
d. From a loss of physical control perspective, ICs HS6, HS7 and HG7 are appropriate, and therefore, make this part of HG1 redundant and unnecessary.
2. Any event which causes a loss of spent fuel pool level will be bounded by ICs AA2, AS2 and AG2, regardless of whether it was based upon a Hostile Action or not, thus making this part of HG1 redundant and unnecessary.
a. An event that leads to a radiological release will be bounded by ICs AU1, AA1, AS1 and AG1. Events that lead to radiological releases in excess of EPA PAGs will be bounded by EALs AG1 and HG7, thus making this part of HG1 redundant and unnecessary.

ICs AA2, AS2, AG2, AS1, AG1, HS1, HS6, HS7 and HG7 have been implemented consistent with NEI 99-01, Revision 6, and thus HG1 is adequately bounded as described above.

Therefore, this is an acceptable deviation from the generic NEI 99-01, Revision 6, guidance and is consistent with NRC approved EP FAQ 2015-013.

to 0CAN031801 Page 15 of 120 NEI ANO Description IC Example EAL EAL HS6 1 HS6.1 Deleted defueled mode applicability. Control of the cited safety functions are not critical for a defueled reactor as there is no energy source in the reactor vessel or RCS.

The Mode applicability for the reactivity control safety function has been limited to Modes 1, 2, and 3 (hot operating conditions). In the cold operating modes adequate shutdown margin exists under all conditions.

Therefore, this is an acceptable deviation from the generic NEI 99-01, Revision 6, guidance and is consistent with NRC approved EP FAQ 2015-014.

CA6 1 CA6.1 The proposed ANO CA6.1 and SA9.1 wording is intended to ensure that an Alert should be declared SA9 1 SA9.1 only when actual or potential performance issues with SAFETY SYSTEMS have occurred as a result of a hazardous event. The occurrence of a hazardous event will result in an Unusual Event classification at a minimum. In order to warrant escalation to the Alert classification, the hazardous event should cause indications of degraded performance to one train of a SAFETY SYSTEM with either indications of degraded performance on the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second SAFETY SYSTEM train, such that the operability or reliability of the second train is a concern. In addition, escalation to the Alert classification should not occur if the damage from the hazardous event is limited to a SAFETY SYSTEM that was inoperable, or out of service, prior to the event occurring. As such, the proposed EALs will reduce the potential of declaring an Alert when events are in progress that do not involve an actual or potential substantial degradation of the level of safety of the plant, i.e., does not cause significant concern with shutting down or cooling down the plant.

EALs CA6.1 and SA9.1 do not directly escalate to a Site Area Emergency or a General Emergency due to a hazardous event. The Fission Product Barrier and/or Abnormal Radiation Levels/Radiological Effluent recognition categories would provide an escalation path to a Site Area Emergency or a General Emergency.

The EALs and the Basis sections have been revised to ensure potential escalations from an Unusual Event to an Alert, due to a hazardous event, is appropriate as the concern with these EALs is: (1) a hazardous event has occurred, (2) one SAFETY SYSTEM train is having performance issues as a result of the hazardous event, and (3) either the second SAFETY SYSTEM train is having performance issues or the VISIBLE DAMAGE is enough to be concerned that the second SAFETY SYSTEM train may have operability or reliability issues.

The definition for VISIBLE DAMAGE has been revised to reflect the fact that the EALs are based upon SAFETY SYSTEM trains rather than individual components or structures.

to 0CAN031801 Page 16 of 120 NEI ANO Description IC Example EAL EAL CA6 1 CA6.1 (continued)

SA9 1 SA9.1 Note 10 has been added to CA6.1 and SA9.1 as it meets the intent of the EALs, is consistent with other EALs (e.g., EAL HA5.1 which was previously endorsed by the NRC), and ensures that declared emergencies are based upon unplanned events with the potential to pose a radiological risk to the public.

Note 11 has been added to CA6.1 and SA9.1 to help reinforce and succinctly capture the more detailed information from the revised basis section related to when conditions would require the declaration of an Alert.

CA6.1 and SA9.1 are consistent with NRC FAQ 2016-002 addressing degraded performance or visible damage to more than one safety system train caused by the specified events.

Based on the above information, this revised wording is an acceptable deviation from the generic NEI 99-01, Revision 6, guidance and is consistent with NRC-approved EP FAQ 2016-002.

to 0CAN031801 Page 17 of 120 Category A Abnormal Rad Levels / Radiological Effluent NEI NEI IC Wording and Mode ANO ANO IC Wording and Mode Difference/Deviation Justification IC# Applicability IC#(s) Applicability Release of gaseous or liquid radioactivity greater than Release of gaseous or liquid 2 times the (site-specific radioactivity greater than 2 times effluent release controlling the ODCM limits for 60 minutes The ANO ODCM is the site-specific effluent release AU1 AU1 document) limits for 60 minutes or longer controlling document.

or longer. MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Reading on ANY effluent Example EALs #1 and #2 have been combined into a radiation monitor greater than single EAL to simplify presentation.

2 times the (site-specific The NEI phrase effluent radiation monitor greater effluent release controlling than 2 times the (site-specific effluent release document) limits for controlling document) and "effluent radiation monitor 1 60 minutes or longer: greater than 2 times the alarm setpoint established by (site-specific monitor list and a current radioactivity discharge permit " have been Reading on any Table 1[2]A-1 threshold values replaced with any Table 1[2]A-1 effluent radiation effluent radiation monitor corresponding to 2 times the AU1.1 monitor > column "UE".

> column "UE" for 60 min.

controlling document limits) UE thresholds for all ANO continuously monitored (Notes 1, 2, 3) gaseous and liquid release pathways are listed in Reading on ANY effluent Tables 1[2]A-1 to consolidate the information in a radiation monitor greater than single location and, thereby, simplify identification of 2 times the alarm setpoint the thresholds by the EAL user. The values shown in 2

established by a current Table 1[2]A-1 column UE, consistent with the NEI radioactivity discharge permit bases, represent two times the ODCM release limits for 60 minutes or longer. for gaseous and liquid releases.

to 0CAN031801 Page 18 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Sample analysis for a gaseous or liquid release indicates a Sample analysis for a gaseous concentration or release rate or liquid release indicates a The ANO ODCM is the site-specific effluent release 3 greater than 2 times the (site- AU1.2 concentration or release rate controlling document.

specific effluent release > 2 x ODCM limits for 60 min.

controlling document) limits for (Notes 1, 2) 60 minutes or longer.

Note 1: The Emergency The classification timeliness note has been Director should declare standardized across the ANO EAL scheme by the event promptly referencing the "time limit" specified within the EAL upon determining that wording.

the time limit has been Added The Emergency Director is not allowed an The Emergency Director exceeded, or will likely additional 15 minutes to declare after the time limit is should declare the Unusual be exceeded. The exceeded. To reinforce the concept that the EAL Event promptly upon Emergency Director is timing component runs concurrent with the determining that 60 minutes not allowed an classification timeliness clock.

has been exceeded, or will additional 15 minutes to likely be exceeded.

declare after the time If an ongoing release is limit is exceeded.

detected and the release Note 2: If an ongoing release is The classification timeliness note has been start time is unknown, detected and the standardized across the ANO EAL scheme by Notes assume that the release N/A release start time is referencing the "time limit" specified within the EAL duration has exceeded unknown, assume that wording.

60 minutes.

the release duration If the effluent flow past an has exceeded the effluent monitor is known to specified time limit.

have stopped due to actions Note 3: If the effluent flow past None to isolate the release path, an effluent monitor is then the effluent monitor known to have stopped reading is no longer valid for due to actions to isolate classification purposes.

the release path, then the effluent monitor reading is no longer VALID for classification purposes.

to 0CAN031801 Page 19 of 120 Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm to 0CAN031801 Page 20 of 120 Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge to 0CAN031801 Page 21 of 120 NEI NEI IC Wording and Mode ANO ANO IC Wording and Mode Applicability Difference/Deviation Justification IC# Applicability IC#(s)

UNPLANNED loss of water UNPLANNED loss of water level above AU2 level above irradiated fuel. AU2 irradiated fuel. None MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

UNPLANNED water level drop in the REFUELING PATHWAY as indicated by low water level alarm, visual observation,

a. UNPLANNED water level or BWST[RWT] level drop due to drop in the REFUELING makeup demands PATHWAY as indicated by AND ANY of the following:

UNPLANNED rise in corresponding area (site-specific level radiation levels as indicated by any of indications). the following radiation monitors: Site-specific level indications incorporated.

AND 1 AU2.1 Unit 1 Site-specific area radiation monitors

b. UNPLANNED rise in area incorporated.

o RE-8009 Spent Fuel Area radiation levels as indicated by ANY of the o RE-8017 Fuel Handling Area following radiation Unit 2 monitors. o 2RE-8914 Spent Fuel Area (site-specific list of area o 2RE-8915 Spent Fuel Area radiation monitors) o 2RE-8916 Spent Fuel Area o 2RE-8912 Containment Incore Instrumentation to 0CAN031801 Page 22 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Release of gaseous or liquid radioactivity resulting in offsite Release of gaseous or liquid radioactivity dose greater than 10 mrem resulting in offsite dose greater than AA1 TEDE or 50 mrem thyroid AA1 10 mrem TEDE or 50 mrem thyroid CDE. None CDE. MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

The ANO radiation monitors that detect Reading on ANY of the radioactivity effluent release to the following radiation monitors environment are listed in Table 1[2]A-1. UE, greater than the reading Reading on any Table 1[2]A-1 effluent Alert, SAE and GE thresholds for all ANO 1 shown for 15 minutes or AA1.1 radiation monitor > column "ALERT" for continuously monitored gaseous and liquid longer: 15 min. (Notes 1, 2, 3, 4) release pathways are listed in Table 1[2]A-1 (site-specific monitor list and to consolidate the information in a single threshold values) location and, thereby, simplify identification of the thresholds by the EAL-user.

Dose assessment using actual meteorology indicates doses Dose assessment using actual greater than 10 mrem TEDE or meteorology indicates doses > 10 mrem The site boundary is the site-specific receptor 2 AA1.2 50 mrem thyroid CDE at or TEDE or 50 mrem thyroid CDE at or point.

beyond (site-specific dose beyond the SITE BOUNDARY (Note 4) receptor point).

Analysis of a liquid effluent sample indicates a Analysis of a liquid effluent sample concentration or release rate indicates a concentration or release rate that would result in doses that would result in doses > 10 mrem The site boundary is the site-specific receptor 3 greater than 10 mrem TEDE or AA1.3 TEDE or 50 mrem thyroid CDE at or point.

50 mrem thyroid CDE at or beyond the SITE BOUNDARY for beyond (site-specific dose 60 min. of exposure (Notes 1, 2) receptor point) for one hour of exposure.

to 0CAN031801 Page 23 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Field survey results indicate EITHER of the following at or Field survey results indicate EITHER of beyond (site-specific dose the following at or beyond the SITE receptor point): BOUNDARY:

Closed window dose rates Closed window dose rates greater than 10 mR/hr > 10 mR/hr expected to continue for The site boundary is the site-specific receptor 4 AA1.4 60 min.

expected to continue for point.

60 minutes or longer. Analyses of field survey samples Analyses of field survey indicate thyroid CDE > 50 mrem for samples indicate thyroid 60 min. of inhalation.

CDE greater than 50 mrem (Notes 1, 2) for one hour of inhalation.

Note 1: The Emergency Director should The classification timeliness note has been declare the event promptly upon standardized across the ANO EAL scheme by determining that the time limit referencing the "time limit" specified within the The Emergency Director has been exceeded, or will EAL wording.

should declare the Alert likely be exceeded. The Added The Emergency Director is not promptly upon determining Emergency Director is not allowed an additional 15 minutes to declare that the applicable time has allowed an additional after the time limit is exceeded. To reinforce been exceeded, or will likely 15 minutes to declare after the the concept that the EAL timing component be exceeded. time limit is exceeded.

Notes N/A runs concurrent with the classification If an ongoing release is timeliness clock.

detected and the release start time is unknown, assume that the release Note 2: If an ongoing release is The classification timeliness note has been duration has exceeded detected and the release start standardized across the ANO EAL scheme by 15 minutes. time is unknown, assume that referencing the "time limit" specified within the the release duration has EAL wording.

exceeded the specified time limit.

to 0CAN031801 Page 24 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

If the effluent flow past an Note 3: If the effluent flow past an None effluent monitor is known to effluent monitor is known to have stopped due to actions have stopped due to actions to to isolate the release path, isolate the release path, then then the effluent monitor the effluent monitor reading is reading is no longer valid for no longer valid for classification classification purposes. purposes.

Notes The pre-calculated effluent N/A Note 4 The pre-calculated effluent Incorporated site-specific EAL numbers (cont.)

monitor values presented in monitor values presented in associated with generic EAL#1.

EAL #1 should be used for EALs AA1.1, AS1.1 and AG1.1 emergency classification should be used for emergency assessments until the results classification assessments until from a dose assessment the results from a dose using actual meteorology are assessment using actual available. meteorology are available.

to 0CAN031801 Page 25 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Significant lowering of water Significant lowering of water level level above, or damage to, AA2 AA2 above, or damage to, irradiated fuel. None irradiated fuel.

MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Added the defined term IMMINENT.

Determination of irradiated fuel uncovery in the Uncovery of irradiated fuel in IMMINENT uncovery of irradiated fuel refueling pathway will always be an anticipatory 1 AA2.1 the REFUELING PATHWAY. in the REFUELING PATHWAY. determination as no direct indication is available to determine when the irradiated fuel has become uncovered.

Damage to irradiated fuel resulting in a release of The EAL is clarified to refer to mechanical radioactivity from the fuel as Damage to irradiated fuel resulting in damage to irradiated fuel in alignment with the indicated by ANY of the a release of radioactivity basis description.

2 following radiation monitors: AA2.2 AND Site-specific list of radiation monitors (site-specific listing of radiation High alarm on any Table 1[2]A-2 incorporated.

monitors, and the associated radiation monitor.

readings, setpoints and/or Radiation monitor high alarms specified.

alarms)

For ANO, Level 2, which corresponds to ~10 ft.

Lowering of spent fuel pool Lowering of spent fuel pool level to above the top of the fuel racks in the SFP, is an 3 level to (site-specific Level 2 AA2.3 387.0 ft. [389.5 ft.] (Alarm 2) on indicated level of:

value). [See Developer Notes] LIT-2020-3(4) [2LIT-2020-1(2)] Unit 1: 387.0 ft. (Alarm 2) on LIT-2020-3(4)

Unit 2: 389.5 ft. (Alarm 2) on 2LIT-2020-1(2) to 0CAN031801 Page 26 of 120 Table 1A-2 Unit 1 Fuel Damage Radiation Monitors RE-8009 Spent Fuel Area RE-8017 Fuel Handling RE-8060 Containment High Range Radiation Monitors RE-8061 Containment High Range Radiation Monitors RX-9820 (SPING 1) Containment Purge RX-9825 (SPING 2) Radwaste Area RX-9830 (SPING 3) Fuel Handling Area Table 2A-2 Unit 2 Fuel Damage Radiation Monitors 2RE-8905 Containment Equipment Hatch Area 2RE-8909 Containment Personnel Access Area 2RE-8912 Containment Incore Inst.

2RE-8914 Spent Fuel Area 2RE-8915 Spent Fuel Area 2RE-8916 Spent Fuel Area 2RE-8925-1 Containment High Range Radiation Monitors 2RE-8925-2 Containment High Range Radiation Monitors 2RX-9820 (SPING 5) Containment Purge 2RX-9825 (SPING 6) Radwaste Area 2RX-9830 (SPING 7) Fuel Handling Area to 0CAN031801 Page 27 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

AA3 Radiation levels that impede AA3 Radiation levels that IMPEDE access to EAL AA3.2 mode applicability has been access to equipment equipment necessary for normal plant limited to the applicable mode of necessary for normal plant operations, cooldown or shutdown. Table 1[2]A-3 (Modes 3 and 4).

operations, cooldown or MODE: All (AA3.2 Modes 3 and 4 only) shutdown MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Dose rate greater than No other site-specific areas requiring 15 mR/hr in ANY of the continuous occupancy exist at ANO.

following areas: The Control Room envelope (Unit 1 and Control Room Unit 2) is monitored for excessive radiation Central Alarm Station Dose rate > 15 mR/hr in EITHER of the by five detectors. These radiation following areas: detectors are RE-8001, 2RE-8001A, 1 (other site-specific AA3.1 2RE-8001B, 2RE-8750-1A, and areas/rooms) Control Room 2RE-8750-1B. There are no permanently Central Alarm Station (by survey) installed area radiation monitors in CAS that may be used to assess this EAL threshold. Therefore, this threshold is evaluated using local radiation survey for this area.

to 0CAN031801 Page 28 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

An UNPLANNED event The site-specific list of plant rooms or results in radiation levels that areas with entry-related mode applicability prohibit or impede access to are tabularized in Tables 1[2]A-3.

any of the following plant The bulleted bases item the action for rooms or areas: which room/area entry is required is of an (site-specific list of plant administrative or record keeping nature rooms or areas with entry- An UNPLANNED event results in radiation (e.g., normal rounds or routine 2 related mode applicability AA3.2 levels that prohibit or IMPEDE access to inspections) was removed from the list of identified) any Table 1[2]A-3 room or area. (Note 5) exceptions to classification in the basis information. These actions are a consideration when the site-specific list was developed. Rooms requiring entry for these types of actions are already excluded from the list when it was developed.

If the equipment in the listed Note 5 If the equipment in the listed room room or area was already or area was already inoperable or inoperable or out-of-service Note N/A out-of-service before the event None before the event occurred, occurred, then no emergency then no emergency classification is warranted.

classification is warranted.

to 0CAN031801 Page 29 of 120 Table 1A-3 Unit 1 Safe Operation & Shutdown Rooms/Areas Room/Area Mode A-4 Switchgear Room 3, 4 Upper North Electrical Penetration Room 3, 4 Lower South Electrical Equipment Room 3, 4 Table 2A-3 Unit 2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux Building 317 Emergency Core Cooling Rooms 3, 4 Aux Building 317 Tendon Gallery Access 3, 4 Aux Building 335 Charging Pumps / MCC 2B-52 3, 4 Aux Building 354 MCC 2B-62 Area 3, 4 Emergency Diesel Generator Corridor 3, 4 Lower South Piping Penetration Room 3, 4 Aux Building 386 Containment Hatch 3, 4 to 0CAN031801 Page 30 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Release of gaseous radioactivity resulting in offsite Release of gaseous radioactivity resulting in dose greater than 100 mrem offsite dose greater than 100 mrem TEDE AS1 TEDE or 500 mrem thyroid AS1 or 500 mrem thyroid CDE. None CDE. MODE: All MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

The ANO radiation monitors that detect Reading on ANY of the radioactivity effluent release to the following radiation monitors environment are listed in Tables 1[2]A-1.

greater than the reading UE, Alert, SAE and GE thresholds for all Reading on any Table 1[2]A-1 effluent shown for 15 minutes or ANO continuously monitored gaseous and 1 AS1.1 radiation monitor > column "SAE" for longer: liquid release pathways are listed in 15 min. (Notes 1, 2, 3, 4)

Table 1[2]A-1 to consolidate the (site-specific monitor list and information in a single location and, threshold values) thereby, simplify identification of the thresholds by the EAL-user.

Dose assessment using actual meteorology indicates doses Dose assessment using actual meteorology greater than 100 mrem TEDE indicates doses > 100 mrem TEDE or The site boundary is the site-specific 2 AS1.2 or 500 mrem thyroid CDE at or 500 mrem thyroid CDE at or beyond the receptor point.

beyond (site-specific dose SITE BOUNDARY. (Note 4) receptor point) to 0CAN031801 Page 31 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Field survey results indicate EITHER of the following at or beyond (site-specific dose Field survey results indicate EITHER of the receptor point): following at or beyond the SITE Closed window dose BOUNDARY:

rates greater than Closed window dose rates 100 mR/hr expected to > 100 mR/hr expected to continue for The site boundary is the site-specific 3 AS1.3 60 min.

continue for 60 minutes or receptor point.

longer. Analyses of field survey samples Analyses of field survey indicate thyroid CDE > 500 mrem for samples indicate thyroid 60 min. of inhalation.

CDE greater than (Notes 1, 2) 500 mrem for one hour of inhalation.

The Emergency Director Note 1: The Emergency Director should The classification timeliness note has been should declare the Site declare the event promptly upon standardized across the ANO EAL scheme Area Emergency promptly determining that the time limit has by referencing the "time limit" specified upon determining that the been exceeded, or will likely be within the EAL wording.

applicable time has been exceeded. The Emergency Added The Emergency Director is not exceeded, or will likely be Director is not allowed an allowed an additional 15 minutes to exceeded. additional 15 minutes to declare declare after the time limit is exceeded. To If an ongoing release is after the time limit is exceeded reinforce the concept that the EAL timing Notes detected and the release component runs concurrent with the start time is unknown, classification timeliness clock.

assume that the release duration has exceeded 15 minutes. Note 2: If an ongoing release is detected The classification timeliness note has been and the release start time is standardized across the ANO EAL scheme unknown, assume that the release by referencing the "time limit" specified duration has exceeded the within the EAL wording.

specified time limit.

to 0CAN031801 Page 32 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

If the effluent flow past an Note 3: If the effluent flow past an effluent None effluent monitor is known to monitor is known to have stopped have stopped due to actions due to actions to isolate the to isolate the release path, release path, then the effluent then the effluent monitor monitor reading is no longer reading is no longer valid VALID for classification purposes.

for classification purposes. Note 4 The pre-calculated effluent monitor Notes Incorporated site-specific EAL numbers (cont.) The pre-calculated effluent values presented in EALs AA1.1, associated with generic EAL#1.

monitor values presented in AS1.1 and AG1.1 should be used EAL #1 should be used for for emergency classification emergency classification assessments until the results from assessments until the a dose assessment using actual results from a dose meteorology are available.

assessment using actual meteorology are available.

to 0CAN031801 Page 33 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Spent fuel pool level at (site- Spent fuel pool level at the top of the specific Level 3 description). fuel racks. Top of the fuel racks is the site-specific Level 3 AS2 AS2 description.

MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

For ANO, Level 3, which corresponds to the top Lowering of spent fuel pool Lowering of spent fuel pool level to of the fuel racks in the SFP, is an indicated level 1 level to (site-specific Level 3 AS2.1 377.0 ft.[379.5 ft.] (Alarm 3) on of:

value) LIT-2020-3(4)[2LIT-2020-1(2)]. Unit 1: 377.0 ft. (Alarm 3) on LIT-2020-3(4)

Unit 2: 379.5 ft. (Alarm 3) on 2LIT-2020-1(2) to 0CAN031801 Page 34 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Release of gaseous Release of gaseous radioactivity radioactivity resulting in offsite resulting in offsite dose greater than dose greater than AG1 AG1 1,000 mrem TEDE or 5,000 mrem None 1,000 mrem TEDE or thyroid CDE 5,000 mrem thyroid CDE.

MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

The ANO radiation monitors that detect Reading on ANY of the radioactivity effluent release to the environment following radiation monitors are listed in Tables 1[2]A-1.

greater than the reading Reading on any Table A-1 effluent UE, Alert, SAE and GE thresholds for all ANO 1 shown for 15 minutes or AG1.1 radiation monitor > column "GE" for continuously monitored gaseous and liquid longer: 15 min. (Notes 1, 2, 3, 4) release pathways are listed in Tables 1[2]A-1 to (site-specific monitor list and consolidate the information in a single location threshold values) and, thereby, simplify identification of the thresholds by the EAL-user.

Dose assessment using actual meteorology indicates Dose assessment using actual doses greater than meteorology indicates doses The site boundary is the site-specific receptor 2 1,000 mrem TEDE or AG1.2 > 1000 mrem TEDE or 5000 mrem point.

5,000 mrem thyroid CDE at thyroid CDE at or beyond the SITE or beyond (site-specific dose BOUNDARY. (Note 4) receptor point).

to 0CAN031801 Page 35 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Field survey results indicate EITHER of the following at or Field survey results indicate EITHER beyond (site-specific dose of the following at or beyond the SITE receptor point): BOUNDARY:

Closed window dose Closed window dose rates rates greater than > 1000 mR/hr expected to 1,000 mR/hr expected to continue for 60 min. The site boundary is the site-specific receptor 3 AG1.3 continue for 60 minutes point.

or longer. Analyses of field survey samples indicate thyroid CDE Analyses of field survey > 5000 mrem for 60 min. of samples indicate thyroid inhalation.

CDE greater than 5,000 mrem for one hour (Notes 1, 2) of inhalation.

to 0CAN031801 Page 36 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme by The Emergency Director promptly upon determining referencing the "time limit" specified within the should declare the Site that the time limit has been EAL wording.

Area Emergency promptly exceeded, or will likely be Added The Emergency Director is not allowed upon determining that the exceeded. The Emergency an additional 15 minutes to declare after the applicable time has been Director is not allowed an time limit is exceeded. To reinforce the exceeded, or will likely be additional 15 minutes to concept that the EAL timing component runs exceeded. declare after the time limit is concurrent with the classification timeliness If an ongoing release is exceeded. clock.

detected and the release start time is unknown, Note 2: If an ongoing release is The classification timeliness note has been assume that the release detected and the release start standardized across the ANO EAL scheme by duration has exceeded time is unknown, assume that referencing the "time limit" specified within the 15 minutes. the release duration has EAL wording.

If the effluent flow past an exceeded the specified time effluent monitor is known limit.

Notes to have stopped due to Note 3: If the effluent flow past an None actions to isolate the effluent monitor is known to release path, then the have stopped due to actions effluent monitor reading is to isolate the release path, no longer valid for then the effluent monitor classification purposes. reading is no longer VALID for classification purposes for The pre-calculated effluent classification purposes.

monitor values presented in EAL #1 should be used Note 4 The pre-calculated effluent Incorporated site-specific EAL numbers for emergency monitor values presented in associated with generic EAL#1.

classification assessments EALs AA1.1, AS1.1 and until the results from a AG1.1 should be used for dose assessment using emergency classification actual meteorology are assessments until the results available. from a dose assessment using actual meteorology are available.

to 0CAN031801 Page 37 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Spent fuel pool level cannot Spent fuel pool level cannot be be restored to at least (site-restored to at least the top of the fuel Top of the fuel racks is the site-specific Level 3 AG2 specific Level 3 description) AG2 racks for 60 minutes or longer. description.

for 60 minutes or longer.

MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

For ANO, Level 3, which corresponds to the top Spent fuel pool level cannot Spent fuel pool level cannot be of the fuel racks in the SFP, is an indicated level be restored to at least (site- restored to at least 377.0 ft.[379.5 ft.] of:

1 AG2.1 specific Level 3 value) for (Alarm 3) on LIT-2020-3(4)

Unit 1: 377.0 ft. (Alarm 3) on LIT-2020-3(4) 60 minutes or longer. [2LIT-2020-1(2)] for 60 min. (Note 1)

Unit 2: 379.5 ft. (Alarm 3) on 2LIT-2020-1(2)

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme by The Emergency Director promptly upon determining referencing the "time limit" specified within the should declare the General that the time limit has been EAL wording.

Emergency promptly upon exceeded, or will likely be Added The Emergency Director is not allowed Note N/A determining that 60 minutes exceeded. The Emergency an additional 15 minutes to declare after the has been exceeded, or will Director is not allowed an time limit is exceeded. To reinforce the likely be exceeded. additional 15 minutes to concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded. clock.

to 0CAN031801 Page 38 of 120 Category C Cold Shutdown / Refueling System Malfunction NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

UNPLANNED loss of (reactor vessel/RCS [PWR] or RPV UNPLANNED loss of RCS inventory.

[BWR]) inventory for Deleted the words for 15 minutes or longer CU1 15 minutes or longer. CU1 MODE: 5 - Cold Shutdown, as the 15 minute criteria only applies to EAL #1.

6 - Refueling MODE: Cold Shutdown, Refueling NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

UNPLANNED loss of reactor coolant results in (reactor UNPLANNED loss of reactor coolant vessel/RCS [PWR] or RPV results in RCS water level less than a 1 CU1.1 None

[BWR]) level less than a required lower limit for 15 min.

required lower limit for (Note 1) 15 minutes or longer.

Added the words due to loss of RCS

a. (Reactor vessel/RCS inventory to be consistent with the IC wording.

RCS level cannot be monitored

[PWR] or RPV [BWR]) Replaced the term increase with the word rise level cannot be AND EITHER consistent with allowed usage.

monitored. UNPLANNED rise in any 2 CU1.2 Site-specific applicable sumps and tanks are AND Table 1[2]C-1 sump/tank level listed in Table 1[2]C-1 to improve the readability due to loss of RCS inventory

b. UNPLANNED increase in of the EAL.

(site-specific sump and/or Visual observation of UNISOLABLE RCS leakage Added bulleted criteria Visual observation to tank) levels. include direct observation of significant RCS unisolable leakage.

to 0CAN031801 Page 39 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme by The Emergency Director promptly upon determining referencing the "time limit" specified within the should declare the Unusual that the time limit has been EAL wording.

Event promptly upon exceeded, or will likely be Note N/A Added The Emergency Director is not allowed determining that 15 minutes exceeded. The Emergency has been exceeded, or will Director is not allowed an an additional 15 minutes to declare after the time likely be exceeded. additional 15 minutes to limit is exceeded. To reinforce the concept that declare after the time limit is the EAL timing component runs concurrent with exceeded. the classification timeliness clock.

Table 1C-1 Unit 1 Sumps / Tanks Reactor Building Sump Reactor Drain Tank Aux. Building Equipment Drain Tank Aux. Building Sump Quench Tank Table 2C-1 Unit 2 Sumps / Tanks CNTMT Sump Reactor Drain Tank LRW Waste Tank (2T-20)

Holdup Tank Aux. Building Sump Quench Tank to 0CAN031801 Page 40 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss of all but one AC power Loss of all but one AC power source source to emergency buses to vital buses for 15 minutes or longer. vital buses is the ANO-specific terminology for CU2 for 15 minutes or longer. CU2 MODE: 5 - Cold Shutdown, emergency buses.

MODE: Cold Shutdown, 6 - Refueling, DEF - Defueled Refueling, Defueled NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. AC power capability to (site-specific emergency AC power capability, Table 1[2]C-3, to buses) is reduced to a vital 4.16 KV buses A3[2A3] and single power source for A4[2A4] reduced to a single power 4.16KV buses A3[2A3] and A4[2A4] are the 15 minutes or longer.

source for 15 min. (Note 1) emergency (vital) buses.

1 AND CU2.1 AND Site-specific AC power sources are tabularized

b. Any additional single in Table 1[2]C-3.

Any additional single power source power source failure will failure will result in loss of all AC result in loss of all AC power to SAFETY SYSTEMS power to SAFETY SYSTEMS.

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme by The Emergency Director promptly upon determining referencing the "time limit" specified within the should declare the Unusual that the time limit has been EAL wording.

Event promptly upon exceeded, or will likely be Added The Emergency Director is not allowed Note N/A determining that 15 minutes exceeded. The Emergency an additional 15 minutes to declare after the has been exceeded, or will Director is not allowed an time limit is exceeded. To reinforce the likely be exceeded. additional 15 minutes to concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded. clock.

to 0CAN031801 Page 41 of 120 Table 1C-3 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite DG1 DG2 AAC Gen Table 2C-3 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)

Onsite 2DG1 2DG2 AAC Gen to 0CAN031801 Page 42 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Unplanned increase in RCS Unplanned rise in RCS temperature temperature. Replaced the term increase with the word CU3 CU3 MODE: 5 - Cold Shutdown, MODE: Cold Shutdown, rise consistent with allowed usage.

6 - Refueling Refueling NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Replaced the term increase with the word rise consistent with allowed usage.

UNPLANNED increase in 200°F is the site-specific Tech. Spec. cold RCS temperature to greater UNPLANNED rise in RCS temperature shutdown temperature limit.

1 than (site-specific Technical CU3.1 to > 200°F due to loss of decay heat Specification cold shutdown removal capability Added due to loss of decay heat removal temperature limit) capability to reinforce the generic bases that states EAL #1 involves a loss of decay heat removal capability Loss of ALL RCS temperature and (reactor Loss of all RCS temperature and RCS 2 vessel/RCS [PWR] or RPV CU3.2 None level indication for 15 min. (Note 1)

[BWR]) level indication for 15 minutes or longer.

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme by The Emergency Director promptly upon determining referencing the "time limit" specified within the should declare the Unusual that the time limit has been EAL wording.

Event promptly upon exceeded, or will likely be Added The Emergency Director is not allowed Note N/A determining that 15 minutes exceeded. The Emergency an additional 15 minutes to declare after the has been exceeded, or will Director is not allowed an time limit is exceeded. To reinforce the likely be exceeded additional 15 minutes to concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded. clock.

to 0CAN031801 Page 43 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss of Vital DC power for Loss of Vital DC power for 15 minutes 15 minutes or longer. or longer.

CU4 CU4 None MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, Refueling 6 - Refueling NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Indicated voltage is less than 105 VDC is the site-specific minimum vital DC (site-specific bus voltage Indicated voltage is < 105 VDC on bus voltage.

1 value) on required Vital DC CU4.1 required vital 125 VDC buses for buses for 15 minutes or 15 min. (Note 1) Safety-related DC bus operability requirements longer. are specified in Technical Specifications.

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme by The Emergency Director promptly upon determining referencing the "time limit" specified within the should declare the Unusual that the time limit has been EAL wording.

Event promptly upon exceeded, or will likely be Added The Emergency Director is not allowed Note N/A determining that 15 minutes exceeded. The Emergency an additional 15 minutes to declare after the has been exceeded, or will Director is not allowed an time limit is exceeded. To reinforce the likely be exceeded. additional 15 minutes to concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded. clock.

to 0CAN031801 Page 44 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss of all onsite or offsite Loss of all onsite or offsite communications capabilities. communications capabilities.

CU5 CU5 None MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, Refueling, Defueled 6 - Refueling, DEF - Defueled NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Loss of ALL of the following onsite communication 1 methods:

(site specific list of communications methods) Loss of all Table 1[2]C-5 onsite Example EALs #1, 2 and 3 have been combined communication methods into a single EAL for simplification of Loss of ALL of the following ORO communications OR presentation.

2 methods: Loss of all Table 1[2]C-5 State and Replaced ORO with State and local agency CU5.1 local agency communication methods for clarification.

(site specific list of communications methods) OR Table 1[2]C-5 provides a site-specific list of Loss of all Table 1[2]C-5 NRC onsite, State and local agency (ORO) and NRC Loss of ALL of the following communication methods communications methods.

NRC communications 3 methods:

(site specific list of communications methods) to 0CAN031801 Page 45 of 120 Table 1[2]C-5 Communication Methods System Onsite State/Local NRC Station radio system X ANO plant phone system X Gaitronics X Telephone Systems:

Commercial Microwave X X Satellite VOIP INFORM Notification System X Emergency Notification System (ENS) X to 0CAN031801 Page 46 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) Significant loss of RCS inventory Added the word Significant to differentiate inventory the Alert loss of RCS inventory IC from the CA1 CA1 MODE: 5 - Cold Shutdown, Unusual Event IC which is Unplanned loss of MODE: Cold Shutdown, 6 - Refueling RCS inventory.

Refueling NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Loss of RCS inventory as indicated by RVLMS Levels 1 through 8 [RVLMS Levels 1 Loss of (reactor vessel/RCS EITHER: through 5] indicating DRY is the site-specific

[PWR] or RPV [BWR]) RVLMS Levels 1 through 8 reactor vessel level corresponding to lowest 1 inventory as indicated by CA1.1 [1 through 5] indicate DRY RVLMS indicated level above the bottom of the level less than (site-specific RCS Hot Leg.

Reactor vessel level 368.5 ft.

level). (LT-1195/LT-1196)[0 in. Reactor vessel level 368.5 ft.[0 in.] corresponds (L4791/L4792)] (bottom of hot leg) to the bottom of RCS Hot Leg.

a. (Reactor vessel/RCS

[PWR] or RPV [BWR]) RCS level cannot be monitored for Site-specific applicable sumps and tanks are level cannot be monitored 15 min. (Note 1) listed in Table 1[2]C-1 to improve the readability for 15 minutes or longer AND EITHER of the EAL.

AND 2 CA1.2 UNPLANNED rise in any Replaced the term increase with the word

b. UNPLANNED increase in Table 1[2]C-1 Sump / Tank level rise consistent with allowed usage.

(site-specific sump and/or due to a loss of RCS inventory tank) levels due to a loss Added bulleted criteria Visual observation to of (reactor vessel/RCS Visual observation of UNISOLABLE include direct observation of significant RCS

[PWR] or RPV [BWR]) RCS leakage leakage.

inventory.

to 0CAN031801 Page 47 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme by The Emergency Director promptly upon determining referencing the "time limit" specified within the should declare the Alert that the time limit has been EAL wording.

promptly upon determining exceeded, or will likely be Added The Emergency Director is not allowed Note N/A that 15 minutes has been exceeded. The Emergency an additional 15 minutes to declare after the exceeded, or will likely be Director is not allowed an time limit is exceeded. To reinforce the exceeded. additional 15 minutes to concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded. clock.

to 0CAN031801 Page 48 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss of all offsite and all Loss of all offsite and all onsite AC onsite AC power to power to vital buses for 15 minutes or emergency buses for Vital buses is the ANO-specific terminology for CA2 CA2 longer.

15 minutes or longer. emergency buses.

MODE: 5 - Cold Shutdown, MODE: Cold Shutdown, 6 - Refueling, DEF - Defueled Refueling, Defueled NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Loss of ALL offsite and ALL Loss of all offsite and all onsite AC onsite AC Power to (site- 4.16KV buses A3[2A3] and A4[2A4] are the site-1 CA2.1 power to vital 4.16 KV buses A3[2A3]

specific emergency buses) for specific emergency buses.

and A4[2A4] for 15 min. (Note 1) 15 minutes or longer.

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme by The Emergency Director promptly upon determining referencing the "time limit" specified within the should declare the Unusual that the time limit has been EAL wording.

Event promptly upon exceeded, or will likely be Added The Emergency Director is not allowed Note N/A determining that 15 minutes exceeded. The Emergency an additional 15 minutes to declare after the has been exceeded, or will Director is not allowed an time limit is exceeded. To reinforce the likely be exceeded. additional 15 minutes to concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded. clock.

to 0CAN031801 Page 49 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Inability to maintain the plant Inability to maintain plant in cold in cold shutdown. shutdown.

CA3 CA3 None MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, Refueling 6 - Refueling NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

UNPLANNED increase in Example EALs #1 and #2 have been combined RCS temperature to greater into a single EAL as EAL #2 is the alternative than (site-specific Technical threshold based on a loss of RCS temperature 1 Specification cold shutdown UNPLANNED rise in RCS temperature indication.

temperature limit) for greater to > 200°F for > Table 1[2]C-4 duration Replaced the term increase with the word than the duration specified in (Note 1) rise consistent with allowed usage the following table.

CA3.1 OR 200°F is the site-specific Tech. Spec. cold UNPLANNED RCS pressure Unplanned RCS pressure rise shutdown temperature limit.

increase greater than (site- > 10 psig (this EAL does not apply Table 1[2]C-3 is the site-specific implementation specific pressure reading). during water-solid plant conditions) of the generic RCS Reheat Duration Threshold 2 (This EAL does not apply table.

during water-solid plant 10 psig is the site-specific pressure rise conditions. [PWR])

readable by Control Room indications.

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme by The Emergency Director promptly upon determining referencing the "time limit" specified within the should declare the Unusual that the time limit has been EAL wording.

Event promptly upon exceeded, or will likely be Added The Emergency Director is not allowed Note N/A determining that 15 minutes exceeded. The Emergency an additional 15 minutes to declare after the has been exceeded, or will Director is not allowed an time limit is exceeded. To reinforce the likely be exceeded. additional 15 minutes to concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded. clock.

to 0CAN031801 Page 50 of 120 Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Status Heat-up Duration Intact (but not at reduced inventory [PWR]) Not applicable 60 minutes*

Established 20 minutes*

Not intact (or at 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 1[2]C-4: RCS Heat-up Duration Thresholds CONTAINMENT RCS Status Heat-up Duration CLOSURE Status Intact (but not lowered inventory) N/A 60 min.*

Not intact established 20 min.*

OR lowered inventory not established 0 min.

  • If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.

to 0CAN031801 Page 51 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Hazardous event affecting a Hazardous event affecting SAFETY SAFETY SYSTEM needed Pluralized safety systems to be consistent with SYSTEMS needed for the current for the current operating NRC EP FAQ 2016-002 that specifies degraded CA6 CA6 operating mode.

mode. performance or visible damage in more than MODE: 5 - Cold Shutdown, one safety system train.

MODE: Cold Shutdown, 6 - Refueling Refueling to 0CAN031801 Page 52 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. The occurrence of ANY of the following hazardous events:

Seismic event (earthquake)

Internal or external flooding event The occurrence of any Table 1[2]C-6 The hazardous events have been tabularized High winds or tornado hazardous event in Table 1[2]C-6.

strike AND CA6.1 reflects NRC FAQ 2016-002 requiring FIRE Event damage has caused indications degraded performance or visible damage to EXPLOSION of degraded performance on one train of more than one train of a safety system caused (site-specific hazards) a SAFETY SYSTEM needed for the by the specified events.

Other events with similar current operating mode This wording is a deviation from NEI 99-01, hazard characteristics as AND EITHER: Revision 6, CA6 generic wording and determined by the Shift Event damage has caused bases but is deemed acceptable in order to 1 Manager CA6.1 indications of degraded ensure that an Alert is declared only when AND performance to the second train a hazardous event causes actual or

b. EITHER of the following: of the SAFETY SYSTEM needed potential performance issues with safety for the current operating mode systems. This is consistent with
1. Event damage has NRC-approved EP FAQ 2016-002.

caused indications of Event damage has resulted in degraded performance VISIBLE DAMAGE to the second The word a is replaced with the in the FAQ in at least one train of a train of the SAFETY SYSTEM wording to provide agreement with the FAQ SAFETY SYSTEM needed for the current operating basis information indicating that the criteria is needed for the current mode applicable to another train of the same safety operating mode. (Notes 10, 11) system.

OR

2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.

to 0CAN031801 Page 53 of 120 Note 10: If the affected SAFETY SYSTEM train was already inoperable Added Note 10 consistent with the N/A N/A N/A or out of service before the hazardous recommendation of NRC EP FAQ 2016-002.

event occurred, then emergency classification is not warranted Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to Added Note 11 consistent with the N/A N/A N/A at least one train of a SAFETY recommendation of NRC EP FAQ 2016-002.

SYSTEM, then this emergency classification is not warranted.

Table 1[2]C-6 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 to 0CAN031801 Page 54 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) Loss of RCS inventory affecting core inventory affecting core decay decay heat removal capability CS1 heat removal capability. CS1 None MODE: 5 - Cold Shutdown, MODE: Cold Shutdown, 6 - Refueling Refueling NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Unit 1: RVLMS Level 9 is at elevation 367.69 ft.

a. CONTAINMENT The bottom of the hotleg is at 368 ft.

CLOSURE not RVLMS Level 9 corresponds to CONTAINMENT CLOSURE not established. approximately 6 below the bottom of established AND the hotleg.

1 CS1.1 AND

b. (Reactor vessel/RCS Unit 2: The top of active fuel is 61.4 in. below RVLMS Levels 1 through 9 the bottom of the hotleg. RVLMS

[PWR] or RPV [BWR])

[1 through 6] indicate DRY Level 6 is 47 in. above the top of active level less than (site-specific level). fuel, which is 61.4 in. - 47 in. = 14.4 in.

below the bottom ID of the hot leg.

Unit 1 cannot measure reactor vessel at or near the top of active fuel or below. The Unit 2 RVLMS does not provide a positive indication of

a. CONTAINMENT level at or near the top of active fuel, but does CLOSURE established. provide an indication of core uncovery at Level 7. Consistent with the generic developers AND guidance: If the design and operation of water 2 b. (Reactor vessel/RCS N/A N/A level instrumentation is such that this level value

[PWR] or RPV [BWR]) cannot be determined at any time during Cold level less than Shutdown or Refueling modes, then do not (site-specific level). include EAL #2 (classification will be accomplished in accordance with EAL #3).

Unit 2 RVLMS levels 7 through 11 are indications of core uncovery.

to 0CAN031801 Page 55 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. (Reactor vessel/RCS

[PWR] or RPV [BWR]) [1. RVLMS Levels 1 through 7 level cannot be monitored indicate DRY] On Unit 2, RVLMS level 7 is an indication of for 30 minutes or longer. core uncovery when the RVLMS system is in

[OR]

AND service. An ANO CS1.2 EAL threshold is

[2] RCS level cannot be monitored

b. Core uncovery is for 30 min. (Note 1) provided for Unit 2 only where there is indication indicated by ANY of the of core uncovery without applying the 30-minute following: AND time period because of the known core (Site-specific radiation Core uncovery is indicated by uncovery condition.

monitor) reading any of the following:

Replaced the term increase with the word greater than (site- UNPLANNED rise in any rise consistent with allowed usage.

3 CS1.2 Table 1[2]C-1 sump/tank level specific value) Table 1[2]C-1 provides a tabularized list of site-Erratic source range of sufficient magnitude to specific applicable sumps and tanks.

monitor indication indicate core uncovery Containment High Range Radiation Monitors

[PWR] Containment high range RE-8060/8061[2RE-8925-1/8925-2] are the UNPLANNED increase radiation monitor site-specific radiation monitors that would be in (site-specific sump RE-8060/8061 indicative of likely core uncovery in the and/or tank) levels of [2RE-8925-1/8925-2] reading Refueling mode. The dose rate due to core sufficient magnitude to > 10 R/hr shine when the top of the core becomes indicate core uncovery Erratic Source Range Monitor uncovered should result in dose rates > 10 R/hr.

(Other site-specific indication indications)

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme by The Emergency Director promptly upon determining referencing the "time limit" specified within the should declare the Site Area that the time limit has been EAL wording.

Emergency promptly upon exceeded, or will likely be Added The Emergency Director is not allowed Note N/A determining that 30 minutes exceeded. The Emergency an additional 15 minutes to declare after the has been exceeded, or will Director is not allowed an time limit is exceeded. To reinforce the likely be exceeded additional 15 minutes to concept that the EAL timing component runs declare after the time limit is concurrent with the classification timeliness exceeded. clock.

to 0CAN031801 Page 56 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) Loss of RCS inventory affecting fuel inventory affecting fuel clad clad integrity with containment CG1 integrity with containment CG1 challenged None challenged MODE: 5 - Cold Shutdown, MODE: Cold Shutdown, 6 - Refueling Refueling NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. (Reactor vessel/RCS Unit 1 cannot measure reactor vessel at or near

[PWR] or RPV [BWR]) the top of active fuel or below. The Unit 2 level less than (site- RVLMS does not provide a positive indication of specific level) for level at or near the top of active fuel, but does 30 minutes or longer. provide an indication of core uncovery at AND Level 7. Consistent with the generic developers guidance: If the design and operation of water 1 b. ANY indication from the N/A N/A level instrumentation is such that this level value Containment Challenge cannot be determined at any time during Cold Table (see below).

Shutdown or Refueling modes, then do not include EAL #2 (classification will be accomplished in accordance with EAL #3).

Unit 2 RVLMS levels 7 through 11 are indications of core uncovery.

to 0CAN031801 Page 57 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. (Reactor vessel/RCS

[PWR] or RPV [BWR])

level cannot be monitored for 30 minutes or longer. On Unit 2, RVLMS level 7 is an indication of AND core uncovery when the RVLMS system is in service. An ANO CG1.1 EAL threshold is

b. Core uncovery is provided for Unit 2 only where there is indication indicated by ANY of the of core uncovery without applying the 30-minute following:

time period because of the known core (Site-specific radiation uncovery condition. Entergy EAL CG1.2 is monitor) reading provided for both units.

greater than (site-specific value) RVLMS Levels 1 through 7 indicate Replaced the term increase with the word DRY rise consistent with allowed usage.

Erratic source range 2 monitor indication CG1.1 AND Table 1[2]C-2 provides a tabularized list of

[PWR] containment challenge indications.

Any Containment Challenge UNPLANNED indication, Table 1[2]C-2 Containment High Range Radiation Monitors increase in (site- RE-8060/8061 [2RE-8925-1/8925-2] are the specific sump and/or site-specific radiation monitors that would be tank) levels of indicative of likely core uncovery in the sufficient magnitude to Refueling mode. The dose rate due to core indicate core uncovery shine when the top of the core becomes uncovered should result in dose rates > 10 R/hr.

(Other site-specific indications) 3% hydrogen concentration in the presence of oxygen represents an explosive mixture in AND containment.

c. ANY indication from the Containment Challenge Table (see below).

to 0CAN031801 Page 58 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. (Reactor vessel/RCS

[PWR] or RPV [BWR])

level cannot be monitored for 30 minutes or longer. On Unit 2, RVLMS level 7 is an indication of AND RCS level cannot be monitored for core uncovery when the RVLMS system is in 30 min. (Note 1) service. Entergy EAL CG1.1 is provided for

b. Core uncovery is indicated by ANY of the AND Unit 2. Entergy EAL CG1.2 is provided for both following: Core uncovery is indicated by any of units.

(Site-specific radiation the following: Replaced the term increase with the word monitor) reading UNPLANNED rise in any rise consistent with allowed usage.

greater than (site- Table 1[2] C-1 sump/tank level Table 1[2]C-1 provides a tabularized list of site-specific value) of sufficient magnitude to specific applicable sumps and tanks.

Erratic source range indicate core uncovery Table 1[2]C-2 provides a tabularized list of 2 monitor indication CG1.2 Containment High Range containment challenge indications.

[PWR] Radiation Monitor Containment High Range Radiation Monitors UNPLANNED RE-8060/8061 RE-8060/8061[2RE-8925-1/8925-2] are the increase in (site- [2RE-8925-1/8925-2] reading site-specific radiation monitors that would be specific sump and/or > 10 R/hr indicative of likely core uncovery in the tank) levels of Erratic Source Range Monitor Refueling mode. The dose rate due to core sufficient magnitude to indication shine when the top of the core becomes indicate core uncovery uncovered should result in dose rates > 10 R/hr.

AND (Other site-specific 3% hydrogen concentration in the presence of Any Containment Challenge indications) oxygen represents an explosive mixture in indication, Table 1[2]C-2 AND containment.

c. ANY indication from the Containment Challenge Table (see below).

to 0CAN031801 Page 59 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

The Emergency Director Note 1: The Emergency Director The classification timeliness note has been should declare the General should declare the event standardized across the ANO EAL scheme by Emergency promptly upon promptly upon determining referencing the "time limit" specified within the determining that 30 minutes that the time limit has been EAL wording.

has been exceeded, or will exceeded, or will likely be Added The Emergency Director is not allowed likely be exceeded. exceeded. The Emergency an additional 15 minutes to declare after the Director is not allowed an additional 15 minutes to time limit is exceeded. To reinforce the declare after the time limit is concept that the EAL timing component runs Note N/A concurrent with the classification timeliness exceeded.

clock.

N/A Note 6: If CONTAINMENT Note 6 implements the asterisked note CLOSURE is re-established associated with the Containment Closure prior to exceeding the requirement.

30-minute time limit, declaration of a General Emergency is not required.

to 0CAN031801 Page 60 of 120 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 time limit, then declaration of a General Emergency is not required.

Table 1[2]C-2 Containment Challenge Indications CONTAINMENT CLOSURE not established (Note 6)

Containment hydrogen concentration > 3%

UNPLANNED rise in containment pressure to 0CAN031801 Page 61 of 120 Category D Permanently Defueled Station Malfunction ANO ANO IC NEI IC# NEI IC Wording Difference/Deviation Justification IC#(s) Wording PD-AU1 PD-AU2 PD-SU1 PD-HU1 PD-HU2 Recognition Category D NEI Recognition Category PD ICs and EALs are applicable only to N/A N/A PD-HU3 Permanently Defueled Station permanently defueled stations. ANO is not a defueled station.

PD-AA1 PD-AA2 PD-HA1 PD-HA3 to 0CAN031801 Page 62 of 120 Category E Independent Spent Fuel Storage Installation (ISFSI)

NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Damage to a loaded cask Damage to a loaded cask E-HU1 confinement BOUNDARY. EU1 confinement BOUNDARY. None MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Damage to a loaded cask confinement BOUNDARY as Damage to a loaded cask indicated by an on-contact CONFINEMENT BOUNDARY as The specified dose rates represent 2 times the radiation reading greater than indicated by an on-contact radiation site-specific cask technical specification 1 (2 times the site-specific cask EU1.1 reading on the surface of a loaded allowable levels per the ISFSI Technical specific technical spent fuel cask (VSC-24 VCC or Specifications (licensing document).

specification allowable HI-STORM overpack) > any radiation level) on the surface Table 1[2]E-1 value of the spent fuel cask.

Table 1[2]E-1 ISFSI Dose Rates VSC-24 VCC HI-STORM 200 mrem/hr on the sides 60 mrem/hr (gamma + neutron) on the top or outlet vent 400 mrem/hr on the top 600 mrem/hr (gamma + neutron on 700 mrem/hr at the air inlet the side of the side of the overpack 200 mrem/hr at the air outlet (excluding inlet and outlet ducts) to 0CAN031801 Page 63 of 120 Category F Fission Product Barrier Degradation NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Any Loss or any Potential Any loss or any potential loss of Loss of either the Fuel Clad either Fuel Clad or RCS barrier or RCS barrier.

FA1 FA1 MODE: 1 - Power Operation, None MODE: Power Operation, Hot 2 - Startup, 3 - Hot Standby, 4 - Hot Standby, Startup, Hot Shutdown Shutdown NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Any Loss or any Potential Any loss or any potential loss of Table 1[2]F-1 provides the fission product 1 Loss of either the Fuel Clad FA1.1 either Fuel Clad or RCS barrier loss and potential loss thresholds.

or RCS barrier. (Table 1[2]F-1).

to 0CAN031801 Page 64 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss or Potential Loss of any Loss or potential loss of any two two barriers. barriers.

FS1 MODE: Power Operation, FS1 MODE: 1 - Power Operation, None Hot Standby, Startup, Hot 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Loss or Potential Loss of any Loss or potential loss of any two Table 1[2]F-1 provides the fission product 1 FS1.1 two barriers. barriers (Table 1[2]F-1). barrier loss and potential loss thresholds.

to 0CAN031801 Page 65 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss of any two barriers and Loss of any two barriers and loss or Loss or Potential Loss of third potential loss of the third barrier.

barrier.

FG1 FG1 MODE: 1 - Power Operation, None MODE: Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Hot Standby, Startup, Hot Shutdown Shutdown NEI Ex. ANO EAL #

NEI Example EAL Wording EAL #

ANO EAL Wording Difference/Deviation Justification Loss of any two barriers Loss of any two barriers and AND Table 1[2]F-1 provides the fission product 1 Loss or Potential Loss of third FG1.1 Loss or potential loss of the third barrier loss and potential loss thresholds.

barrier.

barrier (Table 1[2]F-1).

to 0CAN031801 Page 66 of 120 PWR Fuel Clad Fission Product Barrier Degradation Thresholds ANO NEI FPB# NEI Threshold Wording ANO FPB Wording Difference/Deviation Justification FPB #(s)

FC Loss RCS or SG Tube Leakage N/A N/A N/A 1 Not Applicable Inadequate Heat Removal FC Loss A. Core exit thermocouple Consistent with the generic developers notes FCB2 CETs > 1200°F.

2 readings greater than (site- 1200°F CET temperature is used.

specific temperature value).

RCS Activity/CMNT Rad A 750[700] R/hr (768[682] R/hr rounded for A. Containment radiation readability) reading in the containment is used monitor reading greater than to indicate a loss of the Fuel Clad barrier and a (site-specific value) release of reactor coolant, with elevated Containment high range activity indicative of fuel damage, into the OR radiation monitor RE-8060/8061 FCB5 containment. This value assumes an FC Loss B. (Site-specific indications that [2RE-8925-1/8925-2]

instantaneous release and dispersal of the reactor coolant activity is > 750[700] R/hr.

3 reactor coolant noble gas and iodine inventory greater than 300 Ci/gm associated with a concentration of dose equivalent I-131). approximately 300 µCi/gm Dose Equivalent I-131 into the containment atmosphere.

Coolant activity > 300 µCi/gm 300 µCi/gm DEI-131 is the site-specific FCB6 dose equivalent I-131. indication for this reactor coolant activity.

FC Loss CNMT Integrity or Bypass N/A N/A N/A 4 Not Applicable FC Loss Other Indications No other site-specific Fuel Clad Loss indication N/A N/A 5 A. (site-specific as applicable) has been identified for ANO.

ED Judgment Any condition in the opinion of FC Loss A. ANY condition in the opinion the Emergency Director that of the Emergency Director FCB7 None 6 indicates loss of the fuel clad that indicates Loss of the barrier.

Fuel Clad barrier.

to 0CAN031801 Page 67 of 120 ANO NEI FPB# NEI Threshold Wording ANO FPB Wording Difference/Deviation Justification FPB #(s)

The above core level indication on Unit 1 is used to monitor the approach to and recovery from ICC conditions, but the CETs are used to identify core uncovery, and are the only positive indication of core uncovery.

RCS or SG Tube Leakage FC P-Loss RVLMS Levels 1 through 9 The reactor vessel level indicators installed in A. RCS/reactor vessel level FCB1 1 [1 through 7] indicate DRY. Unit 1 extend from the top of the reactor vessel less than (site-specific level) to the fuel alignment plate and indicate that the lowest sensor is greater than 2 feet above the top of active fuel.

For Unit 2, RVLMS level 7 is an indication of core uncovery.

Inadequate Heat Removal A. Core exit thermocouple Consistent with the generic developers notes readings greater than FCB3 CETs > 700°F.

700°F CET temperature is used.

(site-specific temperature value)

FC P-Loss OR RCS heat removal cannot be 2 established using steam The initiation of HPI[Once Through] cooling is a B. Inadequate RCS heat generators readily identifiable procedurally driven action removal capability via steam generators as indicated by FCB4 that is taken when steam generators are not AND (site-specific indications). functioning as an effective RCS heat removal HPI[Once Through] cooling source.

initiated.

FC P-Loss RCS Activity/CMNT Rad N/A N/A N/A 3 Not Applicable FC P-Loss CNMT Integrity or Bypass N/A N/A N/A 4 Not Applicable FC P-Loss Other Indications No other site-specific Fuel Clad Potential Loss N/A N/A 5 A. (site-specific as applicable) indication has been identified for ANO.

to 0CAN031801 Page 68 of 120 ANO NEI FPB# NEI Threshold Wording ANO FPB Wording Difference/Deviation Justification FPB #(s)

Emergency Director Judgment Any condition in the opinion of FC P-Loss A. Any condition in the opinion the Emergency Director that of the Emergency Director FCB8 None 6 indicates potential loss of the that indicates Potential Loss Fuel Clad barrier of the Fuel Clad barrier.

to 0CAN031801 Page 69 of 120 PWR RCS Fission Product Barrier Degradation Thresholds ANO NEI FPB# NEI IC Wording ANO FPB Wording Difference/Deviation Justification FPB #(s)

RCS or SG Tube Leakage ESAS[ESFAS] is the site-specific A. An automatic or manual nomenclature for ECCS (SI).

ECCS (SI) actuation is An automatic or manual ESAS Added Failure to isolate the leak (from the required by EITHER of the [ESFAS] actuation required by Control Room or locally), within 15 minutes or if RCS Loss following: EITHER: known that the leak cannot be isolated within RCB1 15 minutes, from the start of the leak requires 1 1. UNISOLABLE RCS UNISOLABLE RCS leakage leakage immediate classification to the basis. This provides agreement with the definition of OR SG tube RUPTURE Unisolable and ensures isolation attempts,

2. SG tube RUPTURE. both locally and remotely, are achieved in a timely manner.

RCS Loss Inadequate Heat Removal N/A N/A N/A 2 Not Applicable A 40[50] R/hr (42.8[50.4] R/hr rounded for readability) reading in containment is used to indicate a loss of the RCS barrier and a release of reactor coolant, at the T.S. coolant activity limit, into the containment. This value RCS Activity/CMNT Rad Containment high range assumes an instantaneous release and RCS Loss A. Containment radiation radiation monitor RE-8060/8061 RCB5 dispersal of the reactor coolant noble gas and 3 monitor reading greater than [2RE-8925-1/8925-2] iodine inventory associated T.S. coolant (site-specific value). > 40[50] R/hr. activity into the containment atmosphere.

Site-specific information added to the basis on the phenomenon of thermally induced current and its potential effects on the radiation monitor indication.

RCS Loss CNMT Integrity or Bypass N/A N/A N/A 4 Not Applicable RCS Loss Other Indications No other site-specific RCS Loss indication has N/A N/A 5 A. (site-specific as applicable). been identified for ANO.

to 0CAN031801 Page 70 of 120 ANO NEI FPB# NEI IC Wording ANO FPB Wording Difference/Deviation Justification FPB #(s)

Emergency Director Judgment Any condition in the opinion of RCS Loss A. ANY condition in the opinion the Emergency Director that of the Emergency Director RCB6 None 6 indicates loss of the RCS that indicates Loss of the barrier.

RCS barrier.

ANO uses the alternative indication of the RCS or SG Tube Leakage capacity of one pump for the threshold leakage A. Operation of a standby value as described in the NEI guidance.

charging (makeup) pump is UNISOLABLE RCS leakage or Added Failure to isolate the leak (from the required by EITHER of the S/G tube leakage > 50[44] gpm Control Room or locally), within 15 minutes or if RCS following:

RCB2 excluding normal reductions in known that the leak cannot be isolated within P-Loss 1 1. UNISOLABLE RCS 15 minutes, from the start of the leak requires leakage RCS inventory (e.g., letdown, RCP seal leakoff) immediate classification to the basis. This OR provides agreement with the definition of

2. SG tube leakage. Unisolable and ensures isolation attempts, both locally and remotely, are achieved in a OR timely manner.

to 0CAN031801 Page 71 of 120 ANO NEI FPB# NEI IC Wording ANO FPB Wording Difference/Deviation Justification FPB #(s)

B. RCS cooldown rate greater UNISOLABLE RCS leakage or than (site-specific S/G tube leakage > 50[44] gpm pressurized thermal shock excluding normal reductions in criteria/limits defined by site- RCS inventory (e.g., letdown, specific indications). RCP seal leakoff) Unit 1 and Unit 2 specific PTS criteria is Unit 1: specified.

PTS limits apply (RT14) Note 12 - Once PTS limits are first invoked, if AND RCS temperature and pressure are not brought RCS pressure and temperature within the limits within 15 minutes, this are left of the NDTT/LTOP limit threshold is met and an immediate declaration RCB3 lines on EOP Figure 3 (Note 12) is warranted. This threshold is met immediately upon exceeding the limits after Unit 2: this initial 15 minute period until PTS limits no Uncontrolled RCS cooldown longer apply is added to allow RCS (50°F step change which is parameters to be brought within the limits in a below 500°F from NOT) timely manner when they are first outside the AND limits. RCS parameters must be maintained RCS pressure and temperature within afterward.

are to the left of line B (200 degrees MTS), Standard Attachment 1, P-T Limits (Note 12)

Inadequate Heat Removal RCS heat removal cannot be The initiation of HPI[Once Through] cooling is a A. Inadequate RCS heat established readily identifiable procedurally driven action RCS removal capability via steam RCB4 AND that is taken when steam generators are not P-Loss 2 generators as indicated by functioning as an effective RCS heat removal HPI[Once Through] cooling (site-specific indications). initiated. source.

RCS CS Activity/CMNT Rad N/A N/A N/A P-Loss 3 Not Applicable RCS CNMT Integrity or Bypass N/A N/A N/A P-Loss 4 Not Applicable to 0CAN031801 Page 72 of 120 ANO NEI FPB# NEI IC Wording ANO FPB Wording Difference/Deviation Justification FPB #(s)

RCS Other Indications No other site-specific RCS Potential Loss N/A N/A P-Loss 5 A. (site-specific as applicable) indication has been identified for ANO.

Emergency Director Judgment Any condition in the opinion of RCS A. ANY condition in the opinion the Emergency Director that of the Emergency Director RCB7 None P-Loss 6 indicates potential loss of the that indicates Potential Loss RCS barrier of the RCS barrier.

to 0CAN031801 Page 73 of 120 PWR Containment Fission Product Barrier Degradation Thresholds ANO NEI FPB# NEI IC Wording ANO FPB Wording Difference/Deviation Justification FPB #(s)

RCS or SG Tube Leakage The threshold is reworded to clarify that A. A leaking or RUPTURED SG the steam generator leakage is that is FAULTED outside of A S/G that is leaking level of leakage associated with the containment. > 50[44] gpm (excluding normal related the NEI RCS barrier potential CNMT Loss CNB1 reductions in RCS inventory) or loss threshold 1.A (ANO RCB2).

1 that is RUPTURED is also Revised the table on page 2 of the FAULTED outside of containment basis information to reflect pump capacity values to align with the change made to the EAL.

CNMT Loss Inadequate Heat Removal N/A N/A N/A 2 Not Applicable CNMT Loss RCS Activity/CMNT Rad N/A N/A N/A 3 Not applicable CNMT Integrity or Bypass Containment isolation is required Added Failure to isolate the leak (from A. Containment isolation is the Control Room or locally), within AND EITHER: 15 minutes or if known that the leak required Containment integrity has cannot be isolated within 15 minutes, AND been lost based on from the start of the leak requires EITHER of the following: CNB4 Emergency Director immediate classification to the basis.

1. Containment integrity has judgment This provides agreement with the been lost based on definition of Unisolable and ensures CNMT Loss UNISOLABLE pathway from Emergency Director isolation attempts, both locally and Containment to the 4 judgment. remotely, are achieved in a timely environment exists manner.

OR

2. UNISOLABLE pathway from the containment to the environment exists. Indications of RCS leakage CNB5 None OR outside of containment B. Indications of RCS leakage outside of containment.

to 0CAN031801 Page 74 of 120 ANO NEI FPB# NEI IC Wording ANO FPB Wording Difference/Deviation Justification FPB #(s)

CNMT Loss Other Indications No other site-specific Containment Loss N/A N/A 5 A. (site-specific as applicable) indication has been identified for ANO.

Emergency Director Judgment Any condition in the opinion of CNMT Loss ANY condition in the opinion of the Emergency Director that the Emergency Director that CNB9 None 6 indicates loss of the containment indicates Loss of the Containment barrier.

barrier.

CNMT P-Loss RCS or SG Tube Leakage N/A N/A N/A 1 Not Applicable Inadequate Heat Removal A. 1. (Site-specific criteria for entry into core cooling CETs > 1200°F Consistent with the generic developers CNMT P-Loss restoration procedure) AND notes 1200°F CET temperature is used.

CNB2 2 AND Restoration procedures not Added Note 1 consistent with other

2. Restoration procedure not effective within 15 min. (Note 1) thresholds with a timing component.

effective within 15 minutes.

10,000[12,000] R/hr (10,300[12,100] R/hr rounded for readability) reading in the containment is used to indicate a potential loss of the containment barrier and a release of RCS Activity/CMNT Rad Containment high range reactor coolant, with significant activity CNMT P-Loss A. Containment radiation monitor radiation monitor RE-8060/8061 indicative of 20% fuel damage, into the CNB3 3 reading greater than [2RE-8925-1/8925-2] reading containment. This value assumes an (site-specific value). > 10,000[12,000] R/hr instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with a concentration associated with 20% clad damage into the containment atmosphere.

to 0CAN031801 Page 75 of 120 ANO NEI FPB# NEI IC Wording ANO FPB Wording Difference/Deviation Justification FPB #(s)

Containment pressure 73.7 psia is the site specific CNMT Integrity or Bypass CNB6

> 73.7 psia. containment design pressure.

A. Containment pressure greater than (site-specific value)

OR B. Explosive mixture exists 3% hydrogen concentration in the inside containment Containment hydrogen CNB7 presence of oxygen represents an concentration > 3%.

OR explosive mixture in containment.

CNMT P-Loss C. 1. Containment pressure 4 greater than (site-specific pressure setpoint) The Containment pressure setpoint is AND the pressure at which the Containment

2. Less than one full train of Containment pressure > 44.7 psia Spray System should actuate and begin (site-specific system or [23.3 psia] with < one full train of performing its function.

equipment) is operating CNB8 containment heat removal Added Note 1 consistent with other per design for 15 minutes systems (Note 9) operating per thresholds with a timing component.

or longer. design for 15 min. (Note 1) Added Note 9 to clarify what constitutes a full train of containment heat removal systems.

CNMT P-Loss Other Indications No other site-specific Containment A. (site-specific as applicable) N/A N/A Potential Loss indication has been 5 identified for ANO.

Emergency Director Judgment Any condition in the opinion of CNMT P-Loss A. ANY condition in the opinion the Emergency Director that of the Emergency Director CNB10 None 6 indicates potential loss of the that indicates Potential Loss containment barrier.

of the Containment barrier.

to 0CAN031801 Page 76 of 120 Category H Hazards and Other Conditions Affecting Plant Safety NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Confirmed SECURITY Confirmed SECURITY CONDITION or HU1 CONDITION or threat HU1 threat. None MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

A SECURITY CONDITION A SECURITY CONDITION that does that does not involve a not involve a HOSTILE ACTION as 1 HOSTILE ACTION as reported by ANO Security Shift reported by the (site-specific Supervision security shift supervision). OR Example EALs #1, 2 and 3 have been combined Notification of a credible HU1.1 Notification of a credible security threat into a single EAL for ease of presentation and 2 security threat directed at the directed at the site use.

site. OR A validated notification from A validated notification from the NRC 3 the NRC providing information providing information of an aircraft of an aircraft threat. threat.

to 0CAN031801 Page 77 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Seismic event greater than Seismic event greater than OBE HU2 OBE levels. HU2 levels. None MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Seismic event greater than Operating Basis Earthquake (OBE) as indicated by: Seismic event > OBE as indicated by The ANO OBE alarm is located on the seismic 1 HU2.1 annunciation of the 0.10 g acceleration network control center, C529-NCC in the Unit 1 (site-specific indication that a alarm Control Room.

seismic event met or exceeded OBE limits) to 0CAN031801 Page 78 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Hazardous event. Hazardous event.

HU3 HU3 None MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

A tornado strike within the A tornado strike within the 1 HU3.1 None PROTECTED AREA. PROTECTED AREA.

Internal room or area flooding of Internal room or area FLOODING of a a magnitude sufficient to require magnitude sufficient to require manual Replaced the word needed with required manual or automatic electrical or automatic electrical isolation of a 2 HU3.2 by Technical Specifications consistent isolation of a SAFETY SYSTEM SAFETY SYSTEM component with the generic bases.

component needed for the required by Technical Specifications current operating mode. for the current operating mode.

Movement of personnel within Movement of personnel within the the PROTECTED AREA is PROTECTED AREA is IMPEDED due Changed the term offsite to external to the impeded due to an offsite event to an event external to the PROTECTED AREA to address events 3 HU3.3 involving hazardous materials PROTECTED AREA involving located external to the PROTECTED AREA (e.g., an offsite chemical spill or hazardous materials (e.g., an offsite but not considered offsite.

toxic gas release). chemical spill or toxic gas release).

A hazardous event that results in A hazardous event that results in on-on-site conditions sufficient to site conditions sufficient to prohibit the 4 prohibit the plant staff from HU4.1 Added reference to Note 7.

plant staff from accessing the site via accessing the site via personal personal vehicles. (Note 7) vehicles.

(Site-specific list of natural or No other site-specific hazard has been 5 N/A N/A technological hazard events) identified for ANO.

EAL #3 does not apply to routine Note 7: This EAL does not apply to traffic impediments such as fog, routine traffic impediments This note, designated Note #7, is intended to Note snow, ice, or vehicle N/A such as fog, snow, ice, or apply to generic example EAL #4, not #3 as breakdowns or accidents. vehicle breakdowns or specified in the generic guidance.

accidents.

to 0CAN031801 Page 79 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

FIRE potentially degrading the FIRE potentially degrading the level of HU4 level of safety of the plant. HU4 safety of the plant. None MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications: A FIRE is not extinguished within 15 min. of any of the following FIRE Report from the field detection indications (Note 1):

(i.e., visual observation)

Report from the field (i.e., visual Receipt of multiple (more observation) than 1) fire alarms or indications Receipt of multiple (more than 1) Table 1[2]H-1 provides a tabularized list of 1 HU4.1 fire alarms or indications site-specific fire areas.

Field verification of a single fire alarm Field verification of a single fire alarm AND AND

b. The FIRE is located within ANY of the following plant The FIRE is located within any rooms or areas: Table 1[2]H-1 area.

(site-specific list of plant rooms or areas) to 0CAN031801 Page 80 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. Receipt of a single fire Table 1[2]H-1 provides a tabularized list of alarm (i.e., no other site-specific fire areas.

indications of a FIRE). In addition, the wording in the Basis section AND supporting fire detection and response

b. The FIRE is located within design is modified to remove specific ANY of the following plant Receipt of a single fire alarm (i.e., no reference to 10 CFR 50, Appendix R. The rooms or areas: other indications of a FIRE) Basis statement relating to Criterion 3 of AND 10 CFR 50, Appendix A is maintained, along (site-specific list of plant The fire alarm is indicating a FIRE with generic statements that are applicable rooms or areas) 2 HU4.2 within any Table 1[2]H-1 area without regard to Appendix R. Both ANO AND units are NFPA 805 plants; therefore, the
c. The existence of a FIRE is AND requirements of Appendix R are no longer not verified within The existence of a FIRE is not verified applicable. This wording is a difference 30-minutes of alarm receipt. within 30 min. of alarm receipt. from NEI 99-01, Revision 6, HU4 generic (Note 1) wording and bases. This difference is acceptable in order eliminate reference to an inappropriate licensing basis while maintaining sufficient information to address fire prevention and fire system functions A FIRE within the plant or ISFSI

[for plants with an ISFSI outside A FIRE within the PROTECTED AREA the plant Protected Area]

not extinguished within 60 min. of the ANO has an ISFSI located inside the plant 3 PROTECTED AREA not HU4.3 initial report, alarm or indication. Protected Area.

extinguished within 60-minutes (Note 1) of the initial report, alarm or indication.

A FIRE within the plant or ISFSI

[for plants with an ISFSI outside A FIRE within the PROTECTED AREA the plant Protected Area]

that requires firefighting support by an ANO has an ISFSI located inside the plant 4 PROTECTED AREA that HU4.4 offsite fire response agency to Protected Area.

requires firefighting support by extinguish an offsite fire response agency to extinguish.

to 0CAN031801 Page 81 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme Note: The Emergency Director by referencing the "time limit" specified within promptly upon determining should declare the the EAL wording.

that the time limit has been Unusual Event promptly exceeded, or will likely be Added The Emergency Director is not Note upon determining that N/A exceeded. The Emergency allowed an additional 15 minutes to declare the applicable time has Director is not allowed an after the time limit is exceeded. To reinforce been exceeded, or will additional 15 minutes to the concept that the EAL timing component likely be exceeded.

declare after the time limit is runs concurrent with the classification exceeded. timeliness clock.

Table 1H-1 Unit 1 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Penthouse/MSIV Room Exceptions:

Boric Acid Mix Tank Room (Chem Add Area), 404 (157-B), EDG Exhaust Fan area on 386 (1-E and 2-E)

Turbine Building All elevations including: Pipechase under ICW Coolers, CRD Pump Pit/T-28 Room/Area under ICW Pumps Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)

Manholes adjacent to Intake Structure (MH-05/MH-06)

Intake Structure (354 and 366)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10) to 0CAN031801 Page 82 of 120 Table 2H-1 Unit 2 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Aux Extension Turbine Building All elevations Outside Areas Intake Structure (354 and 366)

Concrete Manhole East, NE of intake (2MH-01)

Concrete Manhole East of Turbine Building next to train bay (2MH-03)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10) to 0CAN031801 Page 83 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Other conditions exist which in Other conditions exist that in the the judgment of the Emergency judgment of the Emergency Director HU7 Director warrant declaration of a HU7 None warrant declaration of a UE.

(NO)UE.

MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Other conditions exist which in the judgment of the Emergency Other conditions exist which in the Director indicate that events are judgment of the Emergency Director in progress or have occurred indicate that events are in progress or which indicate a potential have occurred which indicate a degradation of the level of safety potential degradation of the level of of the plant or indicate a security safety of the plant or indicate a security 1 HU7.1 None threat to facility protection has threat to facility protection has been been initiated. No releases of initiated. No releases of radioactive radioactive material requiring material requiring offsite response or offsite response or monitoring monitoring are expected unless further are expected unless further degradation of SAFETY SYSTEMS degradation of safety systems occurs.

occurs.

to 0CAN031801 Page 84 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

HOSTILE ACTION within the HOSTILE ACTION within the OWNER OWNER CONTROLLED AREA CONTROLLED AREA or airborne HA1 or airborne attack threat within HA1 None attack threat within 30 minutes.

30 minutes.

MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

A HOSTILE ACTION is occurring A HOSTILE ACTION is occurring or or has occurred within the has occurred within the OWNER 1 OWNER CONTROLLED AREA CONTROLLED AREA as reported by as reported by the (site-specific ANO Security Shift Supervision Example EALs #1 and #2 have been security shift supervision). HA1.1 OR combined into a single EAL for ease of use.

A validated notification from A validated notification from NRC of an 2 NRC of an aircraft attack threat aircraft attack threat within 30 min. of within 30 minutes of the site. the site.

to 0CAN031801 Page 85 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Gaseous release impeding Gaseous release IMPEDING access to access to equipment necessary equipment necessary for normal plant The mode applicability has been limited to HA5 for normal plant operations, HA5 operations, cooldown or shutdown. the modes restrictions of Table H-2, Modes 3 cooldown or shutdown. MODE: 3 - Hot Standby, 4 - Hot and 4 only.

MODE: All Shutdown NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. Release of a toxic, corrosive, The site-specific list of plant rooms or areas asphyxiant or flammable gas with entry-related mode applicability are into any of the following plant tabularized in Table 1[2]H-2.

rooms or areas: The bulleted bases item the action for which (site-specific list of plant Release of a toxic, corrosive, room/area entry is required is of an rooms or areas with entry- asphyxiant or flammable gas into any administrative or record keeping nature (e.g.,

related mode applicability Table 1[2]H-2 room or area normal rounds or routine inspections) was 1 HA5.1 identified) AND removed from the list of exceptions to AND Entry into the room or area is classification in the basis information. These prohibited or IMPEDED. (Note 5) actions are a consideration when the site-

b. Entry into the room or area is specific list was developed. Rooms requiring prohibited or impeded.

entry for these types of actions are already excluded from the list when it was developed.

Note: If the equipment in the Note 5: If the equipment in the listed listed room or area was room or area was already already inoperable or inoperable or out-of-service Note out-of-service before the N/A None before the event occurred, event occurred, then no then no emergency emergency classification classification is warranted.

is warranted.

to 0CAN031801 Page 86 of 120 Table 1H-2 Unit 1 Safe Operation & Shutdown Rooms/Areas Room/Area Mode A-4 Switchgear Room 3, 4 Upper North Electrical Penetration Room 3, 4 Lower South Electrical Equipment Room 3, 4 Table 2H-2 Unit 2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux Building 317 Emergency Core Cooling Rooms 3, 4 Aux Building 317 Tendon Gallery Access 3, 4 Aux Building 335 Charging Pumps / MCC 2B-52 3, 4 Aux Building 354 MCC 2B-62 Area 3, 4 Emergency Diesel Generator Corridor 3, 4 Lower South Piping Penetration Room 3, 4 Aux Building 386 Containment Hatch 3, 4 to 0CAN031801 Page 87 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Control Room evacuation Control Room evacuation resulting in resulting in transfer of plant transfer of plant control to alternate HA6 control to alternate locations. HA6 locations. None MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

An event has resulted in plant control being transferred from An event has resulted in plant control Shutdown activities at ANO are transferred the Control Room to 1 HA6.1 being transferred from the Control from the Control Room to multiple locations (site-specific remote shutdown Room to alternate locations. within the plant.

panels and local control stations).

to 0CAN031801 Page 88 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Other conditions exist which in Other conditions exist that in the the judgment of the Emergency judgment of the Emergency Director HA7 Director warrant declaration of HA7 None warrant declaration of an Alert.

an Alert.

MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Other conditions exist which, in the judgment of the Emergency Other conditions exist which, in the Director, indicate that events are judgment of the Emergency Director, in progress or have occurred indicate that events are in progress or which involve an actual or have occurred which involve an actual potential substantial degradation or potential substantial degradation of of the level of safety of the plant the level of safety of the plant or a or a security event that involves 1 HA7.1 security event that involves probable None probable life threatening risk to life threatening risk to site personnel or site personnel or damage to site damage to site equipment because of equipment because of HOSTILE HOSTILE ACTION. Any releases are ACTION. Any releases are expected to be limited to small expected to be limited to small fractions of the EPA Protective Action fractions of the EPA Protective Guideline exposure levels.

Action Guideline exposure levels.

to 0CAN031801 Page 89 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

HOSTILE ACTION within the HOSTILE ACTION within the HS1 PROTECTED AREA. HS1 PROTECTED AREA. None MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

A HOSTILE ACTION is occurring A HOSTILE ACTION is occurring or or has occurred within the has occurred within the PROTECTED 1 PROTECTED AREA as reported HS1.1 None AREA as reported by ANO Security by the (site-specific security shift Shift Supervision.

supervision).

to 0CAN031801 Page 90 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Inability to control a key safety function Deleted defueled mode applicability. Control Inability to control a key safety from outside the Control Room. of the cited safety functions is not critical for function from outside the Control MODE: 1 - Power Operation, a defueled reactor as there is no energy HS6 Room. HS6 source in the reactor vessel or RCS.

2 - Startup, 3 - Hot Standby, 4 - Hot MODE: All Shutdown, 5 - Cold Shutdown, This is an acceptable deviation from the 6 - Refueling generic NEI 99-01 Revision 6 guidance.

NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. An event has resulted in plant control being transferred from the Control Room to (site-specific An event has resulted in plant control Shutdown activities at ANO are transferred remote shutdown panels being transferred from the Control from the Control Room to multiple locations and local control stations). Room to alternate locations within the plant.

AND AND The Mode applicability for the reactivity

b. Control of ANY of the Control of any of the following key control safety function has been limited to 1 following key safety HS6.1 safety functions is not reestablished Modes 1, 2, and 3 (hot operating conditions).

functions is not within 15 min. (Note 1): In the cold operating modes adequate reestablished within Reactivity (Modes 1, 2 and 3 shutdown margin exists under all conditions.

(site-specific number of only) EP FAQ 2015-014.

minutes).

Core cooling This is an acceptable deviation from the Reactivity control generic NEI 99-01 Revision 6 guidance.

RCS heat removal Core cooling [PWR] /

RPV water level [BWR]

RCS heat removal to 0CAN031801 Page 91 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Other conditions exist which in Other conditions exist that in the the judgment of the Emergency judgment of the Emergency Director HS7 Director warrant declaration of a HS7 warrant declaration of a Site Area None Site Area Emergency. Emergency.

MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Other conditions exist which in the judgment of the Emergency Other conditions exist which in the Director indicate that events are judgment of the Emergency Director in progress or have occurred indicate that events are in progress or which involve actual or likely have occurred which involve actual or major failures of plant functions likely major failures of plant functions needed for protection of the needed for protection of the public or public or HOSTILE ACTION that HOSTILE ACTION that results in results in intentional damage or intentional damage or malicious acts, malicious acts, (1) toward site 1 HS7.1 (1) toward site personnel or equipment None personnel or equipment that that could lead to the likely failure of or, could lead to the likely failure of (2) that prevent effective access to or, (2) that prevent effective equipment needed for the protection of access to equipment needed for the public. Any releases are not the protection of the public. Any expected to result in exposure levels releases are not expected to which exceed EPA Protective Action result in exposure levels which Guideline exposure levels beyond the exceed EPA Protective Action SITE BOUNDARY.

Guideline exposure levels beyond the site boundary.

to 0CAN031801 Page 92 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

IC HG1 and associated example EAL are not implemented in the ANO scheme.

There are several other ICs that are redundant with this IC, and are better suited HOSTILE ACTION resulting in to ensure timely and effective emergency loss of physical control of the declarations. In addition, the development of HG1 facility. N/A N/A new spent fuel pool level EALs, as a result of MODE: All NRC Order EA-12-051, clarified the intended emergency classification level for spent fuel pool level events.

This is an acceptable deviation from the generic NEI 99-01 Revision 6 guidance.

to 0CAN031801 Page 93 of 120 NEI Ex. NEI Example EAL ANO ANO EAL Difference/Deviation Justification EAL # Wording EAL # Wording IC HG1 and associated example EAL are not implemented in the ANO scheme.

a. A HOSTILE There are several other ICs that are redundant with this IC, and are better suited to ACTION is ensure timely and effective emergency declarations. In addition, the development of occurring or has new spent fuel pool level EALs, as a result of NRC Order EA-12-051, clarified the occurred within the intended emergency classification level for spent fuel pool level events. This deviation PROTECTED is justified because:

AREA as reported by the (site-specific 1. Hostile Action in the Protected Area is bounded by ICs HS1 and HS7. Hostile security shift Action resulting in a loss of physical control is bound by EAL HG7, as well as any supervision). event that may lead to radiological releases to the public in excess of Environmental Protection Agency (EPA) Protective Action Guides (PAGs).

AND

a. If, for whatever reason, the Control Room must be evacuated, and control of
b. EITHER of the safety functions (e.g., reactivity control, core cooling, and RCS heat removal) following has cannot be reestablished, then IC HS6 would apply, as well as IC HS7 if desired occurred: by the EAL decision-maker.
1. ANY of the b. Also, as stated above, any event (including Hostile Action) that could following safety reasonably be expected to have a release exceeding EPA PAGs would be functions bound by IC HG7.

1 cannot be N/A N/A controlled or c. From a Hostile Action perspective, ICs HS1, HS7 and HG7 are appropriate, and maintained. therefore, make this part of HG1 redundant and unnecessary.

Reactivity d. From a loss of physical control perspective, ICs HS6, HS7 and HG7 are control appropriate, and therefore, make this part of HG1 redundant and unnecessary.

Core cooling 2. Any event which causes a loss of spent fuel pool level will be bounded by ICs AA2,

[PWR]/RPV AS2 and AG2, regardless of whether it was based upon a Hostile Action or not, thus water level making this part of HG1 redundant and unnecessary.

[BWR] a. An event that leads to a radiological release will be bounded by ICs AU1, AA1, RCS heat AS1 and AG1. Events that lead to radiological releases in excess of EPA PAGs removal will be bounded by EALs AG1 and HG7, thus making this part of HG1 redundant and unnecessary.

OR ICs AA2, AS2, AG2, AS1, AG1, HS1, HS6, HS7 and HG7 have been implemented

2. Damage to consistent with NEI 99-01, Revision 6, and thus HG1 is adequately bounded as spent fuel has described above.

occurred or is IMMINENT. EP FAQ 2015-013 This is an acceptable deviation from the generic NEI 99-01 Revision 6 guidance.

to 0CAN031801 Page 94 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Other conditions exist which in Other conditions exist that in the the judgment of the Emergency judgment of the Emergency Director HG7 Director warrant declaration of a HG7 warrant declaration of a General None General Emergency. Emergency.

MODE: All MODE: All NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Other conditions exist which in the judgment of the Emergency Other conditions exist which in the Director indicate that events are judgment of the Emergency Director in progress or have occurred indicate that events are in progress or which involve actual or have occurred which involve actual or IMMINENT substantial core IMMINENT substantial core degradation or melting with degradation or melting with potential potential for loss of containment for loss of containment integrity or 1 HG7.1 None integrity or HOSTILE ACTION HOSTILE ACTION that results in an that results in an actual loss of actual loss of physical control of the physical control of the facility. facility. Releases can be reasonably Releases can be reasonably expected to exceed EPA Protective expected to exceed EPA Action Guideline exposure levels Protective Action Guideline offsite for more than the immediate site exposure levels offsite for more area.

than the immediate site area.

to 0CAN031801 Page 95 of 120 Category S System Malfunction NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss of all offsite AC power Loss of all offsite AC power capability capability to emergency buses to vital buses for 15 minutes or longer.

for 15 minutes or longer. vital buses is the ANO-specific terminology SU1 SU1 MODE: 1 - Power Operation, MODE: Power Operation, for emergency buses.

2 - Startup, 3 - Hot Standby, 4 - Hot Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Loss of ALL offsite AC power Loss of all offsite AC power capability, 4.16 KV buses A3[2A3] and A4[2A4] are the capability to (site-specific Table 1[2]S-1, to vital 4.16 KV buses site-specific emergency buses.

1 SU1.1 emergency buses) for A3[2A3] and A4[2A4] for 15 min. Site-specific AC power sources are 15 minutes or longer. (Note 1) tabularized in Table 1[2]S-1.

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme promptly upon determining by referencing the "time limit" specified within The Emergency Director should the EAL wording.

that the time limit has been declare the Unusual Event exceeded, or will likely be Added The Emergency Director is not Note promptly upon determining that N/A exceeded. The Emergency allowed an additional 15 minutes to declare 15 minutes has been exceeded, Director is not allowed an after the time limit is exceeded. To reinforce or will likely be exceeded.

additional 15 minutes to the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded. timeliness clock.

to 0CAN031801 Page 96 of 120 Table 1S-1 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite Unit Auxiliary Transformer (main generator via main transformer)

DG1 DG2 AAC Gen Table 2S-1 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)

Onsite Unit Auxiliary Transformer (main generator via main transformer) 2DG1 2DG2 AAC Gen to 0CAN031801 Page 97 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

UNPLANNED loss of Control UNPLANNED loss of Control Room Room indications for 15 minutes indications for 15 minutes or longer.

or longer.

SU2 SU3 MODE: 1 - Power Operation, None MODE: Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

An UNPLANNED event results An UNPLANNED event results in the The site-specific Safety System Parameter in the inability to monitor one or inability to monitor one or more list is tabulated in Table 1[2]S-2.

1 more of the following parameters SU3.1 Table 1[2]S-2 parameters from within Added the words to at least one S/G to from within the Control Room for the Control Room for 15 min. Auxiliary or emergency feedwater flow. This 15 minutes or longer. (Note 1) is consistent with Level in at least on S/G.

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme promptly upon determining by referencing the "time limit" specified within The Emergency Director should the EAL wording.

that the time limit has been declare the Unusual Event exceeded, or will likely be Added The Emergency Director is not Note promptly upon determining that N/A exceeded. The Emergency allowed an additional 15 minutes to declare 15 minutes has been exceeded, Director is not allowed an after the time limit is exceeded. To reinforce or will likely be exceeded.

additional 15 minutes to the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded. timeliness clock.

to 0CAN031801 Page 98 of 120

[BWR parameter list] [PWR parameter list]

Reactor Power Reactor Power RPV Water Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In-Core/Core Exit Temperature Suppression Pool Level Levels in at least (site-specific number) steam generators Suppression Pool Temperature Steam Generator Auxiliary or Emergency Feed Water Flow Table 1[2]S-2 Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one S/G EFW flow to at least one S/G to 0CAN031801 Page 99 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Reactor coolant activity greater RCS activity greater than Technical than Technical Specification Specification allowable limits.

allowable limits MODE: 1 - Power Operation, Changed Reactor coolant to read RCS for SU3 SU4 MODE: Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot consistency with normally used terminology.

Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Unit 1 RE-1237S, Failed Fuel Monitor, is in the letdown system to monitor the letdown (Site-specific radiation monitor) Failed Fuel Iodine radiation monitor line for evidence of fuel damage.

1 reading greater than (site- SU4.1 RI-1237S[2RITS-4806B] reading specific value). > 9.0 E5 cpm Unit 2 specific activity monitor 2RITS-4806B monitors the letdown fluid for the presence of Iodine-131.

RCS sample activity > 1.0 uCi/gm dose Changed Reactor coolant to read RCS for equivalent I-131 for > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (Note 1) consistency with normally used terminology.

Sample analysis indicates that a OR ANO Unit 1 T.S. LCO 3.4.12 and Unit 2 T.S.

reactor coolant activity value is RCS sample activity > 60 uCi/gm dose LCO 3.4.8 provides the TS allowable coolant 2 greater than an allowable limit SU4.2 equivalent I-131 activity limits that are duplicated in the EAL.

specified in Technical OR Specifications.

RCS sample activity

> 2200[3100] uCi/gm dose equivalent Xe-133 for > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (Note 1) to 0CAN031801 Page 100 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

RCS leakage for 15 minutes or RCS leakage for 15 minutes or longer.

longer.

SU4 SU5 MODE: 1 - Power Operation, None MODE: Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

RCS unidentified or pressure Example EALs #1, 2 and 3 have been boundary leakage greater than combined into a single EAL for usability.

1 (site-specific value) for Changed the term RCS to Reactor coolant 15 minutes or longer. RCS unidentified or pressure boundary for the third threshold. For ANO, leakage leakage > 10 gpm for 15 min. (Note 1)

RCS identified leakage greater outside containment is not termed RCS OR leakage.

2 than (site-specific value) for 15 minutes or longer. RCS identified leakage > 25 gpm for Added Failure to isolate the leak (from the SU5.1 15 min. (Note 1) Control Room or locally), within 15 minutes OR or if known that the leak cannot be isolated Leakage from the RCS to a Reactor coolant leakage to a location within 15 minutes, from the start of the leak location outside containment outside containment > 25 gpm for requires immediate classification to the 3 basis. This provides agreement with the greater than 25 gpm for 15 min. (Note 1) 15 minutes or longer. definition of Unisolable and ensures isolation attempts, both locally and remotely, are achieved in a timely manner.

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme promptly upon determining by referencing the "time limit" specified within The Emergency Director should the EAL wording.

that the time limit has been declare the Unusual Event exceeded, or will likely be Added The Emergency Director is not Note promptly upon determining that N/A exceeded. The Emergency allowed an additional 15 minutes to declare 15 minutes has been exceeded, Director is not allowed an after the time limit is exceeded. To reinforce or will likely be exceeded.

additional 15 minutes to the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded. timeliness clock.

to 0CAN031801 Page 101 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Automatic or manual (trip [PWR]

Automatic or manual trip fails to shut

/ scram [BWR]) fails to shutdown SU5 SU6 down the reactor. None the reactor.

MODE: 1 - Power Operation MODE: Power Operation NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

As specified in the generic developers guidance Developers may include site-An automatic trip did not shut down specific EOP criteria indicative of a the reactor as indicated by reactor successful reactor shutdown in an EAL

a. An automatic (trip [PWR] / power > 5% after any RPS setpoint is statement, the Basis or both (e.g., a reactor scram [BWR]) did not exceeded power level). Reactor power < 5% is the shutdown the reactor.

AND site-specific indication of a successful reactor AND trip.

1 b. A subsequent manual SU6.1 A subsequent automatic trip or manual Added the words "... as indicated by reactor action taken at the reactor trip action taken at the reactor control power > 5% after any RPS setpoint is control consoles is console (C03[2C03/2C14]) (manual exceeded" to clarify that it is a failure of the successful in shutting down reactor trip pushbuttons or automatic trip when a valid trip signal has the reactor. DROPS[DSS]) is successful in shutting been exceeded.

down the reactor as indicated by reactor power 5% (Note 8) Panels C03[2C03/2C14] are the site-specific reactor control consoles with manual trip capability.

to 0CAN031801 Page 102 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. A manual trip ([PWR] / As specified in the generic developers scram [BWR]) did not guidance Developers may include shutdown the reactor. site-specific EOP criteria indicative of a A manual trip did not shut down the successful reactor shutdown in an EAL AND reactor as indicated by reactor power statement, the Basis or both (e.g., a reactor
b. EITHER of the following: > 5% after any manual trip action was power level). Reactor power < 5% is the
1. A subsequent manual initiated site-specific indication of a successful reactor action taken at the trip.

AND reactor control Added the words "... as indicated by reactor 2 consoles is successful SU6.2 A subsequent automatic trip or manual power > 5% after any manual trip action was in shutting down the trip action taken at the reactor control initiated" to clarify that it is a failure of any reactor. console (C03[2C03/2C14]) (manual manual trip when an actual manual trip signal OR reactor trip pushbuttons or has been inserted.

DROPS[DSS]) is successful in shutting 2 A subsequent down the reactor as indicated by Combined conditions b.1 and b.2 into a automatic (trip [PWR] / reactor power 5% (Note 8) single statement to simplify the presentation.

scram [BWR]) is Panels C03[2C03/2C14] are the site-specific successful in shutting reactor control consoles with manual trip down the reactor. capability.

Note: A manual action is any operator action, or set Note 8: A manual action is any of actions, which operator action, or set of causes the control rods actions, which causes the to be rapidly inserted control rods to be rapidly Notes into the core, and does N/A inserted into the core, and None not include manually does not include manually driving in control rods or driving in control rods or implementation of implementation of boron boron injection injection strategies.

strategies.

to 0CAN031801 Page 103 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss of all onsite or offsite Loss of all onsite or offsite communications capabilities. communications capabilities.

SU6 MODE: Power Operation, SU7 MODE: 1 - Power Operation, None Startup, Hot Standby, Hot 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Loss of ALL of the following onsite communication methods:

1 (site-specific list of communications methods) Loss of all Table 1[2]S-4 onsite Example EALs #1, 2 and 3 have been communication methods combined into a single EAL for simplification Loss of ALL of the following OR of presentation.

ORO communications methods:

2 Loss of all Table 1[2]S-4 State and Replaced ORO with State and local (site-specific list of SU7.1 local agency communication methods agency for clarification.

communications methods) OR Table 1[2]S-4 provides a site-specific list of Loss of all Table 1[2]S-4 NRC onsite, State and local agency (ORO) and Loss of ALL of the following NRC communications methods.

communication methods.

NRC communications methods:

3 (site-specific list of communications methods) to 0CAN031801 Page 104 of 120 Table 1[2]S-4 Communication Methods System Onsite State/Local NRC Station radio system X ANO plant phone system X Gaitronics X Telephone Systems:

Commercial Microwave X X Satellite VOIP INFORM Notification System X Emergency Notification System (ENS) X to 0CAN031801 Page 105 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Failure to isolate containment or Failure to isolate containment or loss loss of containment pressure of containment pressure control.

control. [PWR]

SU7 SU8 MODE: 1 - Power Operation, None MODE: Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. Failure of containment to Reworded EAL to better describe the intent.

isolate when required by an Penetrations cannot close, but they can be actuation signal. isolated by closure of one or more isolation AND valves associated with that penetration. The 1 revised wording maintains the generic

b. ALL required penetrations example EAL intent while more clearly are not closed within Any penetration is not closed within describing failure to isolate threshold.

15 minutes of the actuation signal. 15 min. of an ESAS[CIAS] actuation ESAS[CIAS] is the site-specific system that signal initiates containment isolation signals.

a. Containment pressure OR The Containment pressure setpoint is the greater than (site-specific SU8.1 pressure at which the Containment Spray Containment pressure > 44.7 psia pressure). System should actuate and begin performing

[23.3 psia] with < one full train of AND containment heat removal systems its function.

b. Less than one full train of (Note 9) operating per design for Added statement to the NEI basis that 2 (site-specific system or 15 min. (Note 1) penetrations are considered closed when equipment) is operating per one of the two associated valves are closed design for 15 minutes or or a check valve is intact. This change longer. provides clarification and meets the intent of the EAL of ensuring that a functional boundary is maintained between the containment and the outside environment.

to 0CAN031801 Page 106 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme promptly upon determining by referencing the "time limit" specified within that the time limit has been the EAL wording.

exceeded, or will likely be Added The Emergency Director is not N/A N/A N/A exceeded. The Emergency allowed an additional 15 minutes to declare Director is not allowed an after the time limit is exceeded. To reinforce additional 15 minutes to the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded. timeliness clock.

Note 9: One full train of containment heat removal systems consists Added new Note 9 to clarify what constitutes of one train of N/A N/A N/A one full train of containment heat removal RB[Containment] Spray and systems.

one train of RB[Containment]

Cooling System.

to 0CAN031801 Page 107 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss of all but one AC power source to emergency buses for Loss of all but one AC power source 15 minutes or longer. to vital buses for 15 minutes or longer. vital buses is the ANO-specific terminology SA1 SA1 for emergency buses.

MODE: Power Operation, MODE: 1 - Power Operation Startup NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. AC power capability to (site-specific emergency buses) AC power capability, Table 1[2]S-1, to is reduced to a single power vital 4.16 KV buses A3[2A3] and source for 15 minutes or A4[2A4] reduced to a single power 4.16KV buses A3[2A3] and A4[2A4] are the longer. source for 15 min. (Note 1) site-specific emergency buses.

1 SA1.1 AND AND Site-specific AC power sources are listed in

b. Any additional single power Any additional single power source Table 1[2]S-1.

source failure will result in a failure will result in loss of all AC loss of all AC power to power to SAFETY SYSTEMS.

SAFETY SYSTEMS.

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme promptly upon determining by referencing the "time limit" specified within The Emergency Director should the EAL wording.

that the time limit has been declare the Alert promptly upon exceeded, or will likely be Added The Emergency Director is not Note determining that 15 minutes has N/A exceeded. The Emergency allowed an additional 15 minutes to declare been exceeded, or will likely be Director is not allowed an after the time limit is exceeded. To reinforce exceeded.

additional 15 minutes to the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded. timeliness clock.

to 0CAN031801 Page 108 of 120 Table 1S-1 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite Unit Auxiliary Transformer (main generator via main transformer)

DG1 DG2 AAC Gen Table 2S-1 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (backfed from main transformer)

Onsite Unit Auxiliary Transformer (main generator via main transformer) 2DG1 2DG2 AAC Gen to 0CAN031801 Page 109 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

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

SA2 transient in progress. SA3 None MODE: 1 - Power Operation, MODE: Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

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.

AND ANY of the following transient An UNPLANNED event results in the events in progress. inability to monitor one or more The site-specific Safety System Parameter Table 1[2]S-2 parameters from within list to listed in Table 1[2]S-2.

Automatic or manual the Control Room for 15 min.

runback greater than 25% The site-specific significant transients list to 1 SA3.1 (Note 1) thermal reactor power listed in Table 1[2]S-3.

AND ANO is a PWR and thus does not include Electrical load rejection greater than 25% full Any significant transient is in progress, thermal power oscillations > 10%.

electrical load Table 1[2]S-3 Reactor scram [BWR] / trip

[PWR]

ECCS (SI) actuation Thermal power oscillations greater than 10% [BWR]

to 0CAN031801 Page 110 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme promptly upon determining by referencing the "time limit" specified within The Emergency Director should the EAL wording.

that the time limit has been declare the Unusual Event exceeded, or will likely be Added The Emergency Director is not Note promptly upon determining that N/A exceeded. The Emergency allowed an additional 15 minutes to declare 15 minutes has been exceeded, Director is not allowed an after the time limit is exceeded. To reinforce or will likely be exceeded.

additional 15 minutes to the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded. timeliness clock.

to 0CAN031801 Page 111 of 120

[BWR parameter list] [PWR parameter list]

Reactor Power Reactor Power RPV Water Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In-Core/Core Exit Temperature Suppression Pool Level Levels in at least (site-specific number) steam generators Suppression Pool Temperature Steam Generator Auxiliary or Emergency Feed Water Flow Table 1[2]S-2 Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one S/G EFW flow to at least one S/G Table 1[2]S-3 Significant Transients Reactor trip Runback > 25% thermal power Electrical load rejection > 25% electrical load Safety injection actuation to 0CAN031801 Page 112 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Automatic or manual (trip [PWR]

/ scram [BWR]) fails to shutdown Automatic or manual trip fails to shut the reactor, and subsequent down the reactor and subsequent manual actions taken at the manual actions taken at the reactor SA5 reactor control consoles are not SA6 control consoles are not successful in None successful in shutting down the shutting down the reactor.

reactor. MODE: 1 - Power Operation MODE: Power Operation NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

An automatic or manual trip fails to As specified in the generic developers

a. An automatic or manual (trip shut down the reactor as indicated by guidance Developers may include site-

[PWR] / scram [BWR]) did reactor power > 5% specific EOP criteria indicative of a not shutdown the reactor. successful reactor shutdown in an EAL AND statement, the Basis or both (e.g., a reactor AND power level). Reactor power < 5% is the 1 SA6.1 Manual trip actions taken at the reactor

b. Manual actions taken at the control console (C03[2C03/2C14]) site-specific indication of a successful reactor reactor control consoles are (manual reactor trip pushbuttons or trip.

not successful in shutting DROPS[DSS]) are not successful in Panels C03[2C03/2C14] are the site-specific down the reactor. shutting down the reactor as indicated reactor control consoles with manual trip by reactor power > 5%. (Note 8) capability.

Note: A manual action is any Note 8: A manual action is any operator action, or set of operator action, or set of actions, which causes actions, which causes the the control rods to be control rods to be rapidly rapidly inserted into the Notes N/A inserted into the core, and None core, and does not does not include manually include manually driving driving in control rods or in control rods or implementation of boron implementation of boron injection strategies.

injection strategies.

to 0CAN031801 Page 113 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Hazardous event affecting a Hazardous event affecting SAFETY SAFETY SYSTEM needed for SYSTEMS needed for the current Pluralized safety systems to be consistent the current operating mode. operating mode. with NRC EP FAQ 2016-002 that specifies SA9 SA9.1 MODE: Power Operation, MODE: 1 - Power Operation, degraded performance or visible damage in Startup, Hot Standby, Hot 2 - Startup, 3 - Hot Standby, 4 - Hot more than one safety system train.

Shutdown Shutdown to 0CAN031801 Page 114 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. The occurrence of ANY of the following hazardous events:

Seismic event (earthquake)

Internal or external flooding event The occurrence of any Table 1[2]S-5 High winds or tornado hazardous event The hazardous events have been tabularized strike AND in Table 1[2]S-5.

FIRE Event damage has caused indications SA9.1 reflects NRC FAQ 2016-002 requiring EXPLOSION of degraded performance on one train degraded performance or visible damage to of a SAFETY SYSTEM needed for the more than one train of a safety system (site-specific hazards) caused by the specified events.

current operating mode Other events with similar This wording is a deviation from NEI 99-hazard characteristics as AND EITHER:

01 Revision 6 SA9 generic wording and determined by the Shift Event damage has caused bases but is deemed acceptable in order 1 Manager SA9.1 indications of degraded to ensure that an Alert is declared only AND performance to the second when a hazardous event causes actual or train of the SAFETY SYSTEM potential performance issues with safety

b. EITHER of the following:

needed for the current systems. This is consistent with

1. Event damage has operating mode caused indications of NRC-approved EP FAQ 2016-002.

Event damage has resulted in The word a is replaced with the in the degraded performance VISIBLE DAMAGE to the FAQ wording to provide agreement with the in at least one train of a second train of the SAFETY FAQ basis information indicating that the SAFETY SYSTEM SYSTEM needed for the criteria is applicable to another train of the needed for the current current operating mode. same safety system.

operating mode.

(Notes 10, 11)

OR

2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.

to 0CAN031801 Page 115 of 120 NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service Added Note 10 consistent with the N/A N/A N/A before the hazardous event recommendation of NRC EP FAQ 2016-002.

occurred, then emergency classification is not warranted Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded Added Note 11 consistent with the N/A N/A N/A performance to at least one recommendation of NRC EP FAQ 2016-002.

train of a SAFETY SYSTEM, then this emergency classification is not warranted.

Table 1[2]S-5 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 to 0CAN031801 Page 116 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss of all offsite and all onsite Loss of all offsite and all onsite AC AC power to emergency buses power to vital buses for 15 minutes or for 15 minutes or longer. longer. vital buses is the ANO-specific terminology SS1 SS1 MODE: Power Operation, MODE: 1 - Power Operation, for emergency buses.

Startup, Hot Standby, Hot 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Loss of ALL offsite and ALL Loss of all offsite and all onsite AC onsite AC power to (site-specific 4.16KV buses A3[2A3] and A4[2A4] are the 1 SS1.1 power to vital 4.16 KV buses A3[2A3]

emergency buses) for site-specific emergency buses.

and A4[2A4] for 15 min. (Note 1) 15 minutes or longer.

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme promptly upon determining by referencing the "time limit" specified within The Emergency Director should the EAL wording.

that the time limit has been declare the Unusual Event exceeded, or will likely be Added The Emergency Director is not Note promptly upon determining that N/A exceeded. The Emergency allowed an additional 15 minutes to declare 15 minutes has been exceeded, Director is not allowed an after the time limit is exceeded. To reinforce or will likely be exceeded.

additional 15 minutes to the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded. timeliness clock.

to 0CAN031801 Page 117 of 120 NEI ANO IC#

NEI IC Wording IC#(s)

ANO IC Wording Difference/Deviation Justification Inability to shutdown the reactor Inability to shut down the reactor causing a challenge to (core causing a challenge to core cooling or SS5 cooling [PWR] / RPV water level SS6 None RCS heat removal.

[BWR]) or RCS heat removal.

MODE: 1 - Power Operation MODE: Power Operation NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. An automatic or manual (trip [PWR] / scram [BWR]) As specified in the generic developers did not shutdown the guidance Developers may include site-reactor. An automatic or manual trip fails to specific EOP criteria indicative of a AND shut down the reactor as indicated by successful reactor shutdown in an EAL reactor power > 5% statement, the Basis or both (e.g., a reactor
b. All manual actions to AND power level). Reactor power < 5% is the shutdown the reactor have site-specific indication of a successful reactor been unsuccessful. All actions to shut down the reactor trip.

AND are not successful as indicated by reactor power > 5% Deleted the term manual actions from the 1 c. EITHER of the following SS6.1 second condition. For generic IC SS5, all conditions exist: AND EITHER: actions to shut down the reactor can be (Site-specific indication CETs > 1200°F credited, not just those actions from the of an inability to RCS heat removal cannot be reactor control panel that may be identified adequately remove heat established using steam as manual actions.

from the core) generators and HPI[Once Indication that heat removal is extremely (Site-specific indication Through] cooling initiated challenged is manifested by the loss of both of an inability to steam generators as a heat sink, requiring adequately remove heat the initiation of HPI [Once Through] cooling.

from the RCS) to 0CAN031801 Page 118 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss of all Vital DC power for 15 Loss of all vital DC power for minutes or longer. 15 minutes or longer.

SS8 MODE: Power Operation, SS2 MODE: 1 - Power Operation, None Startup, Hot Standby, Hot 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

Indicated voltage is less than 105 VDC is the site-specific minimum vital Indicated voltage is < 105 VDC on D01 DC bus voltage.

(site-specific bus voltage value) 1 SS2.1 [2D01] and D02[2D02] vital 125 VDC on ALL (site-specific Vital DC DC buses on D01[2D01] and D02[2D02] are buses for 15 min. (Note 1) busses) for 15 minutes or longer. the site-specific credited vital DC buses.

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme promptly upon determining by referencing the "time limit" specified within The Emergency Director should the EAL wording.

that the time limit has been declare the Unusual Event exceeded, or will likely be Added The Emergency Director is not Note promptly upon determining that N/A exceeded. The Emergency allowed an additional 15 minutes to declare 15 minutes has been exceeded, Director is not allowed an after the time limit is exceeded. To reinforce or will likely be exceeded.

additional 15 minutes to the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded. timeliness clock.

to 0CAN031801 Page 119 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Prolonged loss of all offsite and Prolonged loss of all offsite and all all onsite AC power to onsite AC power to vital buses.

emergency buses. vital buses is the ANO-specific terminology SG1 SG1a MODE: 1 - Power Operation, MODE: Power Operation, for emergency buses.

2 - Startup, 3 - Hot Standby, 4 - Hot Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses).

Loss of all offsite and all onsite AC AND power to vital 4.16 KV buses A3[2A3] 4.16KV buses A3[2A3] and A4[2A4] are the

b. EITHER of the following: and A4[2A4] site-specific emergency buses.

Restoration of at least AND EITHER: 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the site-specific SBO coping 1 one AC emergency bus in SG1.1 Restoration of at least one vital analysis time.

less than (site-specific 4.16 KV bus in < 4 hrs is not CETs reading > 1200°F indicates significant hours) is not likely. likely (Note 1) core exit superheating and core uncovery.

(Site-specific indication of CETs > 1200°F an inability to adequately remove heat from the core)

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme The Emergency Director should promptly upon determining by referencing the "time limit" specified within declare the General Emergency that the time limit has been the EAL wording.

promptly upon determining that exceeded, or will likely be Added The Emergency Director is not Note N/A exceeded. The Emergency (site-specific hours) has been allowed an additional 15 minutes to declare exceeded, or will likely be Director is not allowed an after the time limit is exceeded. To reinforce exceeded. additional 15 minutes to the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded. timeliness clock.

to 0CAN031801 Page 120 of 120 NEI ANO NEI IC Wording ANO IC Wording Difference/Deviation Justification IC# IC#(s)

Loss of all AC and Vital DC Loss of all vital AC and vital DC power power sources for 15 minutes or sources for 15 minutes or longer.

longer. Vital buses is the ANO-specific terminology SG8 SG1b MODE: 1 - Power Operation, MODE: Power Operation, for emergency buses.

2 - Startup, 3 - Hot Standby, 4 - Hot Startup, Hot Standby, Hot Shutdown Shutdown NEI Ex. ANO NEI Example EAL Wording ANO EAL Wording Difference/Deviation Justification EAL # EAL #

a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency Loss of all offsite and all onsite AC 4.16KV buses A3[2A3] and A4[2A4] are the buses) for 15 minutes or power to vital 4.16 KV buses A3[2A3] site-specific emergency buses.

longer. and A4[2A4] for 15 min.

1 AND SG1.2 AND 105 VDC is the site-specific minimum vital DC bus voltage.

b. Indicated voltage is less Indicated voltage is < 105 VDC on D01 than (site-specific bus [2D01] and D02[2D02] vital 125 VDC D01[2D01] and D02[2D02] are the credited voltage value) on ALL (site- buses for 15 min. (Note 1) site-specific vital DC buses.

specific Vital DC busses) for 15 minutes or longer.

Note 1: The Emergency Director The classification timeliness note has been should declare the event standardized across the ANO EAL scheme promptly upon determining by referencing the "time limit" specified within The Emergency Director should the EAL wording.

that the time limit has been declare the Unusual Event exceeded, or will likely be Added The Emergency Director is not Note promptly upon determining that N/A exceeded. The Emergency allowed an additional 15 minutes to declare 15 minutes has been exceeded, Director is not allowed an after the time limit is exceeded. To reinforce or will likely be exceeded.

additional 15 minutes to the concept that the EAL timing component declare after the time limit is runs concurrent with the classification exceeded. timeliness clock.

Enclosure 5 to 0CAN031801 Proposed EAL Matrix Chart and Review Table (for information only) to 0CAN031801 Page 1 of 22 UNIT 1 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Release of gaseous radioactivity resulting in offsite dose Release of gaseous radioactivity resulting in offsite dose Release of gaseous OR liquid radioactivity resulting in offsite Release of gaseous or liquid radioactivity greater than 2 greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE greater than 100 mrem TEDE or 500 mrem thyroid CDE dose greater than 10 mrem TEDE or 50 mrem thyroid CDE times the ODCM limits for 60 minutes or longer 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF AG1.1 AS1.1 AA1.1 AU1.1 Reading on any Table 1A-1 effluent radiation monitor Reading on any Table 1A-1 effluent radiation monitor Reading on any Table 1A-1 effluent radiation monitor Reading on any Table 1A-1 effluent radiation

> column GE for 15 min. (Notes 1, 2, 3, 4) > column SAE for 15 min. (Notes 1, 2, 3, 4) > column ALERT for 15 min. (Notes 1, 2, 3, 4) monitor > column UE for 60 min. (Notes 1, 2, 3)

AG1.2 AS1.2 AA1.2 AU1.2 Dose assessment using actual meteorology indicates Dose assessment using actual meteorology indicates Dose assessment using actual meteorology indicates Sample analysis for a gaseous or liquid release doses > 1000 mrem TEDE or 5000 mrem thyroid doses > 100 mrem TEDE or 500 mrem thyroid CDE at doses > 10 mrem TEDE or 50 mrem thyroid CDE at or indicates a concentration or release rate > 2 x CDE at or beyond the SITE BOUNDARY (Note 4) or beyond the SITE BOUNDARY (Note 4) beyond the SITE BOUNDARY (Note 4) ODCM limits for 60 min. (Notes 1, 2) 1 AG1.3 Field survey results indicate EITHER of the following AS1.3 Field survey results indicate EITHER of the following AA1.3 Analysis of a liquid effluent sample indicates a Rad at or beyond the SITE BOUNDARY: at or beyond the SITE BOUNDARY: concentration or release rate that would result in doses Effluent > 10 mrem TEDE or 50 mrem thyroid CDE at or

- Closed window dose rates > 1000 mR/hr - Closed window dose rates > 100 mR/hr expected to continue for 60 min. expected to continue for 60 min. beyond the SITE BOUNDARY for 60 min. of exposure (Notes 1, 2)

- Analyses of field survey samples indicate - Analyses of field survey samples indicate thyroid CDE > 5000 mrem for 60 min. of thyroid CDE > 500 mrem for 60 min. of AA1.4 inhalation inhalation Field survey results indicate EITHER of the following at (Notes 1, 2) (Notes 1, 2) or beyond the SITE BOUNDARY:

- Closed window dose rates > 10 mR/hr expected to continue for 60 min.

- Analyses of field survey samples indicate thyroid CDE > 50 mrem for 60 min. of inhalation (Notes 1, 2)

A Spent fuel pool level cannot be restored to at least the top of the fuel racks for 60 minutes or longer Spent fuel pool level at the top of the fuel racks Significant lowering of water level above, or damage to, irradiated fuel UNPLANNED loss of water level above irradiated fuel Abnorm. 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF Rad AG2.1 AS2.1 AA2.1 AU2.1 Levels /

Rad Spent fuel pool level cannot be restored to at least Lowering of spent fuel pool level to 377.0 ft. (Alarm 3) IMMINENT uncovery of irradiated fuel in the UNPLANNED water level drop in the REFUELING Effluent 2 377.0 ft. (Alarm 3) on LIT-2020-3(4) for 60 min.

(Note 1) on LIT-2020-3(4) REFUELING PATHWAY AA2.2 PATHWAY as indicated by low water level alarm, visual observation, or BWST level drop due to Irradiated makeup demands Fuel Damage to irradiated fuel resulting in a release of Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds radioactivity AND Event Monitor GE SAE Alert UE AND UNPLANNED rise in corresponding area radiation levels as indicated by any of the following radiation RX-9820 High alarm on any Table 1A-2 radiation monitor monitors:

Containment Purge 4.15E+01 µCi/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1) AA2.3 - RE-8009 Spent Fuel Area Gaseous RX-9825 Lowering of spent fuel pool level to 387.0 ft. (Alarm 2)

Radwaste Area 2.67E+01 µCi/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc - RE-8017 Fuel Handling (SPING 2) on LIT-2020-3(4)

RX-9820 Radiation levels that IMPEDE access to equipment Fuel Handling Area 6.20E+02 µCi/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3) necessary for normal plant operations, cooldown or shutdown Emergency RX-9835 Table 1A-2 Unit 1 Fuel Damage Radiation Monitors Penetration Room (SPING 4) 6.55E+02 µCi/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc AA3.1 1 2 3 4 5 6 DEF RE-8009 Spent Fuel Area Dose rate > 15 mR/hr in EITHER of the following RE-8017 Fuel Handling Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm areas: RE-8060 Containment High Range Radiation Monitor

- Control Room 3 - Central Alarm Station (by survey)

RE-8061 Containment High Range Radiation Monitor RE-9820 (SPING 1) Containment Purge Area RE-9825 (SPING 2) Radwaste Area Rad Table 1A-3 Unit 1 Safe Operation & Shutdown Rooms/Areas AA3.2 RE-9830 (SPING 3) Fuel Handling Area 3 4 Levels Room / Area Mode An UNPLANNED event results in radiation levels that None prohibit or IMPEDE access to any Table 1A-3 room or A-4 Switchgear Room 3, 4 area (Note 5)

Upper North Electrical Penetration Room 3, 4 Lower South Electrical Equipment Room 3, 4 to 0CAN031801 Page 2 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Loss of RCS inventory affecting fuel clad integrity with Loss of RCS inventory affecting core decay heat removal Significant loss of RCS inventory UNPLANNED loss of RCS inventory containment challenged capability 5 6 5 6 5 6 5 6 CG1.1 [Unit 2 ONLY] CS1.1 CA1.1 CU1.1 CONTAINMENT CLOSURE not established Loss of RCS inventory as indicated by EITHER: UNPLANNED loss of reactor coolant results in RCS CG1.2 AND - RVLMS Levels 1 through 8 indicate DRY water level less than a required lower limit for 15 min. (Note 1)

RCS level cannot be monitored for 30 min. (Note 1) RVLMS Levels 1 through 9 indicate DRY - Reactor vessel level 368.5 ft. (LT-1195/LT-1196)

CU1.2 1 AND CS1.2 (bottom of hot leg)

RCS level cannot be monitored Core uncovery is indicated by any of the following: RCS level cannot be monitored for 30 min. (Note 1) CA1.2 RCS RCS level cannot be monitored for 15 min. (Note 1) AND EITHER Level - UNPLANNED rise in any Table 1C-1 sump/tank AND level of sufficient magnitude to indicate core AND EITHER - UNPLANNED rise in any Table 1C-1 Core uncovery is indicated by any of the following: sump/tank level due to loss of RCS inventory uncovery - UNPLANNED rise in any Table 1C-1

- UNPLANNED rise in any Table 1C-1 sump/tank

- Containment High Range Radiation Monitor level of sufficient magnitude to indicate core Sump/Tank level due to a loss of RCS inventory - Visual observation of UNISOLABLE RCS RE-8060/8061 reading > 10 R/hr leakage uncovery - Visual observation of UNISOLABLE RCS leakage

- Erratic Source Range Monitor indication - Containment high range radiation monitor AND RE-8060/8061 reading > 10 R/hr Any Containment Challenge indication, Table 1C-2 - Erratic Source Range Monitor indication Loss of all offsite and all onsite AC power to vital buses for Loss of all but one AC power source to vital buses for 15 minutes or longer 15 minutes or longer 5 6 DEF 5 6 DEF 2 CA2.1 CU2.1 Loss of None None Loss of all offsite and all onsite AC power to vital AC power capability, Table 1C-3, to vital 4.16 KV Vital AC 4.16 KV buses A3 and A4 for 15 min. (Note 1) buses A3 and A4 reduced to a single power source Power for 15 min. (Note 1)

C AND Any additional single power source failure will result Cold in loss of all AC power to SAFETY SYSTEMS SD/Refuel System Inability to maintain plant in cold shutdown UNPLANNED rise in RCS temperature Malfunct.

5 6 5 6 CA3.1 CU3.1 3 UNPLANNED rise in RCS temperature to > 200°F for UNPLANNED rise in RCS temperature to > 200°F None None > Table 1C-4 duration (Note 1) due to loss of decay heat removal capability RCS Temp. OR CU3.2 UNPLANNED RCS pressure rise > 10 psig due to a Loss of all RCS temperature and RCS level loss of RCS cooling (this EAL does not apply during indication for 15 min. (Note 1) water-solid plant conditions)

Loss of Vital DC power for 15 minutes or longer 4 5 6 Loss of None None None CU4.1 Vital DC Indicated voltage is < 105 VDC on vital 125 VDC Power buses for 15 min. (Note 1)

Loss of all onsite or offsite communications capabilities 5 6 DEF CU5.1 5 Loss of all Table 1C-5 onsite communication methods None None None Loss of OR Comm.

Loss of all Table 1C-5 State and local agency communication methods OR Loss of all Table 1C-5 NRC communication methods to 0CAN031801 Page 3 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode 5 6 CA6.1 The occurrence of any Table 1C-6 hazardous event AND C 6 Event damage has caused indications of degraded Hazardous performance on one train of a SAFETY SYSTEM Cold Event None None needed for the current operating mode None SD/Refuel Affecting AND EITHER System Safety - Event damage has caused indications of Malfunct. Systems degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode

- Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)

Table 1C-1 Unit 1 Sumps / Tanks Table 1C-3 Unit 1 AC Power Sources Table 1C-5 Communication Methods Table 1C-6 Hazardous Events Offsite System Onsite State / Local NRC

  • Reactor Building Sump
  • Reactor Drain Tank
  • Startup Transformer No. 1 Station radio system X
  • Internal or external FLOODING event
  • Aux. Building Equipment Drain Tank
  • Startup Transformer No. 2
  • Unit Auxiliary Transformer (from ANO plant phone system X
  • EXPLOSION
  • Quench Tank Onsite Gaitronics X
  • Other events with similar hazard characteristics as determined by the
  • DG1 Telephone Systems: Shift Manager
  • DG2
  • Commercial Table 1C-2 Containment Challenge Indications
  • AAC Gen
  • Microwave X X
  • Satellite
  • CONTAINMENT CLOSURE not established (Note 6)
  • VOIP
  • UNPLANNED rise in containment pressure INFORM Notification System X Emergency Notification System (ENS) X Table 1C-4 RCS Heat-up Duration Thresholds CONTAINMENT Heat-up RCS Status CLOSURE Status Duration Intact (but not lowered inventory) N/A 60 min.*

Not intact Established 20 min.*

OR Lowered inventory not established 0 min.

  • If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable to 0CAN031801 Page 4 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Damage to a loaded cask CONFINEMENT BOUNDARY 1 2 3 4 5 6 DEF EU1.1 Table 1E-1 ISFSI Dose Rates Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation VSC-24 VCC HI-STORM reading on the surface of a loaded spent fuel cask (VSC-24 VCC or HI-STORM overpack) > any

- 200 mrem/hr on the - 60 mrem/hr Table 1E-1 value sides (gamma +

E - 400 mrem/hr on the neutron) on the ISFSI top top or outlet vent None None

- 700 mrem/hr at the - 600 mrem/hr air inlet (gamma +

neutron on the

- 200 mrem/hr at the side of the side of air outlet the overpack (excluding inlet and outlet ducts)

GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT 1 2 3 4 1 2 3 4 1 2 3 4 F FG1.1 FS1.1 FS1.1 None Fission Product Loss of any two barriers Loss or potential loss of any two barriers (Table 1F-1) Any loss or any potential loss of either Fuel Clad or Barriers AND RCS barrier (Table 1F-1)

Loss or potential loss of the third barrier (Table 1F-1) to 0CAN031801 Page 5 of 22 Table 1F-1 Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FCB) Reactor Coolant System Barrier (RCB) Containment Barrier (CNB)

Category Loss Potential Loss Loss Potential Loss Loss Potential Loss RCB2 UNISOLABLE RCS leakage or S/G tube leakage

> 50 gpm excluding normal RCB1 An automatic or manual reductions in RCS inventory CNB1 A S/G that is leaking ESAS actuation required (e.g., letdown, RCP seal > 50 gpm (excluding A. RCS or S/G by EITHER: leakoff) normal reductions in RCS FCB1 RVLMS Levels 1 Tube None through 9 indicate DRY - UNISOLABLE RCS RCB3 PTS limits apply (RT14) inventory) or that is None RUPTURED is also Leakage leakage AND FAULTED outside of

- S/G tube RUPTURE RCS pressure and containment temperature are left of the NDTT/LTOP limit lines on EOP Figure 3 (Note 12)

FCB3 CETs > 700°F RCB4 RCS heat removal cannot CNB2 CETs > 1200°F B Inadequate FCB4 RCS heat removal be established using steam cannot be established AND Heat FCB2 CETs > 1200°F None generators None using steam generators Restoration procedures Removal AND not effective within AND HPI cooling initiated 15 min. (Note 1)

HPI cooling initiated FCB5 Containment High Range Radiation C CTMT Monitor RE-8060/8061 CNB3 Containment High Range RCB5 Containment High Range Radiation Monitor Radiation / > 750 R/hr None Radiation Monitor None None RE-8060/8061 RCS Activity FCB6 Coolant activity RE-8060/8061 > 40 R/hr

> 10,000 R/hr

> 300 Ci/gm dose equivalent I-131 CNB4 Containment isolation is required CNB6 Containment pressure AND EITHER: > 73.7 psia

- Containment integrity CNB7 Containment hydrogen D CTMT has been lost based on concentration > 3%

Emergency Director CNB8 Containment pressure Integrity or None None None None judgment > 44.7 psia with < one full Bypass - UNISOLABLE pathway train of containment heat from Containment to the removal systems (Note 9) environment exists operating per design for CNB5 Indications of RCS leakage 15 min. (Note 1) outside of Containment FCB7 Any condition in the FCB8 Any condition in the CNB10 Any condition in the E Emergency RCB6 Any condition in the RCB7 Any condition in the opinion CNB9 Any condition in the opinion of the opinion of the opinion of the opinion of the Emergency of the Emergency Director opinion of the Emergency Director Emergency Director Emergency Director that Director that indicates that indicates potential loss Director that indicates loss Emergency Director that that indicates loss of indicates potential loss indicates potential loss of Judgment the Fuel Clad barrier of the Fuel Clad barrier loss of the RCS barrier of the RCS barrier of the Containment barrier the Containment barrier to 0CAN031801 Page 6 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HOSTILE ACTION within the PROTECTED AREA HOSTILE ACTION within the OWNER CONTROLLED Confirmed SECURITY CONDITION or threat AREA or airborne attack threat within 30 minutes 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF HS1.1 HA1.1 HU1.1 A HOSTILE ACTION is occurring or has occurred A HOSTILE ACTION is occurring or has occurred A SECURITY CONDITION that does not involve a within the PROTECTED AREA as reported by ANO within the OWNER CONTROLLED AREA as reported HOSTILE ACTION as reported by ANO Security Shift 1 None Security Shift Supervision by ANO Security Shift Supervision Supervision Security OR OR A validated notification from NRC of an aircraft attack Notification of a credible security threat directed at the NOTES threat within 30 min. of the site site Note 1: The Emergency Director should declare the event promptly upon determining that the OR time limit has been exceeded, or will likely be exceeded. The Emergency Director is A validated notification from the NRC providing not allowed an additional 15 minutes to declare after the time limit is exceeded. information of an aircraft threat Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Seismic event greater than OBE levels

[Refer to CA6.1 or SA9.1 for potential 2 Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate theNone release path, then the effluent monitor reading is no longer escalation due to a seismic event]

1 2 3 4 5 6 DEF NoneVALID for HU2.1 Seismic classification purposes.

Event Note 4: The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and Seismic event > OBE as indicated by annunciation of None H AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

the 0.10 g acceleration alarm Natural or Technological Hazard Hazards Note 5: 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 2 3 4 5 6 DEF Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time HU3.1 limit, declaration of a General Emergency is not required.

Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, ice, or A tornado strike within the PROTECTED AREA vehicle breakdowns or accidents. HU3.2 Note 8: A manual action is any operator action, or set of actions, which causes the control Internal room or area FLOODING of a magnitude rods to be rapidly inserted into the core, and does not include manually driving in sufficient to require manual or automatic electrical 3 control rods or implementation of boron injection strategies.

Note 9: One full train of containment heat removal systems consists of one train of RB

[Refer to CA6.1 or SA9.1 for potential escalation due to a hazardous event]

isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating Natural or [Containment]

NoneSpray and one train of RB [Containment] Cooling System.

None mode Technical Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service None HU3.3 Hazard before the hazardous event occurred, then emergency classification is not warranted.

Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of Movement of personnel within the PROTECTED AREA degraded performance to at least one train of a SAFETY SYSTEM, then this is IMPEDED due to an event external to the emergency classification is not warranted. PROTECTED AREA involving hazardous materials Note 12: Once PTS limits are first invoked, if RCS temperature and pressure are not brought (e.g., an offsite chemical spill or toxic gas release) within the limits within 15 minutes, this threshold is met and an immediate declaration HU3.4 is warranted. This threshold is met immediately upon exceeding the limits after this A hazardous event that results in on-site conditions initial 15 minute period until PTS limits no longer apply. sufficient to prohibit the plant staff from accessing the site via personal vehicles (Note 7) to 0CAN031801 Page 7 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Fire potentially degrading the level of safety of the plant 1 2 3 4 5 6 DEF Table 1H-1 Unit 1 Fire Areas HU4.1 A FIRE is not extinguished within 15 min. of any of the Reactor Building following FIRE detection indications (Note 1):

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

- Receipt of multiple (more than 1) fire alarms or Auxiliary Building indications All elevations including: Penthouse/MSIV Room - Field verification of a single fire alarm Exceptions: AND Boric Acid Mix Tank Room (Chem Add Area), The FIRE is located within any Table 1H-1 area 404 (157-B), EDG Exhaust Fan area on 386 HU4.2 (1-E and 2-E)

[Refer to CA6.1 or SA9.1 for potential Receipt of a single fire alarm (i.e., no other indications 4 None None escalation due to a fire]

of a FIRE)

Fire Turbine Building AND All elevations including: Pipechase under ICW Coolers, None The fire alarm is indicating a FIRE within any CRD Pump Pit/T-28 Room/Area under ICW Pumps Table 1H-1 area Outside Areas AND The existence of a FIRE is not verified within 30 min.

Manholes adjacent to Startup #2 XFMR (MH-03/MH-04) of alarm receipt (Note 1)

Manholes adjacent to Intake Structure (MH-05/MH-06) HU4.3 Intake Structure (354 and 366) A FIRE within the PROTECTED AREA not Diesel Fuel Vault extinguished within 60 min. of the initial report, alarm or indication (Note 1)

Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)

HU4.4 H A FIRE within the PROTECTED AREA that requires firefighting support by an offsite fire response agency Hazards to extinguish Gaseous release IMPEDING access to Table 1H-2 Unit 1 Safe Operation & Shutdown Rooms/Areas equipment necessary for normal plant operations, cooldown or shutdown Room/Area Mode 3 4 5 None HA5.1 A-4 Switchgear Room None 3, 4 None Hazardous Release of a toxic, corrosive, asphyxiant or flammable Gases Upper North Electrical Penetration Room 3, 4 gas into any Table 1H-2 room or area Lower South Electrical Equipment Room 3, 4 AND Entry into the room or area is prohibited or IMPEDED (Note 5)

Inability to control a key safety function from Control Room evacuation resulting in transfer of plant control outside the Control Room to alternate locations DEF 1 2 3 4 5 6 DEF HS6.1 HA6.1 An event has resulted in plant control being An event has resulted in plant control being transferred 6 transferred from the Control Room to alternate from the Control Room to alternate locations Control None locations None Room AND Evacuation Control of any of the following key safety functions is not re-established within 15 min. (Note 1):

- Reactivity (Modes 1, 2 and 3 only)

- Core cooling

- RCS heat removal to 0CAN031801 Page 8 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Other conditions exist that in the judgment of the Other conditions exist that in the judgment of the Other conditions exist that in the judgment of the Other conditions exist that in the judgment of the Emergency Director warrant declaration of a Emergency Director warrant declaration of a Emergency Director warrant declaration of an Emergency Director warrant declaration of a UE GENERAL EMERGENCY SITE AREA EMERGENCY ALERT 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF HG7.1 HS7.1 HA7.1 HU7.1 Other conditions exist which, in the judgment of the Other conditions exist which, in the judgment of the Other conditions exist which, in the judgment of the Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in Emergency Director, indicate that events are in Emergency Director, indicate that events are in Emergency Director, indicate that events are in H 7 progress or have occurred which involve actual or progress or have occurred which involve actual or progress or have occurred which involve an actual or progress or have occurred which indicate a potential IMMINENT substantial core degradation or melting likely major failures of plant functions needed for potential substantial degradation of the level of degradation of the level of safety of the plant or ED Hazards with potential for loss of containment integrity or protection of the public or HOSTILE ACTION that safety of the plant or a security event that involves indicate a security threat to facility protection has Judgment HOSTILE ACTION that results in an actual loss of results in intentional damage or malicious acts, probable life threatening risk to site personnel or been initiated. No releases of radioactive material physical control of the facility. Releases can be (1) toward site personnel or equipment that could lead damage to site equipment because of HOSTILE requiring offsite response or monitoring are expected reasonably expected to exceed EPA Protective to the likely failure of or, (2) that prevent effective ACTION. Any releases are expected to be limited to unless further degradation of SAFETY SYSTEMS Action Guideline exposure levels offsite for more access to equipment needed for the protection of the small fractions of the EPA Protective Action occurs.

than the immediate site area. public. Any releases are not expected to result in Guideline exposure levels.

exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the SITE BOUNDARY.

to 0CAN031801 Page 9 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Prolonged loss of all offsite and all onsite AC power to vital Loss of all offsite and all onsite AC power to vital buses for Loss of all but one AC power source to vital buses for Loss of all offsite AC power capability to vital buses for buses 15 minutes or longer 15 minutes or longer 15 minutes or longer 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 SG1.1 SS1.1 SA1.1 SU1.1 Loss of all offsite and all onsite AC power to vital Loss of all offsite and all onsite AC power to vital AC power capability, Table 1S-1, to vital 4.16 KV Loss of all offsite AC power capability, Table 1S-1, 4.16 KV buses A3 and A4 4.16 KV buses A3 and A4 for 15 min. (Note 1) buses A3 and A4 reduced to a single power source for to vital 4.16 KV buses A3 and A4 for 15 min.

AND EITHER: 15 min. (Note 1) (Note 1)

- Restoration of at least one vital 4.16 KV bus AND 1 in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely (Note 1) Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Loss of - CETs > 1200°F Vital AC Loss of all vital AC and vital DC power sources for Power 15 minutes or longer Table 1S-1 Unit 1 AC Power Sources Offisite SG1.2

  • Startup Transformer No. 1 Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3 and A4 for 15 min. (Note 1)
  • Startup Transformer No. 2 AND
  • Unit Auxiliary Transformer (from 22 KV switchyard)

Indicated voltage is < 105 VDC on D01 and D02 vital Onsite 125 VDC buses for 15 min. (Note 1)

Loss of all vital DC power for 15 minutes or longer

  • DG1 2 1 2 3 4
  • DG2 Loss of None SS2.1 None
  • AAC Gen None Vital DC S Power Indicated voltage is < 105 VDC on D01 and D02 vital 125 VDC buses for 15 min. (Note 1)

System Malfunct. UNPLANNED loss of Control Room indications for UNPLANNED loss of Control Room indications for Table 1S-3 Significant Transients 15 minutes or longer with a significant transient in progress 15 minutes or longer None 1 2 3 4 3

  • Runback > 25% thermal power None An UNPLANNED event results in the inability to An UNPLANNED event results in the inability to Control
  • Electrical load rejection > 25% electrical load monitor one or more Table 1S-2 parameters from monitor one or more Table 1S-2 parameters from Room Indications
  • Safety injection actuation within the Control Room for 15 min. (Note 1) within the Control Room for 15 min. (Note 1)

AND Any significant transient is in progress, Table 1S-3 RCS activity greater than Technical Specification allowable limits Table 1S-2 Unit 2 Safety System Parameters 1 2 3 4

  • Reactor power SU4.1 None Failed Fuel Iodine radiation monitor RI-1237S

> 9.0 E5 cpm

  • CET temperature SU4.2 None None RCS sample activity > 1.0 µCi/gm dose equivalent RCS Activity
  • Level in at least one S/G I-131 for > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (Note 1)
  • EFW flow to at least one S/G OR RCS sample activity > 60 µCi/gm dose equivalent I-131 OR RCS sample activity > 2200 µCi/gm dose equivalent Xe-133 for > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (Note 1) to 0CAN031801 Page 10 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT RCS leakage for 15 minutes or longer 1 2 3 4 SU5.1 RCS unidentified or pressure boundary leakage 5 > 10 gpm for 15 min. (Note 1)

None None None RCS OR Leakage RCS identified leakage > 25 gpm for 15 min. (Note 1)

OR Reactor coolant leakage to a location outside containment > 25 gpm for 15 min. (Note 1)

Inability to shut down the reactor causing a challenge to Automatic or manual trip fails to shut down the reactor and Automatic or manual trip fails to shut down the reactor core cooling or RCS heat removal subsequent manual actions taken at the reactor control consolers are not successful in shutting down the reactor 1 1 1 SS6.1 SA6.1 SU6.1 An automatic or manual trip fails to shut down the An automatic or manual trip fails to shut down the An automatic trip did not shut down the reactor as reactor as indicated by reactor power > 5% reactor as indicated by reactor power > 5% indicated by reactor power > 5% after any RPS AND AND setpoint is exceeded All actions to shut down the reactor are not Manual trip actions taken at the reactor control AND successful as indicated by reactor power > 5% console (C03) (manual reactor trip pushbuttons or A subsequent automatic trip or manual trip action 6 AND EITHER DROPS) are not successful in shutting down the reactor as indicated by reactor power > 5% (Note 8) taken at the reactor control console (C03) (manual reactor trip pushbuttons or DROPS) is successful in None - CETs >1200°F RPS shutting down the reactor as indicated by reactor Failure - RCS heat removal cannot be established power 5% (Note 8) using steam generators and HPI cooling SU6.2 initiated A manual trip did not shut down the reactor as S indicated by reactor power > 5% after any manual trip action was initiated System Table 1S-4 Communication Methods AND Malfunct. A subsequent automatic trip or manual trip action System Onsite State / Local NRC taken at the reactor control console (C03 ) (manual reactor trip pushbuttons or DROPS) is successful in Station radio system X shutting down the reactor as indicated by reactor power 5% (Note 8)

ANO plant phone system X Loss of all onsite or offsite communications capabilities None 1 2 3 4 Gaitronics X SU7.1 Loss of all Table 1S-4 onsite communication 7 Telephone Systems: methods None

  • Commercial None OR Loss of Comm.
  • Microwave X X Loss of all Table 1S-4 State and local agency communication methods
  • Satellite OR
  • VOIP Loss of all Table 1S-4 NRC communication methods INFORM Notification System X Failure to isolate containment or loss of containment pressure control Emergency Notification System (ENS) X 1 2 3 4 SU8.1 8 Any penetration is not closed within 15 min. of an None None None CTMT ESAS actuation signal Failure OR Containment pressure > 44.7 psia with < one full train of containment heat removal systems (Note 9) operating per design for 15 min. (Note 1) to 0CAN031801 Page 11 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode Table 1S-5 Hazardous Events 1 2 3 4 SA9.1
  • Seismic event (earthquake) The occurrence of any Table 1S-5 hazardous event
  • Internal or external FLOODING event AND None 9
  • High winds or tornado strike Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM S Hazardous
  • FIRE needed for the current operating mode Event
  • EXPLOSION None None System AND EITHER Affecting Malfunct.
  • Other events with similar hazard characteristics as - Event damage has caused indications of Safety determined by the Shift Manager degraded performance to the second train of Systems the SAFETY SYSTEM needed for the current operating mode

- Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11) to 0CAN031801 Page 12 of 22 UNIT 2 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Release of gaseous radioactivity resulting in offsite dose Release of gaseous radioactivity resulting in offsite dose Release of gaseous OR liquid radioactivity resulting in offsite Release of gaseous or liquid radioactivity greater than 2 greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE greater than 100 mrem TEDE or 500 mrem thyroid CDE dose greater than 10 mrem TEDE or 50 mrem thyroid CDE times the ODCM limits for 60 minutes or longer 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF AG1.1 AS1.1 AA1.1 AU1.1 Reading on any Table 2A-1 effluent radiation monitor Reading on any Table 2A-1 effluent radiation monitor Reading on any Table 2A-1 effluent radiation monitor Reading on any Table 2A-1 effluent radiation

> column GE for 15 min. (Notes 1, 2, 3, 4) > column SAE for 15 min. (Notes 1, 2, 3, 4) > column ALERT for 15 min. (Notes 1, 2, 3, 4) monitor > column UE for 60 min. (Notes 1, 2, 3)

AG1.2 AS1.2 AA1.2 AU1.2 Dose assessment using actual meteorology indicates Dose assessment using actual meteorology indicates Dose assessment using actual meteorology indicates Sample analysis for a gaseous or liquid release doses > 1000 mrem TEDE or 5000 mrem thyroid doses > 100 mrem TEDE or 500 mrem thyroid CDE at doses > 10 mrem TEDE or 50 mrem thyroid CDE at or indicates a concentration or release rate > 2 x CDE at or beyond the SITE BOUNDARY (Note 4) or beyond the SITE BOUNDARY (Note 4) beyond the SITE BOUNDARY (Note 4) ODCM limits for 60 min. (Notes 1, 2) 1 AG1.3 Field survey results indicate EITHER of the following AS1.3 Field survey results indicate EITHER of the following AA1.3 Analysis of a liquid effluent sample indicates a Rad at or beyond the SITE BOUNDARY: at or beyond the SITE BOUNDARY: concentration or release rate that would result in doses Effluent > 10 mrem TEDE or 50 mrem thyroid CDE at or

- Closed window dose rates > 1000 mR/hr - Closed window dose rates > 100 mR/hr expected to continue for 60 min. expected to continue for 60 min. beyond the SITE BOUNDARY for 60 min. of exposure (Notes 1, 2)

- Analyses of field survey samples indicate - Analyses of field survey samples indicate thyroid CDE > 5000 mrem for 60 min. of thyroid CDE > 500 mrem for 60 min. of AA1.4 inhalation inhalation Field survey results indicate EITHER of the following at (Notes 1, 2) (Notes 1, 2) or beyond the SITE BOUNDARY:

- Closed window dose rates > 10 mR/hr expected to continue for 60 min.

- Analyses of field survey samples indicate thyroid CDE > 50 mrem for 60 min. of inhalation (Notes 1, 2)

Spent fuel pool level cannot be restored to at least the top Spent fuel pool level at the top of the fuel racks Significant lowering of water level above, or damage to, UNPLANNED loss of water level above irradiated fuel A of the fuel racks for 60 minutes or longer irradiated fuel Abnorm. 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF Rad AG2.1 AS2.1 AA2.1 AU2.1 Levels /

Rad Spent fuel pool level cannot be restored to at least Lowering of spent fuel pool level to 379.5 ft. (Alarm 3) IMMINENT uncovery of irradiated fuel in the UNPLANNED water level drop in the REFUELING Effluent 379.5 ft. (Alarm 3) on 2LIT-2020-1(2) for 60 min. on 2LIT-2020-1(2) REFUELING PATHWAY PATHWAY as indicated by low water level alarm, 2 (Note 1) AA2.2 visual observation, or RWT level drop due to makeup demands Irradiated Table 2A-1 Unit 1 Effluent Monitor Classification Thresholds Damage to irradiated fuel resulting in a release of radioactivity AND Fuel Monitor GE SAE Alert UE Event AND UNPLANNED rise in corresponding area radiation Containment Purge 2RX-9820 1.88E+01 µCi/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.84E-04 µCi/cc levels as indicated by any of the following radiation (SPING 5) High alarm on any Table 2A-2 radiation monitor monitors:

Gaseous 2RX-9825 AA2.3 - 2RE-8914 Spent Fuel Area Radwaste Area 2.35E+01 µCi/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc (SPING 6) Lowering of spent fuel pool level to 389.5 ft. (Alarm 2) - 2RE-8915 Spent Fuel Area 2RX-9820 on 2LIT-2020-1(2)

Fuel Handling Area 6.86E+02 µCi/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc - 2RE-8916 Spent Fuel Area (SPING 7)

- 2RE-8912 Containment Incore Instrumentation Emergency 2RX-9835 5.88E+02 µCi/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8) Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown BMS Liquid Radwaste 2RE-2330 ---- ---- ---- 2.46E+05 cpm Table 2A-2 Unit 1 Fuel Damage Radiation Monitors AA3.1 Liquid 1 2 3 4 5 6 DEF Regenerative Waste 2RE-8905 Containment Equipment Hatch Area 2RE-4423 ---- ---- ---- 2.46E+05 cpm Discharge Dose rate > 15 mR/hr in EITHER of the following 2RE-8909 Containment Personnel Access Area areas: 2RE-8912 Containment Incore Instrumentation 3 Table 2A-3 Unit 2 Safe Operation & Shutdown Rooms/Areas - Control Room 2RE-8914 Spent Fuel Area Area - Central Alarm Station (by survey) 2RE-8916 Spent Fuel Area None Room / Area Mode Rad 2RE-9825-1 Containment High Range Radiation Monitors Levels Aux Building 317 Emergency Core Cooling Rooms 3, 4 AA3.2 3 4 2RE-9825-2 Containment High Range Radiation Monitors Aux Building 317 Tendon Gallery Access 3, 4 2Rx-9820 (SPING 5) Containment Purge Aux Building 335 Charging Pumps/MCC 2B-52 3, 4 An UNPLANNED event results in radiation levels that Aux Building 354 MCC 2B-62 Area 3, 4 2Rx-9825 (SPING 6) Radwaste Area prohibit or IMPEDE access to any Table 2A-3 room or Emergency Diesel Generator Corridor 3, 4 2Rx-9830 (SPING 7) Fuel Handling Area area (Note 5)

Lower South Piping Penetration Room 3, 4 Aux Building 386 Containment Hatch 3, 4 to 0CAN031801 Page 13 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Loss of RCS inventory affecting fuel clad integrity with Loss of RCS inventory affecting core decay heat removal Significant loss of RCS inventory UNPLANNED loss of RCS inventory containment challenged capability 5 6 5 6 5 6 5 6 CG1.1 CS1.1 CA1.1 CU1.1 RVLMS Levels 1 through 7 indicate DRY CONTAINMENT CLOSURE not established Loss of RCS inventory as indicated by EITHER: UNPLANNED loss of reactor coolant results in RCS AND AND - RVLMS Levels 1 through 5 indicate DRY water level less than a required lower limit for 15 min. (Note 1)

Any Containment Challenge indication, Table 2C-2 RVLMS Levels 1 through 6 indicate DRY - Reactor vessel level 0 in. (L4791/L4792) (bottom of hot leg) CU1.2 CG1.2 CS1.2 RCS level cannot be monitored 1 RCS level cannot be monitored for 30 min. (Note 1) RVLMS Levels 1 through 7 indicate DRY CA1.2 AND EITHER AND OR RCS level cannot be monitored for 15 min. (Note 1)

RCS AND EITHER - UNPLANNED rise in any Table 2C-1 Level Core uncovery is indicated by any of the following: RCS level cannot be monitored for 30 min. (Note 1) sump/tank level due to loss of RCS inventory

- UNPLANNED rise in any Table 2C-1 sump/tank AND - UNPLANNED rise in any Table 2C-1 level of sufficient magnitude to indicate core Sump/Tank level due to a loss of RCS inventory - Visual observation of UNISOLABLE RCS Core uncovery is indicated by any of the following: leakage uncovery

- UNPLANNED rise in any Table 2C-1 sump/tank

- Visual observation of UNISOLABLE RCS leakage

- Containment High Range Radiation Monitor level of sufficient magnitude to indicate core 2RE-8925-1/8925-2 reading > 10 R/hr uncovery

- Erratic Source Range Monitor indication - Containment high range radiation monitor AND 2RE-8925-1/8925-2 reading > 10 R/hr Any Containment Challenge indication, Table 2C-2 - Erratic Source Range Monitor indication Loss of all offsite and all onsite AC power to vital buses for Loss of all but one AC power source to vital buses for 15 minutes or longer 15 minutes or longer 5 6 DEF 5 6 DEF 2 CA2.1 CU2.1 Loss of None None Loss of all offsite and all onsite AC power to vital AC power capability, Table 2C-3, to vital 4.16 KV 4.16 KV buses 2A3 and 2A4 for 15 min. (Note 1) buses 2A3 and 2A4 reduced to a single power C Vital AC Power source for 15 min. (Note 1)

Cold AND SD/Refuel Any additional single power source failure will result System in loss of all AC power to SAFETY SYSTEMS Malfunct.

Inability to maintain plant in cold shutdown UNPLANNED rise in RCS temperature 5 6 5 6 CA3.1 CU3.1 3 UNPLANNED rise in RCS temperature to > 200°F for UNPLANNED rise in RCS temperature to > 200°F None None > Table 2C-4 duration (Note 1) due to loss of decay heat removal capability RCS Temp. OR CU3.2 UNPLANNED RCS pressure rise > 10 psig due to a Loss of all RCS temperature and RCS level loss of RCS cooling (this EAL does not apply during indication for 15 min. (Note 1) water-solid plant conditions)

Loss of Vital DC power for 15 minutes or longer 4 5 6 Loss of None None None CU4.1 Vital DC Indicated voltage is < 105 VDC on vital 125 VDC Power buses for 15 min. (Note 1)

Loss of all onsite or offsite communications capabilities 5 6 DEF CU5.1 5 Loss of all Table 2C-5 onsite communication methods None None None Loss of OR Comm. Loss of all Table 2C-5 State and local agency communication methods OR Loss of all Table 2C-5 NRC communication methods to 0CAN031801 Page 14 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode 5 6 CA6.1 The occurrence of any Table 2C-6 hazardous event AND C 6 Event damage has caused indications of degraded Hazardous performance on one train of a SAFETY SYSTEM Cold Event None None needed for the current operating mode None SD/Refuel Affecting AND EITHER System Safety - Event damage has caused indications of Malfunct. Systems degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode

- Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)

Table 2C-1 Unit 2 Sumps / Tanks Table 2C-3 Unit 2 AC Power Sources Table 2C-5 Communication Methods Table 2C-6 Hazardous Events Offsite System Onsite State / Local NRC

  • Startup Transformer No. 3 Station radio system X
  • Internal or external FLOODING event
  • Reactor Drain Tank
  • Startup Transformer No. 2
  • Unit Auxiliary Transformer (backfed ANO plant phone system X
  • FIRE
  • EXPLOSION
  • Aux. Building Sump Onsite Gaitronics X
  • Other events with similar hazard
  • Quench Tank characteristics as determined by the
  • 2DG1 Telephone Systems: Shift Manager
  • 2DG2
  • Commercial Table 2C-2 Containment Challenge Indications
  • AAC Gen
  • Microwave X X
  • Satellite
  • CONTAINMENT CLOSURE not established (Note 6)
  • VOIP
  • UNPLANNED rise in containment pressure INFORM Notification System X Emergency Notification System (ENS) X Table 2C-4 RCS Heat-up Duration Thresholds CONTAINMENT Heat-up RCS Status CLOSURE Status Duration Intact (but not lowered inventory) N/A 60 min.*

Not intact Established 20 min.*

OR Lowered inventory not established 0 min.

  • If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable to 0CAN031801 Page 15 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Damage to a loaded cask CONFINEMENT BOUNDARY 1 2 3 4 5 6 DEF EU1.1 Table 2E-1 ISFSI Dose Rates Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation VSC-24 VCC HI-STORM reading on the surface of a loaded spent fuel cask (VSC-24 VCC or HI-STORM overpack) > any

- 200 mrem/hr on the - 60 mrem/hr Table 2E-1 value sides (gamma +

E - 400 mrem/hr on the neutron) on the ISFSI top top or outlet vent None None

- 700 mrem/hr at the - 600 mrem/hr air inlet (gamma +

neutron on the

- 200 mrem/hr at the side of the side of air outlet the overpack (excluding inlet and outlet ducts)

GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT 1 2 3 4 1 2 3 4 1 2 3 4 F FG1.1 FS1.1 FS1.1 None Fission Product Loss of any two barriers Loss or potential loss of any two barriers (Table 2F-1) Any loss or any potential loss of either Fuel Clad or Barriers AND RCS barrier (Table 2F-1)

Loss or potential loss of the third barrier (Table 2F-1) to 0CAN031801 Page 16 of 22 Table 2F-1 Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FCB) Reactor Coolant System Barrier (RCB) Containment Barrier (CNB)

Category Loss Potential Loss Loss Potential Loss Loss Potential Loss FCB1 RVLMS Levels 1 RCB1 An automatic or manual RCB2 UNISOLABLE RCS leakage CNB1 A S/G that is leaking through 7 indicate DRY ESFAS actuation required or S/G tube leakage > 44 gpm (excluding by EITHER: > 44 gpm excluding normal normal reductions in RCS

- UNISOLABLE RCS reductions in RCS inventory inventory) or that is leakage (e.g., letdown, RCP seal RUPTURED is also leakoff) FAULTED outside of

- S/G tube RUPTURE A. RCS or S/G RCB3 Uncontrolled RCS cooldown containment Tube None (50°F step change which is None below 500°F from NOT)

Leakage AND RCS pressure and temperature are left of line B (200 degrees MTS)

Standard Attachment 1, P-T Limits (Note 12)

FCB2 CETs > 1200°F FCB3 CETs > 700°F RCB4 RCS heat removal cannot CNB2 CETs > 1200°F FCB4 RCS heat removal be established using steam AND B Inadequate cannot be established generators Restoration procedures Heat using steam generators None AND None not effective within Removal AND Once Through cooling 15 min. (Note 1)

Once Through cooling initiated initiated FCB5 Containment High RCB5 Containment High Range CNB3 Containment High Range Range Radiation Radiation Monitor Radiation Monitor C CTMT Monitor 2RE-8925-1/ 2RE-8925-1/8925-2 2RE-8925-1/8925-2 Radiation / 8925-2 > 700 R/hr None > 50 R/hr None None > 12,000 R/hr RCS Activity FCB6 Coolant activity

> 300 Ci/gm dose equivalent I-131 CNB4 Containment isolation is CNB6 Containment pressure required > 73.7 psia AND EITHER: CNB7 Containment hydrogen

- Containment integrity concentration > 3%

D CTMT has been lost based on CNB8 Containment pressure Emergency Director > 23.3 psia with < one full Integrity or None None None None judgment train of containment heat Bypass - UNISOLABLE pathway removal systems from Containment to the (Note 9) operating per environment exists design for 15 min.

(Note 1)

CNB5 Indications of RCS leakage outside of Containment FCB7 Any condition in the FCB8 Any condition in the RCB6 Any condition in the RCB7 Any condition in the opinion CNB9 Any condition in the CNB10 Any condition in the E Emergency opinion of the opinion of the opinion of the Emergency of the Emergency Director opinion of the Emergency opinion of the Emergency Director Emergency Director Director that indicates loss that indicates potential loss Director that indicates loss Emergency Director Director that indicates loss of that indicates potential of the RCS barrier of the RCS barrier of the Containment barrier that indicates potential Judgment the Fuel Clad barrier loss of the Fuel Clad loss of the barrier Containment barrier to 0CAN031801 Page 17 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HOSTILE ACTION within the PROTECTED AREA HOSTILE ACTION within the OWNER CONTROLLED Confirmed SECURITY CONDITION or threat AREA or airborne attack threat within 30 minutes 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF HS1.1 HA1.1 HU1.1 A HOSTILE ACTION is occurring or has occurred A HOSTILE ACTION is occurring or has occurred A SECURITY CONDITION that does not involve a within the PROTECTED AREA as reported by ANO within the OWNER CONTROLLED AREA as reported HOSTILE ACTION as reported by ANO Security Shift 1 None Security Shift Supervision by ANO Security Shift Supervision Supervision Security OR OR A validated notification from NRC of an aircraft attack Notification of a credible security threat directed at the NOTES threat within 30 min. of the site site Note 1: The Emergency Director should declare the event promptly upon determining that the OR time limit has been exceeded, or will likely be exceeded. The Emergency Director is A validated notification from the NRC providing not allowed an additional 15 minutes to declare after the time limit is exceeded. information of an aircraft threat Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit. Seismic event greater than OBE levels

[Refer to CA6.1 or SA9.1 for potential 2 Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate theNone release path, then the effluent monitor reading is no longer escalation due to a seismic event]

1 2 3 4 5 6 DEF NoneVALID for HU2.1 Seismic classification purposes.

Event Note 4: The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and Seismic event > OBE as indicated by annunciation of None H AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

the 0.10 g acceleration alarm Natural or Technological Hazard Hazards Note 5: 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 2 3 4 5 6 DEF Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time HU3.1 limit, declaration of a General Emergency is not required.

Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, ice, or A tornado strike within the PROTECTED AREA vehicle breakdowns or accidents. HU3.2 Note 8: A manual action is any operator action, or set of actions, which causes the control Internal room or area FLOODING of a magnitude rods to be rapidly inserted into the core, and does not include manually driving in sufficient to require manual or automatic electrical 3 control rods or implementation of boron injection strategies.

Note 9: One full train of containment heat removal systems consists of one train of RB

[Refer to CA6.1 or SA9.1 for potential escalation due to a hazardous event]

isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating Natural or [Containment]

NoneSpray and one train of RB [Containment] Cooling System.

None mode Technical Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service None HU3.3 Hazard before the hazardous event occurred, then emergency classification is not warranted.

Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of Movement of personnel within the PROTECTED AREA degraded performance to at least one train of a SAFETY SYSTEM, then this is IMPEDED due to an event external to the emergency classification is not warranted. PROTECTED AREA involving hazardous materials Note 12: Once PTS limits are first invoked, if RCS temperature and pressure are not brought (e.g., an offsite chemical spill or toxic gas release) within the limits within 15 minutes, this threshold is met and an immediate declaration HU3.4 is warranted. This threshold is met immediately upon exceeding the limits after this A hazardous event that results in on-site conditions initial 15 minute period until PTS limits no longer apply. sufficient to prohibit the plant staff from accessing the site via personal vehicles (Note 7) to 0CAN031801 Page 18 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Fire potentially degrading the level of safety of the plant Table 2H-1 Unit 2 Fire Areas 1 2 3 4 5 6 DEF Reactor Building HU4.1 A FIRE is not extinguished within 15 min. of any of the All elevations following FIRE detection indications (Note 1):

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

All elevations including: Aux Extension - Receipt of multiple (more than 1) fire alarms or indications Turbine Building - Field verification of a single fire alarm All elevations AND The FIRE is located within any Table 2H-1 area Outside Areas HU4.2 Intake Structure (354 and 366)

[Refer to CA6.1 or SA9.1 for potential Receipt of a single fire alarm (i.e., no other indications 4 None Concrete Manhole East, NE of intake (2MH-01) None escalation due to a fire]

of a FIRE)

Fire AND Concrete Manhole East of Turbine Building next to train None bay (2MH-03) The fire alarm is indicating a FIRE within any Table 2H-1 area Diesel Fuel Vault AND Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)

The existence of a FIRE is not verified within 30 min.

of alarm receipt (Note 1)

HU4.3 A FIRE within the PROTECTED AREA not extinguished within 60 min. of the initial report, alarm Table 2H-2 Unit 2 Safe Operation & Shutdown Rooms/Areas or indication (Note 1)

HU4.4 H Room/Area Mode A FIRE within the PROTECTED AREA that requires firefighting support by an offsite fire response agency Hazards Aux Building 317 Emergency Core Cooling Rooms 3, 4 to extinguish Aux Building 317 Tendon Gallery Access 3, 4 Gaseous release IMPEDING access to Aux Building 335 Charging Pumps / MCC 2B-52 3, 4 equipment necessary for normal plant operations, cooldown or shutdown Aux Building 354 MCC 2B-62 Area 3, 4 3 4 5 None Emergency Diesel Generator Corridor 3, 4 HA5.1 Lower South Piping Penetration Room None 3, 4 None Hazardous Release of a toxic, corrosive, asphyxiant or flammable Gases Aux Building 386 Containment Hatch 3, 4 gas into any Table 2H-2 room or area AND Entry into the room or area is prohibited or IMPEDED (Note 5)

Inability to control a key safety function from Control Room evacuation resulting in transfer of plant control outside the Control Room to alternate locations DEF 1 2 3 4 5 6 DEF HS6.1 HA6.1 An event has resulted in plant control being An event has resulted in plant control being transferred 6 transferred from the Control Room to alternate from the Control Room to alternate locations Control None locations None Room AND Evacuation Control of any of the following key safety functions is not re-established within 15 min. (Note 1):

- Reactivity (Modes 1, 2 and 3 only)

- Core cooling

- RCS heat removal to 0CAN031801 Page 19 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Other conditions exist that in the judgment of the Other conditions exist that in the judgment of the Other conditions exist that in the judgment of the Other conditions exist that in the judgment of the Emergency Director warrant declaration of a Emergency Director warrant declaration of a Emergency Director warrant declaration of an Emergency Director warrant declaration of a UE GENERAL EMERGENCY SITE AREA EMERGENCY ALERT 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF HG7.1 HS7.1 HA7.1 HU7.1 Other conditions exist which, in the judgment of the Other conditions exist which, in the judgment of the Other conditions exist which, in the judgment of the Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in Emergency Director, indicate that events are in Emergency Director, indicate that events are in Emergency Director, indicate that events are in H 7 progress or have occurred which involve actual or progress or have occurred which involve actual or progress or have occurred which involve an actual or progress or have occurred which indicate a potential IMMINENT substantial core degradation or melting likely major failures of plant functions needed for potential substantial degradation of the level of degradation of the level of safety of the plant or ED Hazards with potential for loss of containment integrity or protection of the public or HOSTILE ACTION that safety of the plant or a security event that involves indicate a security threat to facility protection has Judgment HOSTILE ACTION that results in an actual loss of results in intentional damage or malicious acts, probable life threatening risk to site personnel or been initiated. No releases of radioactive material physical control of the facility. Releases can be (1) toward site personnel or equipment that could lead damage to site equipment because of HOSTILE requiring offsite response or monitoring are expected reasonably expected to exceed EPA Protective to the likely failure of or, (2) that prevent effective ACTION. Any releases are expected to be limited to unless further degradation of SAFETY SYSTEMS Action Guideline exposure levels offsite for more access to equipment needed for the protection of the small fractions of the EPA Protective Action occurs.

than the immediate site area. public. Any releases are not expected to result in Guideline exposure levels.

exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the SITE BOUNDARY.

to 0CAN031801 Page 20 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Prolonged loss of all offsite and all onsite AC power to vital Loss of all offsite and all onsite AC power to vital buses for Loss of all but one AC power source to vital buses for Loss of all offsite AC power capability to vital buses for buses 15 minutes or longer 15 minutes or longer 15 minutes or longer 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 SG1.1 SS1.1 SA1.1 SU1.1 Loss of all offsite and all onsite AC power to vital Loss of all offsite and all onsite AC power to vital AC power capability, Table 1S-1, to vital 4.16 KV Loss of all offsite AC power capability, Table 2S-1, 4.16 KV buses 2A3 and 2A4 4.16 KV buses 2A3 and 2A4 for 15 min. (Note 1) buses 2A3 and 2A4 reduced to a single power source to vital 4.16 KV buses 2A3 and 2A4 for 15 min.

AND EITHER: for 15 min. (Note 1) (Note 1)

- Restoration of at least one vital 4.16 KV bus AND 1 in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely (Note 1) Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Loss of - CETs > 1200°F Vital AC Loss of all vital AC and vital DC power sources for Table 2S-1 Unit 2 AC Power Sources Power 15 minutes or longer Offisite SG1.2

  • Startup Transformer No. 3 Loss of all offsite and all onsite AC power to vital
  • Startup Transformer No. 2 4.16 KV buses A3 and A4 for 15 min. (Note 1)

AND Onsite Indicated voltage is < 105 VDC on 2D01 and 2D02

  • Unit Auxiliary Transformer (main generator via main transformer) vital 125 VDC buses for 15 min. (Note 1)
  • 2DG1 Loss of all vital DC power for 15 minutes or longer 2 1 2 3 4
  • 2DG2 None None
  • AAC Gen None Loss of SS2.1 Vital DC Indicated voltage is < 105 VDC on 2D01 and 2D02 S Power vital 125 VDC buses for 15 min. (Note 1)

System UNPLANNED loss of Control Room indications for UNPLANNED loss of Control Room indications for Malfunct. Table 1S-3 Significant Transients 15 minutes or longer with a significant transient in progress 15 minutes or longer None 1 2 3 4 1 2 3 4 3

  • Runback > 25% thermal power An UNPLANNED event results in the inability to An UNPLANNED event results in the inability to None Control monitor one or more Table 2S-2 parameters from monitor one or more Table 2S-2 parameters from
  • Electrical load rejection > 25% electrical load Room within the Control Room for 15 min. (Note 1) within the Control Room for 15 min. (Note 1)

Indications

  • Safety injection actuation AND Any significant transient is in progress, Table 2S-3 RCS activity greater than Technical Specification allowable limits Table 1S-2 Unit 2 Safety System Parameters 1 2 3 4

> 9.0 E5 cpm

  • CET temperature SU4.2 None None RCS sample activity > 1.0 µCi/gm dose equivalent RCS Activity
  • Level in at least one S/G I-131 for > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (Note 1)
  • EFW flow to at least one S/G OR RCS sample activity > 60 µCi/gm dose equivalent I-131 OR RCS sample activity > 3100 µCi/gm dose equivalent Xe-133 for > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (Note 1) to 0CAN031801 Page 21 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT RCS leakage for 15 minutes or longer 1 2 3 4 SU5.1 RCS unidentified or pressure boundary leakage 5 > 10 gpm for 15 min. (Note 1)

None None None RCS OR Leakage RCS identified leakage > 25 gpm for 15 min. (Note 1)

OR Reactor coolant leakage to a location outside containment > 25 gpm for 15 min. (Note 1)

Inability to shut down the reactor causing a challenge to Automatic or manual trip fails to shut down the reactor and Automatic or manual trip fails to shut down the reactor core cooling or RCS heat removal subsequent manual actions taken at the reactor control consolers are not successful in shutting down the reactor 1 1 1 SS6.1 SA6.1 SU6.1 An automatic or manual trip fails to shut down the An automatic or manual trip fails to shut down the An automatic trip did not shut down the reactor as reactor as indicated by reactor power > 5% reactor as indicated by reactor power > 5% indicated by reactor power > 5% after any RPS AND AND setpoint is exceeded All actions to shut down the reactor are not Manual trip actions taken at the reactor control AND successful as indicated by reactor power > 5% console (2C03/2C14) (manual reactor trip A subsequent automatic trip or manual trip action 6 AND EITHER pushbuttons or DSS) are not successful in shutting down the reactor as indicated by reactor power > 5%

taken at the reactor control console (2C03/2C14)

(manual reactor trip pushbuttons or DSS) is None - CETs >1200°F RPS (Note 8) successful in shutting down the reactor as indicated Failure - RCS heat removal cannot be established by reactor power 5% (Note 8) using steam generators and Once Through SU6.2 cooling initiated A manual trip did not shut down the reactor as S indicated by reactor power > 5% after any manual trip action was initiated System Table 2S-4 Communication Methods AND Malfunct. A subsequent automatic trip or manual trip action System Onsite State / Local NRC taken at the reactor control console (2C03/2C14)

(manual reactor trip pushbuttons or DSS) is Station radio system X successful in shutting down the reactor as indicated by reactor power 5% (Note 8)

ANO plant phone system X Loss of all onsite or offsite communications capabilities None 1 2 3 4 Gaitronics X SU7.1 Loss of all Table 2S-4 onsite communication 7 Telephone Systems: methods None

  • Commercial None OR Loss of Comm.
  • Microwave X X Loss of all Table 2S-4 State and local agency communication methods
  • Satellite OR
  • VOIP Loss of all Table 2S-4 NRC communication methods INFORM Notification System X Failure to isolate containment or loss of containment pressure control Emergency Notification System (ENS) X 1 2 3 4 SU8.1 8 Any penetration is not closed within 15 min. of an None None None CTMT CIAS actuation signal Failure OR Containment pressure > 23.3 psia with < one full train of containment heat removal systems (Note 9) operating per design for 15 min. (Note 1) to 0CAN031801 Page 22 of 22 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode Table 1S-5 Hazardous Events 1 2 3 4 SA9.1
  • Seismic event (earthquake) The occurrence of any Table 2S-5 hazardous event
  • Internal or external FLOODING event AND None 9
  • High winds or tornado strike Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM S Hazardous
  • FIRE needed for the current operating mode Event
  • EXPLOSION None None System AND EITHER Affecting Malfunct.
  • Other events with similar hazard characteristics as - Event damage has caused indications of Safety determined by the Shift Manager degraded performance to the second train of Systems the SAFETY SYSTEM needed for the current operating mode

- Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)

Enclosure 6 to 0CAN031801 Supporting Referenced Document Pages

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 Table of Contents Section Page

1. PURPOSE ............................................................................................................................2
2. DEVELOPMENT METHODOLOGY AND BASES................................................................2 2.1 Threshold Limits ..........................................................................................................2 2.2 Effluent Release Points ...............................................................................................5 2.3 Source Term ................................................................................................................8 2.4 Effluent Flow ..............................................................................................................10 2.5 Release Duration .......................................................................................................11 2.6 Meteorology ...............................................................................................................12
3. DESIGN INPUTS ................................................................................................................13 3.1 General Constants and Conversion Factors ..............................................................13 3.2 Liquid Effluent ............................................................................................................13 3.3 Gaseous Effluent .......................................................................................................14
4. CALCULATIONS ................................................................................................................16 4.1 AU1.1 Liquid Release ................................................................................................16 4.2 AU1.1 Gaseous Release ...........................................................................................17 4.3 AA1.1, AS1.1 and AG1.1 Gaseous Release .............................................................17
5. CONCLUSIONS .................................................................................................................18
6. REFERENCES ...................................................................................................................18 ATTACHMENTS Attachment 1, AU1.1 Liquid Effluent EAL Calculations .........................................................20 Attachment 2, AU1.1 Gaseous Effluent EAL Calculations.....................................................21 Attachment 3, AA1.1, AS1.1 and AG1.1 URI Gaseous Effluent EAL Calculations................22 Page 1 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0

1. PURPOSE The Arkansas Nuclear One (ANO) Emergency Action Level (EAL) Technical Bases Manual contains background information, event declaration thresholds, bases and references for the EAL and Fission Product Barrier (FPB) values used to implement the Nuclear Energy Institute (NEI) 99-01 Revision 6 EAL guidance. This calculation document provides additional technical detail specific to the derivation of the gaseous and liquid radiological effluent EAL values developed in accordance with the guidance in NEI 99-01 Revision 6.

Documentation of the assumptions, calculations and results are provided for the Ax1 series EAL effluent monitor values associated with the following NEI 99-01 Revision 6 EALs:

NEI EAL AU1.1 (gaseous and liquid)

NEI EAL AA1.1 (gaseous and liquid)

NEI EAL AS1.1 (gaseous)

NEI EAL AG1.1 (gaseous)

2. DEVELOPMENT METHODOLOGY AND BASES 2.1 Threshold Limits 2.1.1 AU1.1 Liquid Threshold Limits Guidance Criteria AU1 addresses a release of gaseous or liquid radioactivity greater than 2 times the Offsite Dose Calculation Manual (ODCM) limits for 60 minutes or longer.

ANO Bases ODCM Section L 2.3.1 states that the concentration limits for the radioactive liquid effluents released to the discharge canal are as follows:

Less than or equal to the concentrations specified in 10 CFR Part 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases Less than or equal to 2.0E-04 Ci/ml total activity for dissolved and entrained noble gases The site specific AU1.1 liquid effluent EAL threshold values will equate to 2 times the ODCM limit.

Page 2 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 2.1.2 AU1.1 Gaseous Threshold Limits Guidance Criteria AU1 addresses a release of gaseous or liquid radioactivity greater than 2 times the Offsite Dose Calculation Manual (ODCM) limits for 60 minutes or longer.

ANO Bases ODCM Section L 2.4.1 states that the dose rate limits for the radioactive gaseous effluents released from the site to unrestricted areas are as follows:

Less than or equal to 500 mrem/yr to the total body (Noble Gasses)

Less than or equal to 3000 mrem/yr to the skin (Noble Gasses)

Less than or equal to 1500 mrem/yr to any organ (I-131, H-3, and for all radionuclides in particulate form with half-lives greater than 8 days)

ODCM gaseous setpoint calculations are based on the noble gas limits. Organ dose includes inhalation, ingestion and deposition pathways and are applied in unrestricted area site boundary gaseous effluent dose calculations used in the Annual Radioactive Effluent Release Report. Ingestion pathway bases are not compatible or directly comparable with short term event considerations, and are not a significant contribution to the total dose (total body or skin dose limits from noble gas are the major exposure pathway). Thus, the organ dose limit is not applicable for EAL threshold determination.

The site specific AU1.1 gaseous effluent EAL threshold values will equate to 2 times the ODCM limit for the lesser of the total body or skin exposure pathways.

2.1.3 AA1.1 Liquid Threshold Limits Guidance Criteria AA1 addresses a release of radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.

This is based on values at 1% of the EPA Protective Action Guides (PAGs).

Per NEI 99-01, the effluent monitor readings should correspond to the above dose limits at the site-specific dose receptor point (consistent with the calculation methodology employed) for one hour of exposure.

Page 3 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 ANO Bases The liquid effluent limits are based on the water concentration values given in 10 CFR 20 Appendix B Table 2 Column 2 (see Section 2.1.1 above). The 10 CFR 20 values are equivalent to the radionuclide concentrations which, if ingested continuously over the course of a year, would produce a total effective dose equivalent of 0.05 rem (50 mrem).

The EPA PAGs are based on a TEDE dose from immersion, inhalation and deposition.

The 10 CFR 20 limits and the EPA limits do not represent the same type of exposure and thus cannot be compared on a one to one basis.

Thus, the site specific EALs will not contain an AA1.1 liquid effluent monitor threshold value that equates to 1% of the EPA PAG. However, EALs AA1.3 (liquid effluent sample analysis) and AA1.4 (field survey results) will remain applicable for liquid effluent releases that exceed their respective thresholds.

2.1.4 AA1.1 Gaseous Threshold Limits Guidance Criteria AA1 addresses a release of radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.

Per NEI 99-01, the effluent monitor readings are based on values at 1% of the EPA Protective Action Guides (PAGs) at the site-specific dose receptor point (consistent with the calculation methodology employed) for one hour of exposure.

ANO Bases The gaseous effluent limits for AA1.1 are based on values that equate to an offsite dose greater than 10 mrem TEDE or 50 mrem CDE thyroid, which are 1% of the EPA PAGs.

2.1.5 AS1.1 Gaseous Threshold Limits Guidance Criteria AS1 addresses a release of radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE.

This is based on values at 10% of the EPA Protective Action Guides (PAGs) at the site-specific dose receptor point (consistent with the calculation methodology employed) for one hour of exposure.

ANO Bases The gaseous effluent limits for AS1.1 are based on values that equate to an offsite dose greater than 100 mrem TEDE or 500 mrem CDE thyroid, which are 10% of the EPA PAGs.

Page 4 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 2.1.6 AG1.1 Gaseous Threshold Limits Guidance Criteria AG1 addresses a release of radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE.

This is based on values at 100% of the EPA Protective Action Guides (PAGs) at the site-specific dose receptor point (consistent with the calculation methodology employed) for one hour of exposure.

ANO Bases The gaseous effluent limits for AG1.1 are based on values that equate to an offsite dose greater than 1,000 mrem TEDE or 5,000 mrem CDE thyroid, which are 100% of the EPA PAGs.

2.2 Effluent Release Points Note - All effluent release points assume a background reading of zero to conservatively account for all modes of operation applicable to the EALs.

2.2.1 Liquid Release Points Guidance Criteria Per NEI 99-01, the AU1 IC addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways (EAL AU1.1) and planned batch releases from non-continuous release pathways (EAL AU1.2).

Per NEI 99-01, the AA1 IC includes events or conditions involving a radiological release, whether gaseous or liquid, monitored or un-monitored. 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 site-specific monitor list and threshold values should be determined with consideration of the selection of the appropriate installed gaseous and liquid effluent monitors.

ANO Bases There are three monitored liquid effluent lines that discharge to the environment at ANO (ODCM Section 2.1):

ANO-1: RE-4642 - Liquid Radwaste Monitor ANO-2: 2RE-2330 - Liquid Radwaste Monitor 2RE-4423 - Liquid Radwaste Monitor Page 5 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 2.2.2 Gaseous Release Points Guidance Criteria Per NEI 99-01, the AU1 IC addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways (EAL #1) and planned batch releases from non-continuous release pathways (EAL #2).

Per NEI 99-01, the AA1 IC includes events or conditions involving a radiological release, whether gaseous or liquid, monitored or un-monitored. 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.

Per NEI 99-01, the AS1 and AG1 ICs address monitored and un-monitored releases of gaseous radioactivity. 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 site-specific monitor list and threshold values should include the effluent monitors described in emergency plan and emergency dose assessment procedures.

ANO Bases There are ten monitored gaseous effluent lines that discharge to the environment at ANO (ODCM Section 3.1.2.a):

ANO-1: RX-9820 (SPING 1) - Unit 1 Containment Purge Exhaust RX-9825 (SPING 2) - Unit 1 Radwaste Area Exhaust (RE-4830 - Waste Gas Holdup System Monitor is upstream to RX-9825)

RX-9830 (SPING 3) - Unit 1 Fuel Handling Area Exhaust RX-9835 (SPING 4) - Unit 1 Penetration Room Exhaust ANO-2: 2RX-9820 (SPING 5) - Unit 2 Containment Purge Exhaust (2RE-8233 -

Containment Building Purge Monitor is upstream to 2RX-9820) 2RX-9825 (SPING 6) - Unit 2 Radwaste Area Exhaust (2RE-2429 -

Waste Gas Holdup System Monitor is upstream to 2RX-9825) 2RX-9830 (SPING 7) - Unit 2 Fuel Handling Area Exhaust 2RX-9835 (SPING 8) - Unit 2 Penetration Room Exhaust 2RX-9845 (SPING 10) - Auxiliary Building Extension Exhaust (ABE)

Per STM 2-47-2, Turbine Building ABE Ventilation, the most probably release of radioactivity through this pathway would be due to a primary-to-secondary leak where radioactivity from the steam generators would be sent to the Start Up / Blowdown DI and possibly released via the Page 6 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 ABE ventilation. However, Operations has administrative controls in place via Abnormal Operating Procedures (AOP) and Emergency Operating Procedures (EOP) to control / limit any release via this pathway due to this type of event.

Radioactivity from the Auxiliary Building Extension (ABE) exhaust is normally below detectable limits. Review of the 2017 Unit 2 gaseous release permits revealed that the weekly analyses of the ABE pathway did not contain any measurable radioactivity from the vent and thus no release permits were required during 2017. Since this pathway does not typically discharge radioactivity above detection limits during normal operations, the pathway does not meet the NEI 99-01 criteria for an EAL threshold: normally occurring continuous radioactivity release or a planned batch release from non-continuous release pathways.

Therefore, no threshold will be developed for EAL AU1.1 for this pathway. EALs AU1.2 and AU1.3 will continue to be valid for a release from the ABE.

2RX-9850 (SPING 11) - Low Level Radwaste Building Exhaust Per U2 SAR, Section 11.5.6.1, Low Level Radioactive Waste Storage Building (LLRWSB), the LLRWSB is designed to provide a controlled environment for receiving and shipping, inspection, equipment sorting, compaction, and decontamination activities associated with on-site storage and off-site shipment of LLRW. The only potential release of radioactivity would occur during compacting operations; however, this process is not currently used.

Radioactivity from the Low Level Radwaste Building exhaust is normally below detectable limits. Review of the 2017 Unit 2 gaseous release permits revealed that the LLRWSB weekly analyses did not contain any measurable radioactivity from the vent and thus no release permits were required during 2017. Since this pathway does not typically discharge radioactivity above detection limits during normal operations, the pathway does not meet the NEI 99-01 criteria for an EAL threshold:

normally occurring continuous radioactivity release or a planned batch release from non-continuous release pathways. Therefore, no threshold will be developed for EAL AU1.1 for this pathway. EALs AU1.2 and AU1.3 will continue to be valid for a release from the LLRWSB.

Page 7 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 2.3 Source Term 2.3.1 AU1.1 Liquid Source Term Guidance Criteria NEI 99-01 does not provide specific guidance for AU1 liquid source term assumptions.

ANO Bases The ODCM setpoint method calls for a sample to be obtained and a gross gamma (Cs-137 equivalent) count and a gamma isotopic analysis performed.

Since liquid releases vary in isotopic composition, Cs-137 is considered a reasonable representative isotope and is used as the assumed source term for the liquid effluent EAL calculations.

2.3.2 AU1.1 Gaseous Source Term Guidance Criteria NEI 99-01 does not provide specific guidance for AU1 gaseous source term assumptions.

ANO Bases The gaseous source term is based upon the NUREG-1940 Table 1-6 noble gas fraction of activity available at shutdown.

2.3.3 AA1.1, AS1.1 and AG1.1 Gaseous Source Terms Guidance Criteria NEI 99-01 specifies that the calculation of monitor readings will require use of an assumed release isotopic mix; the selected mix should be the same for ICs AA1, AS1 and AG1.

ANO Bases The AA1.1, AS1.1 and AG1.1 gaseous EAL thresholds are based upon the ANO URI dose model results using input assumptions applicable to the event, pathway and particular monitor.

The source term used in the URI dose model is taken from NUREG-1940 Table 1.1 (URI Requirements Specification Appendix A Section A.2).

The process reductions used in the URI dose model are taken from NUREG-1228 and NUREG-1465 (URI Requirements Specification Appendix A Sections A.4 and A.5).

Note - HUT is hold-up time.

Page 8 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 URI input assumptions for the gaseous release points are as follows:

Unit 1 Containment CP Filter RCS HUT < 2 hrs CP Exhaust Env Working Sprays On RX-9820 (SPING 1) is modeled to release path A utilizing an event with fuel clad damage.

Containment Aux Building RWA Filter RCS HUT < 2 hrs RWA Exhaust Env HUT < 2 hrs Working Sprays On RX-9825 (SPING 2) is modeled to release path D utilizing an event with fuel clad damage.

Fuel Building FHA Filter SFP SFA Exhaust Env HUT < 2 hrs Working RX-9830 (SPING 3) is modeled to release path M utilizing an event with underwater fuel clad damage.

Containment Aux Building EPPR Filter RCS HUT < 2 hrs PPR Exhaust Env HUT < 2 hrs Working Sprays On RX-9835 (SPING 4) is modeled to release path C utilizing an event with fuel clad damage.

Unit 2 Containment CP Filter RCS HUT < 2 hrs CP Exhaust Env Working Sprays On 2RX-9820 (SPING 5) is modeled to release path A utilizing an event with fuel clad damage.

Containment Aux Building RWA Filter RCS HUT < 2 hrs RWA Exhaust Env HUT < 2 hrs Working Sprays On 2RX-9825 (SPING 6) is modeled to release path D utilizing an event with fuel clad damage.

Page 9 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 Fuel Building FHA Filter SFP SFA Exhaust Env HUT < 2 hrs Working 2RX-9830 (SPING 7) is modeled to release path M utilizing an event with underwater fuel clad damage.

Containment Aux Building EPPR Filter RCS HUT < 2 hrs PPR Exhaust Env HUT < 2 hrs Working Sprays On 2RX-9835 (SPING 8) is modeled to release path C utilizing an event with fuel clad damage.

For RCS initiated accidents, 0 time after shutdown (TAS) is used as no credit is taken for source term decay.

For the spent fuel accident, the new fuel age option is used with 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> for time after shutdown (TAS).

2.4 Effluent Flow 2.4.1 Effluent Liquid Discharge Flow Guidance Criteria NEI 99-01 does not provide specific guidance for effluent liquid flow assumptions.

ANO Bases Discharge Flow Unit 1 SAR Section 11.1.1 describes the liquid waste processing system for Unit 1. The radioactive waste disposal systems are designed to collect, store, process, monitor, and safely dispose all liquids, gases and solids which are potentially radioactive. U1 SAR Table 11-6 discharge flows are as follows:

Treated Waste Pumps, P-47A/B - 85 gpm Max Flow Rate to Discharge Flume Filtered Waste Pumps P-53A/B - 38 gpm Max Flow Rate to Discharge Flume Laundry Drain Pump, P 50 gpm Max Flow Rate to Discharge Flume A representative discharge flow rate of 85 gpm is used as the input for purposes of the U1 liquid effluent EAL calculations.

Unit 2 SAR Section 11.2.1 describes the liquid waste processing system for Unit 2.

Radioactive liquid wastes which are discharged from the plant are first processed by the Waste Management System (WMS) or the Boron Management System (BMS). The Page 10 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 contents of turbine building sumps and detergent wastes are routinely discharged unprocessed due to their very small potential for radioactive contamination. Discharge flows per U2 SAR are as follows:

Treated Waste Pumps, 2P-47A/B - 50 gpm Max Flow Rate to Discharge Flume (Table 11.2-2)

Treated Waste Pumps, 2P-53A/B - 50 gpm Max Flow Rate to Discharge Flume (Table 11.2-8)

Regenerative Waste Tank Pumps, 2P-135A/B - 100 gpm Max Flow Rate to Discharge Flume (Table 11.2-23)

A representative discharge flow rate of 100 gpm is used as the input for purposes of the U2 liquid effluent EAL calculations.

Dilution Flow Per ODCM Section 2.1.4, dilution volume is the number of circulating water pumps in operation multiplied by the approximate flowrate of a circulating water pump (normally 191,500 gpm) or an indicated flow rate.

A normal dilution flow rate of one circulating water pump (191,500 gpm) is selected for EAL calculations.

2.4.2 Effluent Gaseous Vent Flow Guidance Criteria NEI 99-01 does not provide specific guidance for effluent gaseous vent flow assumptions.

ANO Bases Vent flow values for AU1.1, AA1.1, AS1.1 and AG1.1 use the URI default flow values.

2.5 Release Duration Guidance Criteria Per NEI 99-01, the effluent monitor readings for AA1.1, AS1.1 and AG1.1 gaseous EAL threshold values should correspond to a dose at the site-specific dose receptor point (consistent with the calculation methodology employed) for one hour of exposure.

ANO Bases The effluent monitor readings for AA1.1, AS1.1 and AG1.1 gaseous EAL threshold values are calculated for a release duration of one hour.

Page 11 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 2.6 Meteorology Guidance Criteria The effluent monitor readings should correspond to the applicable dose limit at the site-specific dose receptor point. The site-specific dose receptor point is the distance(s) and/or locations used by the licensee to distinguish between on-site and offsite doses. The selected distance(s) and/or locations should reflect the content of the emergency plan, and the procedural methodology used to determine offsite doses and protective action recommendations. This is typically the boundary of the Owner Controlled Area.

Monitor readings will be calculated using a set of assumed meteorological data or atmospheric dispersion factors; the data or factors selected for use should be the same for ICs AA1, AS1 and AG1.

ANO Bases The site specific meteorology used for the EAL calculation inputs are based upon the FSAR and ODCM as documented below.

2.6.1 ODCM Gaseous Dispersion Factor (U1 SAR 2.3.6.2.5)

The highest annual average X/Q value for a ground level release, derived using the methodology of Regulatory Guide 1.111, is 2.0E-5 sec/m3 in the west-southwest sector at a distance of 0.65 miles.

For purposes of EALs thresholds the SAR historical stability class is used as a basis and any changes in SAR stability results need not require a recalculation of this input.

2.6.2 ODCM Gaseous Dispersion Factor (U1 SAR 2.3.6.2.5)

The predominant stability class of E is determined from the seasonal and annual percent frequency tables.

For purposes of EAL thresholds a long term historical meteorological stability of class E is used as a basis and any changes in seasonal or annual stability results need not require a redetermination of this input.

2.6.3 Wind Speed 190 (elevated) wind speed having the greatest number of intervals for all stability classes is 5 kts or 5.75 mph (U1 SAR Table 2-40).

40 (ground level) wind speed having the greatest number of intervals for all stability classes is 4 mph (U1 SAR Table 2-41).

For purposes of EALs thresholds the SAR historical meteorological wind speeds are used as a basis and any changes in annual predominant wind speed results need not require a recalculation of this input.

Page 12 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 2.6.4 Wind Direction 190 (elevated) wind direction having the greatest number of intervals for all stability classes is sector E (U1 SAR Table 2-40).

40 (elevated) wind direction having the greatest number of intervals for all stability classes is sector E (U1 SAR Table 2-41).

For purposes of EALs thresholds the SAR historical meteorological wind directions are used as a basis and any changes in annual predominant wind direction results need not require a recalculation of this input.

2.6.5 Other Parameters No precipitation is assumed to occur for the duration of the release and plume transport across the EPZ.

3. DESIGN INPUTS 3.1 General Constants and Conversion Factors 3.1.1 472 cc/sec per cfm 3.1.2 106 Ci per Ci 3.2 Liquid Effluent 3.2.1 Liquid Effluent Monitor Ranges
1) RE-4642 (STM 1-62 Table 62.2, TDL185 0080/0090) ................... 1E+0 to 1E+8 cpm
2) 2RE-2330 (TDW120 2020 Section 1.1.2.1) ................................... 1E+0 to 1E+6 cpm
3) 2RE-4423 (TDW120 2020 Section 1.1.2.1) ................................... 1E+0 to 1E+6 cpm 3.2.2 Offset Factor (EMS Report)
1) RE-4642 .............................................................................................. 3.027E+07 cpm
2) 2RE-2330 ............................................................................................ 2.054E+06 cpm
3) 2RE-4423 ............................................................................................ 2.054E+06 cpm 3.2.3 Slope Factor (EMS Report)
1) RE-4642 ............................................................................. 9.572E-01 cpm per µCi/ml
2) 2RE-2330 ........................................................................... 9.178E-01 cpm per µCi/ml
3) 2RE-4423 ........................................................................... 9.178E-01 cpm per µCi/ml Page 13 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 3.2.4 Liquid Effluent Dilution Flowrate - DV (ODCM 2.1.4)

1) Minimum Flow ......................................................................................... 191,500 gpm 3.2.5 Liquid Effluent Actual Flowrate - FA
1) RE-4642 Liquid Radwaste Discharge (see section 2.4.1) ............................... 85 gpm
2) 2RE-2330 Liquid Radwaste Discharge (see section 2.4.1) ........................... 100 gpm
3) 2RE-4423 Liquid Radwaste Discharge (see section 2.4.1) ........................... 100 gpm 3.2.6 10 CFR 20 Appendix B, Table 2, Column 2 Source Term Limit (MPCi)

Cs-137 .............................................................................................................. 1E-6 Ci/ml 3.3 Gaseous Effluent 3.3.1 Gaseous Effluent Monitor Ranges (TDE070 0290)

Note - Containment Purge, Radwaste Area, Fuel Handling Area and Penetration Room SPING monitors have identical ranges.

1) Low Range ............................................................. 1.12E-7 to 3.63E-2 Ci/cc Xe-133
2) Medium Range...................................................... 4.16E-5 to 6.76E+1 Ci/cc Xe-133
3) High Range ........................................................... 4.57E-3 to 5.51E+3 Ci/cc Xe-133 3.3.2 Gaseous Effluent Source Flow (URI default values)
1) Unit 1 RX-9820 (Containment Purge) ...................................................... 1.8E+04 cfm RX-9825 (Radwaste Area) ............................................................ 4.4E+04 cfm RX-9830 (Fuel Handling Area) ...................................................... 4.0E+04 cfm RX-9835 (Penetration Room) ........................................................ 1.8E+03 cfm
2) Unit 2 2RX-9820 (Containment Purge) .................................................. 3.97E+04 cfm 2RX-9825 (Radwaste Area) .......................................................... 5.0E+04 cfm 2RX-9830 (Fuel Handling Area) .................................................... 3.6E+04 cfm 2RX-9835 (Penetration Room) ...................................................... 2.0E+03 cfm 3.3.3 AU1.1 Dispersion Factor (X/Q)

Dispersion Factor (SAR 2.3.6.2.5) ..............................................................2.0E-05 sec/m3 Page 14 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 3.3.4 AU1.1 Gaseous Source Term Fraction (Ai)

NUREG-1940 Table 1-6 noble gas fraction of activity available at shutdown.

Isotopic Fraction Ai (unitless)

Kr-83m 1.83E-02 Kr-85 1.70E-03 Kr-85m 3.71E-02 Kr-87 7.40E-02 Kr-88 1.02E-01 Xe-131m 2.20E-03 Xe-133 3.26E-01 Xe-133m 1.03E-02 Xe-135 8.54E-02 Xe-135m 6.90E-02 Xe-138 2.74E-01 1.00E+00 3.3.5 ODCM Dose Factors (Regulatory Guide 1.109 Table B-1)

Note - RG 1.109 values converted from mRem/yr per Ci/m3 to mRem/yr per µCi/m3.

Total Body Dose Skin Beta Dose Gamma Air Dose Factor - Ki Factor - Li Factor - Mi (mRem/yr / µCi/m3) (mRem/yr / µCi/m3) (mRad/yr / µCi/m3)

Kr-83m 7.56E-02 0.00E+00 1.93E+01 Kr-85 1.61E+01 1.34E+03 1.72E+01 Kr-85m 1.17E+03 1.46E+03 1.23E+03 Kr-87 5.92E+03 9.73E+03 6.17E+03 Kr-88 1.47E+04 2.37E+03 1.52E+04 Xe-131m 9.15E+01 4.76E+02 1.56E+02 Xe-133 2.94E+02 3.06E+02 3.53E+02 Xe-133m 2.51E+02 9.94E+02 3.27E+02 Xe-135 1.81E+03 1.86E+03 1.92E+03 Xe-135m 3.12E+03 7.11E+02 3.36E+03 Xe-138 8.83E+03 4.13E+03 9.21E+03 Page 15 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0

4. CALCULATIONS 4.1 AU1.1 Liquid Release 4.1.1 ODCM Liquid Release Limit (ODCM Section 2.1)

+

= x x x +

Where:

ML Radiation monitor setpoint equivalent to the ODCM limit (cpm)

A Allocation fraction for the specific unit (1 selected for EAL calculations)

Offset Detector response for the minimum detectable sample activity calculated from the calibration data (cpm)

SA Gross gamma (Cs-137 equivalent) activity for the tank (µCi/ml)

(Cs-137 10 CFR 20 limit of 1E-6 Ci/ml selected for EAL calculations)

Slope Log of the detector response (cpm) / Log of activity concentration (µCi/ml)

DV Dilution volume flowrate (gpm)

Ci Concentration of isotope i (µCi/ml) (Cs-137 10 CFR 20 limit of 1E-6 Ci/ml selected for EAL calculations)

MPCi 10 CFR 20 isotope i concentration limit (Ci/ml) (Cs-137 10 CFR 20 limit of 1E-6 Ci/ml selected for EAL calculations)

CTNG Total concentration of noble gases (µCi/ml) (No noble gas assumed in the liquid discharge for EAL calculations)

MPCTNG 10 CFR 20 Total Noble Gas limit of 2E-4 (Ci/ml)

FA Actual flowrate (gpm) - maximum flowrate of the discharge pump B background countrate prior to the release (cpm) (0 cpm selected for EAL calculations) 4.1.2 AU1.1 Liquid Release EAL Threshold AU1.1 liquid is two times (2x) the calculated ODCM limit setpoint.

See Attachment 1 for the spreadsheet calculations that develop the AU1.1 liquid effluent EAL threshold values for each applicable monitor.

Page 16 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 4.2 AU1.1 Gaseous Release 4.2.1 ODCM Gaseous Release Limit 500 Limit total body 472 f Ai K i Q i 3000 Limit Skin 472 f Ai Li 1.1M i Q i Where:

Limit radiation monitor reading equivalent to the ODCM limit (Ci/cc) 500/3000 ODCM Limit - 500 total body or 3000 skin (mrem/yr) 472 conversion factor (cc/ft3 per sec/min) f vent flow (cfm)

X/Q highest annual average gaseous site boundary dispersion factor (sec/m3)

Ai isotopic fraction of the mix activity released (unitless)

Ki total body dose factor (mrem/yr per µCi/m3)

Li + 1.1Mi skin dose factor (mrem/yr per µCi/m3) 4.2.2 AU1.1 Gaseous Release EAL Threshold AU1.1 is two times (2x) the lesser of the calculated total body or skin value ODCM limit setpoint.

See Attachment 2 for the spreadsheet calculations that develop the AU1.1 gaseous effluent EAL threshold values for each applicable monitor.

4.3 AA1.1, AS1.1 and AG1.1 Gaseous Release The AA1.1, AS1.1 and AG1.1 gaseous release EAL threshold are developed using the site specific URI dose assessment models with the inputs described in Section 2 above.

Note - URI calculations were performed for each unit. There was no difference in results between units.

Refer to Attachment 3 for the results of the URI gaseous effluent EAL threshold calculations.

Page 17 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0

5. CONCLUSIONS 5.1 Unit 1 Monitor # Monitor Name GE SAE Alert UE 4.15E+1 4.15E+0 4.15E-1 1.21E-3 RX-9820 Containment Purge (Ci/cc) (Ci/cc) (Ci/cc) (Ci/cc) 2.67E+1 2.67E+0 2.67E-1 4.94E-4 Gaseous RX-9825 Radwaste Area (Ci/cc) (Ci/cc) (Ci/cc) (Ci/cc) 6.20E+2 6.20E+1 6.20E+0 5.44E-4 RX-9830 Fuel Handling Area (Ci/cc) (Ci/cc) (Ci/cc) (Ci/cc) 6.55E+2 6.55E+1 6.55E+0 1.21E-2 RX-9835 Penetration Room (Ci/cc) (Ci/cc) (Ci/cc) (Ci/cc)

Liquid 2.46E+05 RE-4642 Liquid Radwaste N/A N/A N/A (cpm) 5.2 Unit 2 Monitor # Monitor Name GE SAE Alert UE 1.88+01 1.88E+00 1.88E-01 5.48E-4 2RX-9820 Containment Purge (Ci/cc) (Ci/cc) (Ci/cc) (Ci/cc) 2.35+01 2.35E+00 2.35E-01 4.35E-4 Gaseous 2RX-9825 Radwaste Area (Ci/cc) (Ci/cc) (Ci/cc) (Ci/cc) 6.86E+02 6.86E+01 6.86E+00 6.04E-4 2RX-9830 Fuel Handling Area (Ci/cc) (Ci/cc) (Ci/cc) (Ci/cc) 5.88E+02 5.88E+01 5.88E+00 1.09E-2 2RX-9835 Penetration Room (Ci/cc) (Ci/cc) (Ci/cc) (Ci/cc) 2.45E+04 2RE-2330 Liquid Radwaste N/A N/A N/A (cpm)

Liquid 2.45E+05 2RE-4423 Liquid Radwaste N/A N/A N/A (cpm)

6. REFERENCES 6.1 10 CFR Part 20, Appendix B, Table 2, Column 2 6.2 Regulatory Guide 1.109 Table B-1 6.3 NEI 99-01 Revision 6, Methodology for Development of Emergency Action Levels, November 2012 6.4 NUREG-1940, RASCAL 4, Description of Models and Methods, December 2012 6.5 NUREG-1228, Source Term Estimation During Incident Response to Severe Nuclear Power Plant Accidents, October 1988 Page 18 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 6.6 ANO Offsite Dose Calculation Manual (ODCM), Revision 25 6.7 Unified RASCAL Interface Requirement Specification, Draft 051611 6.8 Unified RASCAL Interface Requirement Specification ANO Unit 1 Site Annex, Version 1.1 6.9 Unified RASCAL Interface Requirement Specification ANO Unit 2 Site Annex, Version 1.1 6.10 ANO1 Safety Analysis Report (SAR), Amendment 26 6.11 ANO2 Safety Analysis Report (SAR), Amendment 27 6.12 STM 1-62, Radiation Monitoring, Revision 13 6.13 STM 2-47-2, Turbine Building and Auxiliary Building Extension Ventilation, Revision 15 6.14 TD L185.0080, Operation and Maintenance Samplers, Revision 0 6.15 TD L185 0080.0090, Operation and Maintenance Digital Ratemeter Model DRM-100 and DRM-100S, Revision 4 6.16 TDW120 2020, Installation, Operation, and Maintenance Instructions Switchboard Edgewise Instruments Five Inch Classification 252 Line, Revision 0 6.17 TDE070 0290, Instruction Manual Particulate, Iodine and Noble Gas Air Monitor Model SPING-3A/SPING-4A, Revision 15 6.18 EMS Activity Monitors Report dated 10/07/15 Page 19 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 ATTACHMENT 1 AU1.1 Liquid Effluent EAL Calculations RU1.1 EAL Threshold Actual Flowrate (Fa)

Expected Countrate Monitor Setpoint -

(cpm)

Monitor Offset Slope K=Offset

  • S^Slope M=A*(K*Fm/Fa)+B Value (cpm)

RE-4642 3.03E+07 9.57E-01 5.47E+01 85 1.23E+05 2.46E+05 2RE-2330 2.05E+06 9.18E-01 6.39E+00 100 1.22E+04 2.45E+04 2RE-4423 2.05E+06 9.18E-01 6.39E+00 100 1.22E+04 2.45E+04 Gross gamma Cs-137 Equivalent Activity - S (µCi/ml): 1.00E-06 Dilution Volume Flowrate - DV (gpm): 1.92E+05 Cs-137 Activity - C (µCi/ml): 1.00E-06 Cs-137 10 CFR 20 Limit - MPC (µCi/ml): 1.00E-06 Dilution Factor - DF=i(Ci/MPCi) + CTNG/MPCTNG: 1.00E+00 Theoretical Release Rate - Fm=DV/DF (gpm): 1.92E+05 Allocation Fraction - A: 100%

Background (cpm): 0 Page 20 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 ATTACHMENT 2 AU1.1 Gaseous Effluent EAL Calculations Total Body Dose Factor - Ki Gamma Air Dose Factor - Mi Skin Beta Dose Factor - Li Source Term Fraction - Ai Ai x Ki Ai x (Li + 1.1Mi)

(mRem/yr per µCi/m3) (mRem/yr per µCi/m3) (mRad/yr per µCi/m3) (mRem/yr per µCi/m3) (mRem/yr per µCi/m3)

Kr-83m 7.56E-02 0.00E+00 1.93E+01 1.83E-02 1.38E-03 3.89E-01 Kr-85 1.61E+01 1.34E+03 1.72E+01 1.70E-03 2.74E-02 2.31E+00 Kr-85m 1.17E+03 1.46E+03 1.23E+03 3.71E-02 4.34E+01 1.04E+02 Kr-87 5.92E+03 9.73E+03 6.17E+03 7.40E-02 4.38E+02 1.22E+03 Kr-88 1.47E+04 2.37E+03 1.52E+04 1.02E-01 1.50E+03 1.95E+03 Xe-131m 9.15E+01 4.76E+02 1.56E+02 2.20E-03 2.01E-01 1.42E+00 Xe-133 2.94E+02 3.06E+02 3.53E+02 3.26E-01 9.59E+01 2.26E+02 Xe-133m 2.51E+02 9.94E+02 3.27E+02 1.03E-02 2.59E+00 1.39E+01 Xe-135 1.81E+03 1.86E+03 1.92E+03 8.54E-02 1.55E+02 3.39E+02 Xe-135m 3.12E+03 7.11E+02 3.36E+03 6.90E-02 2.15E+02 3.04E+02 Xe-138 8.83E+03 4.13E+03 9.21E+03 2.74E-01 2.42E+03 3.90E+03 1.00E+00 4.87E+03 8.07E+03 Calculation Constants Total Body-DDE (mRem/yr): 500 Skin Dose-SDE (mRem/yr): 3000 UCF (CFM to cc/sec): 472 X/Q (sec/m3): 2.00E-05 DCF (mRad to mRem): 1.1 Calculation Results Unit 1: RX-9820 RX-9825 RX-9830 RX-9835 Flow (cfm): 1.80E+04 4.40E+04 4.00E+04 1.80E+03 Limit-TB (µCi/cc): 6.04E-04 2.47E-04 2.72E-04 6.04E-03 Limit-Skin (µCi/cc): 2.19E-03 8.95E-04 9.85E-04 2.19E-02 2x ODCM (µCi/cc): 1.21E-03 4.94E-04 5.44E-04 1.21E-02 Unit 2: 2RX-9820 2RX-9825 2RX-9830 2RX-9835 Flow (cfm): 3.97E+04 5.00E+04 3.60E+04 2.00E+03 Limit-TB (µCi/cc): 2.74E-04 2.18E-04 3.02E-04 5.44E-03 Limit-Skin (µCi/cc): 9.92E-04 7.88E-04 1.09E-03 1.97E-02 2x ODCM (µCi/cc): 5.48E-04 4.35E-04 6.04E-04 1.09E-02 Page 21 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 ATTACHMENT 3 AA1.1, AS1.1 and AG1.1 Gaseous Effluent EAL Calculations Page 22 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9820 (SPING 1) Containment Purge Exhaust - Alert Dose Assessment ANO Unit 1 Wednesday, October 07, 2015 15:52 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <CP Filters> < Env> PRF: 3.00E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = Working Steam Gen: = N/A Aux / FHB HUT: = N/A Filters: = N/A Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: CP Gas Conc Readings: 4.15E-01 µCI/cc Flowrate: 18000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem M

S.B. 8.00E+00 5.32E+00 1.19E+00 6.77E-01 7.19E+00 5.01E+01 0.7 7.44E+00 4.92E+00 1.11E+00 6.66E-01 6.70E+00 4.56E+01 P L 1.0 5.36E+00 3.47E+00 8.68E-01 5.91E-01 4.93E+00 3.26E+01 N K O

1.5 3.55E+00 2.26E+00 6.52E-01 4.47E-01 3.36E+00 2.35E+01 2.0 2.40E+00 1.52E+00 5.12E-01 3.15E-01 2.35E+00 1.86E+01 G J 3.0 2.14E+00 1.41E+00 3.61E-01 2.20E-01 1.99E+00 1.32E+01 Q R H 4.0 1.63E+00 1.05E+00 2.89E-01 1.67E-01 1.50E+00 1.05E+01 U I 5.0 1.36E+00 8.64E-01 2.53E-01 1.35E-01 1.25E+00 9.29E+00 T

7.0 9.84E-01 6.27E-01 2.01E-01 0.00E+00 8.29E-01 7.67E+00 10.0 5.72E-01 3.56E-01 1.24E-01 0.00E+00 4.80E-01 5.00E+00 S Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 155234.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Validate against Emergency Action Levels * *
  • Particulate 6.56E-04 (0.0%)

Iodine 1.61E-02 (0.5%)

Reviewed By: Noble Gas 3.53E+00 (99.5%)

Page 23 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9820 (SPING 1) Containment Purge Exhaust - Site Area Emergency Dose Assessment ANO Unit 1 Wednesday, October 07, 2015 15:52 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <CP Filters> < Env> PRF: 3.00E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = Working Steam Gen: = N/A Aux / FHB HUT: = N/A Filters: = N/A Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: CP Gas Conc Readings: 4.15E+00 µCI/cc Flowrate: 18000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem M

S.B. 8.00E+01 5.32E+01 1.19E+01 6.77E+00 7.19E+01 5.01E+02 0.7 7.44E+01 4.92E+01 1.11E+01 6.66E+00 6.70E+01 4.56E+02 P L 1.0 5.36E+01 3.47E+01 8.68E+00 5.91E+00 4.93E+01 3.26E+02 N K O

1.5 3.55E+01 2.26E+01 6.52E+00 4.47E+00 3.36E+01 2.35E+02 2.0 2.40E+01 1.52E+01 5.12E+00 3.15E+00 2.35E+01 1.86E+02 G J 3.0 2.14E+01 1.41E+01 3.61E+00 2.20E+00 1.99E+01 1.32E+02 Q R H 4.0 1.63E+01 1.05E+01 2.89E+00 1.67E+00 1.50E+01 1.05E+02 U I 5.0 1.36E+01 8.64E+00 2.53E+00 1.35E+00 1.25E+01 9.29E+01 T

7.0 9.84E+00 6.27E+00 2.01E+00 9.23E-01 9.21E+00 7.67E+01 10.0 5.72E+00 3.56E+00 1.24E+00 4.53E-01 5.25E+00 5.00E+00 S Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 155209.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Site Area Emergency * *
  • Particulate 6.56E-03 (0.0%)

Iodine 1.61E-01 (0.5%)

Reviewed By: Noble Gas 3.53E+01 (99.5%)

Page 24 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9820 (SPING 1) Containment Purge Exhaust - General Emergency Dose Assessment ANO Unit 1 Wednesday, October 07, 2015 15:52 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <CP Filters> < Env> PRF: 3.00E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = Working Steam Gen: = N/A Aux / FHB HUT: = N/A Filters: = N/A Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: CP Gas Conc Readings: 4.15E+01 µCI/cc Flowrate: 18000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem M

S.B. 8.00E+01 5.32E+01 1.19E+01 6.77E+00 7.19E+01 5.01E+02 0.7 7.44E+01 4.92E+01 1.11E+01 6.66E+00 6.70E+01 4.56E+02 P L 1.0 5.36E+01 3.47E+01 8.68E+00 5.91E+00 4.93E+01 3.26E+02 N K O

1.5 3.55E+01 2.26E+01 6.52E+00 4.47E+00 3.36E+01 2.35E+02 G

2.0 2.40E+01 1.52E+01 5.12E+00 3.15E+00 2.35E+01 1.86E+02 J 3.0 2.14E+01 1.41E+01 3.61E+00 2.20E+00 1.99E+01 1.32E+02 Q R H 4.0 1.63E+01 1.05E+01 2.89E+00 1.67E+00 1.50E+01 1.05E+02 U I 5.0 1.36E+01 8.64E+00 2.53E+00 1.35E+00 1.25E+01 9.29E+01 T

7.0 9.84E+00 6.27E+00 2.01E+00 9.23E-01 9.21E+00 7.67E+01 10.0 5.72E+00 3.56E+00 1.24E+00 4.53E-01 5.25E+00 5.00E+01 S Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 155647.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: General Emergency * *
  • Particulate 6.56E-02 (0.0%)

Iodine 1.61E+00 (0.5%)

Reviewed By: Noble Gas 3.53E+02 (99.5%)

Page 25 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9825 (SPING 2) Radwaste Area Exhaust - Alert Dose Assessment ANO Unit 1 Wednesday, October 07, 2015 15:59 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <RWA Filters> < Env> PRF: 1.20E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: RWA Gas Conc Readings: 2.67E-01 µCI/cc Flowrate: 44000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.24E+01 8.31E+00 9.39E-01 7.70E-01 1.00E+01 3.15E+01 0.7 1.16E+01 7.68E+00 9.00E-01 7.78E-01 9.36E+00 2.87E+01 1.0 8.36E+00 5.40E+00 7.60E-01 7.38E-01 6.90E+00 2.06E+01 O

1.5 5.52E+00 3.52E+00 5.92E-01 5.66E-01 4.67E+00 1.49E+01 2.0 3.74E+00 2.38E+00 4.56E-01 3.91E-01 3.22E+00 1.18E+01 G 3.0 3.33E+00 2.20E+00 3.23E-01 2.78E-01 2.80E+00 8.30E+00 4.0 2.54E+00 1.64E+00 2.60E-01 2.10E-01 2.11E+00 6.61E+00 5.0 2.12E+00 1.35E+00 2.26E-01 1.68E-01 1.74E+00 5.85E+00 T

7.0 1.54E+00 9.82E-01 1.75E-01 1.09E-01 1.27E+00 4.83E+00 10.0 8.92E-01 5.56E-01 1.03E-01 0.00E+00 6.59E-01 3.15E+00 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 155932.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Validate against Emergency Action Levels * *
  • Particulate 4.13E-04 (0.0%)

Iodine 1.01E-02 (0.2%)

Reviewed By: Noble Gas 5.54E+00 (99.8%)

Page 26 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9825 (SPING 2) Radwaste Area Exhaust - Site Area Emergency Dose Assessment ANO Unit 1 Wednesday, October 07, 2015 15:59 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <RWA Filters> < Env> PRF: 1.20E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: RWA Gas Conc Readings: 2.67E+00 µCI/cc Flowrate: 44000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.24E+02 8.31E+01 9.39E+00 7.70E+00 1.00E+02 3.15E+02 0.7 1.16E+02 7.68E+01 9.00E+00 7.78E+00 9.36E+01 2.87E+02 1.0 8.36E+01 5.40E+01 7.60E+00 7.38E+00 6.90E+01 2.06E+02 1.5 5.52E+01 3.52E+01 5.92E+00 5.66E+00 4.67E+01 1.49E+02 2.0 3.74E+01 2.38E+01 4.56E+00 3.91E+00 3.22E+01 1.18E+02 3.0 3.33E+01 2.20E+01 3.23E+00 2.78E+00 2.80E+01 8.30E+01 4.0 2.54E+01 1.64E+01 2.60E+00 2.10E+00 2.11E+01 6.61E+01 5.0 2.12E+01 1.35E+01 2.26E+00 1.68E+00 1.74E+01 5.85E+01 7.0 1.54E+01 9.82E+00 1.75E+00 1.09E+00 1.27E+01 4.83E+01 10.0 8.92E+00 5.56E+00 1.03E+00 4.90E+01 7.08E+00 3.15E+01 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 155911.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Site Area Emergency * *
  • Particulate 4.13E-03 (0.0%)

Iodine 1.01E-01 (0.2%)

Reviewed By: Noble Gas 5.54E+01 (99.8%)

Page 27 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9825 (SPING 2) Radwaste Area Exhaust - General Emergency Dose Assessment ANO Unit 1 Wednesday, October 07, 2015 15:58 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <RWA Filters> < Env> PRF: 1.20E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: RWA Gas Conc Readings: 2.67E+01 µCI/cc Flowrate: 44000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.24E+03 8.31E+02 9.39E+01 7.70E+01 1.00E+03 3.15E+03 0.7 1.16E+03 7.68E+02 9.00E+01 7.78E+01 9.36E+02 2.87E+03 1.0 8.36E+02 5.40E+02 7.60E+01 7.38E+01 6.90E+02 2.06E+03 1.5 5.52E+02 3.52E+02 5.92E+01 5.66E+01 4.67E+02 1.49E+03 2.0 3.74E+02 2.38E+02 4.56E+01 3.91E+01 3.22E+02 1.18E+03 3.0 3.33E+02 2.20E+02 3.23E+01 2.78E+01 2.80E+02 8.30E+02 4.0 2.54E+02 1.64E+02 2.60E+01 2.10E+01 2.11E+02 6.61E+02 5.0 2.12E+02 1.35E+02 2.26E+01 1.68E+01 1.74E+02 5.85E+02 7.0 1.54E+02 9.82E+01 1.75E+01 1.09E+01 1.27E+02 4.83E+02 10.0 8.92E+01 5.56E+01 1.03E+01 4.90E+00 7.08E+01 3.15E+02 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 155849.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: General Emergency * *
  • Particulate 4.13E-02 (0.0%)

Iodine 1.01E+00 (0.2%)

Reviewed By: Noble Gas 5.54E+02 (99.8%)

Page 28 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9830 (SPING 3) Spent Fuel Area Exhaust - Alert Dose Assessment ANO Unit 1 Wednesday, October 07, 2015 16:05 Method: Detailed Assessment - Monitored Release Release Pathway: <SF> <Under Water> <Fuel Bldg> <FHA Filters> < Env> PRF: 4.00E-04 Containment HUT: = N/A Containment Sprays: = N/A Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Spent Fuel Accident - Under Water Damage: 0.560% On Site 57 m Time After S/D (hh:mm): 80:01 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: FH Gas Conc Readings: 6.20E+00 µCI/cc Flowrate: 40000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.42E+01 9.98E+00 0.00E+00 0.00E+00 9.98E+00 3.89E+00 0.7 1.31E+01 9.20E+00 0.00E+00 0.00E+00 9.20E+00 3.54E+00 1.0 9.60E+00 6.72E+00 0.00E+00 0.00E+00 6.72E+00 2.54E+00 1.5 6.80E+00 4.76E+00 0.00E+00 0.00E+00 4.76E+00 1.84E+00 2.0 5.36E+00 3.75E+00 0.00E+00 0.00E+00 3.75E+00 1.46E+00 3.0 3.69E+00 2.56E+00 0.00E+00 0.00E+00 2.56E+00 1.03E+00 4.0 3.11E+00 2.10E+00 0.00E+00 0.00E+00 2.10E+00 8.19E-01 5.0 2.87E+00 1.92E+00 0.00E+00 0.00E+00 1.92E+00 7.27E-01 7.0 2.54E+00 1.69E+00 0.00E+00 0.00E+00 1.69E+00 6.03E-01 10.0 1.88E+00 1.20E+00 0.00E+00 0.00E+00 1.20E+00 3.95E-01 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 160534.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Validate against Emergency Action Levels * *
  • Particulate 9.72E-05 (0.0%)

Iodine 2.31E-04 (0.0%)

Reviewed By: Noble Gas 1.17E+02 (100.0%)

Page 29 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9830 (SPING 3) Spent Fuel Area Exhaust - Site Area Emergency Dose Assessment ANO Unit 1 Wednesday, October 07, 2015 16:04 Method: Detailed Assessment - Monitored Release Release Pathway: <SF> <Under Water> <Fuel Bldg> <FHA Filters> < Env> PRF: 4.00E-04 Containment HUT: = N/A Containment Sprays: = N/A Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Spent Fuel Accident - Under Water Damage: 0.560% On Site 57 m Time After S/D (hh:mm): 80:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: FH Gas Conc Readings: 6.20E+01 µCI/cc Flowrate: 40000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.42E+02 9.98E+01 8.74E-01 2.18E-01 1.01E+02 3.89E+01 0.7 1.31E+02 9.20E+01 7.96E-01 1.98E-01 9.30E+01 3.54E+01 1.0 9.60E+01 6.72E+01 5.72E-01 1.42E-01 6.79E+01 2.54E+01 1.5 6.80E+01 4.76E+01 4.12E-01 1.03E-01 4.81E+01 1.84E+01 2.0 5.36E+01 3.75E+01 3.28E-01 0.00E+00 3.78E+01 1.46E+01 3.0 3.69E+01 2.56E+01 2.30E-01 0.00E+00 2.58E+01 1.03E+01 4.0 3.11E+01 2.10E+01 1.83E-01 0.00E+00 2.12E+01 8.19E+00 5.0 2.87E+01 1.92E+01 1.62E-01 0.00E+00 1.94E+01 7.27E+00 7.0 2.54E+01 1.69E+01 1.34E-01 0.00E+00 1.70E+01 6.03E+00 10.0 1.88E+01 1.20E+01 0.00E+00 0.00E+00 1.20E+01 3.95E+00 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 160416.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Site Area Emergency * *
  • Particulate 9.72E-04 (0.0%)

Iodine 2.31E-03 (0.0%)

Reviewed By: Noble Gas 1.17E+03 (100.0%)

Page 30 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9830 (SPING 3) Spent Fuel Area Exhaust - General Emergency Dose Assessment ANO Unit 1 Wednesday, October 07, 2015 16:03 Method: Detailed Assessment - Monitored Release Release Pathway: <SF> <Under Water> <Fuel Bldg> <FHA Filters> < Env> PRF: 4.00E-04 Containment HUT: = N/A Containment Sprays: = N/A Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Spent Fuel Accident - Under Water Damage: 0.560% On Site 57 m Time After S/D (hh:mm): 80:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: FH Gas Conc Readings: 6.20E+02 µCI/cc Flowrate: 40000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.42E+03 9.98E+02 8.74E+00 2.18E+00 1.01E+03 3.89E+02 0.7 1.31E+03 9.20E+02 7.96E+00 1.98E+00 9.30E+02 3.54E+02 1.0 9.60E+02 6.72E+02 5.72E+00 1.42E+00 6.79E+02 2.54E+02 1.5 6.80E+02 4.76E+02 4.12E+00 1.03E+00 4.81E+02 1.84E+02 2.0 5.36E+02 3.75E+02 3.28E+00 8.16E-01 3.79E+02 1.46E+02 3.0 3.69E+02 2.56E+02 2.30E+00 5.06E-01 2.58E+02 1.03E+02 4.0 3.11E+02 2.10E+02 1.83E+00 3.93E-01 2.13E+02 8.19E+01 5.0 2.87E+02 1.92E+02 1.62E+00 3.44E-01 1.94E+02 7.27E+01 7.0 2.54E+02 1.69E+02 1.34E+00 2.79E-01 1.70E+02 6.03E+01 10.0 1.88E+02 1.20E+02 8.79E-01 1.75E-01 1.21E+02 3.95E+01 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 160358.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: General Emergency * *
  • Particulate 9.72E-03 (0.0%)

Iodine 2.31E-02 (0.0%)

Reviewed By: Noble Gas 1.17E+04 (100.0%)

Page 31 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9835 (SPING 4) Penetration Room Exhaust - Alert Dose Assessment ANO Unit 1 Wednesday, October 07, 2015 16:10 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <EPPR Filters> < Env> PRF: 1.20E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: EPPR Gas Conc Readings: 6.55E+00 µCI/cc Flowrate: 1800 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.25E+01 8.35E+00 9.40E-01 7.74E-01 1.01E+01 3.16E+01 0.7 1.16E+01 7.72E+00 9.00E-01 7.83E-01 9.40E+00 2.88E+01 1.0 8.40E+00 5.44E+00 7.64E-01 7.41E-01 6.95E+00 2.06E+01 1.5 5.56E+00 3.54E+00 5.92E-01 5.69E-01 4.70E+00 1.49E+01 2.0 3.75E+00 2.39E+00 4.60E-01 3.93E-01 3.24E+00 1.18E+01 3.0 3.34E+00 2.21E+00 3.24E-01 2.80E-01 2.82E+00 8.31E+00 4.0 2.55E+00 1.64E+00 2.61E-01 2.11E-01 2.12E+00 6.62E+00 5.0 2.13E+00 1.36E+00 2.27E-01 1.69E-01 1.75E+00 5.86E+00 7.0 1.54E+00 9.87E-01 1.76E-01 1.10E-01 1.27E+00 4.84E+00 10.0 8.96E-01 5.59E-01 1.04E-01 0.00E+00 6.62E-01 3.15E+00 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 161015.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Validate against Emergency Action Levels * *
  • Particulate 4.14E-04 (0.0%)

Iodine 1.02E-02 (0.2%)

Reviewed By: Noble Gas 5.56E+00 (99.8%)

Page 32 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9835 (SPING 4) Penetration Room Exhaust - Site Area Emergency Dose Assessment ANO Unit 1 Wednesday, October 07, 2015 16:09 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <EPPR Filters> < Env> PRF: 1.20E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: EPPR Gas Conc Readings: 6.55E+01 µCI/cc Flowrate: 1800 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.25E+02 8.35E+01 9.40E+00 7.74E+00 1.01E+02 3.16E+02 0.7 1.16E+02 7.72E+01 9.00E+00 7.83E+00 9.40E+01 2.88E+02 1.0 8.40E+01 5.44E+01 7.64E+00 7.41E+00 6.95E+01 2.06E+02 1.5 5.56E+01 3.54E+01 5.92E+00 5.69E+00 4.70E+01 1.49E+02 2.0 3.75E+01 2.39E+01 4.60E+00 3.93E+00 3.24E+01 1.18E+02 3.0 3.34E+01 2.21E+01 3.24E+00 2.80E+00 2.82E+01 8.31E+01 4.0 2.55E+01 1.64E+01 2.61E+00 2.11E+00 2.12E+01 6.62E+01 5.0 2.13E+01 1.36E+01 2.27E+00 1.69E+00 1.75E+01 5.86E+01 7.0 1.54E+01 9.87E+00 1.76E+00 1.10E+00 1.27E+01 4.84E+01 10.0 8.96E+00 5.59E+00 1.04E+00 4.92E-01 6.62E+00 3.15E+01 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 160956.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Site Area Emergency * *
  • Particulate 4.14E-03 (0.0%)

Iodine 1.02E-01 (0.2%)

Reviewed By: Noble Gas 5.56E+01 (99.8%)

Page 33 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U1 RX-9835 (SPING 4) Penetration Room Exhaust - General Emergency Dose Assessment ANO Unit 1 Wednesday, October 07, 2015 16:09 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <EPPR Filters> < Env> PRF: 1.20E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: EPPR Gas Conc Readings: 6.55E+02 µCI/cc Flowrate: 1800 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.25E+03 8.35E+02 9.40E+01 7.74E+01 1.01E+03 3.16E+03 0.7 1.16E+02 7.72E+02 9.00E+01 7.83E+01 9.40E+02 2.88E+03 1.0 8.40E+02 5.44E+02 7.64E+01 7.41E+01 6.95E+02 2.06E+03 1.5 5.56E+02 3.54E+02 5.92E+01 5.69E+01 4.70E+02 1.49E+03 2.0 3.75E+02 2.39E+02 4.60E+01 3.93E+01 3.24E+02 1.18E+03 3.0 3.34E+02 2.21E+02 3.24E+01 2.80E+01 2.82E+02 8.31E+02 4.0 2.55E+02 1.64E+02 2.61E+01 2.11E+01 2.12E+02 6.62E+02 5.0 2.13E+02 1.36E+02 2.27E+01 1.69E+01 1.75E+02 5.86E+02 7.0 1.54E+02 9.87E+01 1.76E+01 1.10E+01 1.27E+02 4.84E+02 10.0 8.96E+01 5.59E+01 1.04E+01 4.92E+00 7.11E+01 3.15E+02 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 160932.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: General Emergency * *
  • Particulate 4.14E-02 (0.0%)

Iodine 1.02E+00 (0.2%)

Reviewed By: Noble Gas 5.56E+02 (99.8%)

Page 34 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9820 (SPING 5) Containment Purge Exhaust - Alert Dose Assessment ANO Unit 2 Wednesday, October 07, 2015 16:15 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <CP Filters> < Env> PRF: 3.00E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = Working Steam Gen: = N/A Aux / FHB HUT: = N/A Filters: = N/A Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: CP Gas Conc Readings: 1.88E-01 µCI/cc Flowrate: 39700 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 8.00E+00 5.32E+00 1.19E+00 6.77E-01 7.19E+00 5.01E+01 0.7 7.44E+00 4.92E+00 1.11E+00 6.66E-01 6.70E+00 4.56E+01 1.0 5.36E+00 3.47E+00 8.68E-01 5.90E-01 4.93E+00 3.26E+01 1.5 3.55E+00 2.26E+00 6.52E-01 4.46E-01 3.35E+00 2.35E+01 2.0 2.40E+00 1.52E+00 5.12E-01 3.15E-01 2.35E+00 1.86E+01 3.0 2.14E+00 1.41E+00 3.61E-01 2.20E-01 1.99E+00 1.32E+01 4.0 1.63E+00 1.05E+00 2.89E-01 1.67E-01 1.50E+00 1.05E+01 5.0 1.36E+00 8.64E-01 2.53E-01 1.35E-01 1.25E+00 9.29E+00 7.0 9.84E-01 6.27E-01 2.01E-01 0.00E+00 8.29E-01 7.67E+00 10.0 5.72E-01 3.56E-01 1.24E-01 0.00E+00 4.80E-01 5.00E+00 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 161518.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Validate against Emergency Action Levels * *
  • Particulate 6.56E-04 (0.0%)

Iodine 1.61E-02 (0.5%)

Reviewed By: Noble Gas 3.52E+00 (99.5%)

Page 35 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9820 (SPING 5) Containment Purge Exhaust - Site Area Emergency Dose Assessment ANO Unit 2 Wednesday, October 07, 2015 16:15 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <CP Filters> < Env> PRF: 3.00E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = Working Steam Gen: = N/A Aux / FHB HUT: = N/A Filters: = N/A Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: CP Gas Conc Readings: 1.88E+00 µCI/cc Flowrate: 39700 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 8.00E+01 5.32E+01 1.19E+01 6.77E+00 7.19E+01 5.01E+02 0.7 7.44E+01 4.92E+01 1.11E+01 6.66E+00 6.70E+01 4.56E+02 1.0 5.36E+01 3.47E+01 8.68E+00 5.90E+00 4.93E+01 3.26E+02 1.5 3.55E+01 2.26E+01 6.52E+00 4.46E+00 3.35E+01 2.35E+02 2.0 2.40E+01 1.52E+01 5.12E+00 3.15E+00 2.35E+01 1.86E+02 3.0 2.14E+01 1.41E+01 3.61E+00 2.20E+00 1.99E+01 1.32E+02 4.0 1.63E+01 1.05E+01 2.89E+00 1.67E+00 1.50E+01 1.05E+02 5.0 1.36E+01 8.64E+00 2.53E+00 1.35E+00 1.25E+01 9.29E+01 7.0 9.84E+00 6.27E+00 2.01E+00 9.22E-01 9.21E+00 7.67E+01 10.0 5.72E+00 3.56E+00 1.24E+00 4.52E-01 5.25E+00 5.00E+01 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 161502.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Site Area Emergency * *
  • Particulate 6.56E-03 (0.0%)

Iodine 1.61E-01 (0.5%)

Reviewed By: Noble Gas 3.52E+01 (99.5%)

Page 36 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9820 (SPING 5) Containment Purge Exhaust - General Emergency Dose Assessment ANO Unit 2 Wednesday, October 07, 2015 16:14 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <CP Filters> < Env> PRF: 3.00E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = Working Steam Gen: = N/A Aux / FHB HUT: = N/A Filters: = N/A Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: CP Gas Conc Readings: 1.88E+01 µCI/cc Flowrate: 39700 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 8.00E+02 5.32E+02 1.19E+02 6.77E+01 7.19E+02 5.01E+03 0.7 7.44E+02 4.92E+02 1.11E+02 6.66E+01 6.70E+02 4.56E+03 1.0 5.36E+02 3.47E+02 8.68E+01 5.90E+01 4.93E+02 3.26E+03 1.5 3.55E+02 2.26E+02 6.52E+01 4.46E+01 3.35E+02 2.35E+03 2.0 2.40E+02 1.52E+02 5.12E+01 3.15E+01 2.35E+02 1.86E+03 3.0 2.14E+02 1.41E+02 3.61E+01 2.20E+01 1.99E+02 1.32E+03 4.0 1.63E+02 1.05E+02 2.89E+01 1.67E+01 1.50E+02 1.05E+03 5.0 1.36E+02 8.64E+01 2.53E+01 1.35E+01 1.25E+02 9.29E+02 7.0 9.84E+01 6.27E+01 2.01E+01 9.22E+00 9.21E+01 7.67E+02 10.0 5.72E+01 3.56E+01 1.24E+01 4.52E+00 5.25E+01 5.00E+02 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 161434.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: General Emergency * *
  • Particulate 6.56E-02 (0.0%)

Iodine 1.61E+00 (0.5%)

Reviewed By: Noble Gas 3.52E+02 (99.5%)

Page 37 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9825 (SPING 6) Radwaste Area Exhaust - Alert Dose Assessment ANO Unit 2 Wednesday, October 07, 2015 16:18 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <RWA Filters> < Env> PRF: 1.20E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: RWA Gas Conc Readings: 2.35E-01 µCI/cc Flowrate: 50000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.24E+01 8.31E+00 9.39E-01 7.70E-01 1.00E+01 3.15E+01 0.7 1.16E+01 7.68E+00 9.00E-01 7.78E-01 9.36E+00 2.87E+01 1.0 8.36E+00 5.40E+00 7.60E-01 7.38E-01 6.90E+00 2.06E+01 1.5 5.52E+00 3.52E+00 5.92E-01 5.66E-01 4.67E+00 1.49E+01 2.0 3.74E+00 2.38E+00 4.56E-01 3.91E-01 3.22E+00 1.18E+01 3.0 3.33E+00 2.20E+00 3.23E-01 2.78E-01 2.80E+00 8.30E+00 4.0 2.54E+00 1.64E+00 2.60E-01 2.10E-01 2.11E+00 6.61E+00 5.0 2.12E+00 1.35E+00 2.26E-01 1.68E-01 1.74E+00 5.85E+00 7.0 1.54E+00 9.82E-01 1.75E-01 1.09E-01 1.27E+00 4.83E+00 10.0 8.92E-01 5.56E-01 1.03E-01 0.00E+00 6.59E-01 3.15E+00 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 161818.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Validate against Emergency Action Levels * *
  • Particulate 4.13E-04 (0.0%)

Iodine 1.01E-02 (0.2%)

Reviewed By: Noble Gas 5.55E+00 (99.8%)

Page 38 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9825 (SPING 6) Radwaste Area Exhaust - Site Area Emergency Dose Assessment ANO Unit 2 Wednesday, October 07, 2015 16:17 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <RWA Filters> < Env> PRF: 1.20E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: RWA Gas Conc Readings: 2.35E+00 µCI/cc Flowrate: 50000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.24E+02 8.31E+01 9.39E+00 7.70E+00 1.00E+02 3.15E+02 0.7 1.16E+02 7.68E+01 9.00E+00 7.78E+00 9.36E+01 2.87E+02 1.0 8.36E+01 5.40E+01 7.60E+00 7.38E+00 6.90E+01 2.06E+02 1.5 5.52E+01 3.52E+01 5.92E+00 5.66E+00 4.67E+01 1.49E+02 2.0 3.74E+01 2.38E+01 4.56E+00 3.91E+00 3.22E+01 1.18E+02 3.0 3.33E+01 2.20E+01 3.23E+00 2.78E+00 2.80E+01 8.30E+01 4.0 2.54E+01 1.64E+01 2.60E+00 2.10E+00 2.11E+01 6.61E+01 5.0 2.12E+01 1.35E+01 2.26E+00 1.68E+00 1.74E+01 5.85E+01 7.0 1.54E+01 9.82E+00 1.75E+00 1.09E+00 1.27E+01 4.83E+01 10.0 8.92E+00 5.56E+00 1.03E+00 4.90E-01 7.08E+00 3.15E+01 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 161756.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Site Area Emergency * *
  • Particulate 4.13E-03 (0.0%)

Iodine 1.01E-01 (0.2%)

Reviewed By: Noble Gas 5.55E+01 (99.8%)

Page 39 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9825 (SPING 6) Radwaste Area Exhaust - General Emergency Dose Assessment ANO Unit 2 Wednesday, October 07, 2015 16:17 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <RWA Filters> < Env> PRF: 1.20E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: RWA Gas Conc Readings: 2.35E+01 µCI/cc Flowrate: 50000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.24E+03 8.31E+02 9.39E+01 7.70E+01 1.00E+03 3.15E+03 0.7 1.16E+03 7.68E+02 9.00E+01 7.78E+01 9.36E+02 2.87E+03 1.0 8.36E+02 5.40E+02 7.60E+01 7.38E+01 6.90E+02 2.06E+03 1.5 5.52E+02 3.52E+02 5.92E+01 5.66E+01 4.67E+02 1.49E+03 2.0 3.74E+02 2.38E+02 4.56E+01 3.91E+01 3.22E+02 1.18E+03 3.0 3.33E+02 2.20E+02 3.23E+01 2.78E+01 2.80E+02 8.30E+02 4.0 2.54E+02 1.64E+02 2.60E+01 2.10E+01 2.11E+02 6.61E+02 5.0 2.12E+02 1.35E+02 2.26E+01 1.68E+01 1.74E+02 5.85E+02 7.0 1.54E+02 9.82E+01 1.75E+01 1.09E+01 1.27E+02 4.83E+02 10.0 8.92E+01 5.56E+01 1.03E+01 4.90E+00 7.08E+01 3.15E+02 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 161733.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: General Emergency * *
  • Particulate 4.13E-02 (0.0%)

Iodine 1.01E+00 (0.2%)

Reviewed By: Noble Gas 5.55E+02 (99.8%)

Page 40 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9830 (SPING 7) Spent Fuel Area Exhaust - Alert Dose Assessment ANO Unit 2 Wednesday, October 07, 2015 16:28 Method: Detailed Assessment - Monitored Release Release Pathway: <SF> <Under Water> <Fuel Bldg> <FHA Filters> < Env> PRF: 4.00E-04 Containment HUT: = N/A Containment Sprays: = N/A Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Spent Fuel Accident - Under Water Damage: 0.560% On Site 57 m Time After S/D (hh:mm): 80:02 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: FH Gas Conc Readings: 6.86E+00 µCI/cc Flowrate: 36000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.42E+01 9.98E+00 0.00E+00 0.00E+00 9.98E+00 3.89E+00 0.7 1.31E+01 9.20E+00 0.00E+00 0.00E+00 9.20E+00 3.54E+00 1.0 9.60E+00 6.72E+00 0.00E+00 0.00E+00 6.72E+00 2.54E+00 1.5 6.80E+00 4.76E+00 0.00E+00 0.00E+00 4.76E+00 1.84E+00 2.0 5.36E+00 3.75E+00 0.00E+00 0.00E+00 3.75E+00 1.46E+00 3.0 3.69E+00 2.56E+00 0.00E+00 0.00E+00 2.56E+00 1.03E+00 4.0 3.11E+00 2.10E+00 0.00E+00 0.00E+00 2.10E+00 8.19E-01 5.0 2.87E+00 1.92E+00 0.00E+00 0.00E+00 1.92E+00 7.27E-01 7.0 2.54E+00 1.69E+00 0.00E+00 0.00E+00 1.69E+00 6.03E-01 10.0 1.88E+00 1.20E+00 0.00E+00 0.00E+00 1.20E+00 3.95E-01 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 162831.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Validate against Emergency Action Levels * *
  • Particulate 9.68E-05 (0.0%)

Iodine 2.30E-04 (0.0%)

Reviewed By: Noble Gas 1.17E+02 (100.0%)

Page 41 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9830 (SPING 7) Spent Fuel Area Exhaust - Site Area Emergency Dose Assessment ANO Unit 2 Wednesday, October 07, 2015 16:28 Method: Detailed Assessment - Monitored Release Release Pathway: <SF> <Under Water> <Fuel Bldg> <FHA Filters> < Env> PRF: 4.00E-04 Containment HUT: = N/A Containment Sprays: = N/A Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Spent Fuel Accident - Under Water Damage: 0.560% On Site 57 m Time After S/D (hh:mm): 80:02 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: FH Gas Conc Readings: 6.86E+01 µCI/cc Flowrate: 36000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.42E+02 9.98E+01 8.73E-01 2.18E-01 1.01E+02 3.89E+01 0.7 1.31E+02 9.20E+01 7.96E-01 1.98E-01 9.30E+01 3.54E+01 1.0 9.60E+01 6.72E+01 5.68E-01 1.42E-01 6.79E+01 2.54E+01 1.5 6.80E+01 4.76E+01 4.12E-01 1.03E-01 4.81E+01 1.84E+01 2.0 5.36E+01 3.75E+01 3.27E-01 0.00E+00 3.78E+01 1.46E+01 3.0 3.69E+01 2.56E+01 2.29E-01 0.00E+00 2.58E+01 1.03E+01 4.0 3.11E+01 2.10E+01 1.83E-01 0.00E+00 2.12E+01 8.19E+00 5.0 2.87E+01 1.92E+01 1.62E-01 0.00E+00 1.94E+01 7.26E+00 7.0 2.54E+01 1.69E+01 1.34E-01 0.00E+00 1.70E+01 6.03E+00 10.0 1.88E+01 1.20E+01 0.00E+00 0.00E+00 1.20E+01 3.95E+00 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 162808.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Site Area Emergency * *
  • Particulate 9.68E-04 (0.0%)

Iodine 2.30E-03 (0.0%)

Reviewed By: Noble Gas 1.17E+03 (100.0%)

Page 42 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9830 (SPING 7) Spent Fuel Area Exhaust - General Emergency Dose Assessment ANO Unit 2 Wednesday, October 07, 2015 16:27 Method: Detailed Assessment - Monitored Release Release Pathway: <SF> <Under Water> <Fuel Bldg> <FHA Filters> < Env> PRF: 4.00E-04 Containment HUT: = N/A Containment Sprays: = N/A Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Spent Fuel Accident - Under Water Damage: 0.560% On Site 57 m Time After S/D (hh:mm): 80:02 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: FH Gas Conc Readings: 6.86E+02 µCI/cc Flowrate: 36000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.42E+03 9.98E+02 8.73E+00 2.18E+00 1.01E+03 3.89E+02 0.7 1.31E+03 9.20E+02 7.96E+00 1.98E+00 9.30E+02 3.54E+02 1.0 9.60E+02 6.72E+02 5.68E+00 1.42E+00 6.79E+02 2.54E+02 1.5 6.80E+02 4.76E+02 4.12E+00 1.03E+00 4.81E+02 1.84E+02 2.0 5.36E+02 3.75E+02 3.27E+00 8.14E-01 3.79E+02 1.46E+02 3.0 3.69E+02 2.56E+02 2.29E+00 5.05E-01 2.58E+02 1.03E+02 4.0 3.11E+02 2.10E+02 1.83E+00 3.93E-01 2.13E+02 8.19E+01 5.0 2.87E+02 1.92E+02 1.62E+00 3.43E-01 1.94E+02 7.26E+01 7.0 2.54E+02 1.69E+02 1.34E+00 2.78E-01 1.70E+02 6.03E+01 10.0 1.88E+02 1.20E+02 8.76E-01 1.75E-01 1.21E+02 3.95E+01 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 162750.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: General Emergency * *
  • Particulate 9.68E-03 (0.0%)

Iodine 2.30E-02 (0.0%)

Reviewed By: Noble Gas 1.17E+04 (100.0%)

Page 43 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9835 (SPING 8) Penetration Room Exhaust - Alert Dose Assessment ANO Unit 2 Wednesday, October 07, 2015 16:31 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <EPPR Filters> < Env> PRF: 1.20E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: EPPR Gas Conc Readings: 5.88E+00 µCI/cc Flowrate: 2000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.25E+01 8.32E+00 9.40E-01 7.74E-01 1.01E+01 3.16E+01 0.7 1.16E+01 7.68E+00 9.00E-01 7.83E-01 9.36E+00 2.88E+01 1.0 8.40E+00 5.44E+00 7.60E-01 7.41E-01 6.94E+00 2.06E+01 1.5 5.56E+00 3.53E+00 5.92E-01 5.69E-01 4.69E+00 1.49E+01 2.0 3.74E+00 2.38E+00 4.56E-01 3.93E-01 3.23E+00 1.18E+01 3.0 3.34E+00 2.21E+00 3.24E-01 2.80E-01 2.81E+00 8.31E+00 4.0 2.55E+00 1.64E+00 2.61E-01 2.11E-01 2.11E+00 6.62E+00 5.0 2.12E+00 1.35E+00 2.27E-01 1.69E-01 1.75E+00 5.86E+00 7.0 1.54E+00 9.84E-01 1.75E-01 1.09E-01 1.27E+00 4.84E+00 10.0 8.92E-01 5.57E-01 1.03E-01 0.00E+00 6.60E-01 3.15E+00 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 163140.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Validate against Emergency Action Levels * *
  • Particulate 4.13E-04 (0.0%)

Iodine 1.01E-02 (0.2%)

Reviewed By: Noble Gas 5.55E+00 (99.8%)

Page 44 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9835 (SPING 8) Penetration Room Exhaust - Site Area Emergency Dose Assessment ANO Unit 2 Wednesday, October 07, 2015 16:31 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <EPPR Filters> < Env> PRF: 1.20E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: EPPR Gas Conc Readings: 5.88E+01 µCI/cc Flowrate: 2000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.25E+02 8.32E+01 9.40E+00 7.74E+00 1.01E+02 3.16E+02 0.7 1.16E+02 7.68E+01 9.00E+00 7.83E+00 9.36E+01 2.88E+02 1.0 8.40E+01 5.44E+01 7.60E+00 7.41E+00 6.94E+01 2.06E+02 1.5 5.56E+01 3.53E+01 5.92E+00 5.69E+00 4.69E+01 1.49E+02 2.0 3.74E+01 2.38E+01 4.56E+00 3.93E+00 3.23E+01 1.18E+02 3.0 3.34E+01 2.21E+01 3.24E+00 2.80E+00 2.81E+01 8.31E+01 4.0 2.55E+01 1.64E+01 2.61E+00 2.11E+00 2.11E+01 6.62E+01 5.0 2.12E+01 1.35E+01 2.27E+00 1.69E+00 1.75E+01 5.86E+01 7.0 1.54E+01 9.84E+00 1.75E+00 1.09E+00 1.27E+01 4.84E+01 10.0 8.92E+00 5.57E+00 1.03E+00 4.92E-01 7.09E+00 3.15E+01 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 163125.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: Site Area Emergency * *
  • Particulate 4.13E-03 (0.0%)

Iodine 1.01E-01 (0.2%)

Reviewed By: Noble Gas 5.55E+01 (99.8%)

Page 45 of 46

Radiological Effluent EAL Values EP-CALC-ANO-1701, Rev. 0 U2 2RX-9835 (SPING 8) Penetration Room Exhaust - General Emergency Dose Assessment ANO Unit 2 Wednesday, October 07, 2015 16:31 Method: Detailed Assessment - Monitored Release Release Pathway: <RCS> <Containment> <Aux Bldg> <EPPR Filters> < Env> PRF: 1.20E-03 Containment HUT: = < 2 Hours Containment Sprays: = ON Purge Filters: = N/A Steam Gen: = N/A Aux / FHB HUT: = < 2 Hours Filters: = Working Turb Bldg HUT: = N/A Source Term: Reactor Core Accident - Clad On Site 57 m Time After S/D (hh:mm): 0:00 Wind: From 270° @ 5.8 mph Release Duration (hh:mm): 1.:00 ETE (hh:mm): [N/A] Stability Class: E Precipitation: None Monitor: EPPR Gas Conc Readings: 5.88E+02 µCI/cc Flowrate: 2000 CFM Deposition CDE Evacuation Areas From 0 to 10 Miles Distance Exposure External Plume Inhalation CEDE TEDE Ground DDE Thyroid (Miles) Rate (mR/hr) DDE (mRem) (mRem) (mRem)

(mRem) (mRem S.B. 1.25E+03 8.32E+02 9.40E+01 7.74E+01 1.00E+03 3.16E+03 0.7 1.16E+02 7.68E+02 9.00E+01 7.83E+01 9.36E+02 2.88E+03 1.0 8.40E+02 5.44E+02 7.60E+01 7.41E+01 6.94E+02 2.06E+03 1.5 5.56E+02 3.53E+02 5.92E+01 5.69E+01 4.69E+02 1.49E+03 2.0 3.74E+02 2.38E+02 4.56E+01 3.93E+01 3.23E+02 1.18E+03 3.0 3.34E+02 2.21E+02 3.24E+01 2.80E+01 2.81E+02 8.31E+02 4.0 2.55E+02 1.64E+02 2.61E+01 2.11E+01 2.11E+02 6.62E+02 5.0 2.12E+02 1.35E+02 2.27E+01 1.69E+01 1.75E+02 5.86E+02 7.0 1.54E+02 9.84E+01 1.75E+01 1.09E+01 1.27E+02 4.84E+02 10.0 8.92E+01 5.57E+01 1.03E+01 4.92E+00 7.09E+01 3.15E+02 Assessment Data Results Save to File:

ANO Unit 1 10Miles Monitored Release 10072015 163106.UR17 No PAGs Exceeded Release Rates (Ci/sec)

  • *
  • Classification: General Emergency * *
  • Particulate 4.13E-02 (0.0%)

Iodine 1.01E+00 (0.2%)

Reviewed By: Noble Gas 5.55E+02 (99.8%)

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Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 Table of Contents Section Page

1. PURPOSE ............................................................................................................................2
2. DEVELOPMENT METHODOLOGY AND BASES................................................................2 2.1 Fuel Clad Loss .............................................................................................................2 2.2 Reactor Coolant System Loss .....................................................................................4 2.3 Containment Potential Loss .........................................................................................4 2.4 Source Term ................................................................................................................6 2.5 Decay Considerations ..................................................................................................6
3. DESIGN INPUTS ..................................................................................................................6 3.1 Constants and Conversion Factors .............................................................................6 3.2 Plant Inputs ..................................................................................................................6 3.3 Source Term ................................................................................................................7
4. CALCULATIONS ..................................................................................................................8 4.1 Fuel Clad Damage Estimate Based on 300 µCi/gm DEI-131 ......................................8 4.2 Fission Product Barrier Thresholds .............................................................................9
5. CONCLUSIONS .................................................................................................................10
6. REFERENCES ...................................................................................................................11 ATTACHMENTS Attachment 1, 300 µCi/gm DEI-131 Equivalent Fuel Clad Damage ......................................12 Attachment 2, Fission Product Barrier Threshold Values ......................................................14 Attachment 3, NUREG-1940 Figure 1-1 PWR Containment Monitor Response ...................15 Page 1 of 15

Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0

1. PURPOSE The Arkansas Nuclear One (ANO) Emergency Action Level (EAL) Technical Bases Manual contains background information, event declaration thresholds, bases and references for the EAL and Fission Product Barrier (FPB) values used to implement the Nuclear Energy Institute (NEI) 99-01 Revision 6 EAL guidance. This calculation document provides additional technical detail specific to the derivation of the FPB containment high range radiation monitor (CHRRM) readings developed in accordance with the guidance in NEI 99-01 Revision 6.

Documentation of the assumptions, calculations and results are provided for the values associated the NEI 99-01 Revision 6 Table 9-F-3, PWR EAL Fission Product Barrier Table, thresholds listed below.

NEI Fuel Clad Loss 3.A NEI Reactor Coolant Loss 3.A NEI Containment Potential Loss 3.A

2. DEVELOPMENT METHODOLOGY AND BASES 2.1 Fuel Clad Loss Guidance Criteria Per NEI 99-01 Revision 6, this radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals 300 µCi/gm dose equivalent I-131 (DEI-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 loss threshold since it indicates a loss of both the fuel clad barrier and the RCS barrier.

The reading should be determined assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory, with RCS radioactivity concentration equal to 300 µCi/gm dose equivalent I-131, into the primary containment atmosphere.

ANO Bases The fuel clad FPB threshold value is based on an instantaneous release of reactor coolant into the containment at a percent fuel clad damage equivalent to 300 µCi/gm DEI-131 RCS activity. That percent fuel clad damage value is ratioed to a containment radiation reading for 100% fuel clad damage to determine the fuel clad FPB threshold value in R/hr.

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Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 2.2 Reactor Coolant System Loss Guidance Criteria Per NEI 99-01 Revision 6, this radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for fuel clad barrier loss threshold since it indicates a loss of the RCS barrier only.

The reading should be determined assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory, with RCS activity at Technical Specification allowable limits, into the primary containment atmosphere. RCS activity at this level will typically result in primary containment radiation levels that can be more readily detected by primary containment radiation monitors, and more readily differentiated from those caused by piping or component shine sources. If desired, a plant may use a lesser value of RCS activity for determining this value.

In some cases, the site-specific physical location and sensitivity of the containment radiation monitor(s) may be such that radiation from a cloud of released RCS gases cannot be distinguished from radiation emanating from piping and components containing elevated reactor coolant activity. If so, determine if an alternate indication is available.

ANO Bases The ANO technical specification high value for DEI-131 is 60 µCi/gm. This activity would yield a containment radiation monitor reading approximately 5x lower than the fuel clad loss fission product barrier containment radiation reading equivalent to 300 µCi/gm.

NUREG-1940 Figure 1-1 provides estimates for standard plant containment radiation based on spiked RCS activity, which is slightly less than half the value obtained by the 300 µCi/gm to 60 Ci/gm DEI-131 ratio.

NUREG-1940 Figure 1-1 models a spiked RCS activity that is lower than the RCS activity equivalent to 60 µCi/gm DEI-131 described above (the NUREG-1940 graph is based on a release into containment of 100 times the non-noble gas fission products normally found in the coolant). This is the preferred value for the RCS loss threshold as it provides for a containment monitor escalation of approximately one decade between fission product barrier thresholds at the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> point. NEI 99-01 guidance criteria allows the use of a lesser value for RCS activity (see guidance criteria section above).

The ANO RCS FPB threshold value is based on NUREG-1940 standard plant containment radiation readings for an instantaneous release of spiked reactor coolant, which is lower than 60 µCi/gm DEI-131 Technical Specification allowable limits, and is adjusted for the site specific power rating.

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Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 2.3 Containment Potential Loss Guidance Criteria Per NEI 99-01 Revision 6, this radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that 20% of the fuel cladding has failed. This level of fuel clad failure is well above that used to determine the analogous fuel clad and RCS barrier loss thresholds.

NUREG-1228 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 and the fuel clad barriers. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the classification level to a General Emergency.

NUREG-1228 provides the basis for using the 20% fuel cladding failure value. Unless there is a site-specific analysis justifying a different value, the reading should be determined assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with 20% fuel clad failure into the primary containment atmosphere.

ANO Bases The Containment FPB threshold value is based on an instantaneous release of all reactor coolant into the containment at an equivalent of 20% clad damage.

The ANO FPB containment radiation reading value equivalent to 20% fuel clad damage is obtained by ratio of the 100% fuel clad damage containment radiation reading value to 20% fuel clad damage.

2.4 Source Term Guidance Criteria NEI 99-01 does not specify a basis for the source term activity or the reduction factors.

RG 1.183 provides assumptions for a LOCA used as a reference for FSAR design basis event analysis. Per RG 1.183 Section 1.1.4, Emergency Preparedness Applications:

Requirements for emergency preparedness at nuclear power plants are set forth in 10 CFR 50.47, Emergency Plans. Additional requirements are set forth in Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR Part 50. The planning basis for many of these requirements was published in NUREG-0396, Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants. This joint effort by the Environmental Protection Agency (EPA) and the NRC considered the principal characteristics (such as nuclides released and distances) likely to be involved for a spectrum of design basis and severe (core melt) accidents. No single accident scenario is the basis of the required preparedness. The Page 4 of 15

Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 objective of the planning is to provide public protection that would encompass a wide spectrum of possible events with a sufficient basis for extension of response efforts for unanticipated events. These requirements were issued after a long period of involvement by numerous stakeholders, including the Federal Emergency Management Agency, other Federal agencies, local and State governments (and in some cases, foreign governments), private citizens, utilities, and industry groups.

Although the AST provided in this guide was based on a limited spectrum of severe accidents, the particular characteristics have been tailored specifically for DBA analysis use. The AST is not representative of the wide spectrum of possible events that make up the planning basis of emergency preparedness. Therefore, the AST is insufficient by itself as a basis for requesting relief from the emergency preparedness requirements of 10 CFR 50.47 and Appendix E to 10 CFR Part 50.

Thus, RG 1.183 is not used as a basis for the containment radiation monitor thresholds.

Guidance contained in NUREG-1940 is considered representative of the wide spectrum of possible events that make up the emergency preparedness planning basis and provides radiological consequence assessment methods which are acceptable to the NRC.

Additionally, the source term used to develop the effluent EAL thresholds and in the Unified RASCAL Interface/Radiological Assessment System for Consequence Analysis (URI/RASCAL) dose assessment model is from NUREG-1940. Thus, NUREG-1940 has been selected as a source term basis for the fission product barrier containment radiation thresholds for conformance to NRC guidance and consistency with other source term bases used within the Entergy emergency preparedness program.

ANO Bases 2.4.1 The NUREG-1940 source term inputs used for the fission product barrier containment radiation thresholds are as follows:

Fuel Clad Damage Equivalent to 300 µCi/g DEI-131 - NUREG-1940 Table 1-1 equilibrium core activity, in conjunction with the NUREG-1940 Table 1-5 non-noble gas release fraction, is used to develop the site specific iodine source term.

Fuel Clad and Containment Barrier Thresholds - NUREG-1940 Figure 1-1 for cladding failure is used as a basis to establish these thresholds.

RCS Barrier Threshold - NUREG-1940 Figure 1-1 for spiked coolant is used as a basis to establish this threshold.

Note - Source term reduction from containment spray is not included as an assumption for these thresholds.

2.4.2 NUREG-1940 source term is based on a generic plant with a power rating of 3000 MWt.

The ANO site specific source term is derived from the licensed core thermal power output of 2,568 megawatts for Unit 1 and 3,026 megawatts for Unit 2 (SAR Section 1.1).

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Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 2.4.3 Dose equivalent iodine 131 (DEI-131) dose conversion factors (DCFs) are developed from EPA-400-R-92-001 isotopic DCFs. EPA-400 is the basis for the protective action guidelines and is the appropriate source for DCFs used in emergency preparedness.

The DEI-131 dose conversion factors are not based on the FSAR Chapter 15 or other 10 CFR 20 reference sources as those are not reflective of the exposure assumptions used within the EPA guidance for emergency preparedness use.

2.5 Decay Considerations Guidance Criteria Fission product barrier thresholds and their associated EALs are applicable only when the plant is in Hot Shutdown, Startup, or Power Operation modes (known as the hot operating modes).

The events for these thresholds correspond to an instantaneous release of all reactor coolant mass into the primary containment.

ANO Bases Consistent with the NUREG-1940 graphs, the instantaneous release of the RCS to the containment is assumed to occur one hour after the damage event / reactor scram to account for damage progression, dispersion of activity and decay of the very short half-life isotopes.

3. DESIGN INPUTS 3.1 Constants and Conversion Factors None 3.2 Plant Inputs 3.2.1 Rated Power
1) Standard Plant (NUREG-1940 Section 1.2.4) ...........................................3,000 MWt
2) Unit 1 (SAR Section 1.1) ...........................................................................2,568 MWt
3) Unit 2 (SAR Section 1.1) ...........................................................................3,026 MWt 3.2.2 RCS Water Mass at STP (1302.022 Attachment 3 Section 2.3)
1) Unit 1 ...................................................................................................... 2.41E+8 gm
2) Unit 2 ...................................................................................................... 2.14E+8 gm 3.2.3 Standard Plant Containment Radiation Reading (NUREG-1940 Figure 1-1)
1) 100% fuel clad damage (spray off) ................... 60,000 R/hr (@ 1 hr after shutdown)
2) 100% spiked coolant (spray off) .............................. 50 R/hr (@ 1 hr after shutdown)

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Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 3.2.4 Monitor Range

1) RE-8060/8061 (TM GO63.0010/TD G063 0020) ............... 1.00E+0 to 1.00E+8 R/hr
2) 2RE-8925-1/2RE-8925-2 (TM GO63.0010/TD G063 0020) 1.00E+0 to 1.00E+8 R/hr 3.3 Source Term 3.3.1 Source Term Activity (NUREG-1940 Table 1-1)

Core Activity (Ci/MWt) 1-131 2.67E+04 1-132 3.88E+04 1-133 5.42E+04 1-134 5.98E+04 1-135 5.18E+04 3.3.2 Monitor Range

1) Non-Noble Gasses (I, Cs, Rb) - Fuel Clad Damage .................................. 0.05 (5%)

3.3.3 Release Fractions - RFCore (NUREG-1940 Table 1-5)

Rem/hr per µCi/cc 1-131 1.3E+06 1-132 7.7E+03 1-133 2.2E+05 1-134 1.3E+03 1-135 3.8E+04 Page 7 of 15

Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0

4. CALCULATIONS 4.1 Fuel Clad Damage Estimate Based on 300 µCi/gm DEI-131 4.1.1 Equivalent Iodine Core Activity 100% Core Activityi(Ci) = Core Activityi(Ci/MWt) x Unit MWt Core Activity (Ci)

Unit 1 Unit 2 1-131 6.86E+07 8.08E+07 1-132 9.96E+07 1.17E+08 1-133 1.39E+08 1.64E+08 1-134 1.54E+08 1.81E+08 1-135 1.33E+08 1.57E+08 Total 5.94E+08 7.00E+08 4.1.2 100% Core Activity Equivalent Reactor Coolant Iodine Concentrations 100% Core RCS Activityi(Ci) x 106 100% Core RCS Activityi(µCi/gm) =

RCS Mass (gm)

RCS Activity (Ci/gm)

Unit 1 Unit 2 1-131 2.85E+05 3.78E+05 1-132 4.13E+05 5.49E+05 1-133 5.78E+05 7.66E+05 1-134 6.37E+05 8.46E+05 1-135 5.52E+05 7.32E+05 Total 2.46E+06 3.27E+06 4.1.3 100% Core Activity Equivalent Reactor Coolant Iodine Concentrations 100% Clad Damage RCS Activityi(µCi/gm) = 100% Core RCS Activityi(µCi/gm) x RFCore RCS Activity (Ci/gm)

Unit 1 Unit 2 1-131 1.42E+04 1.89E+04 1-132 2.07E+04 2.74E+04 1-133 2.89E+04 3.83E+04 1-134 3.19E+04 4.23E+04 1-135 2.76E+04 3.66E+04 Total 1.23E+05 1.64E+05 Page 8 of 15

Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 4.1.4 100% Fuel Clad Damage Activity Equivalent Reactor Coolant DEI-131 Concentrations 100% DEI RCS Activityi(µCi/gm) =

=

100% Clad Damage RCS Activityi(µCi/gm) x DEI DCFi Note - The DEI DCF value for each iodine isotope is determined as follows:

EPA - 400 Table 5 - 2 Iodine DCFi(Rem/hr per µCi/cc)

DEI DCFi =

EPA - 400 Table 5 - 2 Iodine DCFI-131(Rem/hr per µCi/cc)

DEI DCF RCS Activity (Ci/gm)

(unit less) Unit 1 Unit 2 1-131 1.00E+00 1.42E+04 1.89E+04 1-132 5.92E-03 1.22E+02 1.62E+02 1-133 1.69E-01 4.89E+03 6.48E+03 1-134 1.00E-03 3.19E+01 4.23E+01 1-135 2.92E-02 8.07E+02 1.07E+03 Total 2.01E+04 2.66E+04 4.1.5  % Fuel Clad Damage Activity Equivalent Reactor Coolant at 300 µCi/gm DEI-131 300 µCi/gm

% Clad Damage =

100% DEI RCS Activity(µCi/gm)

U1 300 Ci/gm DEI-131..................................................... 1.49% Fuel Clad Damage U2 300 Ci/gm DEI-131..................................................... 1.13% Fuel Clad Damage See Attachment 1 for the spreadsheet calculations that develop the fuel clad source term activity and the % clad damage.

4.2 Fission Product Barrier Thresholds See Attachment 2 for the spreadsheet calculations that develop the FPB threshold monitor readings.

4.2.1 Containment Potential Loss (20% Fuel Clad Damage Monitor Reading)

MWtUnit Unit20% clad(R/hr) = Std Plant100% clad(R/hr) x 20% x MWtStd Plant U1 Containment Potential Loss Threshold Monitor Reading ........... 1.03E+4 R/hr U2 Containment Potential Loss Threshold Monitor Reading ........... 1.21E+4 R/hr Page 9 of 15

Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 4.2.2 Fuel Clad Loss (300 µCi/gm DEI-131 Equivalent Clad Damage Monitor Reading)

MWtU1 Unit1.49% clad(R/hr) = Std Plant100% clad(R/hr) x 1.49% x MWtStd Plant MWtU2 Unit1.13% clad(R/hr) = Std Plant100% clad(R/hr) x 1.13% x MWtStd Plant U1 Fuel Clad Loss Threshold Monitor Reading ................................. 7.68E+2 R/hr U2 Fuel Clad Loss Threshold Monitor Reading ................................. 6.82E+2 R/hr 4.2.3 RCS Loss (Spiked Coolant Monitor Reading)

MWtUnit UnitSpiked(R/hr) = Std Plant100% Spiked(R/hr) x MWtStd Plant U1 RCS Loss Threshold Monitor Reading ......................................... 4.28E+1 R/hr U2 RCS Loss Threshold Monitor Reading ......................................... 5.04E+1 R/hr

5. CONCLUSIONS 5.1 300 µCi/gm DEI-131 is equivalent to:
1) Unit 1 .............................................................................. 1.49% fuel clad (gap) damage
2) Unit 2 .............................................................................. 1.13% fuel clad (gap) damage 5.2 Calculated containment high range radiation monitor values are as follows:

Fuel Clad RCS Containment Loss Loss Potential Loss Unit 1 7.68E+2 R/hr 4.28E+1 R/hr 1.03E+4 R/hr Unit 2 6.82E+2 R/hr 5.04E+1 R/hr 1.21E+4 R/hr Based on monitor accuracy/readability and human factors, the EAL Fission Product Barrier thresholds are established as follows:

Fuel Clad RCS Containment Loss Loss Potential Loss Unit 1 750 R/hr 40 R/hr 10,000 R/hr Unit 2 700 R/hr 50 R/hr 12,000 R/hr Page 10 of 15

Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0

6. REFERENCES 6.1 NEI 99-01 R6, Development of Emergency Action Levels for Non-Passive Reactors, September 2012 6.2 EPA-400-R-92-001, Manual of Protective action Guides and Protective Actions for Nuclear Incidents, May 1992 6.3 NUREG-1940, RASCAL 4: Description of Models and Methods, December 2012 6.4 NUREG-1228, Source Term Estimation During Incident Response to Severe Nuclear Power Plant Accidents, October 1988 6.5 Regulatory Guide 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, July 2000 6.6 ANO1 Safety Analysis Report (SAR)
1) Section 1.1, Introduction, Amendment 20 6.7 ANO2 Safety Analysis Report (SAR)
1) Section 1.1, Introduction, Amendment 17 6.8 ANO1 Technical Specifications
1) Section 3.4.12, RCS Specific Activity, Amendment 243 6.9 ANO2 Technical Specifications
1) Section 3.4.8, RCS Specific Activity, Amendment 293 6.10 1302.022, Core Damage Assessment, Change 5 6.11 TM GO63.00, General Atomic Tech Manual, Revision 2 6.12 TD G063 0020, General Atomic Tech Manual, Revision 2 Page 11 of 15

Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 ATTACHMENT 1 300 µCi/gm DEI-131 Equivalent Clad Damage Unit 1 NUREG-1940 Table 1-1 U1 RCS Activity U1 Core Activity (Ci)

EPA-400 Table 5-2 U1 RCS Activity U1 RCS Activity Dose Conversion DEI DCF Factors (Rem/hr per

(µCi/gm 100% Core) (µCi/gm 100% Clad)

Core Activity (Ci/MWt) µCi/cc) (µCi/gm 100% Gap DEI)

I-131 2.67E+04 6.86E+07 2.85E+05 1.42E+04 1.30E+06 1.00E+00 1.42E+04 I-132 3.88E+04 9.96E+07 4.13E+05 2.07E+04 7.70E+03 5.92E-03 1.22E+02 I-133 5.42E+04 1.39E+08 5.78E+05 2.89E+04 2.20E+05 1.69E-01 4.89E+03 I-134 5.98E+04 1.54E+08 6.37E+05 3.19E+04 1.30E+03 1.00E-03 3.19E+01 I-135 5.18E+04 1.33E+08 5.52E+05 2.76E+04 3.80E+04 2.92E-02 8.07E+02 Total 2.31E+04 5.94E+08 2.46E+06 1.23E+05 2.01E+04 U1 Rate Power (MWt): 2568 RCS Liquid Volume (gm): 2.41E+08 Halogen Release Fraction: 5.0%

Target DEI: 3.00E+02

%Clad Damage: 1.49%

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Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 Unit 2 NUREG-1940 Table 1-1 U2 RCS Activity U2 Core Activity (Ci)

EPA-400 Table 5-2 U2 RCS Activity U2 RCS Activity Dose Conversion DEI DCF Factors (Rem/hr per

(µCi/gm 100% Core) (µCi/gm 100% Clad)

Core Activity (Ci/MWt) µCi/cc) (µCi/gm 100% Gap DEI)

I-131 2.67E+04 8.08E+07 3.78E+05 1.89E+04 1.30E+06 1.00E+00 1.89E+04 I-132 3.88E+04 1.17E+08 5.49E+05 2.74E+04 7.70E+03 5.92E-03 1.62E+02 I-133 5.42E+04 1.64E+08 7.66E+05 3.83E+04 2.20E+05 1.69E-01 6.48E+03 I-134 5.98E+04 1.81E+08 8.46E+05 4.23E+04 1.30E+03 1.00E-03 4.23E+01 I-135 5.18E+04 1.57E+08 7.32E+05 3.66E+04 3.80E+04 2.92E-02 1.07E+03 Total 2.31E+05 7.00E+08 3.27E+06 1.64E+05 2.66E+04 U2 Rate Power (MWt): 3026 RCS Liquid Volume (gm): 2.14E+08 Halogen Release Fraction: 5.0%

Target DEI: 3.00E+02

%Clad Damage: 1.13%

Page 13 of 15

Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 ATTACHMENT 2 Fission Product Barrier Threshold Values Reading for 300 Rated Power (MWt)

Reading for 100% Reading for 20% Reading for Spiked

% Damage for 300 µCi/gm RCS µCi/gm RCS Activity Clad Failure (R/hr) Clad Failure (R/hr) Activity RCS Activity (R/hr)

(R/hr)

Unit 1 2568 5.14E+04 1.03E+04 1.49% 7.68E+02 4.28E+01 Unit 2 3026 6.05E+04 1.21E+04 1.13% 6.82E+02 5.04E+01 NUREG-1940 100% Clad Failure (R/hr): 6.00E+04 NUREG-1940 100% Spiked Coolant (R/hr): 5.00E+01 Standard Plant (MWt): 3000 Page 14 of 15

Containment High Range Radiation Monitor EAL Values EP-CALC-ANO-1702, Rev. 0 ATTACHMENT 3 NUREG-1940 Figure 1-1 PWR Containment Monitor Response Page 15 of 15

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