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{{#Wiki_filter:ATTACHMENT 10DISCUSSION OF REVISIONTO THERADIOLOGICAL EMERGENCY PLAN ANNEXFORQUAD CITIES NUCLEAR POWER STATIONEP-AA-1 006Enclosures00SEnclosure 10A -EAL Comparison Matrix DocumentEnclosure 10B -EAL Red-Line Basis DocumentEnclosure 10C -EAL Basis Document NEI
{{#Wiki_filter:ATTACHMENT 10DISCUSSION OF REVISIONTO THERADIOLOGICAL EMERGENCY PLAN ANNEXFORQUAD CITIES NUCLEAR POWER STATIONEP-AA-1 006Enclosures 00SEnclosure 10A -EAL Comparison Matrix DocumentEnclosure 10B -EAL Red-Line Basis DocumentEnclosure 10C -EAL Basis Document NEI 99-01REVISION 6DEVELOPMENT OF EMERGENCY ACTIONLEVELS FOR NON-PASSIVE REACTORSATTACHMENT 10DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FORQUAD CITIES NUCLEAR STATIONm Exelon Generation.
NEI 99-01 Rev 6 Proposed EAL Justification AG1Initiating Condition
-GENERAL EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mremTEDE or 5,000 mrem thyroid CDE.Operating Mode Applicability:
AllExample Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the General Emergency promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.
* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due toactions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.
* The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.
: 1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 1000 mR/hr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than5000 mrem for one hour of inhalation.
RG1Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 1,000mRem TEDE or 5,000 mRem thyroid CDE.Operating Mode Applicability:
1,2.3,4,5,D Emergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release pathto the environment is established.
If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.
* The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.
: 1. The sum of readings on the Rx Bldg and Chimney SPINGs > 3.84 E+09uCilsec for > 15 minutes (as determined by Control Room Panels or PPDS-Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond thesite boundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate
> 5000 mRem CDEThyroid for 60 minutes of inhalation.
1'1 No Change M Difference FIDeviation
: 1) Listed site-specific monitors and Threshold values to ensure timelyclassification.
: 2) Added the following to bullet #3" Classification based on effluent monitorreadings assumes that a release path to the environment is established."
In orderto delete the following from the basis "Classification based on effluent monitorreadings assumes that a release path to the environment is established.
If theeffluent flow past an effluent monitor is known to have stopped due to actions toisolate the release path, then the effluent monitor reading is no longer valid forclassification purposes."
This allows for more timely classification since all thebasis information pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 11x17 procedure matrix used by the SM.Page I of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification AS1Initiating Condition
-SITE AREA EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 100 mremTEDE or 500 mrem thyroid CDE.Operating Mode Applicability:
AllExample Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the Site Area Emergency promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.
* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due toactions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.
* The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.
: 1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 100 mR/hr expected tocontinue for 60 minutes or longer." Analysis of field survey samples indicate thyroid CDE greater than500 mrem for one hour of inhalation.
RS1Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 100 mRemTEDE or 500 mRem thyroid CDE.Operating Mode Applicability:
1,2,3,4,5,D Emergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
I If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release pathto the environment is established.
If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then
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* t* r~* ** *fl ~ ..U U~*~~*RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYA reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.Escalation of the emergency classification level would be via IC RAG1 or FG1.Basis Reference(s):1. NEI 99-01 Rev 6, SS5Month 20XXQC 3-57EP-AA-1006 (Revision XX)
* t* r~* ** *fl ~ ..U U~*~~*RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYA reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
ExAIon NuclearOusari ities Annex Exelon Nucla~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSA36Initiating Condition:Automatic or manual scram fails to shutdown the reactor, and subsequent manualactions taken at the reactor control consoles are not successful in shutting down thereactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.1. An-aAutomatic or manual scram did not shutdown the reactor as indicated byReactor Power > 5%.AND2. Manual / ARI actions taken at the reactr control cnc.s.clReactor Console are notsuccessful in shutting down the reactor as indicated by Reactor Power > 5%.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and subsequent operator manualactions taken at the reactor control consoles to shutdown the reactor are alsounsuccessful. This condition represents an actual or potential substantial degradationof the level of safety of the plant. An emergency declaration is required even if thereactor is subsequently shutdown by an action taken away from the reactor controlconsoles since this event entails a significant failure of the RPS.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 amanual reactor scram. This action does not include manually driving in control rods orimplementation of boron injection strategies. If this action(s) is unsuccessful, operatorswould immediately pursue additional manual actions at locations away from the reactorcontrol consoles (e.g., locally opening breakers). Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the reactor control consoles".Taking the Reactor Mode Switch to SHUTDOWN is considered to be a manual scramaction.The plant response to the failure of an automatic or manual reactor scram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If the failure to shutdown the reactor is prolongedMonth 20XXQC 3-58EP-AA-1006 (Revision XX)
RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.
Escalation of the emergency classification level would be via IC RAG1 or FG1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SS5Month 20XXQC 3-57EP-AA-1006 (Revision XX)
ExAIon NuclearOusari ities Annex Exelon Nucla~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSA36Initiating Condition:
Automatic or manual scram fails to shutdown the reactor, and subsequent manualactions taken at the reactor control consoles are not successful in shutting down thereactor.Operating Mode Applicability:
1,2Emergency Action Level (EAL):Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.
: 1. An-aAutomatic or manual scram did not shutdown the reactor as indicated byReactor Power > 5%.AND2. Manual / ARI actions taken at the reactr control cnc.s.clReactor Console are notsuccessful in shutting down the reactor as indicated by Reactor Power > 5%.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and subsequent operator manualactions taken at the reactor control consoles to shutdown the reactor are alsounsuccessful.
This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if thereactor is subsequently shutdown by an action taken away from the reactor controlconsoles since this event entails a significant failure of the RPS.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 amanual reactor scram. This action does not include manually driving in control rods orimplementation of boron injection strategies.
If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the reactorcontrol consoles (e.g., locally opening breakers).
Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the reactor control consoles".
Taking the Reactor Mode Switch to SHUTDOWN is considered to be a manual scramaction.The plant response to the failure of an automatic or manual reactor scram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged Month 20XXQC 3-58EP-AA-1006 (Revision XX)
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* U **RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYenough to cause a challenge to the RPV water level or RCS heat removal safetyfunctions, the emergency classification level will escalate to a Site Area Emergency viaIC MSS35. Depending upon plant responses and symptoms, escalation is also possiblevia IC FS1. Absent the plant conditions needed to meet either IC MSS35 or FS1, anAlert declaration is appropriate for this event.It is recognized that plant responses or symptoms may also require an Alert declarationin accordance with the Recognition Category F ICs; however, this IC and EAL areincluded to ensure a timely emergency declaration.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Basis Reference(s):1. NEI 99-01 Rev 6, SA5Month 20XXQC 3-59EP-AA-1006 (Revision XX)
* U **RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYenough to cause a challenge to the RPV water level or RCS heat removal safetyfunctions, the emergency classification level will escalate to a Site Area Emergency viaIC MSS35. Depending upon plant responses and symptoms, escalation is also possiblevia IC FS1. Absent the plant conditions needed to meet either IC MSS35 or FS1, anAlert 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 areincluded to ensure a timely emergency declaration.
O.,ad Cities Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSU31Initiating Condition:Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.1. a. Ap,-aAutomatic scram -did not shutdown the reactor as indicated by ReactorPower > 5%..ANDb. A-sSubsequent manual action taken at the reactor control consl ReactorConsole is successful in shutting down the reactor.OR2. a. A-mManual scram / ARI did not shutdown the reactor as indicated byReactor Power > 5%.ANDb. EITHER of the following:1. A-sSubsequent manual / ARI action taken at the reactor controlGeRseleeReactor Console is successful in shutting down the reactor.OR2. A-sSubsequent automatic scram / ARI -is successful in shutting downthe reactor.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and either a subsequent operatormanual action taken at the reactor control consoles or an automatic scram is successfulin shutting down the reactor. This event is a precursor to a more significant conditionand thus represents a potential degradation of the level of safety of the plant.EAL #1 BasisFollowing the failure on an automatic reactor scram, operators will promptly initiatemanual actions at the reactor control consoles to shutdown the reactor (e.g., initiate amanual reactor scram). If these manual actions are successful in shutting down thereactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.Month 20XXQC 3-60EP-AA-1006 (Revision XX)
A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
I=xelon NuclearQ~mzrl iCigti Annex Exellon NucleanrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYEAL #2 BasisIf an initial manual reactor trip is unsuccessful, operators will promptly take manualaction at another location(s) on the reactor control consoles to shutdown the reactor(e.g., initiate a manual reactor scram / ARI using a different switch). Depending uponseveral factors, the initial or subsequent effort to manually scram the reactor, or aconcurrent plant condition, may lead to the generation of an automatic reactor scramsignal. If a subsequent manual or automatic scram / ARI is successful in shutting downthe reactor, core heat generation will quickly fall to a level within the capabilities of theplant's 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 amanual reactor scram). This action does not include manually driving in control rods orimplementation of boron injection strategies. Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the reactor control consoles".Taking the Reactor Mode Switch to Shutdown is considered to be a manual scramaction.The plant response to the failure of an automatic or manual reactor tscram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If subsequent operator manual actions taken at thereactor control consoles are also unsuccessful in shutting down the reactor, then theemergency classification level will escalate to an Alert via IC MSA35. Depending uponthe plant response, escalation is also possible via IC FAI. Absent the plant conditionsneeded to meet either IC MSA35 or FA1, an Unusual Event declaration is appropriatefor this event.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Should a reactor scram signal be generated as a result of plant work (e.g., RPS setpointtesting), the following classification guidance should be applied." If the signal generated as a result of plant work causes a plant transient that createda real condition that should have included an automatic reactor scram and the RPSfails to automatically shutdown the reactor, then this IC and the EALs are applicable,and should be evaluated." If the signal generated as a result of plant work does not cause a plant transient butshould have generated an RPS scram signal and the scram failure is determinedthrough other means (e.g., assessment of test results), then this IC and the EALsare not applicable and no classification is warranted.Month 20XXQC 3-61EP-AA-1006 (Revision XX)
Basis Reference(s):
Exelon NuclearQuad Cities Annex Eeo ulaRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis Reference(s):1. NEI 99-01 Rev 6, SU5Month 20XXQC 3-62EP-AA-1006 (Revision XX)
: 1. NEI 99-01 Rev 6, SA5Month 20XXQC 3-59EP-AA-1006 (Revision XX)
QU2d Cities AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSA42Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the eventAle~ promptly upondetermining that the applicable time 45 minutes-has been exceeded, or will likelybe exceeded.1. a. AR,-UNPLANNED event results in the inability to monitor one Or mRcANYTable Mlef parameters from within the Control Room for > 15minutes oF loRge-.[see table below]JB WR parameter &41tReactor PoWerR"V Water- Level"VX PrcSSUrcPrimary ContainmentSuppression Pool LevelSUPPrcssion Pool Temperatur-eTable M1 Control Room Parameters* Reactor Power* RPV Water Level* RPV Pressure* Drywell Pressure* Torus Level* Torus TemperatureANDb. Any Table M2ef the, g transient events in progress.A 4 m m I I IS:utmabG Or Manuai rlunroK reatr tn-Mar ;-499% toreRnal reactor pGWerZ =' aL;-. aLwr" " EGGS (SI) actuation......................Month 20XXQC 3-63EP-AA-1006 (Revision XX) flimori rtifigsa AnnovI:valnn Nngr-loarA.uaI (~i*ice Annciv Fvailnn hImur~Iihnr a-.. U. fl ~5t~ .... U U --*~~*RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYTable M2 Significant Transients" Turbine Trip" Reactor Scram* ECCS Activation" Recirc. Runback > 25% Reactor Power Change" Thermal Power oscillations > 10% Reactor Power ChangeBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses the difficulty associated with monitoring rapidly changing plantconditions during a transient without the ability to obtain SAFETY SYSTEM parametersfrom within the Control Room. During this condition, the margin to a potential fissionproduct barrier challenge is reduced. It thus represents a potential substantialdegradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for one er mereany of Ithe listed parameters cannot be determined from within the Control Room. Thissituation would require a loss of all of the Control Room sources for the givenparameter(s). For example, the reactor power level cannot be determined from anyanalog, computer point, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated 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 itsignificantly impaired the capability to perform emergency assessments. In particular,emergency assessments necessary to implement abnormal operating procedures,emergency operating procedures, and emergency plan implementing proceduresaddressing emergency classification, accident assessment, or protective actiondecision-making.This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity control, RPV-leve!RPV water level and RCS heat removal.Month 20XXQC 3-64EP-AA-1006 (Revision XX) f-l"tari t'ifigm AnnawIPvalnn NiiilloorA.u~~I (~*ine Aflflcv Fv~Inn MmuI~2r ~4 ... as. U. %fl n,... S U *.u**RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYThe loss of the ability to determine neo Or mereany of these parameters from within theControl Room is considered to be more significant than simply a reportable condition.In addition, if all indication sources for ene or-moreany of the listed parameters are lost,then the ability to determine the values of other SAFETY SYSTEM parameters may beimpacted as well. For example, if the value for RPV water level cannot be determinedfrom the indications and recorders on a main control board, the SPDS or the plantcomputer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation of the emergency classification level would be via ICs FS1 or IC RAS1.Basis Reference(s):1. NEI 99-01 Rev 6, SA2Month 20XXQC 3-65EP-AA-1006 (Revision XX) eliinrf r-ifina AnnavI=walnn M, r~lakrA u i~rI (~i*iaa Ann~v FvMnn Ma.,,IgimrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSU421Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Eventevent promptly upondetermining that the applicable time 15 minutes-has been exceeded, or will likelybe exceeded.a- An-UNPLANNED event results in the inability to monitor one orFmoRe.ANY Table M1parameters from within the Control Room for > 15 minutes.Table M1 Control Room Parameters* Reactor Power" RPV Water Level* RPV Pressure* Drywell Pressure" Torus Level" Torus Temperature1. of the fglloWin. Dq...ar.A.t rs, from. Within the Control Room. for 15 m;inuiteorloge-II2. [BWRpomaranwtc 3. IiS4 Wi~4. Reactor Power- 6. Reactor. Pow57--8.RVWater- L" 9. &RCS Leve110-.RPX' Pressur-e 11. -R-CSF P-r-essur e12. Prniw 12. In Corv./ComeContainment Exit Temp,,rt,-14. uppessin P15. Levels in at leastLeve (site-speetie17. Steam CencratorTemper-ataf AffliliniffOf___ Wate-F NOWMonth 20XXQC 3-66EP-AA-1006 (Revision XX)
O.,ad Cities Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSU31Initiating Condition:
Exallon NuclearOuad Cities Annex Eeo ulaRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses the difficulty associated with monitoring normal plant conditionswithout the ability to obtain SAFETY SYSTEM parameters from within the ControlRoom. This condition is a precursor to a more significant event and represents apotential degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for one OF moreany ofthe listed parameters cannot be determined from within the Control Room. Thissituation would require a loss of all of the Control Room sources for the givenparameter(s). For example, the reactor power level cannot be determined from anyanalog, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)to determine if an NRC event report is required. The event would be reported if itsignificantly impaired the capability to perform emergency assessments. In particular,emergency assessments necessary to implement abnormal operating procedures,emergency operating procedures, and emergency plan implementing proceduresaddressing emergency classification, accident assessment, or protective actiondecision-making.This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity control, core cooling and RCS heat removal. The loss ofthe ability to determine eoe or mereany of these parameters from within the ControlRoom is considered to be more significant than simply a reportable condition. Inaddition, if all indication sources for one er mereany of the listed parameters are lost,then the ability to determine the values of other SAFETY SYSTEM parameters may beimpacted as well. For example, if the value for reactor vessel level cannot bedetermined from the indications and recorders on a main control board, the SPDS or theplant computer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation of the emergency classification level would be via IC MSA42-.Month 20XXQC 3-67EP-AA-1006 (Revision XX) rl"nrl ifine AnnavFPylnn umlrlnrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis Reference(s):1. NEI 99-01 Rev 6, SU2Month 20XXQC 3-68EP-AA-1006 (Revision XX)}}
Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:
1,2Emergency Action Level (EAL):Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.
: 1. a. Ap,-aAutomatic scram -did not shutdown the reactor as indicated by ReactorPower > 5%..ANDb. A-sSubsequent manual action taken at the reactor control consl ReactorConsole is successful in shutting down the reactor.OR2. a. A-mManual scram / ARI did not shutdown the reactor as indicated byReactor Power > 5%.ANDb. EITHER of the following:
: 1. A-sSubsequent manual / ARI action taken at the reactor controlGeRseleeReactor Console is successful in shutting down the reactor.OR2. A-sSubsequent automatic scram / ARI -is successful in shutting downthe reactor.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and either a subsequent operatormanual action taken at the reactor control consoles or an automatic scram is successful in shutting down the reactor.
This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.EAL #1 BasisFollowing the failure on an automatic reactor scram, operators will promptly initiatemanual actions at the reactor control consoles to shutdown the reactor (e.g., initiate amanual reactor scram). If these manual actions are successful in shutting down thereactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.Month 20XXQC 3-60EP-AA-1006 (Revision XX)
I=xelon NuclearQ~mzrl iCigti Annex Exellon NucleanrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYEAL #2 BasisIf an initial manual reactor trip is unsuccessful, operators will promptly take manualaction at another location(s) on the reactor control consoles to shutdown the reactor(e.g., initiate a manual reactor scram / ARI using a different switch).
Depending uponseveral factors, the initial or subsequent effort to manually scram the reactor, or aconcurrent plant condition, may lead to the generation of an automatic reactor scramsignal. If a subsequent manual or automatic scram / ARI is successful in shutting downthe reactor, core heat generation will quickly fall to a level within the capabilities of theplant's 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 amanual reactor scram). This action does not include manually driving in control rods orimplementation of boron injection strategies.
Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the reactor control consoles".
Taking the Reactor Mode Switch to Shutdown is considered to be a manual scramaction.The plant response to the failure of an automatic or manual reactor tscram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If subsequent operator manual actions taken at thereactor control consoles are also unsuccessful in shutting down the reactor, then theemergency classification level will escalate to an Alert via IC MSA35. Depending uponthe plant response, escalation is also possible via IC FAI. Absent the plant conditions needed to meet either IC MSA35 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 scram signal be generated as a result of plant work (e.g., RPS setpointtesting),
the following classification guidance should be applied." If the signal generated as a result of plant work causes a plant transient that createda real condition that should have included an automatic reactor scram and the RPSfails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.
" If the signal generated as a result of plant work does not cause a plant transient butshould have generated an RPS scram signal and the scram failure is determined through other means (e.g., assessment of test results),
then this IC and the EALsare not applicable and no classification is warranted.
Month 20XXQC 3-61EP-AA-1006 (Revision XX)
Exelon NuclearQuad Cities Annex Eeo ulaRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis Reference(s):
: 1. NEI 99-01 Rev 6, SU5Month 20XXQC 3-62EP-AA-1006 (Revision XX)
QU2d Cities AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSA42Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.
Operating Mode Applicability:
1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the eventAle~
promptly upondetermining that the applicable time 45 minutes-has been exceeded, or will likelybe exceeded.
: 1. a. AR,-UNPLANNED event results in the inability to monitor one Or mRcANYTable Mlef parameters from within the Control Room for > 15minutes oF loRge-.[see table below]JB WR parameter  
&41tReactor PoWerR"V Water- Level"VX PrcSSUrcPrimary Containment Suppression Pool LevelSUPPrcssion Pool Temperatur-e Table M1 Control Room Parameters
* Reactor Power* RPV Water Level* RPV Pressure* Drywell Pressure* Torus Level* Torus Temperature ANDb. Any Table M2ef the, g transient events in progress.
A 4 m m I I IS:utmabG Or Manuai rlunroK reatr tn-Mar ;-499% toreRnal reactor pGWerZ =' aL;-. aLwr"  
" EGGS (SI) actuation......................
Month 20XXQC 3-63EP-AA-1006 (Revision XX) flimori rtifigsa AnnovI:valnn Nngr-loar A.uaI (~i*ice Annciv Fvailnn hImur~Iihnr a-.. U. fl ~5t~ .... U U --*~~*RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYTable M2 Significant Transients
" Turbine Trip" Reactor Scram* ECCS Activation
" Recirc. Runback > 25% Reactor Power Change" Thermal Power oscillations  
> 10% Reactor Power ChangeBasis:UNPLANNED:
A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.
This IC addresses the difficulty associated with monitoring rapidly changing plantconditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fissionproduct 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 er mereany of Ithe listed parameters cannot be determined from within the Control Room. Thissituation would require a loss of all of the Control Room sources for the givenparameter(s).
For example, the reactor power level cannot be determined from anyanalog, computer point, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated 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 itsignificantly 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 actiondecision-making.
This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity  
: control, RPV-leve!RPV water level and RCS heat removal.Month 20XXQC 3-64EP-AA-1006 (Revision XX) f-l"tari t'ifigm AnnawIPvalnn Niiilloor A.u~~I (~*ine Aflflcv Fv~Inn MmuI~2r ~4 ... as. U. %fl n,... S U *.u**RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYThe loss of the ability to determine neo Or mereany of these parameters from within theControl Room is considered to be more significant than simply a reportable condition.
In addition, if all indication sources for ene or-moreany of the listed parameters are lost,then the ability to determine the values of other SAFETY SYSTEM parameters may beimpacted as well. For example, if the value for RPV water level cannot be determined from the indications and recorders on a main control board, the SPDS or the plantcomputer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.
Escalation of the emergency classification level would be via ICs FS1 or IC RAS1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SA2Month 20XXQC 3-65EP-AA-1006 (Revision XX) eliinrf r-ifina AnnavI=walnn M, r~lakrA u i~rI (~i*iaa Ann~v FvMnn Ma.,,Igimr RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSU421Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:
1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Eventevent promptly upondetermining that the applicable time 15 minutes-has been exceeded, or will likelybe exceeded.
a- An-UNPLANNED event results in the inability to monitor one orFmoRe.ANY Table M1parameters from within the Control Room for > 15 minutes.Table M1 Control Room Parameters
* Reactor Power" RPV Water Level* RPV Pressure* Drywell Pressure" Torus Level" Torus Temperature
: 1. of the fglloWin.
Dq...ar.A.t rs, from. Within the Control Room. for 15 m;inuiteorloge-II2. [BWRpomaranwtc  
: 3.
IiS4 Wi~4. Reactor Power- 6. Reactor.
Pow57--8.RVWater-L" 9. &RCS Leve110-.RPX' Pressur-e  
: 11. -R-CSF P-r-essur e12. Prniw 12. In Corv./Come Containment Exit Temp,,rt,-
: 14. uppessin P15. Levels in at leastLeve (site-speetie
: 17. Steam Cencrator Temper-ataf AffliliniffOf
___ Wate-F NOWMonth 20XXQC 3-66EP-AA-1006 (Revision XX)
Exallon NuclearOuad Cities Annex Eeo ulaRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:UNPLANNED:
A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.
This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the ControlRoom. This condition is a precursor to a more significant event and represents apotential degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for one OF moreany ofthe listed parameters cannot be determined from within the Control Room. Thissituation would require a loss of all of the Control Room sources for the givenparameter(s).
For example, the reactor power level cannot be determined from anyanalog, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)to determine if an NRC event report is required.
The event would be reported if itsignificantly 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 actiondecision-making.
This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity  
: control, core cooling and RCS heat removal.
The loss ofthe ability to determine eoe or mereany of these parameters from within the ControlRoom is considered to be more significant than simply a reportable condition.
Inaddition, if all indication sources for one er mereany of the listed parameters are lost,then the ability to determine the values of other SAFETY SYSTEM parameters may beimpacted as well. For example, if the value for reactor vessel level cannot bedetermined from the indications and recorders on a main control board, the SPDS or theplant computer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.
Escalation of the emergency classification level would be via IC MSA42-.Month 20XXQC 3-67EP-AA-1006 (Revision XX) rl"nrl ifine AnnavFPylnn umlrlnrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis Reference(s):
: 1. NEI 99-01 Rev 6, SU2Month 20XXQC 3-68EP-AA-1006 (Revision XX)}}

Revision as of 13:59, 1 July 2018

Attachment 10: Discussion of Revision to the Radiological Emergency Plan Annex for Quad Cities Nuclear Power Station, Cover Through Page QC 3-68
ML14164A076
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 05/30/2014
From:
Exelon Generation Co
To:
NRC/FSME, Office of Nuclear Material Safety and Safeguards
Shared Package
ML14164A053 List:
References
RA-14-032, RS-14-115, TMI-14-046 EP-AA-1006, NEI 99-01, Rev. 6
Download: ML14164A076 (136)
v • d • e


Text

ATTACHMENT 10DISCUSSION OF REVISIONTO THERADIOLOGICAL EMERGENCY PLAN ANNEXFORQUAD CITIES NUCLEAR POWER STATIONEP-AA-1 006Enclosures 00SEnclosure 10A -EAL Comparison Matrix DocumentEnclosure 10B -EAL Red-Line Basis DocumentEnclosure 10C -EAL Basis Document NEI 99-01REVISION 6DEVELOPMENT OF EMERGENCY ACTIONLEVELS FOR NON-PASSIVE REACTORSATTACHMENT 10DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FORQUAD CITIES NUCLEAR STATIONm Exelon Generation.

NEI 99-01 Rev 6 Proposed EAL Justification AG1Initiating Condition

-GENERAL EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mremTEDE or 5,000 mrem thyroid CDE.Operating Mode Applicability:

AllExample Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the General Emergency promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.

  • If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due toactions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.
  • The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.
1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 1000 mR/hr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than5000 mrem for one hour of inhalation.

RG1Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1,000mRem TEDE or 5,000 mRem thyroid CDE.Operating Mode Applicability:

1,2.3,4,5,D Emergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

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

If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.

  • The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.
1. The sum of readings on the Rx Bldg and Chimney SPINGs > 3.84 E+09uCilsec for > 15 minutes (as determined by Control Room Panels or PPDS-Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond thesite boundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate

> 5000 mRem CDEThyroid for 60 minutes of inhalation.

1'1 No Change M Difference FIDeviation

1) Listed site-specific monitors and Threshold values to ensure timelyclassification.
2) Added the following to bullet #3" Classification based on effluent monitorreadings assumes that a release path to the environment is established."

In orderto delete the following from the basis "Classification based on effluent monitorreadings assumes that a release path to the environment is established.

If theeffluent flow past an effluent monitor is known to have stopped due to actions toisolate the release path, then the effluent monitor reading is no longer valid forclassification purposes."

This allows for more timely classification since all thebasis information pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 11x17 procedure matrix used by the SM.Page I of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification AS1Initiating Condition

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

AllExample Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the Site Area Emergency promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.

  • If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due toactions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.
  • The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.
1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 100 mR/hr expected tocontinue for 60 minutes or longer." Analysis of field survey samples indicate thyroid CDE greater than500 mrem for one hour of inhalation.

RS1Initiating Condition:

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

1,2,3,4,5,D Emergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

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

If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.

The pre-calculated effluent monitor values presented in EAL #1 should be usedfor emergency classification assessments until the results from a doseassessment using actual meteorology are available.

1. The sum of readings on the Rx Bldg and Chimney SPINGs > 3.84 E+08uCi/sec for > 15 minutes (as determined by Control Room Panels or PPDS -Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond thesite boundary of EITHER:a. > 100 mRem TEDEORb. > 500 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >100 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate

> 500 mRem CDEThyroid for 60 minutes of inhalation.

D No Change I Difference 1-- Deviation

1) Listed site-specific monitors and Threshold values to ensure timelyclassification.
2) Added the following to bullet #3" Classification based on effluent monitorreadings assumes that a release path to the environment is established."

In orderto delete the following from the basis "Classification based on effluent monitorreadings assumes that a release path to the environment is established.

If theeffluent flow past an effluent monitor is known to have stopped due to actions toisolate the release path, then the effluent monitor reading is no longer valid forclassification purposes."

This allows for more timely classification since all thebasis information pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 1 1x17 procedure matrix used by the SM.Page 2 of 66 NEI 99-01 Rev 6 1 Proposed EAL I Justification AA1Initiating Condition

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

AllExample Emergency Action Levels: (1 or 2 or 3)Note:* The Emergency Director should declare the Alert promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

  • If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped dueto actions to isolate the release path, then the effluent monitor reading isno longer valid for classification purposes.
  • The pre-calculated effluent monitor values presented in EAt #1 should beused for emergency classification assessments until the results from adose assessment using actual meteorology are available.
1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site-specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 10mrem TEDE or 50 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Analysis of a liquid effluent sample indicates a concentration or releaserate that would result in doses greater than 10 mrem TEDE or 50 mremthyroid CDE at or beyond (site-specific dose receptor point) for one hour ofexposure.
4. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 10 mR/hr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than50 mrem for one hour of inhalation.

RA1Initiating Condition:

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

1,2,3,4, 5, DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

  • If an ongoing release is detected and the release start time is unknown, assumethat the release duration has exceeded 15 minutes.Classification based on effluent monitor readings assumes that a release pathto the environment is established.

If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.

The pre-calculated effluent monitor values presented in EAL #1 should be usedfor emergency classification assessments until the results from a doseassessment using actual meteorology are available.

1. The sum of readings on the Rx Bldg and Chimney SPINGs > 3.84 E+07uCi/sec for > 15 minutes (as determined by Control Room Panels or PPDS-Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond thesite boundary of EITHER:a. > 10 mRemTEDEORb. > 50 mRem CDE ThyroidOR3. Analysis of a liquid effluent sample indicates a concentration or release ratethat would result in doses greater than EITHER of the following at or beyondthe site boundarya. 10 mRem TEDE for 60 minutes of exposureORb. 50 mRem CDE Thyroid for 60 minutes of exposureOR4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mRihr areexpected to continue fork 60 minutes.ORb. Analyses of field survey samples indicate

> 50 mRemCDE Thyroid for 60 minutes of inhalation.

H No Change Difference L- Deviation

1) Listed site-specific monitors and Threshold values to ensure timely classification.
2) Added the following to bullet #3" Classification based on effluent monitorreadings assumes that a release path to the environment is established."

In orderto delete the following from the basis "Classification based on effluent monitorreadings assumes that a release path to the environment is established.

If theeffluent flow past an effluent monitor is known to have stopped due to actions toisolate the release path, then the effluent monitor reading is no longer valid forclassification purposes."

This allows for more timely classification since all the basisinformation pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 11x17 procedure matrix used by the SM.3) A calculation was performed, in accordance with (IAW) guidance provided in NEI99-01 revision 6 EAL AA1, to determine the effluent monitor response for aradioactive liquid release via the normal site release pathway.

The liquid releasewould contain activity equivalent to provide 10mrem TEDE or 50mrem thyroid CDEat the site boundary.

The calculation determined the effluent monitor responsewould be >110% of the instrument maximum range and as such, lAW NEI 99-01Rev 6 guidance, was not included in this EAL.Page 3 of 66 0NEI 99-01 Rev 6 Proposed EAL Justification AU1Initiating Condition

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

AltExample Emergency Action Levels: (1 or 2 or 3)Note:* The Emergency Director should declare the Unusual Event promptly upondetermining that 60 minutes has been exceeded, or will likely beexceeded.

  • If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 60 minutes.* If the effluent flow past an effluent monitor is known to have stopped,indicating that the release path is isolated, the effluent monitor reading isno longer valid for classification purposes.
1. Reading on ANY effluent radiation monitor greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes orlonger:(site-specific monitor list and threshold values corresponding to 2 timesthe controlling document limits)2. Reading on ANY effluent radiation monitor greater than 2 times thealarm setpoint established by a current radioactivity discharge permit for60 minutes or longer.3. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times (site-specific effluent releasecontrolling document limits) for 60 minutes or longer.RUIInitiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for60 minutes or longer.Operating Mode Applicability:

1,2,3,4,5, DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

  • If an ongoing release is detected and the release start time is unknown, assumethat the release duration has exceeded 60 minutes.* Classification based on effluent monitor readings assumes that a release pathto the environment is established.

If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.

1. Reading on ANY of the following effluent monitors

> 2 times alarmsetpoint established by a current radioactive release discharge permitfor a 60 minutes.* Radwaste Effluent Monitor 1/2-1799-01 OR* Discharge Permit specified monitorOR2. The sum of readings on the Rx Bldg and Chimney SPINGs > 4.38 E+05uCilsec for > 60 minutes (as determined by Control Room Panels or PPDS-Total Noble Gas Release Rate).OR3. Confirmed sample analyses for gaseous or liquid releases indicateconcentrations or release rates > 2 times ODCM Limit with a releaseduration of > 60 minutes.1 No Change E Difference e Deviation

1) Listed site-specific monitors and Threshold values to ensure timely classification.
2) Added the following to bullet #3" Classification based on effluent monitorreadings assumes that a release path to the environment is established."

In orderto delete the following from the basis "Classification based on effluent monitorreadings assumes that a release path to the environment is established.

If theeffluent flow past an effluent monitor is known to have stopped due to actions toisolate the release path, then the effluent monitor reading is no longer valid forclassification purposes."

This allows for more timely classification since all the basisinformation pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 1 1x17 procedure matrix used by the SM.Page 4 of 66 NEI 99-01 Rev 6 Proposed EAL Justification AG2 RG2Initiating Condition

-GENERAL EMERGENCY No Change Difference Deviation Spent fuel pool level cannot be restored to at least (site-specific Level 3description) for 60 minutes or longer. 1) EAL not used in accordance with the discussion in Section 1.4, NRC OrderEA-1 2-051, it is recommended that this EAL be implemented when the enhancedOperating Mode Applicability:

All spent fuel pool level instrumentation is available for use. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is beingExample Emergency Action Levels: tracked in accordance with Exelon Generation

Company, LLC's Initial StatusReport to March 12, 2012 Commission Order Modifying Licenses with Regard forNOTES: The Emergency Director should declare the General Emergency Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) datedpromptly upon determining that 60 minutes has been exceeded, October 25,2012.or will likely be exceeded1. Spent fuel pool level cannot be restored to at least (site-specific Level 3description) for 60 minutes or longer.Page 5 of 66 NEI 99-01 Rev 6 Proposed EAL Justification AS2 RS2Initiating Condition

-SITE AREA EMERGENCY AR No Change 1X- Difference

[]Deviation Spent fuel pool level cannot be restored to at least (site-specific Level 3description)

1) EAL not used in accordance with the discussion in Section 1.4, NRC OrderEA-1 2-051, it is recommended that this EAL be implemented when the enhancedOperating Mode Applicability:

All spent fuel pool level instrumentation is available for use. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is beingExample Emergency Action Levels: tracked in accordance with Exelon Generation

Company, LLC's Initial StatusReport to March 12, 2012 Commission Order Modifying Licenses with Regard for1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dateddescription)

October 25,2012.Page 6 of 66 0NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition

-ALERT I Condition:

RA2 D No Change E Difference F-- Deviation Significant lowering of water level above, or damage to, irradiated fuel. Significant lowering of water level above, or damage to. irradiated fuel. 1) Listed site-specific monitors and Threshold values to ensure timely classification.

Operating Mode Applicability:

Ail Operating Mode Applicability:

2) EAL #3 not used in accordance with the discussion in Section 1.4, NRC Order1, 2, 3, 4, 5, D EA-1 2-051, it is recommended that this EAL be implemented when the enhancedExample Emergency Action Levels: (1 or 2 or 3) Emergency Action Level (EAL): spent fuel pool level instrumentation is available for use. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is being1. Uncovery of irradiated fuel in the REFUELING PATHWAY.
1. Uncovery of irradiated fuel in the REFUELING PATHWAY.

tracked in accordance with Exelon Generation

Company, LLC's Initial StatusOR Report to March 12, 2012 Commission Order Modifying Licenses with Regard for2. Damage to irradiated fuel resulting in a release of radioactivity from the Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) datedfuel as indicated by ANY of the following radiation monitors:
2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel October 25,2012.as indicated by ANY Table R1 Radiation Monitor reading >1000 mRem/hr.(site-specific listing of radiation
monitors, and the associated
readings, Table R1setpoints and/or alarms) Fuel Handling Incident Radiation Monitors3. Lowering of spent fuel pool level to (site-specific Level 2 value).
  • 1(2) 1705-16A Fuel Pool Rad Monitor.1(2) 1705-16B Fuel Pool Rad MonitorPage 7 of 66 NEI 99-01 Rev 6 1 Proposed EAL I Justification AU2Initiating Condition:

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

AllExample Emergency Action Levels:1. a. UNPLANNED water level drop in the REFUELING PATHWAY asindicated by ANY of the following:

(site-specific level indications).

ANDb. UNPLANNED rise in area radiation levels as indicated by ANY of thefollowing radiation monitors.

(site-specific list of area radiation monitors)

RU2Initiating Condition:

UNPLANNED loss of water level above irradiated fuelOperating Mode Applicability:

1,2, 3,4, 5, DEmergency Action Level (EAL):1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated byANY of the following:

" Refueling Cavity water level < 282 in. (Upper Wide rangesimulated signal).OR" Spent Fuel Pool water level < 19 ft. above the fuel (< -4 ft.indicated level).OR" Indication or report of a drop in water level in the REFUELING PATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable R1.E No Change 1 Difference I: Deviation

1) Listed site specific level indication and monitors to ensure timelyclassification.

Table RIFuel Handling Incident Radiation Monitors* 1(2) 1705-16A Fuel Pool Rad Mon* 1(2) 1705-16B Fuel Pool Rad MonPage 8 of 66 NEI 55-01 Rev 6 Proposed EALNEI 99-01 Rev 6Proposed EALJustification AA3Initiating Condition

-ALERTRadiation levels that impede access to equipment necessary for normal plantoperations, cooldown or shutdown.

Operating Mode Applicability:

AllExample Emergency Action Levels: (1 or 2)Note: If the equipment in the listed room or area was already inoperable, orout of service, before the event occurred, then no emergency classification is warranted

1. Dose rate greater than 15 mR/hr in ANY of the following areas:* Control Room* Central Alarm Station* (other site-specific areas/rooms)
2. An UNPLANNED event results in radiation levels that prevent orsignificantly impede access to any of the following plant rooms orareas:(site-specific list of plant rooms or areas with entry-related modeapplicability identified)

RA3Initiating Condition:

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

Operating Mode Applicability:

1,2,3,4, 5,DEmergency Action Level (EAL):Note:If the equipment in the room or area listed in Table R3 was already inoperable, orout of service, before the event occurred, then no emergency classification iswarranted.

1. Dose rate> 15 mR/hr in ANY of the following Table R2 areas:No Change 1 Difference II7 Deviation
1) Listed site specific plant rooms and areas with identified mode applicability toensure timely classification.

Table R2Areas Requiring Continuous Occupancy

  • Main Control Room (Unit 1 ARM Station #22)* Central Alarm Station -(by survey)OR2. UNPLANNED event results in radiation levels that prohibit or significantly impedeaccess to ANY of the following Table R3 plant rooms or areas:Table R3Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Building*

Mode 3 and 4Turbine Building*

Mode 3*Areas required to establish shutdown coolingPage 9 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT SU3 Initiating Condition:

RU3 [Z No Change Difference Deviation Reactor coolant activity greater than Technical Specification allowable limits. Reactor coolant activity greater than Technical Specification allowable limits. 1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

2) Listed this system category EAL in the radiological category EAL section toPower Operation,
Startup, Hot Standby, Hot Shutdown 1.2, 3 maintain consistency with current and previous revisions of Exelon EALs. This willExample Emergency Action Levels: Emergency Action Level (EAL): ensure a timely classification since the threshold values are more aligned with theradiological category vice system category.
1. (Site-specific radiation monitor) reading greater than (site-specific value). 1. Offgas system radiation monitor HI-HI alarm.OR OR2. Sample analysis indicates that a reactor coolant activity value is greater than 2. Specific coolant activity

> 4.0 uCil/gm Dose equivalent 1-131.an allowable limit specified in Technical Specifications.

Page 10 of 66 NEI 99-01 rev 6 Fission Product Barrier MatrixFC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Category LLoss { Potential Loss Loss L Potential Loss 4Loss Potential Loss* RCS ActivityI PrimaryContainment Pressure

/PrimaryContainment Conditions A. (Site specific indications thatreactor coolant activity isgreater than 300 uCilgmdose equivalent 1-131)NoneA. Primary containment pressuregreater than (site-specific value) due to RCS leakage.NoneA. UNPLANNED rapid drop inprimary containment pressurefollowing primary containment pressure riseORB. Primary containment pressureresponse not consistent withLOCA conditions.

A. Primary containment pressuregreater than (site-specific value)ORB. (site-specific explosive mixture)exists inside primary containment ORC. HCTL exceeded.

A. RPV water level cannot be A. RPV water level cannot berestored and maintained aboveA. Primary containment flooding restored and maintained above2. RPV Water required.

(site-specific RPV water level (site-specific RPV water level None None A. Primary containment floodingLevel corresponding to top of active corresponding to the top of required.

fuel) or cannot be determined.

active fuel) or cannot bedetermined.

A. UNISOLABLE direct downstream pathway to the environment existsafter primary containment isolation signalORA. UNISOLABLE break in any of the A. UNISOLABLE primary systemfUollowing:

(britepecfic anysthems leakage that results in exceeding B. Intentional primary containment following:

( site-specific systems EITHER of the folwn:venting per EOPs3.RCS Leak with potential for high-energy linefollowing:

Rate/ Primary None None breas) 1. Max Normal Operating OR NoneContainment OR Temperature C. UNISOLABLE primary systemIsolation Failure B. Emergency RPV OR leakage that results in exceeding

2. Max Normal Operating Area EITHER of the following:

Depressurization Radiation Level. 1. Max Safe Operating Temperature.

OR2. Max Safe Operating AreaRadiation Level.4.Primary A. Primary Containment A. Primary Containment Radiation A. Primary Containment Radiation Containment Radiation Monitor reading None Monitor reading greater than None None Monitor reading greater than (site-Radiation greater than (site-specific (site-specific value). specific value).value).5. Emergency A. Any Condition in the opinion A. Any Condition in the opinion of A. ANY Condition in the opinion of A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of theDirector of the Emergency Director the Emergency Director that the Emergency Director that E g Directr ta indicatestha inicate Emergency Director that indicates dgment that indicates Loss of the indicates Potential Loss of the indicates Loss of the RCS Potential Loss of the RCS BarrierP Loss of the Containment Barrier.Judgment Fuel Clad Barrier.

Fuel Clad Barrier.

Barrier.

P Barrier.Page t1 of 66 Proposed Fission Product Barrier MatrixFGI Loss of any two barriers AND Loss or Potential Loss of third barrier.TED I FSI Loss or Potential Loss of ANY two barriers.

I FAI ANY Loss or ANY Potential Loss of either Fuel Clad or RCS fFli]FC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Category Loss Potential Loss Loss Potential Loss Loss Potential LossCoolant activity>

300 uCllgm Dose None None1. RCS Activity Equivalent 1-131. None None None2. RPV water level cannot be restored and 1. RPV water level cannot be restored and2. RPV Water 1. Plant conditions indicate Primary maintained 0 -142 inches (TAF) maintained

> -142 Inches (TAF) Plant conditions indicate Primary Containment Containment fending is required.

OR OR None None flooding is required.

Level 3. RPV water level cannot be determined.

2. RPV water level cannot be determined.
3. Primary Containment pressure

> 56 peig.OR1. UNPLANNED rapid drop in Drywell 4. a. Drywell or torus hydrogen concentration

1. Drywell pressure

>2.5 peig. pressure following primary containment 06%.3. Primary AND pressure rise. ANDContainment None None 2. Drywell pressure rise is due to RCS None OR b. Drywell or tows oxygen concentration Pressure/Conditions leakage 2. Drywell pressure response not consistent a 5%.with LOCA conditions.

OR5. Heat Capacity Limit (lGA 200. Figure M)exceeded.

3. UNISOLABLE primary system leakage that1. UNISOLABLE Main Steam Line (MSL), results in EITHER of the following:

HPCI, Feedwater, RWCU or RCIC line a. Secondary Containment areabreak. temperature s QGA 300 Maximum4.RCS Leak Rate None None OR Normal operating levels. None None2. Emergency RPV Depressurization is ORrequired.

b. Secondary Containment area radiation level > OGA 300 Maximum Normaloperating level.5.Primary Drywell radiation monitor reading Drywell radiation monitor reading Drywell radiation monitor readingContainment

> 6.65 E*02 R/hr. None I 1O0R/hr (10.00 E+02 R/hr). None None > 1.55 E+03 RbhrRadiation

1. UNISOLABLE direct downstream pathwayto the environment exists after pnmarycontainment isolation signal.OR2. Intentional Primary Containment venting/purging per EOPs or SAMGs due toaccident conditions.

6.Primary ORContainment None None None None 3. UNISOLABLE primary system leakage that NoneIsolation Failure results in EITHER of the following:

a. Secondary Containment areatemperature s QGA 300,Maximum Safe operating levels.ORb. Secondary Containment arearadiation level s QGA 300,Maximum Safe operating levels7. Emergency A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. ANY Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of theEmergency Director that indicates Loss Emergency Director that indicates Potential Emergency Director that indicates Loss of Emergency Director that indicates Potential Emergency Director that indicates Loss ot the Emergency Director that indicates Potential LossDirector Judgment of the Fuel Clad Barrier.

Loss of the Fuel Clad Barrier the RCS Barrier.

Loss of the RCS Barrier.

Containment Barrier.

of the Containment Barrier.Page 12 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FCI Category:

Fuel Clad Barrier No Change Difference Deviation RCS Activity RCS Activity

1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

Loss LossA. (Site specific indications that reactor coolant activity is greater than 300 uCi/gm Coolant activity

> 300 uCilgm Dose Equivalent 1-131.dose equivalent 1-131)Page 13 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC2 Category:

Fuel Clad Barrier FC2 Z No Change Differce Deviation RPV Water Level RCS Activity

1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

Loss LossA. Primary containment flooding required.

1. Plant conditions indicate Primary Containment flooding is required.

Potential Loss Potential LossA. RPV water level cannot be restored and maintained above (site-specific RPV 2. RPV water level cannot be restored and maintained

> -142 inches (TAF)water level corresponding to top of active fuel) or cannot be determined.

OR3. RPV water level cannot be determined.

Page 14 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC4 Category:

Fuel Clad Barrier 'C5 [fl No Change Difference Deviation Primary Containment Radiation Primary Containment Radiation

1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

Loss LossA. Primary Containment Radiation Monitor reading greater than (site-specific Drywell radiation monitor reading > 6.65 E+02 R/hr.value).Page 15 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC6 Category:

Fuel Clad BarrierFC No Change Differ Deviation Emergency Director Judgment Emergency Director JudgmentOperating Mode Applicability:

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss ofthe Fuel Clad Barrier.

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

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

Loss of the Fuel Clad Barrier.Page 16 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC1 Category:

Reactor Coolant System Barrier RC' E No Change Difference Deviation Primary Containment Pressure Primary Containment Pressure/Conditions

1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

Loss LossA. Primary containment pressure greater than (site-specific value) due to RCS 1. Drywell pressure

>2.5 psig.leakage.

AND2. Drywell pressure rise is due to RCS leakage.Page 17 of 66 NEI 99-01 Rev 6 Proposed EAL Justification RC2Category:

Reactor Coolant System BarrierRPV Water LevelOperating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownFission Product Barrier Threshold:

LossA. RPV water level cannot be restored and maintained above (site-specific RPVlevel corresponding to the top of active fuel) or cannot be determined.

RC2Category:

Reactor Coolant System BarrierRPV Water LevelOperating Mode Applicability:

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

Loss1. RPV water level cannot be restored and maintained

> -142 inches (TAF).OR2. RPV water level cannot be determined.

No Change 1 Difference 1 Deviation

1) Listed site-specific threshold value to ensure timely classification.

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

Reactor Coolant System Barrier RC3 Category:

Reactor Coolant System Barrier RC E No Change Difference Deviation RCS Leak Rate RCS Leak Rate 1) Listed site-specific systems and threshold values to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

Loss LossA. UNISOLABLE break in any of the following:

( site-specific systems with potential

1. UNISOLABLE Main Steam Line (MSL), HPCI, Feedwater,,

RWCU or RCICfor high-energy line breas) line break.OR ORB. Emergency RPV Depressurization

2. Emergency RPV Depressurization is required.

Potential Loss Potential LossA. UNISOLABLE primary system leakage that results in exceeding EITHER of thefollowing:

3. UNISOLABLE primary system leakage that results in EITHER of the following:
a. Secondary Containment area temperature

> QGA 300 Maximum Normal1. Max Normal Operating Temperature.

operating levels.OR OR2. Max Normal Operating Area Radiation Level. b. Secondary Containment area radiation level > QGA 300 Maximum Normaloperating levels.Page 19 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC4 Category:

Reactor Coolant System Barrier 'C5 No Change Difference Deviation Primary Containment Radiation Primary Containment Radiation 1 ) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

Loss LossA. Primary Containment Radiation Monitor reading greater than (site-specific Drywell radiation monitor reading > 100 R/hr (>1.OOE+02 R/hr).value).Page 20 of 66 0NEI 99-01 Rev 6 Proposed EAL Justification RC6 RC7 NOCag [ Dfeee ]DeitoCategory:

Reactor Coolant System Barrier Category:

Reactor Coolant System Barrier No Change Difference Deviation Emergency Director Judgment Emergency director JudgmentOperating Mode Applicability:

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. ANY Condition in the opinion of the Emergency Director that indicates Loss ofthe RCS Barrier.

the RCS Barrier.Potential Loss Potential LossA. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.

2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Page 21 of66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CTI Category:

Containment Barrier No Change Diff n Deviation Primary Containment Conditions Primary Containment Pressure/Conditions

1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

2) The words "and rising" were added to account for the momentary spike inPower Operation,
Startup, Hot Standby, Hot Shutdown 1,2, 3 pressure where pressure is now lowering, the risk of a potential loss ofcontainment is no longer present, this wording is also consistent with present EALFission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

wording.Loss LossC. UNPLANNED rapid drop in primary containment pressure following primary 1. UNPLANNED rapid drop in Drywell pressure following Drywell pressure rise.containment pressure rise OROR 2. Drywell pressure response not consistent with LOCA conditions.

B. Primary containment pressure response not consistent with LOCA conditions.

Potential LossPotential Loss3. Drywall pressure

>56 psig and rising.D. Primary containment pressure greater than (site-specific value) OROR 4. a. Drywell or torus Hydrogen concentration

> 6%.E. (site-specific explosive mixture) exists inside primary containment ANDOR b. Drywell or torus Oxygen concentration

> 5%.OR3. HCTL exceeded.

5. Heat Capacity Limit (QGA 200, Fig. M) exceeded.

Page 22 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT2 Category:

Containment Barrier CT2 No Change Difference Deviation RPV Water Level RPV Water LevelOperating Mode Applicability:

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

Potential Loss -Potential LossA. Primary containment flooding required.

Plant conditions indicate Primary Containment flooding is required.

Page 23 of 66 NEI 99-01 Rev 6CT3Category:

Containment BarrierPrimary Containment Isolation FailureOperating Mode Applicability:

Power Operation,

Startup, Hot Standby.

Hot ShutdownFission Product Barrier Threshold:

LossA. UNISOLABLE direct downstream pathway to the environment exists afterprimary containment isolation signalORB. Intentional primary containment venting per EOPsORC. UNISOLABLE primary system leakage that results in exceeding EITHER of thefollowing:

1. Max Safe Operating Temperature.

OR2. Max Safe Operating Area Radiation Level.Proposed EAL Justification CT6Category:

Containment BarrierPrimary Containment Isolation FailureOperating Mode Applicability:

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

LoSS1. UNISOLABLE direct downstream pathway to the environment exists afterprimary containment isolation signal.OR2. Intentional Primary Containment venting/purging per EOPs or SAMGs due toaccident conditions.

OR3. UNISOLABLE primary system leakage that results in EITHER of the following:

a. Secondary Containment area temperature

> OGA 300 Maximum Safeoperating levels.ORb. Secondary Containment area radiation level > QGA 300 Maximum Safeoperating levels.E No Change 1 Difference 1 Deviation

1) Listed site-specific threshold values to ensure timely classification.

Page 24 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT4 Category:

Containment BarrierT No Change Differnc Deviation Primary Containment Radiation Primary Containment Radiation

1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

Potential Loss Potential LossA. Primary Containment Radiation Monitor reading greater than (site-specific value). Dryweil radiation monitor reading > 1.55 E+03 R/h.Page 25 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT6 Category:

Containment BarrierCTI No Change Diffrenc.

Deviation Emergency director Judgment Emergency Director JudgmentOperating Mode Applicability:

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss ofthe Containment Barrier.

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

2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Page 26 of 66 NEI 99-01 Rev 6 j Proposed EAL Justification SG1Initiating Condition:

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

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the General Emergency promptlyupon determining that (site-specific hours) has been exceeded, or willlikely be exceeded.
1. a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses).ANDb. EITHER of the following:

" Restoration of at least one emergency bus in less than(site-specific hours) is not likely." (Site-specific indication of an inability to adequately remove heat from the core)MG1Initiating Condition:

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

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

1 Loss of ALL offsite AC power to unit ECCS busses.AND2. Failure of Unit EDG 1(2), shared EDG 1/2 and SBO DG 1(2) emergency dieselgenerators to supply power to unit ECCS busses.AND3. EITHER of the following:

a. Restoration of at least one unit ECCS bus in < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is not likely.ORb. RPV water level cannot be restored and maintained

> -166 inches.F No Change FIDifference FIDeviation

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

Page 27 of 66 0NEI 99-01 Rev 6 Proposed EAL [ Justification SS1Initiating Condition:

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

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes time has been exceeded, orwill likely be exceeded.

Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.MS1Initiating Condition:

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

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

1. Loss of ALL offsite AC Power to unit ECCS buses.AND2. Failure of Unit EDG 1(2), shared EDG 1/2 and SBO DG 1(2) emergency dieselgenerators to supply power to unit ECCS busses.AND3. Failure to restore power to at least one ECCS bus in < 15 minutes from the timeof loss of both offsite and onsite AC power.No Change FIDifference F Deviation
1) Listed site specific equipment to ensure timely classification.

Page 28 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification SA1MAIInitiating Condition:

ALERTInitiating Condition:

Loss of all but one AC power source to emergency buses for 15 minutes or longer. Loss of all but one AC power source to emergency buses for 15 minutes or longer.M No Change --Difference D Deviation

1) Listed site specific equipment to ensure timely classification.

Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes time has been exceeded, or will likely be exceeded.
1. a. AC power capability to (site-specific emergency buses) is reduced to asingle power source for 15 minutes or longer.ANDb. Any additional single power source failure will result in loss of all ACpower to SAFETY SYSTEMS.Operating Mode Applicability:

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

1. AC power capability to unit ECCS buses reduced to only one of the following power sources for> 15 minutes.* Reserve auxiliary Transformer TR-12 (TR-22)* Unit Auxiliary Transformer TR-1 1 (TR-21)* Unit Emergency Diesel Generator
  • Station Blackout Diesel Generator
  • Unit crosstie breakersAND2. ANY additional single power source failure will result in a loss of ALL AC powerto SAFETY SYSTEMS.Page 29 of 66 NEI 99-01 Rev 6 1 Proposed EAL I Justification SulInitiating Condition:

UNUSUAL EVENTLoss of all offsite AC power capability to emergency buses for 15 minutes orlonger.Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.

Loss of ALL offsite AC power capability to (site-specific emergency buses) for 15minutes or longerMU1Initiating Condition:

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

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

Loss of ALL offsite AC power capability to unit ECCS buses for > 15 minutes.M No Change FIDifference FIDeviation

1) Listed site specific equipment to ensure timely classification.

Page 30 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SG8Initiating Condition:

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

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the General Emergency promptlyupon determining that 15 minutes has been exceeded, or will likely beexceeded.
1. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses) for 15 minutes or longer.ANDIndicated voltage is less than (site-specific bus voltage value) on ALL(site-specific vital DC buses) for 15 minutes or longer.MG2Initiating Condition:

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

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

1. Loss of ALL offsite AC power to unit ECCS busses.AND2. Failure of Unit EDG 1(2), shared EDG 1/2 and SBO EDG 1(2) emergency diesel generators to supply power to vital busses.AND3. Voltage is < 105 VDC on 125 VDC battery busses #1 and #2.AND4. ALL AC and Vital DC power sources have been lost for >15 minutes.D No Change M Difference FIDeviation
1) Listed site specific equipment to ensure timely classification.
2) in EAL #3 removed the word "indicated" this will allow for an indication problemto not cause confusion on the need to declare.Page 31 of 66 NEt 99-01 Rev 6 Proposed EAL I Justification S33Initiating Condition:

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

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes time has been exceeded, orwill likely be exceeded.

Indicated voltage is less than (site-specific bus voltage value) on ALL Vital DCbuses for 15 minutes or longer.MS2Initiating Condition:

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

1,2,3D No Change M Difference I Deviation

1) Listed site specific equipment and value to ensure timely classification.
2) Removed the word "indicated" this will allow for an indication problem to notcause confusion on the need to declare.Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

Voltage is < 105 VDC on 125 VDC battery buses #1 and #2 for >15 minutes..

Page 32 of 66 0NEI 99-01 Rev 6 Proposed EAL Justification SS5Initiating Condition:

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

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

ANDc. EITHER of the following conditions exist:1. (Site-specific indication of an inability to adequately remove heat from the core)OR2. (Site-specific indication of an inability to adequately remove heat from the RCS)MS3Initiating Condition:

Inability to shutdown the reactor causing a challenge to RPV water level or RCS.heat removal.Operating Mode Applicability:

1,2Emergency Action Level (EAL):1. Automatic scram did not shutdown the reactor as indicated by Reactor Power> 5%.AND2. ALL manual / ARI actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 5%'AND3. EITHER of the following conditions exist:" RPV water level cannot be restored and maintained

> -166 inches.OR" Heat Capacity Limit (QGA 200, Figure M) exceeded.

D1 No Change M Difference Deviation 1 ) Listed site specific indications to ensure timely classification.

2) Mode 2 included in operating mode applicability as per developer notes.Page 33 of 66 0NEI 99-01 Rev 6 1 Proposed EAL Justification SAOInitiating Condition:

ALERTAutomatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor, andsubsequent manual actions taken at the reactor control consoles are notsuccessful in shutting down the reactor.Operating Mode Applicability:

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

1. a. An automatic (trip [PWR] / scram [BWRJ) did not shutdown thereactor.ANDb. Manual action taken at the reactor control consoles are notsuccessful in shutting down the reactor.MA3Initiating Condition:

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

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

1. Automatic or manual scram did not shutdown the reactor as indicated byReactor Power > 5%.AND2. Manual I ARI actions taken at the Reactor Console are not successful inshutting down the reactor as indicated by Reactor Power > 5%.FH1 No Change M Difference FIDeviation
1) Listed site specific indications to ensure timely classification.
2) Mode 2 included in operating mode applicability as per developer notes.Page 34 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU5Initiating Condition:

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

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

1. a. An automatic (trip [PWR] I scram [BWRJ) did not shutdown thereactor.ANDb. A subsequent manual action taken at the reactor control consoles issuccessful in shutting down the reactor.2. a. A manual scram ([PWR] / scram [BWR]) did not shutdown thereactor.ANDb. EITHER of the following:
1. A subsequent manual action taken at the reactor control consolesis successful in shutting down the reactor.OR2. A subsequent automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor.MU3Initiating Condition:

Automatic or manual scram fails to shutdown the reactor.FH No Change J--M Difference

'- Deviation

1) Listed site specific indications to ensure timely classification.
2) Mode 2 included in operating mode applicability as per developer notes.Operating Mode Applicability:

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

1. a. Automatic scram did not shutdown the reactor as indicated by ReactorPower > 5%ANDb. Subsequent manual / ARI action taken at the Reactor Console issuccessful in shutting down the reactor.OR2. a. Manual scram did not shutdown the reactor as indicated by ReactorPower > 5%.ANDb. EITHER of the following:
1. Subsequent manual / ARI action taken at the Reactor Console issuccessful in shutting down the reactor.OR2. Subsequent automatic scram / ARI is successful in shutting downthe reactor.Page 35 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA2Initiating Condition:

ALERTUNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.

Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Alert promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.
1. a. An UNPLANNED event results in the inability to monitor one or more of thefollowing parameters from within the Control Room for 15 minutes or longer.[see table below][ BVVR parameter list] [PWR parameter list]Reactor Power Reactor PowerRPV Level RCS LevelRPV Pressure RCS PressurePrimary Containment Pressure In Core/Core Exit Temperature Levels in at least (site specificSuppression Pool Level number) steam generators nPool Temperature Steam Generator Auxiliary orSuppression PEmergency Feed Water FlowANDb. Any of the following transient events in progress.
  • Automatic or Manual runback greater than 25% thermal reactor power* Electrical load rejection greater than 25% full electrical load* Reactor Scram [BWR] / trip [PWR]* ECCS (SI) actuation
  • Thermal power oscillations greater than 10% [BWR]MA4F No Change IDifference FI Deviation Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.

Operating Mode Applicability:

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

1. UNPLANNED event results in the inability to monitor ANY Table M1 parameter from within the Control Room for >15 minutes.Table M1 Control Room Parameters

" Reactor Power* RPV Water Level* RPV Pressure" Drywell Pressure" Torus Level" Torus Temperature AND 12. ANY Table M2 transient in progress.

Table M2 Significant Transients

" Turbine Trip" Reactor Scram" ECCS Activation

" Recirc. Runback > 25% Reactor Power Change* Thermal Power oscillations

> 10% Reactor Power ChangePage 36 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU2Initiating Condition:

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

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.

An UNPLANNED event results in the inability to monitor one or more of thefollowing parameters from within the Control Room for 15 minutes or longer.[see table below][ BWVR parameter list] [PWR parameter list]Reactor Power Reactor PowerRPV Level RCS LevelRPV Pressure RCS PressurePrimary Containment Pressure In Core/Core Exit Temperature Levels in at least (site specificSuppression Pool Level number) steam generators Steam Generator Auxiliary orSuppression Pool Temperature Emergency Feed Water FlowMU4Initiating Condition:

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

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

UNPLANNED event results in the inability to monitor ANY Table M1 parameter from within the Control Room for > 15 minutes.No Change FIDifference FIDeviation Table M1 Control Room Parameters

  • Reactor Power* RPV Water Level* RPV Pressure* Drywell Pressure* Torus Level* Torus Temperature Page 37 of 66 NEI 99-01 Rev 6 j Proposed EAL Justification SA9Initiating Condition:

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

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:1. a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)
  • Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION
  • (site-specific hazards)* Other events with similar hazard characteristics asdetermined by the Shift ManagerANDb. EITHER of the following:
1. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for thecurrent operating mode.OR2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure needed for the current operating mode.MA5Initiating Condition:

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

1,2,3Emergency Action Level (EAL):1. The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)

  • Internal or external flooding event* High winds or tornado strike* FIRE" EXPLOSION

" Other events with similar hazard characteristics as determined by the Shift ManagerAND2. EITHER of the following:

a. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMrequired by Technical Specifications for the currentoperating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure required by Technical Specifications for the current operating mode.FH No Change FI Difference
1) No additional site specific hazard notedH Deviation
2) Changed the word "needed" to "required" in the IC and "required by Technical Specification" in the EAL to be consistent with terminology used by operators andminimize confusion.

Page 38 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU4Initiating Condition:

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

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.
1. RCS unidentified or pressure boundary leakage greater than (site-specific value) for 15 minutes or longer.2. RCS identified leakage greater than (site-specific value) for 15 minutes orlonger3. Leakage from the RCS to a location outside containment greater than 25gpm for 15 minutes or longerMU6Initiating Condition:

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

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

1. RCS unidentified or pressure boundary leakage in the Drywell > 10 gpm for> 15 minutes.OR2. RCS identified leakage in the Drywell >25 gpm for > 15 minutes.OR3. Leakage from the RCS to a location outside the Drywell >25 gpm for> 15 minutes.D No Change M Difference FIDeviation
1) Listed site specific values to ensure timely classification.
2) Changed wording from containment to Drywell for clarity to better define theprimary containment structure.
3) In EAL #1 and 2 added "into the Drywell" to differentiate between EAL #1/2 and#3. Without this wording would have been in EAL #1 or #2 concurrent with #3. Withthe added wording each EAL can be called separately.

Page 39 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification Initiating Condition:

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

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods:(site-specific list of communications method2. Loss of ALL of the following ORO communications s) methods:(site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods:(site-specific list of communications methods)subInitiating Condition:

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

1,2,3MU7M No Change FIDifference FIDeviation

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

Emergency Action Level (EAL):1. Loss of ALL Table M3 Onsite communications capability affecting theability to perform routine operations.

OR2. Loss of ALL Table M3 Offsite communication capability affecting theability to perform offsite notifications.

OR3. Loss of ALL Table M3 NRC communication capability affecting the abilityto perform NRC notifications.

Table M3 Communications Capability System Onsite Offsite NRCPlant Radio XPlant Page XSound Powered Phones XAll telephone Lines (Commercial and X X Xmicrowave)

ENS X XHPN X XSatellite Phones X XPage 40 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CA2Initiating Condition:

ALERTLoss of all offsite and all onsite AC power to emergency buses for 15 minutes orlonger.Operating Mode Applicability:

Cold Shutdown, Refueling, DefueledExample Emergency Action Levels:Note: The Emergency Director should declare the Alert promptly upondetermining that 15 minutes time has been exceeded, or will likely beexceeded.

Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.CAIInitiating Condition:

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

4,5, DEmergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. Loss of ALL offsite AC power to unit ECCS buses.AND2. Failure of Unit EDG 1(2), shared EDG 1/2 and SBO DG 1(2) emergency diesel generators to supply power to unit ECCS busses.AND3. Failure to restore power to at least one unit ECCS bus in < 15 minutes fromthe time of loss of both offsite and onsite AC power.E No Change 1 1 Difference

[: Deviation

1) Listed site specific equipment to ensure timely classification.

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

UNUSUAL EVENT Initiating Condition:

C No Change Difference Deviation Loss of all but one AC power source to emergency buses for 15 minutes or longer. Loss of all but one AC power source to emergency buses for 15 minutes or 1) Listed site specific equipment to ensure timely classification.

Operating Mode Applicability:

longer.Cold Shutdown, Refueling, Defueled Operating Mode Applicability:

Example Emergency Action Levels: 4, 5, DNote: The Emergency Director should declare the Unusual Event promptly upon Emergency Action Level (EAL):determining that 15 minutes time has been exceeded, or will likely be exceeded.

Note:1. a. AC power capability to (site-specific emergency buses) is reduced to a .The Emergency Director should declare the event promptly uponsingle power source for 15 minutes or longer, determining that the applicable time has been exceeded, or will likely beAND exceeded.

b. Any additional single power source failure will result in loss of all AC 1. AC power capability to unit ECCS buses reduced to only one of thepower to SAFETY SYSTEMS.

following power sources for > 15 minutes.* Reserve auxiliary Transformer TR-12 (TR-22)* Unit auxiliary transformer TR-1 1 (TR-21)* Unit Emergency Diesel Generator

  • Station Blackout Diesel Generator
  • Unit crosstie breakersAND2. ANY additional single power source failure will result in a loss of ALL ACpower to SAFETY SYSTEMS.Page 42 of 66 NEI 99-01 Rev 6 Proposed EAL Justification NEI 99-01 Rev 6Proposed EALJustification CA6Initiating Condition

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

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

  • Internal or external flooding event* High winds or tornado strike* FIRE" EXPLOSION

" (site-specific hazards)" Other events with similar hazard characteristics asdetermined by the Shift ManagerANDb. EITHER of the following:

1. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMneeded for the current operating mode.OR2. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure needed for the currentoperating mode.CA2Initiating Condition:

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

4,5Emergency Action Level (EAL):1. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

  • Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION
  • Other events with similar hazard characteristics asdetermined by the Shift ManagerAND2. EITHER of the following:
a. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMrequired by Technical Specifications for the currentoperating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure required by technical Specifications for the current operating mode.H No Change 1 -l Difference Deviation
1) No additional site specific hazards noted2) Changed the word "needed" to "required" in the IC and "required byTechnical Specification" in the EAL to be consistent with terminology used byoperators and minimize confusion.

Page 43 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU4 CU3 D N hne D Dfeec -eitoInitiating Condition:

UNUSUAL EVENT Initiating Condition:

CU1 No Change Difference Deviation Loss of Vital DC power for 15 minutes or longer. Loss of Vital DC power for 15 minutes or longer. 1) Listed site specific voltage and equipment to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

2) Removed the word "indicated" this will allow for an indication problem to notCold Shutdown, Refueling 4, 5 cause confusion on the need to declare.Example Emergency Action Levels: Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Event promptly upon Note:determining that 15 minutes time has been exceeded, or will likely beexceeded.
  • The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beIndicated voltage is less than (site-specific bus voltage value) on required Vital DC exceeded.

buses for 15 minutes or longer.Voltage is < 105 VDC on required 125 VDC battery buses #1 and #2for> 15 minutes.Page 44 of 66 NEI 99-01 Rev 6 ] Proposed EAL Justification CU5Initiating Condition:

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

Cold Shutdown, Refueling, DefuledExample Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods:(site-specific list of communications method2. Loss of ALL of the following ORO communications s) methods:(site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods:(site-specific list of communications methods)CU4Initiating Condition:

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

4,5, DEmergency Action Level (EAL):I. Loss of ALL Table C1 Onsite communications capability affecting theability to perform routine operations.

OR2. Loss of ALL Table C1 Offsite communication capability affecting theability to perform offsite notifications.

OR3. Loss of ALL Table C1 NRC communication capability affecting theability to perform NRC notifications.

1 -l No Change [: Difference

--Deviation

1) Listed site specific communications methods to ensure timely classification Table Cl Communications Capab litySystem Onsite Offsite NRCPlant Radio XPlant Page XSound Powered Phones xAll telephone Lines (Commercial and X X Xmicrowave)

ENS x xHPN x xSatellite Phones X XPage 45 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CA3Initiating Condition:

ALERTInability to maintain the plant in cold shutdown.

Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Alert promptly upondetermining that the applicable has been exceeded, or will likely beexceeded.

1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit) for greater thanthe duration specified in the following table.2. UNPLANNED RCS pressure increase greater than (site-specific pressurereading).

(This EAL does not apply during water-solid plant conditions.

[PWRJ)CASInitiating Condition:

Inability to maintain plant in cold shutdown.

Operating Mode Applicability:

4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. UNPLANNED rise in RCS temperature

> 212?F due to loss of decayheat removal for > Table C2 duration.

M No Change E: Difference 1 Deviation

1) Listed site specific Technical Specification cold shutdown temperature limit andsite-specific pressure reading to ensure timely classification.

Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up DurationStatusIntact (but notRCS Reduced Not Applicable 60 minutes*Inventory

[PWR])Not Intact (or at Established 20 minutes*reduced inventory

[PWR]) Not Established 0 minutes* If an RCS heat removal system is in operation within this time frame andRCS temperature is being reduced, the EAL is not applicable.

Table C2 RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up DurationStatusIntact Not Applicable 60 minutes*Established 20 minutes*Not IntactNot Established 0 minutesIf an RCS heat removal system is in operation within this timeframe and RCS temperature is being reduced, then EAL #1 is notasolicable.

OR2. UNPLANNED RPV pressure rise >10 psig as a result of temperature rise due to loss of decay heat removal.Page 46 of 66 0NEI 99-01 Rev 6 Proposed EAL Justification CU3 CUS E NeInitiating Condition:

UNUSUAL EVENT Initiating Condition:

Li No Change Difference Deviation UNPLANNED increase in RCS temperature.

UNPLANNED rise in RCS temperature.

1) Listed site specific Technical Specification cold shutdown temperature limitOperating Mode Applicability:

Operating Mode Applicability:

to ensure timely classification.

Cold Shutdown, Refueling 4, 5 2) Changed the word increase to rise in the initiating condition to be consistent Example Emergency Action Levels: (1 or 2) Emergency Action Level (EAL): with operations language and training.

Note: The Emergency Director should declare the Unusual Event promptly Note:upon determining that 15 minutes time has been exceeded, or will likelybe exceeded.

The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely be1. UNPLANNED increase in RCS temperature to greater than (site-specific exceeded.

Technical Specification cold shutdown temperature limit).2. Loss of ALL RCS temperature and (reactor vesselIRCS

[PAR] or RPV[BWR8 ) level indication for 15 minutes or longer,.

UNPLANNED rise in RCS temperature>

212F due to loss of decayheat removal.OR2. Loss of the following for >15 minutes.* ALL RCS temperature indications AND* ALL RPV water level indications Page 47 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CGIInitiating Condition:

GENERAL EMERGENCY Loss of (reactor vessel/RCS (PWRJ or RPV [BWR]) inventory affecting fuel cladintegrity with containment challenged.

Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the General Emergency promptly upon determining that 30 minutes time has been exceeded, orwill likely be exceeded.

1. a. (Reactor vessel/RCS (PWR] or RPV [BWR]) vessel level less than (site-specific level) for 30 minutes or longer.ANDb. ANY indication from the Containment Challenge Table2. a.. (Reactor vessel/RCS EPWR) or RPV [SWR]) vessel level cannot bemonitored for 30 minutes or longer.ANDb. Core uncovery is indicated by ANY of the following:
  • (Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication

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

ANDc. ANY indication from the Containment Challenge Table).CG6Initiating Condition:

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

Operating Mode Applicability:

4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. a. RPV water level < -142 inches (TAF) for > 30 minutes.ANDb. Any Containment Challenge Indication (Table C4)OR2. a. RPV water level unknown for > 30 minutes.ANDb. Core uncovery is indicated by ANY of the following:
  • Table C3 indications of a sufficient magnitude to indicate coreuncovery.

OR* Fuel Handling ARM 1(2)-1705-16A or B >3000 mR/hr.ANDc. ANY Containment Challenge Indication (Table C4)-No Change Wl Difference

-- Deviation 1 ) Listed site specific levels, radiation

monitors, and sumps and tanks to ensuretimely classification.
2) Listed Explosive mixture in the Containment Challenge Table to ensuretimely classification.
3) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Table: Containment Challenge Table* CONTAINMENT CLOSURE not established*
  • (Explosive mixture) exists inside containment
  • UNPLANNED increase in containment pressure* Secondary containment radiation monitor reading above (site-specific value) [BWR]*if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency isnot required.

Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss'Rise in level is attributed to a loss of RPV inventory.

Table C4 Containment Challenge Indications

_> 6% and Oxygen> 5%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established' ANY Secondary Containment radiation monitor > QGA 300,Maximum Safe operating level.'if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency isnot required.

Page 48 of 66 NEI 99-01 Rev 6 Proposed EAL Justification NEI 99-01 Rev 6Proposed EALJustification iCS1Initiating Condition:

SITE AREA EMERGENCY Loss of (reactor vessel/RCS

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

Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 30 minutes time has been exceeded, orwill likely be exceeded.

1. a. CONTAINMENT CLOSURE not established.

ANDb. (Reactor vessel/RCS

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

ANDb. (Reactor vessel/RCS

[PIVR] or RPV [BWVRJ) level less than (site-specific level).3. a. (Reactor vessel/RCS

[PWI/R] or RPV [BVVR]) level cannot bemonitored for 30 minutes or longer.ANDb. Core uncovery is indicated by ANY of the following:

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

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

CS6Initiating Condition:

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

Operating Mode Applicability:

4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

.With CONTAINMENT CLOSURE not established, RPV water level<-65 inchesOR2. With CONTAINMENT CLOSURE established, RPV water level < -142inches (TAF)OR3. a. RPV water level unknown for > 30 minutesANDb. Core uncovery is indicated by ANY of the following:

" Table C3 indications of a sufficient magnitude to indicate coreuncovery.

OR" Fuel Handling ARM 1(2)-1705-16A or B >3000 mR/hr.Table C3 Indications of RCS Leakage-UNPLANNED floor or equipment sump level rise** UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.

[-1 No Change W Difference E ] Deviation

1) Listed site specific values for level, radiation
monitors, and sumps and tanksto ensure timely classification.
2) EAL #1 Quad Cities Station does not have a low, low, low RPV water levelvalue stated within their Technical Specifications, all ESF functions come fromthe low, low value of -55.2inches, NEI 99-01 rev 6 developer notes for CS1request the developer to use the low, low, low value for declaration of a SAEwhen Containment Closure is not established, as such an RPV water level -65inches was selected as the threshold value since it is substantially above TAFRPV water level of -142 inches and substantially below the low, low value of-55.2inches clearly indicating a worsening of the condition and the need toescalate the emergency from an Alert condition.
3) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 49 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CA1Initiating Condition:

ALERTLoss of (reactor vessel/RCS

[PWRI or RPV [BWVRI) inventory Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Alert promptly upondetermining that 15 minutes time has been exceeded, or will likely beexceeded.

1. Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory asindicated by level less than (site-specific level).2. a. (Reactor vesselIRCS

[PWR] or RPV [BWR]) level cannot bemonitored for 15 minutes or longerANDb. UNPLANNED increase in (site-specific sump and/or tank) levels dueto a loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory.

CA6Initiating Condition:

Loss of RPV inventory Operating Mode Applicability:

4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. Loss of RPV inventory as indicated by level < -59inches.

OR2. a. RPV water level unknown for> 15 minutes.ANDb. Loss of RPV inventory per Table C3 indications.

Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.

D No Change W Difference Deviation

1) Listed site specific levels, and sumps and tanks to ensure timelyclassification.
2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 50 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Cu1Initiating Condition:

UNUSUAL EVENTUNPLANNED loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory for15 minutes or longer.Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.

1. UNPLANNED loss of reactor coolant results in (reactor vessel/RCS

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

[PAR] or RPV [BWVR]) level cannot bemonitored.

ANDb. UNPLANNED increase in (site-specific sump and/or tank) levels.CU6Initiating Condition:

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

4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. UNPLANNED loss of reactor coolant results in the inability to restore andmaintain RPV water level above the procedurally established lower limitfor> 16 minutes.OR2. a. RPV water level unknownANDb. Loss of RPV inventory per Table C3 indications.

Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.

D No Change E Difference 1: Deviation

1) Described

'a required lower limit" as a procedurally established lower limit,andlisted site specific sumps and tanks to ensure timely classification.

2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 51 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HGl HGI flf f- ifeene DvitoInitiating Condition:

GENERAL EMERGENCY Initiating Condition:

iG No Change J Difference LJDeviation HOSTILE ACTION resulting in loss of physical control of the facility.

HOSTILE ACTION resulting in loss of physical control of the facility.

1) List site security shift supervision as Security Force.2) Added descriptors to better explain each safety function and allow for aOperating Mode Applicability:

Operating Mode Applicability:

timely classification.

All 1,2, 3, 4, 5, DExample Emergency Action Levels: Emergency Action Level (EAL):a. A HOSTILE ACTION is occurring or has occurred within thePROTECTED AREA as reported by the (site-specific security shift 1. A notification from the Security Force that a HOSTILE ACTION is occurring or hassupervision).

occurred within the PROTECTED AREA.ANDAND 2. a. ANY Table H1 safety function cannot be controlled or maintained.

b. EITHER of the following:

ORb. Damage to spent fuel has occurred or is IMMINENT1. ANY of the following safety functions cannot be controlled ormaintained.

Table H1 Safety Functions

  • Reactivity control .Reactivity Control* Core cooling [PWR] / RPV water level [BW4R] (ability to shut down the reactor and keep it shutdown)

RCS heat removal .RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)OR2. Damage to spent fuel has occurred or is IMMINENTPage 52 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification HSIInitiating Condition:

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

AllExample Emergency Action Levels:A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREAas reported by the (site-security shift supervision).

HSIInitiating Condition:

HOSTILE ACTION within the Protected Area.M No Change 1111] Difference

[-] Deviation

1) List site security shift supervision as Security Force.Operating Mode Applicability:

1,2, 3,4, 5, DEmergency Action Level (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.Page 53 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

ALERT Initiating Condition:

H No Change I Difference FIDeviation HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack 1) List site security shift supervision as Security Force.threat within 30 minutes.

threat within 30 minutes.Operating Mode Applicability:

Operating Mode Applicability:

All 1,2, 3,4, 5, DExample Emergency Action Levels: (1 or 2) Emergency Action Level (EAL):1. A HOSTILE ACTION is occurring or has occurred within the OWNER 1 A validated notification from NRC of an aircraft attack threat < 30 minutesCONTROLLED AREA as reported by the (site-specific security shift from the site.supervision).

2. A validated notification from NRC of an aircraft attack threat within 30 ORminutes of the site.2. Notification by the Security Force that a HOSTILE ACTION is occurring orhas occurred within the OWNER CONTROLED AREA.Page 54 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HUl HUIInitiating Condition:

UNUSUAL EVENT Initiating Condition:

[F No Change F-- Difference L Deviation Confirmed SECURITY CONDITION or threat.Confirmed SECURITY CONDITION or threat. 1) List site security shift supervision as Security Force.Operating Mode Applicabllity:

2) Further described credible security threat through listing a site specificOperating Mode Applicability:

procedure.

All1, 2, 3,4,5, DExample Emergency Action Levels: (I or 2 or 3)Emergency Action Level (EAL):1. A SECURITY CONDITION that does not involve a HOSTILE ACTION asreported by the (site-specific security shift supervision).

1. Notification of a credible security threat directed at the site as determined perSY-AA-101-132, Security Assessment and Response to Unusual Activities.
2. Notification of a credible security threat directed at the site. OR2. A validated notification from the NRC providing information of an aircraft3. A validated notification from the NRC providing information of an aircraft threat.threat.OR3. Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.Page 55 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HS6 HS2mmmInitiating Condition:

SITE AREA EMERGENCY Initiating Condition:

iS2 No Change I[ ] Difference

[ Deviation Inability to control a key safety function from outside the Control Room. Inability to control a key safety function from outside the Control Room. 1) EAL uses the site specific Control Room evacuation procedure toeffectively list all of the alternate locations, panels, and stations requested bythe developer notes. This would be the procedure the Control Room wouldOperating Mode Applicability:

Operating Mode Applicability:

enter should such an event occur, this allows for greater clarity as to whenthis EAL would apply than if each panel and station used in alternate All 1,2, 3, 4, 5, D shutdown were to be listed,2) Added descriptors to better explain each safety function and allow for aExample Emergency Action Levels: (1 and 2) Emergency Action Level (EAL): timely classification.

Note: The Emergency Director should declare the Site Area Emergency Note:promptly upon determining that (site-specific number of minutes) has 3) Changed "An event" to" A Control Room evacuation" to remove confusion been exceeded, or will likely be exceeded.

  • The Emergency Director should declare the event promptly upon determining that if partial plant control was transferred to outside the control room with thethe applicable time has been exceeded, or will likely be exceeded.

control room still manned, due to testing or equipment failure.1. An event has resulted in plant control being transferred from the ControlRoom to (site-specific remote shutdown panels and local control stations).

1 A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per2. Control of ANY of the following key safety functions is not reestablished

  • QCARP 0050-01, SB-i-1 Injection with SSMP and Bringing the Unit towithin (site-specific number of minutes).

Cold ShutdownORReactivity control .OCARP 0050-02, SB-I-1 Injection with RCIC and Bringing the Unit to* Core cooling [PWR] / RPV water level [BWR] Cold Shutdown* RCS heat removal OR.QOA 0010-05, Plant Operation with the Control Room Inaccessible AND2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.Table H1 Safety Functions

  • Reactivity Control(ability to shut down the reactor and keep it shutdown)
  • RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Page 56 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HAS H'A2 mmmInitiating Condition:

ALERT Initiating Condition:

[J No Change [j- Difference FIDeviation Control Room evacuation resulting in transfer of plant control to altemate locations.

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

1) EAL uses the site specific Control Room evacuation procedure to effectively listall of the alternate locations, panels, and stations requested by the developer notes. This would be the procedure the Control Room would enter should such anOperating Mode Applicability:

Operating Mode Applicability:

event occur, this allows for greater clarity as to when this EAL would apply than ifeach panel and station used in alternate shutdown were to be listed,All 1, 2, 3,4,5, 02) Changed "An event" to" A Control Room evacuation" to remove confusion ifpartial plant control was transferred to outside the control room with the controlExample Emergency Action Levels: Emergency Action Level (EAL): room still manned, due to testing or equipment failure.An event has resulted in plant control being transferred from the Control Room to(site-specific remote shutdown panels and local control stations).

A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per:* QCARP 0050-01, SB-i-i Injection with SSMP and Bringing the Unit toCold ShutdownOR* QCARP 0050-02, SB-I-1 Injection with RCIC and Bringing the Unit to ColdShutdownOR* QOA 0010-05, Plant Operation with the Control Room Inaccessible Page 57 of 66 NEI 99-Cl Rev 6 1 Proposed EAL Justification HU4HU3Initiating Condition:

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

Initiating Condition:

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

1,2,3,4,5, DM No Change I Difference FIDeviation

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

AllExample Emergency Action Levels: (1 or 2 or 3 or 4)Note: The Emergency Director should declare the Unusual Eventpromptly upon determining that the applicable time has beenexceeded, or will likely be exceeded.

a. A FIRE is NOT extinguished within 15-minutes of ANY of thefollowing FIRE detection indications:
  • Report from the field (i.e., visual observation)
  • Receipt of multiple (more than 1) fire alarms or indications
  • Field verification of a single fire alarmANDb. The FIRE is located within ANY of the following plant rooms orareas:(site-specific list of plant rooms or areas)2. a. Receipt of a single fire alarm (i.e., no other indications of a FIRE).ANDb. The FIRE is located within ANY of the following plant rooms orareas:(site-specific list of plant rooms or areas)ANDc. The existence of a FIRE is not verified within 30-minutes of alarmreceipt.3. A FIRE within the plant or ISFSI [for plants with an ISFSI outside theplant Protected Area] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.
4. A FIRE within the plant or ISFSI [for plants with an ISFSI outside theplant Protected Area] PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

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

A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of thefollowing FIRE detection indications:

  • Report from the field (i.e., visual observation)
  • Receipt of multiple (more than 1) fire alarms or indications
  • Field verification of a single fire alarmTable H2 Vital Areas* Reactor Building (when inerted the Drywell is exempt)* Main Control Room Envelope* Unit and Shared Emergency Diesel Generator Rooms* 4KV Switchgear Area* Battery Rooms* RHR Service Water Vaults* Turbine Building Cable Tunnel* Cribhouse OR2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of aFIRE).ANDb. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.OR3. A FIRE within the plant or ISFSI PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication.

OR4. A FIRE within the plant or ISFSI PROTECTED AREA that requires firefighting supportby an offsite fire response agency to extinguish.

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

UNUSUAL EVENT Initiating Condition:

LJ No Change M Difference Deviation Seismic event greater than OBE levels. Seismic event greater than OBE levels. 1) Used Alternate developer notes allowed wording since specific Control Roomindication of a seismic event > OBE is not available.

Operating Mode Applicability:

Operating Mode Applicability:

All1,2,3,4, 5, DExample Emergency Action Levels:Emergency Action Level (EAL):Seismic event greater than Operating Basis Earthquake (OBE) as indicated by:a. (site-specific indication that a seismic event met or exceeded OBE limits) 1. Control Room personnel feel an actual or potential seismic event.AND2. The occurrence of a seismic event is confirmed in a manner deemedappropriate by the Shift Manager or Emergency Director.

Page 59 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HA5i HA5if~f~Initiating Condition:

ALERT Initiating Condition:

[AS M No Change [,, Difference

[F, Deviation Gaseous release impeding access to equipment necessary for normal plant Gaseous release impeding access to equipment necessary for normal plant operations,

1) Listed plant specific rooms and areas with entry related mode applicability tooperations, cooldown or shutdown.

cooldown or shutdown.

ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

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

  • If the equipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emergency classification is1. a. Release of a toxic, corrosive, asphyxiant or flammable gas into any warranted.

of the following plant rooms or areas:(site-specific list of plant rooms or areas with entry-related mode 1. Release of a toxic, corrosive, asphyxiant or flammable gas in a Table H3 area.applicability identified)

Table H3AND Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability

b. Entry into the room or area is prohibited or impeded.Reactor Building*

Mode 3 and 4Turbine Building*

Mode 3-Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impeded.Page 60 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENTHazardous EventOperating Mode Applicability:

HU3AllExample Emergency Action Levels: (1 or 2 or 3 or 4)Note: EAL #3 does not apply to routine traffic impediments such as fog, snow,ice, or vehicle breakdowns or accidents.

I. A tornado strike within the PROTECTED AREA.2. Internal room or area flooding of a magnitude sufficient to require manualor automatic electrical isolation of a SAFETY SYSTEM component neededfor the current operating mode.3. Movement of personnel within the PROTECTED AREA is impeded due toan offsite event involving hazardous materials (e.g., an offsite chemicalspill or toxic gas release).

4. A hazardous event that results in on-site conditions sufficient to prohibitthe plant staff from accessing the site via personal vehicles.
5. (Site-specific list of natural or technological hazard events)HU6Initiating Condition:

Hazardous EventOperating Mode Applicability:

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

1. Tornado strike within the PROTECTED AREA.OR2. Internal room or area flooding of a magnitude sufficient to require manual orautomatic electrical isolation of a SAFETY SYSTEM component required byTechnical Specifications for the current operating mode.OR3. Movement of personnel within the PROTECTED AREA is impeded due to anoffsite event involving hazardous materials (e.g., an offsite chemical spill ortoxic gas release).

OR4. A hazardous event that results in on-site conditions sufficient to prohibit theplant staff from accessing the site via personal vehicles.

OR5. Abnormal River level, as indicated by EITHER:a. High river level > 594 ft.ORb. Report of substantial reduction in river level by site personnel andconfirmation by the Corp. of Engineers that Dam #14 has failed.D] No Change n Difference

-] Deviation

1) Included River water level as part of the site specific list of natural ortechnological hazard events. The EAL values selected are the current approvedEALt UE values.2) Changed the word "needed" to "required by Technical Specifications" in the EALto be consistent with terminology used by operators and minimize confusion.

Page 61 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HG7 HG7Initiating Condition:

GENERAL EMERGENCY Initiating Condition:

[i No Change U Difference U Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a General Emergency.

declaration of a General Emergency.

Operating Mode Applicability:

Operating Mode Applicability:

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

Releases can be reasonably expected to exceed EPA Protective Action integrity or HOSTILE ACTION that results in an actual loss of physical control ofGuideline exposure levels off-site for more than the immediate site area. the facility.

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area..Page 62 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HS7 HS7 m D neInitiating Condition:

SITE AREA EMERGENCY Initiating Condition:

L No Change Difference Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a Site Area Emergency.

declaration of a Site Area Emergency.

Operating Mode Applicability:

Operating Mode Applicability:

All 1,2, 3,4, 5, DExample Emergency Action Levels: Emergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicate Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or likely majorfailures of plant functions needed for protection of the public or HOSTILE ACTION that events are in progress or have occurred which involve actual or likely majorthat results in intentional damage or malicious acts; (1) toward site personnel or failures of plant functions needed for protection of the public or HOSTILE ACTIONequipment that could lead to the likely failure of or; (2) that prevent effective that results in intentional damage or malicious acts; (1) toward site personnel oraccess to equipment needed for the protection of the public. Any releases are not equipment that could lead to the likely failure of or; (2) that prevent effective expected to result in exposure levels which exceed EPA Protective Action access to equipment needed for the protection of the public. Any releases are notGuideline exposure levels beyond the site boundary.

expected to result in exposure levels which exceed EPA Protective ActionGuideline exposure levels beyond the site boundary.

Page 63 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

ALERT Initiating Condition:

[jj No Change [j Difference Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an Alert. declaration of an Alert.Operating Mode Applicability:

Operating Mode Applicability:

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

UNUSUAL EVENT Initiating Condition:

LUh No Change [j Difference Deviation Other conditions existing which in the judgment of the Emergency director warrantdeclaration of an UNUSUAL EVENT. Other conditions existing which in the judgment of the Emergency director warrantdeclaration of an UNUSUAL EVENT.Operating Mode Applicability:

Operating Mode Applicability:

All1, 2, 3,4, 5, DExample Emergency Action Levels:Other conditions exist which in the judgment of the Emergency Director indicate Emergency Action Level (EAL):that events are in progress or have occurred which indicate a potential Other conditions exist which in the judgment of the Emergency Director indicatedegradation of the level of safety of the plant or indicate a security threat to facility that events are in progress or have occurred which indicate a potential protection has been initiated.

No releases of radioactive material requiring offsite degradation of the level of safety of the plant or indicate a security threat to facilityresponse or monitoring are expected unless further degradation of safety systems protection has been initiated.

No releases of radioactive material requiring offsiteoccurs. response or monitoring are expected unless further degradation of safety systemsoccurs.Page 65 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification E-HU1E-HU1Initiating Condition:

UNUSUAL EVENTDamage to a loaded cask CONFINEMENT BOUNDARY.

Operating Mode Applicability:

Initiating Condition:

Damage to a loaded cask CONFINEMENT BOUNDARY.

Operating Mode Applicability:

1, 2,3,4,5, DF1 No Change 1-- Difference FIDeviation

1) Listed 2x the site specific cask specific allowable radiation level as perCertificate of Compliance No. 1014 Appendix A Section 5.7.AllExample Emergency Action Levels:Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specifictechnical specification allowable radiation level) on the surface of the spent fuelcask.Emergency Action Level (EAL):Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading:* > 40 mr/hr (gamma + neutron) on the top of the spent fuel caskOR* > 220 mr/hr (gamma + neutron) on the side of the spent fuel cask,excluding inlet and outlet ducts.Page 66 of 66 I=xAInn N.nlmarOijad Citiesa Annex Exelnn NucleIuar RECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARGIInitiating Condition:

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

1, 2,3,4,5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the General _mer=.gency event promptly upondetermining that the applicable time has been exceeded, or will likely be exceeded.

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

If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.

" The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.

(1) Reading on ANY of the following radiation monitor-s greater than the reading shownfor 15 miueso longer:ý(Site Specific monitor list and threshold v:alues)1. The sum of readings on the Rx Bldg and Chimney SPINGs > 3.84 E+09 uCilsec for >15 minutes (as determined by Control Room Panels or PPDS -Total Noble GasRelease Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond (site-speGifi dose receptor POW. ) the site boundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidORMonth 20XXQC 3-1EP-AA-1006 (Revision XX) r1iiesA fifimom AnnmvIP=alnn MnilanrS.'U;I *ll l rl =III 5fl kA~l.I 11 .51 l ilRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS FWild- SU ...y results indicate EITHER of the following at OF beyond (site specific dose,e veptOFv,

.-.,,Closed window do6e rates greater than 1,000 mR'~hr expected to continue for60 minutes or longer.Analyses of field- survey sampler, indicato thyroid CDE greater than 5,000 mrFem:3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected to continuefor > 60 minutes.ORb. Analyses of field survey samples indicate

> 5000 mRem CDE Thyroid for60 minutes of inhalation.

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

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

The TEDE dose is set at the EPA PAG of 1000 mRrem while the 5000 mRem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Classification based on effluent monitor rcadings assumes that. a release path to theenlVironment is established.

if the effluent flow past an effluent monGitor is known to havstopped due to actions to isolate the release path, then the effluent mon0itor reading is- nolonger Valid. f9or clasAsi-ation purposes.

Basis Reference(s):

1. NEI 99-01 Rev 6, AG12. EP-EAL-0606 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Quad Cities StationMonth 20XXQC 3-2EP-AA-1006 (Revision XX)

(I"orl Mfiaa Annov=vm1en kimie-Igftr flu~~~~~_ý.v vvIIiio~wz Fý"rffI.m.I~

RECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARS1Initiating Condition:

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

1, 2,3, 4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the Site Area Emergency event promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.

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

If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.

" The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.

(1) Reading on ANY of the WoloG.ing radiation monitors greater than the reading shownfQr 15 minutes Or Ionger:(Site spc oii aInd threshold values)(2) Dorse assessment using actual meteorology indicates doses greater than 100TEDE or 500 thyrod DE at or beyond (,ite Sp;cifc dose (3) Field survey reaults indicate EITHER of the fllimneg at Or beyond (>ite EpeCificdose receptor poGint):*Closed window dose rates greater than 100 mR'hrf expeeted to coentinlue for- 60 minuteser- lengefn9, Analyses of field survey samples indicate thyroeid CDE greater-than 500 mrwem for- onehour- of inthalation.

3. 1. The sum of readings on the Rx Bldg and Chimney SPINGs > 3.84 E+08 uCllsecfor > 15 minutes (as determined by Control Room Panels or PPDS -Total Noble GasRelease Rate).ORMonth 20XXQC 3-3EP-AA-1006 (Revision XX) flimnrl f'ifidsa AnnghvI::vy--Inn k,,rl--ghr nil an (~i*rne Annav Fva Ii~n him u,.IaarRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS
2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 100 mRem TEDEORb. > 500 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >100 mR/hr are expected to continuefor > 60 minutes.ORb. Analyses of field survey samples indicate

> 500 mRem CDE Thyroid for 60minutes of inhalation.

Basis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite 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 areassociated 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 andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1000 mRrem while the 500 mRfemthyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDEand thyroid CDE.Classific~ation based on effluent monitor readings assumes that a release path tothe enVIronment is established.

If the effluent filw past aI effluent onitor is known tohave stopped due to actions to isolate the ree I pah, then the effluent monAitor readingis no longer valid for classification purposes.

Escalation of the emergency classification level would be via IC RAG1.Basis Reference(s):

1. NEI 99-01 Rev 6, AS1Month 20XXQC 3-4EP-AA-1006 (Revision XX)

Exalon NuclearQuad Cities Annex Eeo ulaRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

2. EP-EAL-0606 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Quad Cities StationMonth 20XXQC 3-5EP-AA-1006 (Revision XX) t'limarl Pifiae AnnnvI=:y--nn N~t-lazar Amman r~it;~ Ann~w Fv~Inn I~J..vIoar RECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS Initiating Condition:

ARA1 IRelease of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mR-emTEDE or 50 mRfem thyroid CDE.Operating Mode Applicability:

1, 2, 3, 4, 5, DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the Ale4-event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

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

If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.

  • The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.

rllfor 15 minutes Or longer:.(site sperific monitor list and threshold value&)(2) Do.e asserssment using ac.tual meteero1rgY i.ndiates doses. greater thaRn 10 mRm..TEDE or 50o mrem thyro-id C-DEM at or bevond (site se~ecfi dose Fece~tGr Do9intLI l *(3) Analysis of a liquid effluent sample indieates a conc-entrantion or releas14e rate thatwould result in doses greater than 10 FW.mrvm TEDE Or 50 mne. thyroid MDE At orbeyond (Site specific doerc Ptooint) for one hour of texposure.

(4) Field survey results indicate EITHER of the following at or beyond (cite .pecificdoserecepto pint):." Closed window dose rats gr-eater-than 10 mR'hrexpected to continue for- 60 minutes or" Analyses of field sur.'ey samples iadiceAc thyroid CDE gr-eater thin 50 ffwem for- oefhour Of inhalatien.

Month 20XXQC 3-6EP-AA-1006 (Revision XX)

Exalon NuclaarOuad Cities Annex Eeo ulaRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

1. The sum of readings on the Rx Bldg and Chimney SPINGs > 3.84 E+07 uCilsecfor > 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble GasRelease Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 50 mRem CDE ThyroidOR3. Analysis of a liquid effluent sample indicates a concentration or release rate thatwould result in doses greater than EITHER of the following at or beyond the siteboundarya. 10 mRem TEDE for 60 minutes of exposureORb. 50 mRem CDE Thyroid for 60 minutes of exposureOR4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mR/hr are expected tocontinue for_> 60 minutes.ORb. Analyses of field survey samples indicate

> 50 mRem CDEThyroid for 60 minutes of inhalation.

Basis:This IC addresses a release of gaseous or liquid radioactivity that results in projected oractual 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 thismagnitude represent an actual or potential substantial degradation of the level of safety ofMonth 20XXQC 3-7EP-AA-1006 (Revision XX)

Quad Cities AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS 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 andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1000 mRfem while the 50 mRfem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Classific-ation based on offluont monitor readings

assumes, that a roloase path tthe is establihe.

If the AMlu, nt flow part an effluent monit is~l known to.-, -.. .. ... -.';.

rchave stopped due to- ac--9tion to igsolate-the release path, then the effluen~t mon~itOF read~ingis noe longer valid for cliiaIo proe. SEscalation of the emergency classification level would be via IC RAS1.Basis Reference(s):

1. NEI 99-01 Rev 6, AA12. EP-EAL-0606 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Quad Cities StationMonth 20XXQC 3-8EP-AA-1006 (Revision XX)

Ouad Cities Annex Exelon NucilearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARUMInitiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM (site- speifireffluent document) limits for 60 minutes or longer.Operating Mode Applicability:

1, 2, 3, 4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the Unusual E vent event promptly upondetermining that 60 -iiwtesthe applicable time has been exceeded, or will likely beexceeded.

" If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established.

If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.

(1) Reading on A NY effluenRt radiation monitor greater than 2 times the (site specificeffuen reease cOntrolling documnent) limits for 60 mninutes or longer:-(site specific-monitor li6t and threshold values corresponding to 2 times thecontrolling docum~ent limits)(2) ReadinRg on A NY e-ffluenAt radiation monFitor groAator-than 2times the alarm setpinet-ablished by a current radioactivi,'

discharge permit fogr 6-0) minuItes6 Or longer.(3) Samnple analysis for a g~asouso;r liquid release indicates a conentratieono repleamse ra-te greater than 2 times, the (site spec-ific effluenA-t release controlling document) limits- for- 6-0 mninutes Or longer.1 .Reading on any of the following effluent monitors

> 2 times alarm setpointestablished by a current radioactive release discharge permit for 2! 60 minutes.* Radwaste Effluent Monitor 1/2-1799-01 OR" Discharge Permit specified monitorOR2. The sum of readings on the Rx Bldg and Chimney SPINGs > 4.38 E+05 uCi/secfor > 60 minutes (as determined Control Room Panels or PPDS -Total NobleGas Release Rate).Month 20XXQC 3-9EP-AA-1006 (Revision XX)

Quad Cities AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS LVACIand SGrIS Rn4dation onitor;r.1706 17 )2fond on Control room8 ---Panels-OF-OR

3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of > 60 minutes.Basis:This IC addresses a potential decrease in the level of safety of the plant as indicated by alow-level radiological release that exceeds regulatory commitments for an extendedperiod of time (e.g., an uncontrolled release).

It includes any gaseous or liquidradiological

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 ofradioactive effluents to the environment.

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

The occurrence of an extended, uncontrolled radioactive release to theenvironment is indicative of degradation in these features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.

Classifiati-n based oR effluent readi;ngs asumes that a Frlaso paththe enyiro~nmePnt_

is established-.

If the effluent-flowt pact an efflueAnt_

moitr i kno~Wn tohav tpped due to actions to isolate the release path, then the effluent mon;itor readingis no longer valid foar c~lassific-atio pupoe.Releases should not be prorated or averaged.

For example, a release exceeding 4 timesrelease limits for 30 minutes does not meet the EAL.EAL #1 BasisEAL--#2--

This EAL addresses radioactivity releases that cause effluent radiation monitorreadings to exceed 2 times the limit established by a radioactivity discharge permit. ThisEAL will typically be associated with planned batch releases from non-continuous releasepathways (e.g., radwaste, waste gas).The effluent monitors listed are those normally used for planned discharges.

If adischarge is performed using a different flowpath or effluent monitor other than thoselisted (e.g., a portable or temporary effluent monitor),

then the declaration criteria will bebased on the monitor specified in the Discharge Permit.EAL #2 BasisEAL-#-I-This EAL addresses normally occurring continuous radioactivity releases frommonitored gaseous OFrlilquid-effluent pathways.

Month 20XXQC 3-10EP-AA-1006 (Revision XX)

(Iiind (Nfigm. Annoyl::xelnn flmmnI Ci~cu Anv Fe~nn NucleharRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS EAL #3 Basis#3 -This EAL addresses uncontrolled gaseous or liquid releases that are detectedby sample analyses or environmental

surveys, particularly on unmonitored pathways(e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river watersystems, etc.).Escalation of the emergency classification level would be via IC RAA1.Basis Reference(s):
1. NEI 99-01 Rev 6, AU12. EP-EAL-0606 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Quad Cities StationMonth 20XXQC 3-11EP-AA-1006 (Revision XX)

I=xelon NuclearOuiad Cities Annex Exellon NucleanrRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARA2 IInitiating Condition:

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

1, 2,3, 4,5, DEmergency Action Level (EAL):=="=! 1K1Q- r3A-rU1A1AN/

'-I1I 7 f t* *l .Iy* *I * * ...(2) Damage to irraidiaEtedC-fu-el reSUlting in a release of radioactivity from the fuel asinicte by 'ANY of the folloin~g radiation monitors:

(site specific liStinig Of radiation

monitors, and the associated readings&,

setpoints and/40r allarm)(3) Lowering of spent fuel pool level to (site specific Level 2 value). [320e Deve~opoNoto&J1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel asindicated by ANY Table R1 Radiation Monitor reading >1000 mRemlhrTable R1Fuel Handling Incident Radiation Monitors0 1(2) 1705-16A Fuel Pool Rad Monitor0 1(2) 1705-16B Fuel Pool Rad MonitorBasis:REFUELING PATHWAY:

all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.IMMINENT:

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

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

Month 20XXQC 3-12EP-AA-1006 (Revision XX)

OsiuI Cities Annex ExeIon NuclanrRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel ~ ~ ~ ýMW~ assmby. orasnFiat oong Of Water levrel within the spent fel poo! (seofuel assembly

... a ....- ." "-- .....' .... .-We ...'" D..veoe.

N.. tes). These events present radiological safety challenges to plantpersonnel 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 theplant.This IC applies to irradiated fuel that is licensed for dry storage up to the point that theloaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss ofthe 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 BasisRAI *4This EAL escalates from RAU2 in that the loss of level, in the affected portion of theREFUELING

PATHWAY, is of sufficient magnitude to have resulted in uncovery ofirradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visualobservation (e.g., reports from personnel or camera images),

as well as significant changes in water and radiation levels, or other plant parameters.

Computational aidsmay also be used (e.g., a boil-off curve). Classification of an event using this EAL shouldbe 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 loweringof water level in some portion of the REFUELING

PATHWAY, the reading may not be areliable indication of whether or not the fuel is actually uncovered.

To the degreepossible, readings should be considered in combination with other available indications ofinventory loss.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.EAL #2 BasisEAL-#2This EAL addresses a release of radioactive material caused by mechanical damage toirradiated fuel. Damaging events may include the dropping, bumping or binding of anassembly, 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 apotential fuel damaging event (e.g., a fuel handling accident).

Escalation of the emergency would be based on either Recognition Category RA-or CICs.Month 20XXQC 3-13EP-AA-1006 (Revision XX)

O.iad Riesw Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS Spent fuel pool Wator level at this value is Within the loWer And of the level rangenecessary to preVent significant dose consequencaes from direct gamrma radiation topersonnel po~ferming Operations in the vicainity of the spent fuel pool. Thiscodtn refloc~te a significant losr, of spent fuel pool Water inventor; and thus iot. is aloa precursor to a loss of the ability to adequately cOOl the irradiated fuel assembles stored in the polEscralat-ion of the Wemegency c-lassific~ation level would be via IQ; ASI1 or A82 (sag ASL2Devoloe,

,oth).;,Basis Reference(s):

1. NEI 99-01 Rev 6, AA2Month 20XXQC 3-14EP-AA-1006 (Revision XX) n"nrl r-ifina AnnavI=Y,-nn N, ielan-r0. .~ ri (~i*igi@

Annoy Fvolnn MivIa~rRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARU2Initiating Condition:

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

1,2,3,4,5, DEmergency Action Level (EAL):(1) a. UNPLAlNNED water level drop in the REFUELING PATHWAIAY as inrdicatby ANY of the following:

(site specific level indieatiens).

b. UNPLANNED rie inae adiation levels as indlicated by ANY of thefollowing radiation monitors.

(site spocific list of area radiation menitor-s)

1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANYof the following:

" Refueling Cavity water level < 282 in. (Upper Wide Range simulated signal).OR* Spent Fuel Pool water level < 19 ft. above the fuel (<4 ft indicated level).OR* Indication or report of a drop in water level in the REFUELING PATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable R1.Table RIFuel Handling Incident Radiation Monitors* 1(2) 1705-16A Fuel Pool Rad Mon* 1(2) 1705-16B Fuel Pool Rad MonMonth 20XXQC 3-15EP-AA-1006 (Revision XX) flivmA r'i#iga Anng%,wP:valnn Kii-rloor A. .~ ,I 1~.*rne Annn~v Fvair~n Mm.rIc~rRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS Basis:UNPLANNED:

A parameter change or an event that is not 1) the result of an intendedevolution 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 whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.This IC addresses a loss in water level above irradiated fuel sufficient to causeelevated radiation levels. This condition could be a precursor to a more serious eventand is also indicative of a minor loss in the ability to control radiation levels within theplant. It is therefore a potential degradation in the level of safety of the plant.A water level deerease-loss will be primarily determined by indications from available levelinstrumentation.

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

A significant drop in the waterlevel may also cause an increase in the radiation levels of adjacent areas that can bedetected by monitors in those locations.

The effects of planned evolutions should be considered.

For example, a refueling bridgearea radiation monitor reading may increase due to planned evolutions such as lifting ofthe 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 inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RAA2.Basis Reference(s):

1. NEI 99-01 Rev 6, AU22. Technical Specification 3.7.83. Technical Specification 3.9.6Month 20XXQC 3-16EP-AA-1006 (Revision XX) flvaýA ('Mgs4m AnngavI::valnn ki~rl-,ldr RECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARA3 IInitiating Condition:

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

Operating Mode Applicability:

1, 2, 3, 4, 5, DEmergency Action Level (EAL):Note:If the equipment in the listed-room or area listed in Table R3 was already inoperable, orout of service, before the event occurred, then no emergency classification is warranted toContr@Ioleefom G enftral Al---m Station0 (other Site Specifi ar-eaSrooms)

I^\ A I I i I A ill *JL--6A)in AR WNPUNNNI-w event rosults 1n Faalialion levels that WGRoENio Or iMDPeA RGracces tany; of the folloWing plant Fooms OF areas:(site 6necific

!irt of ilant reoms Or areas with entr related Mode

...... F .....v............

jV-Io1. Dose rate geate--than>

15 mR/hr in ANY of the areas contained in Table R2:Table R2Areas Requiring Continuous Occupancy

" Main Control Room (Unit 1 ARM Station #22)" Central Alarm Station -(by survey)OR2. UNPLANNED event results in radiation levels that prohibit or significantly impedeaccess to any of the areas contained in Table R3:Month 20XXQC 3-17EP-AA-1006 (Revision XX) flomri fifimcz AnngwvI:v,-Inn Mlill-,ar RECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS Table R3Areas with Entry Related Mode Applicability Area Entry Related ModeApplicability Reactor Building*

Mode 3 and 4Turbine Building*

Mode 3*Areas required to establish shutdown coolingBasis:UNPLANNED:

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

The cause of the parameter change or event may be known or unknown.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient topreclude or impede personnel from performing actions necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal plantproceduresmaintain norm.al plant operation, Or to perform a normF.al plant c .oldown ansh'tdown.

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

Table R3 is a list of plant rooms or areas with entry-related mode applicability that containequipment which require a manual/local action necessary to transition the plant fromnormal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling),

where if this action is not completed the plantwould not be able to attain and maintain cold shutdown.

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

Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including theControl Room.For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, ormay be, procedurally required during the plant operating mode in effect and the elevatedradiation levels preclude the ability to place shutdown cooling in serviccat the time of theelevated radiation levels. The emergency classification is not contingent upon whetherentry is actually necessary at the time of the increased radiation levels. Access should beconsidered as impeded if extraordinary measures are necessary to facilitate entry ofpersonnel into the affected room/area (e.g., installing temporary shielding beyond thatrequired by procedures, requiring use of non-routine protective equipment, requesting anextension in dose limits beyond normal administrative limits).Month 20XXQC 3-18EP-AA-1006 (Revision XX)

Exalon NuclearOuad Cities Annex ExlnNcEar RECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS 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 affectedroom/area (i.e., entry is not required during the operating mode in effect at the time ofthe elevated radiation levels).

For example, the plant is in Mode 1 when the radiation increase occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4." The increased radiation levels are a result of a planned activity that includescompensatory measures which address the temporary inaccessibility of a room orarea (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections).

" The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category RA, Cor F ICs.Basis Reference(s):

1. NEI 99-01 Rev 6, AA32. FSAR Section 3.2Month 20XXQC 3-19EP-AA-1006 (Revision XX) nmvmA ifigsim Annghwi::Ylnn N,,P-lan::r Am.~rI f~4a~ Aatui~w Fvair~n Mi urIn~rRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS SRU3Initiating Condition:

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

1,2,3Emergency Action Level (EAL):(I) (Site specific.

radiation moenitor) reading greater than (site specific value)-.(2) Sample analysis indicates that a reactorcoolant actvity value as greater than ana.llow-able Im;it ;pe ,ified in Technical Spcfi÷atiOnc.

1. Offgas system radiation monitor HI-HI alarm.OR2. Specific coolant activity

> 4.0 uClIgm Dose equivalent 1-131.Basis:This IC addresses a reactor coolant activity value that exceeds an allowable limitspecified in Technical Specifications.

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

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

Fuel claddamage should be assumed to be the cause of elevated Reactor Coolant activity unlessanother cause is known.Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category RA ICs.Basis Reference(s):

1. NEI 99-01 Rev 6, SU32. Technical Specifications 3.4.63. Technical Specifications 3.7.6Month 20XXQC 3-20EP-AA-1006 (Revision XX)

A. .21 (difiaa AnnavI~vnlt~n k~l-I-mrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FG1Initiating Condition:

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

1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):

1 .NEI 99-01 Rev 6, Table 9 I4Table 9-F-2Month 20XXQC 3-21EP-AA-1006 (Revision XX)

(1"nrl ('ifiaa AnnavI:va,-nn K,,r-l,--r A. .~ ri t~itic~@

Annoy Fvolnn N. .rIa~rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FS1Initiating Condition:

Loss or Potential Loss of ANY two barriers.

Operating Mode Applicability:

1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3Table 9-F-2Month 20XXQC 3-22EP-AA-1006 (Revision XX)

Quad Cities AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FAIInitiating Condition:

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

1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the Alert classification level, Fuel Cladding and RCS barriers are weighted moreheavily than the Containment barrier.

Unlike the Containment

barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability.

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

1. NEI 99-01 Rev 6, Table 9-F 3Table 9-F-2Month 20XXQC 3-23EP-AA-1006 (Revision XX)

Quad Cities AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC1Initiating Condition:

RCS ActivityOperating Mode Applicability:

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

LOSSA. (Site Spcciftic ndicatiens that reactor coolant activity is grcatcr than 300uGi/gmR doc......I 3!)Coolant activity

> 300 uCilgm Dose Equivalent 1-131.Basis:This threshold indicates that RCS radioactivity concentration is greater than 300 ýiCi/gmdose equivalent 1-131. Reactor coolant activity above this level is greater than thatexpected for iodine spikes and corresponds to an approximate range of 2% to 5% fuelclad damage. Since this condition indicates that a significant amount of fuel claddamage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highlyelevated activity levels could require several hours to complete.

Nonetheless, asample-related threshold is included as a backup to other indications.

There is no Potential Loss threshold associated with RCS Activity.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table-9F-4Table 9-F-2Month 20XXQC 3-24EP-AA-1006 (Revision XX)

NuclAarOijad Cities Anne~x Exelnn Nuclea~rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC2Initiating Condition:

RPV Water LevelOperating Mode Applicability:

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

LOSSA-.-1. Plant conditions indicate Primary Crontainment flooding is required.

POTENTIAL LOSSA-.2. RPV water level cannot be restored and maintained abovo (site specific RPVwateF. level GOg ...... .. hE , .fuel)..,,,>

-142 inches (TAF)3. RPV water level cannot be determined.

Basis:RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.

Loss 2AThreshold

  1. 1 BasisThe Loss threshold represents the EOP requirement for primary containment flooding.

This is identified in the BWROG F-PGsEOPs/SAGsSAMGs when the phrase, "PrimaryContainment Flooding Is Required,"

appears.

Since a site-specific RPV water level isnot specified here, the Loss threshold phrase, "Primary containment flooding required,"

also accommodates the EOP need to flood the primary containment when RPV waterlevel cannot be determined and core damage due to inadequate core cooling isbelieved to be occurring.

Potential Loss 2-,AThreshold

  1. 2 and #3 BasisThis water level corresponds to the top of the active fuel and is used in the EOPs toindicate a challenge to core cooling.The RPV water level threshold is the same as RCS baF-ei-Barrier Loss threshold-24A.

Thus, this threshold indicates a Potential Loss of the Fuel Clad barrier and a Loss of theRCS barrier that appropriately escalates the emergency classification level to a SiteArea Emergency.

This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV-wat&RPV water level cannot be restored and maintained above thespecified level following depressurization of the RPV (either manually, automatically orby failure of the RCS barrier) or when procedural guidance or a lack of low pressureRPV injection sources preclude Emergency RPV depressurization.

EOPs allow theMonth 20XXQC 3-25EP-AA-1006 (Revision XX)

Quad Cities AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION operator a wide choice of RPV injection sources to consider when restoring RPV waterlevel to within prescribed limits. EOPs also specify depressurization of the RPV in orderto facilitate RPV water level control with low-pressure injection sources.

In some events,elevated RPV pressure may prevent restoration of RPV water level until pressure dropsbelow the shutoff heads of available injection sources.

Therefore, this Fuel Clad barrierPotential Loss is met only after either: 1) the RPV has been depressurized, or requiredemergency RPV depressurization has been attempted, giving the operator anopportunity to assess the capability of low-pressure injection sources to restore RPVwater level or 2) no low pressure RPV injection systems are available, precluding RPVdepressurization in an attempt to minimize loss of RPV inventory.

The term "cannot be restored and maintained above" means the value of RPV waterlevel is not able to be brought above the specified limit (top of active fuel). Thedetermination requires an evaluation of system performance and availability in relationto the RPV water level value and trend. A threshold prescribing declaration when athreshold value cannot be restored and maintained above a specified limit does notrequire immediate action simply because the current value is below the top of activefuel, but does not permit extended operation below the limit; the threshold must beconsidered reached as soon as it is apparent that the top of active fuel cannot beattained.

Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator todeliberately lower RPV water level to the top of activ" fuel in order to reduce reactorpower. RPV water level is then contro.lled beteen the top of activ; fu!l and theMinimum Steam Cooling RPV V^ater Level Although such action is achallenge to core cooling and the Fuel Clad barrier, the immediate need to reducereactor power is the higher priority.

For such events, ICs SA5-MA3 or SS5-MS3 willdictate the need for emergency classification.

Since the loss of ability to determine if adequate core cooling is being provided presentsa significant challenge to the fuel clad barrier, a potential loss of the fuel clad barrier isspecified.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table9 F4,Table 9-F-2Month 20XXQC 3-26EP-AA-1006 (Revision XX)

MwnA Pifigsim AnnmvI:vylnn kielaarAm. a ~4 r~;4i~a Anr~aw ~vciInn MmmI~arRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC5Initiating Condition:

Primary Containment Radiation Operating Mode Applicability:

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

LOSSA. Primary containment radiatonR MGnitor reading greater than (site specific.

value)Drywell radiation monitor reading > 6.65 E+02 R/hr.Basis:L-ess-4.A The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that reactor coolant activityequals 300 [tCi/gm dose equivalent 1-131. Reactor coolant activity above this level isgreater than that expected for iodine spikes and corresponds to an approximate rangeof 2% to 5% fuel clad damage. Since this condition indicates that a significant amountof 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 RCSBarrier RC5 Loss Tthreshold 44-Asince it indicates a loss of both the Fuel Clad Barrierand the RCS Barrier.

Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.

There is no Potential Loss threshold associated with Primary Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table-9-F-4Table 9-F-22. Core Damage Assessment Methodology Month 20XXQC 3-27EP-AA-1006 (Revision XX)

Exalon NuclearOuad Cities Annex Exe.... Nu.. e..RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC7Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

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

LOSS1A. Any condition in the opinion of the Emergency Director that indicates Loss of theFuel Clad Barrier.POTENTIAL LOSS2A. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.Basis:Loss Threshold

  1. 1 BasisThis threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold
  1. 2 BasisPetentwal Io L.,6.AThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table -F-3Table 9-F-2Month 20XXQC 3-28EP-AA-1006 (Revision XX)

Mind (Nfiaa AnnoyIFyalnn khielanrflu .~ rI ('~i*i~@

Ann~w Fvalnn hi.., ia2rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC2Initiating Condition:

RPV Water LevelOperating Mode Applicability:

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

LOSS1. RPV water level cannot be restored and maintained abovo (site "pecific RPV waterlevel correpondin

't the top of active fuel) '> -142 inches (TAF)Gr-OR2. RPV water level cannot be determined.

Basis:Lgs&-2L.A RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.

This water level corresponds to the top of active fuel and is used in the EOPs to indicatechallenge to core cooling.The RPV water level threshold is the same as Fuel Clad bairieF Barrier FC2 Potential Loss threshold--2-A.

Thus, this threshold indicates a Loss of the RCS barrier andPotential Loss of the Fuel Clad barrier and that appropriately escalates the emergency classification level to a Site Area Emergency.

This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV-wateFRPV water level cannot be restored and maintained above thespecified level following depressurization of the RPV (either manually, automatically orby failure of the RCS barrier) or when procedural guidance or a lack of low pressureRPV injection sources preclude Emergency RPV depressurization EOPs allow theoperator a wide choice of RPV injection sources to consider when restoring RPV waterlevel to within prescribed limits. EOPs also specify depressurization of the RPV in orderto facilitate RPV water level control with low-pressure injection sources.

In some events,elevated RPV pressure may prevent restoration of RPV water level until pressure dropsbelow the shutoff heads of available injection sources.

Therefore, this RCS barrier Lossis met only after either: 1) the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assessthe capability of low-pressure injection sources to restore RPV water level or 2) no lowpressure RPV injection systems are available, precluding RPV depressurization in anattempt to minimize loss of RPV inventory.

The term, "cannot be restored and maintained above," means the value of RPV waterlevel is not able to be brought above the specified limit (top of active fuel). TheMonth 20XXQC 3-29EP-AA-1006 (Revision XX)

Exelan NUC102rOijnd Cities Annex Exl... Nu.le.rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION determination requires an evaluation of system performance and availability in relationto the RPV water level value and trend. A threshold prescribing declaration when athreshold value cannot be restored and maintained above a specified limit does notrequire immediate action simply because the current value is below the top of activefuel, but does not permit extended operation beyond the limit; the threshold must beconsidered reached as soon as it is apparent that the top of active fuel cannot beattained.

Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator todeliberately lower RPV water level to the top of arct'e fue-l in order to reduce reactorpower. RPV water leVel i6 then controlled between the top of a.t.ve fuel and theMinimum Steam.Co RPV Water Le'vel (MSCGRV^AW.

Although such action is achallenge to core cooling and the Fuel Clad barrier, the immediate need to reducereactor power is the higher priority.

For such events, ICs SA5-MA3 or SS&MS3 willdictate the need for emergency classification.

There is no RCS Potential Loss threshold associated with RPV Water Level.Basis Reference(s):

1. NEI 99-01 Rev 6, Table-§-F-3Table 9-F-2Month 20XXQC 3-30EP-AA-1006 (Revision XX)

Clmiorl fifiaa Anng%,vIPv--Ign khme-l-or A. marl r~;*;~ Anv~av Fv~Lnn Mm.iIaarRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC3Initiating Condition:

Primary Containment PressureOperating Mode Applicability:

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

LOSSA. Primary containment pressure greater than (site specific" value) due to RCS leakage-.

1. Drywell pressure

>2.5 psig.AND2. Drywell pressure rise is due to RCS leakageBasis:The (site spe.ific.

value)> 2.5 psig primary containment pressure is the 4ryweI4Drywell high pressure setpoint which indicates a LOCA by automatically initiating the-ECCS-of oguivalent makeup system.The second threshold focuses the fission product barrier loss threshold on a failure ofthe RCS instead of the non-LOCA malfunctions that may adversely affect primarycontainment pressure.

Pressures of this magnitude can be caused by non-LOCA eventssuch as a loss of Drywell cooling or inability to control primary containment vent/purge.

The release of mass from the RCS due to the as-designed/expected operation of anyrelief valve does not warrant an emergency classification.

A stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered eitheridentified or unidentified leakage by Technical Specifications and, therefore, is notapplicable to this EAL.There is no Potential Loss threshold associated with Primary Containment Pressure.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table---F--3Table 9-F-2Month 20XXQC 3-31EP-AA-1006 (Revision XX) rlimexri

('Mga AnnimvFval~nn kuir ibrw~s~ ~ ,-~. .5 .~n ~ S SRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC4Initiating Condition:

RCS Leak RateOperating Mode Applicability:

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

LOSSAl. UNISOLABLE Main Steam Line (MSL), HPCI, Feedwater, RWCU or RCIC linebreak. in ANY of the following:

(site specific.

systems with potential for high energy lineOR82. Emergency RPV Depressurization is required.

POTENTIAL LOSS3A. UNISOLABLE primary system leakage that results in EITHER of the following:

a4. Secondary Containment area temperature

> QGA 300 MaximumMax NormalOoperating Tempe~akelevels.

ORb-2. Secondary Containment area radiation level > QGA 300 Maximum Max-Normal Ooperating Area Radiation

,Level.Basis:UNISOLABLE:

An open or breached system line that cannot be isolated, remotely orlocally.Classification of a system break over system leakage is based on information available to the Control Room from the event. Indications that should be considered are:* Reports describing magnitude of steam or water release.* Use of system high flow alarms / indications, if available,

" Significant changes in makeup requirements,

" Abnormal reactor water level changes in response to the event.The use of the above indications provides the Control Room the bases to determine thatthe on going event is more significant than the indications that would be expected fromsystem leakage and therefore should be considered a system break.Month 20XXQC 3-32EP-AA-1006 (Revision XX)

Quad Cities AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Loss Threshold

  1. 1 Basis-3ALarge high-energy lines that rupture outside primary containment can discharge significant amounts of inventory and jeopardize the pressure-retaining capability of theRCS until they are isolated.

If it is determined that the ruptured line cannot be promptlyisolated from the CoGntrol Room, the RCS barrier Loss threshold is met.Loss Threshold

  1. 2 Basis-4BEmergency RPV Depressurization in accordance with the EOPs is indicative of a loss ofthe RCS barrier.

If Emergency RPV Depressurization is performed, the plant operators are directed to open safety relief valves (SRVs) and keep them open. Even though theRCS is being vented into the Torus, a Loss of the RCS barrier exists due to thediminished effectiveness of the RCS to retain fission products within its boundary.

Potential Loss Threshold-

  1. 3 Basis 3-1APotential loss of RCS based on primary system leakage outside the primarycontainment is determined from EOP temperature or radiation Max Normal Operating values in areas such as main steam line tunnel, RCIC, HPCI, etc., which indicate adirect path from the RCS to areas outside primary containment.

A Max Normal Operating value is the highest value of the identified parameter expectedto occur during normal plant operating conditions with all directly associated supportand control systems functioning properly.

The indicators reaching the threshold barriers and confirmed to be caused by RCSleakage from a primary system warrant an Alert classification.

A primary system isdefined to be the pipes, valves, and other equipment which connect directly to the RPVsuch that a reduction in RPV pressure will effect a decrease in the steam or water beingdischarged through an unisolated break in the system.In general, multiple indications should be used to determine if a primary system isdischarging outside Primary Containment.

For example, a high area radiation condition does not necessarily indicate that a primary system is discharging into the ReactorBuilding since this may be caused by radiation shine from nearby steam lines or themovement of radioactive materials.

Conversely, a high area radiation condition inconjunction with other indications (e.g. room flooding, high area temperatures, reports ofsteam in the Reactor Building, an unexpected rise in Feedwater

flowrate, or unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into the Reactor Building.

An UNISOLABLE leak which is indicated by Max Normal Operating values escalates toa Site Area Emergency when combined with Containment Barrier CT6 Loss Tthreshold

  1. 13A (after a containment isolation) and a General Emergency when the Fuel CladBarrier criteria is also exceeded.

Basis Reference(s):

Month 20XXQC 3-33EP-AA-1006 (Revision XX)

Ouad Citie Annex Ex.lon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION

1. NEI 99-01 Rev 6, 1b-9-FTable 9-F-2Month 20XXQC 3-34EP-AA-1006 (Revision XX) flmitsri

('ifina Annnv kJi iijhmrAu. ~ ii t~i*iao Anna~v ** r~. ** 3s 1S fl *RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC5Initiating Condition:

Primary Containment radiation Operating Mode Applicability:

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

LOSS1. Drywell radiation monitor reading > I00R/hr.A. Primary containment radiation reading greatcr than (Site pecific value).Basis:Less-4-AThe radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that reactor coolant activityequals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier FC5 Loss tThreshold 4-A-since it indicates a loss of the RCSBarrier only.There is no Potential Loss threshold associated with Primary Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table-9-F-3Table 9-F-22. Calc. EP-EAL-0611 Month 20XXQC 3-35EP-AA-1006 (Revision XX) tlmmA Mfiaa Annav Klir-lanr flu a~ rI (~j*jgai@

Ann~v Fvalnn Miur6~r~t4a ... rn .. .n S**U * **~c~RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC7Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

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

LOSSAl. Any condition in the opinion of the Emergency Director that indicates Loss of theRCS Barrier.POTENTIAL LOSSA2. Any condition in the opinion of the Emergency Director that indicates Potential ILoss of the RCS Barrier.Basis:Loss 6-AThreshold

  1. 1 BasisThis threshold addresses any other factors that are to be used by the Emergency Director in determining whether the RCS Barrier is lost.Potential Loss 6&AThreshold
  1. 2 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the RCS Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table-Q-F4Table 9-F-2Month 20XXQC 3-36EP-AA-1006 (Revision XX)

Onnrl Cities Annexw ExeIon NucleanrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT2Initiating Condition:

RPV Water LevelOperating Mode Applicability:

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

POTENTIAL LOSSA.-Primary containment flooding is required.

Basis:Potential Loess 2.A.The Potential Loss threshold is identical to the Fuel Clad Barrier FC2 Loss threshold RPV Water Level threshold 2.A. The Potential Loss requirement for PrimaryContainment Flooding indicates adequate core cooling cannot be restored andmaintained and that core damage is possible.

BWR EPGsEOPs/SAGsSAMGs specifythe conditions that require primary containment flooding.

When primary containment flooding is required, the EPGsEOPs are exited and SAGsSAMGs are entered.

Entryinto SAGsSAMGs is a logical escalation in response to the inability to restore andmaintain adequate core cooling.PRA studies indicate that the condition of this Potential Loss threshold could be a coremelt sequence which, if not corrected, could lead to RPV failure and increased potential for primary containment failure.

In conjunction with the RPV water level Loss thresholds in the Fuel Clad and RCS barrier columns, this threshold results in the declaration of aGeneral Emergency.

Basis Reference(s):

1 .NEI 99-01 Rev 6, Table-9-F4Table 9-F-2Month 20XXQC 3-37EP-AA-1006 (Revision XX)

NuclearOuad Cities Annex Exelon NucilearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT3Initiating Condition:

Primary Containment Conditions Operating Mode Applicability:

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

LOSSAl. UNPLANNED rapid drop in prmry .tainmentDrywell pressure following P.aGentaimentDrywell pressure rise.ORB2. Prim.a.y contai.me nDrywell pressure response not consistent with LOCAIconditions.

POTENTIAL LOSSA3. Prim.ay contai÷nmntDrywell pressure greater than (site specific Value)> 56 psigand rising.OR84. (site s .peci.. eXPlosive mixture) exists inside prima.y containment

a. Drywell ortorus hydrogen concentration

> 6%.ANDb. Drywell or torus oxygen concentration

> 5%.ORG5. HTLG-Heat Capacity Limit (QGA 200, Figure M) exceeded.

Basis:UNPLANNED:

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

The cause of the parameter change or event may be known or unknown.Loss !-A-a n-d-,BThreshold

  1. 1 and #2 BasisRapid UNPLANNED loss of primary containment pressure (i.e., not attributable todPywellDrywell spray or condensation effects) following an initial pressure increaseindicates a loss of primary containment integrity.

Primary containment pressure shouldincrease as a result of mass and energy release into the primary containment from aLOCA. Thus, primary containment pressure not increasing under these conditions indicates a loss of primary containment integrity.

These thresholds rely on operator recognition of an unexpected response for thecondition and therefore a specific value is not assigned.

The unexpected (UNPLANNED) response is important because it is the indicator for a containment Month 20XXQC 3-38EP-AA-1006 (Revision XX) f-l"nel Mae AnnoyPgi:n~rn Nh:PlAd-ar A. .~ .1 (~i$i~o Annoy Fvolnn ItJ,,rIo~r RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION bypass condition.

A pressure suppression bypass path would not be an indication of acontainment breach.Potential Loss 4-tAThreshold

  1. 3 BasisThe threshold pressure is the primary containment internal design pressure.

Structural acceptance testing demonstrates the capability of the primary containment to resistpressures greater than the internal design pressure.

A pressure of this magnitude isgreater than those expected to result from any design basis accident and, thus,represent a Potential Loss of the Containment barrier.Potential Loss 4.BThreshold

  1. 4 BasisIf hydrogen concentration reaches or exceeds the lower flammability limit, as defined inplant EOPs, in an oxygen rich environment, a potentially explosive mixture exists. If thecombustible mixture ignites inside the primary containment, loss of the Containment barrier could occur.Potential Loss 4-.GThreshold
  1. 5 BasisThe HCat Capacity Temperatufe Limit (HpTr ) is the highest Torus twmperature fromwhich Eergency RP2V D)Pep-ressu-ri-atinn will no-t raais-e:-

equipmcnt within the Torus which may be required to operate whenM t~he RPV is-*Torus pressure aboeve Priimar,'

Containment PreSSUre Limit A, whilec the rate ofenergy transfer from the RP2V to the containment is greater than the capacityo the GentainmenRt vent.The HCTL is a function of RPV pressure, Torus temperature and Torus water level. It isutilized to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant and therefore, the inability to maintainplant parameters below the limit constitutes a potential loss of containment.

Basis Reference(s):

1 .NEI 99-0 1 Rev 6, Table 9 I= 3Table 9-F7-2Month 20XXQC 3-39EP-AA-1006 (Revision XX) r1minel Pifigaa AnnnvIPv,-Inn M, iP-larAm, ~ rI(*iniaAnnn~v FvaIr~n 1Ji.rIa~r RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT5Initiating Condition:

Primary Containment Radiation Operating Mode Applicability:

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

POTENTIAL LOSSA. PriMaR' containmel#

radiation monGitor reading greatker than (site Spocvific value)1. Drywell radiation monitor reading > 1.55 E+03 R/hr.Basis:There is no Loss threshold associated with Primary Containment Radiation.

Poten~tial Loss 4. A.The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that 20% of the fuel cladding hasfailed. 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-1 228, Source Estimations During Incident Response to Severe Nuclear PowerPlant 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 RCSBarrier and the Fuel Clad Barrier.

It is therefore prudent to treat this condition as apotential loss of containment which would then escalate the emergency classification level to a General Emergency.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3Table 9-F-22. Core Damage Assessment Methodology Month 20XXQC 3-40EP-AA-1006 (Revision XX) flimrl ifima AnnmvIB'vg=nn Ki, lorl'rAl. ~ i*ia@ Annaw Fvc inn Nh.rIc~r u
  • t* St**U fl S** S U .1,RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT6Initiating Condition:

Primary Containment Isolation FailureOperating Mode Applicability:

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

LOSSAl. UNISOLABLE direct downstream pathway to the environment exists after primarycontainment isolation signal.ORB2. Intentional Pprimary CGontainment venting/purging per EOP's or SAMGs due toaccident conditions.

ORC. UNISOLABLE primary system leakage that results in EITHER of the following:

1. Secondary Containment area temperature

> QGA 300, MaximumMa*

SafeQoperating TenpeFakwelevels.

OR2. Secondary Containment area radiation level > QGA 300, MaximumMa*

SafeOoperating I-levels.

Basis:UNISOLABLE:

An open or breached system line that cannot be isolated, remotely orlocally.These thresholds address incomplete containment isolation that allows anUNISOLABLE direct release to the environment.

Loss 3-.AThreshold

  1. 1 BasisThe use of the modifier "direct" in defining the release path discriminates againstrelease paths through interfacing liquid systems or minor release pathways, such asinstrument lines, not protected by the Primary Containment Isolation System (PCIS).Leakage into a closed system is to be considered only if the closed system is breachedand thereby creates a significant pathway to the environment.

Examples includeunisolable Main Steamline, HPCI or RCIC steamline breaks, unisolable RWCU systembreaks, and unisolable containment atmosphere vent paths.Examples of "downstream pathway to the environment" could be through theTurbine/Condenser, or direct release to the Turbine or Reactor Building.

The existence of a filter is not considered in the threshold assessment.

Filters do notremove fission product noble gases. In addition, a filter could become ineffective due toiodine and/or particulate loading beyond design limits (i.e., retention ability has beenexceeded) or water saturation from steam/high humidity in the release stream.Month 20XXQC 3-41EP-AA-1006 (Revision XX)

Ouad Cities Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Following the leakage of RCS mass into primary containment and a rise in primarycontainment

pressure, there may be minor radiological releases associated withallowable primary containment leakage through various penetrations or systemcomponents.

Minor releases may also occur if a primary containment isolation valve(s)fails to close but the primary containment atmosphere escapes to an enclosed system.These releases do not constitute a loss or potential loss of primary containment butshould be evaluated using the Recognition Category A-R ICs.Loss 3,BThreshold

  1. 2 BasisEOPs may direct primary containment isolation valve logic(s) to be intentionally
bypassed, even if offsite radioactivity release rate limits will be exceeded.

Under theseconditions with a valid primary containment isolation signal, the containment should alsobe considered lost if primary containment venting is actually performed.

Intentional venting of primary containment for primary containment pressure orcombustible gas control to the secondary containment and/or the environment is a Lossof the Containment.

Venting for primary containment pressure control when not in anaccident situation (e.g., to control pressure below the dPywelDrywell high pressurescram setpoint) does not meet the threshold condition.

Loss 3.CThreshold

  1. 3 BasisThe Max Safe Operating Temperature and the Max Safe Operating Radiation Level areeach the highest value of these parameters at which neither:

(1) equipment necessary for the safe shutdown of the plant will fail, nor (2) personnel access necessary for thesafe shutdown of the plant will be precluded.

EOPs utilize these temperatures andradiation levels to establish conditions under which RPV depressurization is required.

The temperatures and radiation levels should be confirmed to be caused by RCSleakage from a primary system. A primary system is defined to be the pipes, valves, andother equipment which connect directly to the RPV such that a reduction in RPVpressure will effect a decrease in the steam or water being discharged through anunisolated break in the system.In general, multiple indications should be used to determine if a primary system isdischarging outside Primary Containment.

For example, a high area radiation condition does not necessarily indicate that a primary system is discharging into the ReactorBuilding since this may be caused by radiation shine from nearby steam lines or themovement of radioactive materials.

Conversely, a high area radiation condition inconjunction with other indications (e.g. room flooding, high area temperatures, reports ofsteam in the Reactor Building, an unexpected rise in Feedwater

flowrate, or unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into the Reactor Building.

In combination with RCS Barrier RC4 pPotential Lioss &AThreshold

  1. 3 this threshold would result in a Site Area Emergency.

There is no Potential Loss threshold associated with Primary Containment Isolation Failure.Basis Reference(s):

Month 20XXQC 3-42EP-AA-1006 (Revision XX)

C. utsv4 Mfid~a Annmv~ -~ 5.i=yalnn RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION 1 NEI 99-01 Rev 6, Table-Q-FTable 9-F-2Month 20XXQC 3-43EP-AA-1006 (Revision XX) flimri Pifigha Annghvl~v--lnn klmrI-,ar RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT7Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

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

LOSSAl. Any condition in the opinion of the Emergency Director that indicates Loss of the IContainment Barrier.POTENTIAL LOSSA2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Basis:Loss $-AThreshold

  1. 1 BasisThis threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Containment Barrier is lost.Potential Loss "AThreshold
  1. 2 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in theevent that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table9 F- 3Table 9-F-2Month 20XXQC 3-44EP-AA-1006 (Revision XX) rlimýri ('Mga AnngvFwi:vlnn NllrAaarAu ~rI r~;*;~ Ann~v Fv~Inn Mmmr.6~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSG1Initiating Condition:

Prolonged loss of all Off-site and all On-Site AC power to emergency busses.Operating Mode Applicability:

1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the General Emerge..yevent promptlyupon determining that (site specific hOurS) the applicable time has beenexceeded, or will likely be exceeded.

1---a. Loss of ALL offsite and- ALL, on'it- AC power to ("it Specific em.ergen.y buses)unit ECCS busses.AND2. Failure of Unit EDG 1(2), shared EDG 1/2 and SBO DG 1(2) emergency dieselgenerators to supply power to unit ECCS busses.AND3b. EITHER of the following:

a. Restoration of at least one em&§enGy-unit ECCS bus in < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is notles.than .(site speGift heus-i , .'net likely.ORb. RPV water level cannot be restored and maintained

> -166 inches.(Site specific indic-ation o-fan inability to adequately remRove heat fromn the core)Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.

RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.

Compensated values may be used inaccordance with the SAMG program.This IC addresses a prolonged loss of all power sources to AC emergency buses. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heatMonth 20XXQC 3-45EP-AA-1006 (Revision XX) rl"nrl (ifiaa AnnovP~valnn khnnllanr flu .~ r4 (~i*iao Ann~v Fv~Inn Mumr1~2rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYremoval/pressure

control, spent fuel heat removal and the ultimate heat sink. Aprolonged loss of these buses will lead to a loss of --o Or mo --ny fission productbarriers.

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

The EAL should require declaration of a General Emergency prior to meeting thethresholds for IC FG1. This will allow additional time for implementation of offsiteprotective actions.Escalation of the emergency classification from Site Area Emergency will occur if it isprojected that power cannot be restored to at least one AC emergency bus by the endof the analyzed station blackout coping period. Beyond this time, plant responses andevent trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers.

The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation.

Mitigation actions with a low probability of success should notbe used as a basis for delaying a classification upgrade.

The goal is to maximize thetime 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 powerresults in parameters that indicate an inability to adequately remove decay heat fromthe core.Basis Reference(s):

1. NEI 99-01 Rev 6, SG12. UFSAR 8.3Month 20XXQC 3-46EP-AA-1006 (Revision XX)

Dinid Citiest Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYM$SIInitiating Condition:

Loss of all offsite and all onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:

1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the Sito Area promptlyupon determining that the applicable time 165- inues-has been exceeded, or willlikely be exceeded.

1. Loss of ALL offsite and ALL Power to (site specific emnergeny bus.s)unit ECCS busses fQo 15 minutesorO lonr.AND2. Failure of Unit EDG 1(2), shared EDG 1/2 and SBO DG 1(2) emergency dieselgenerators to supply power to unit ECCS busses.AND3. Failure to restore power to at least one ECCS bus in < 15 minutes from the time ofloss of both offsite and onsite AC powerBasis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.

This IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure

control, spent fuel heat removal andthe ultimate heat sink. In addition, fission product barrier monitoring capabilities may bedegraded under these conditions.

This IC represents a condition that involves actual orlikely major failures of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RAG1, FG1 or MSGI.Month 20XXQC 3-47EP-AA-1006 (Revision XX)

Quad Cities AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis Reference(s):

1. NEI 99-01 Rev 6, SS12. UFSAR 8.3Month 20XXQC 3-48EP-AA-1006 (Revision XX)

IExAlnn Nuclanr0"nd Cifian Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSA1Initiating Condition:

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

1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the eventAled promptly upondetermining that the applicable time 4§5rFinutes-has been exceeded, or will likelybe exceeded.

1. AC power capability to unit ECCS busses reduced to only one of the following power sources for > 15 minutes.* Reserve auxiliary Transformer TR-12 (TR-22)* Unit Auxiliary Transformer TR-1 1 (TR-21)* Unit Emergency Diesel Generator
  • Station Blackout Diesel Generator
  • Unit crosstie breakersa. AC PoWer capability to (site specific buses) is re-dued, to a singlepower Source forF 1 5 minutes o r longer.AND2b. Any additional single power source failure will result in a loss of all AC power toSAFETY SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.

This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS.

In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment.

This IC provides an escalation path from ICMSU1.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below.Month 20XXQC 3-49EP-AA-1006 (Revision XX)

Mind Civinv An.n. Exellon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY" A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).

" A loss of all offeite power and- lo9s86 Of a~ll emer9gency power soreFes (o.g., GAitdie-Sel generators)-'

wih snle train of emergencay buses, being back fed from thUnit mai gnrtor." A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.Escalation of the emergency classification level would be via IC MSS1.Basis Reference(s):

1. NEI 99-01 Rev 6, SA12. UFSAR 8.3Month 20XXQC 3-50EP-AA-1006 (Revision XX)

Exelon NuclearOuad Cities Annex Eeo ulaRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMsulInitiating Condition:

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

1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the Unu'ual E,-cntevent promptly upondetermining that the applicable time 4Min#ute&s-has been exceeded, or will likelybe exceeded. -.Loss of ALL offsite AC power capability to unit ECCS busses (site-speGifiG

.....gen.y bue) ..for > 15 minutes-er-9F i.Basis:This IC addresses a prolonged loss of offsite power. The loss of offsite power sourcesrenders the plant more vulnerable to a complete loss of power to AC emergency buses.This condition represents a potential reduction in the level of safety of the plant.For emergency classification

purposes, "capability" means that an offsite AC powersource(s) is available to the emergency buses, whether or not the buses are poweredfrom it. (e.g. unit cross-tie breakers)

Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof offsite power.Escalation of the emergency classification level would be via IC MSAI.Basis Reference(s):

1. NEI 99-01 Rev 6, SU12. UFSAR 8.3.1Month 20XXQC 3-51EP-AA-1006 (Revision XX)

Explon NuclearOuad Cities Annex Ex......uc...r RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSG21Initiating Condition:

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

1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the General vent promptlyupon determining that the applicable time 4-5miRutes-has been exceeded, or willlikely be exceeded.

1. Loss of ALL offsite AC power to unit ECCS busses.AND2. Failure of Unit EDG 1(2), shared EDG 1/2 and SBO DG 1(2) emergency dieselgenerators to supply power to vital busses.AND3. Voltage is < 105 VDC on 125 VDC battery busses #1 and #2.AND4. All AC and Vital DC power sources have been lost for >15 minutes.buses) for 1 -5 minutes or lOFnger.ANDh Ipdinat.~edr "r'ltin i6 lrwti than (Rite rnne~ific W6i "nltinn AAAIII nnl A' I(cite munific Vitl DvC hice rqw fio 15 min, udte or long.qV J yl I K Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.

Month 20XXQC 3-52EP-AA-1006 (Revision XX) f1mitarl fifima AnndmvPvainn kl"Maar%fA -aI. mý ii r.*; naw FvlnM.rIRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYThis IC addresses a concurrent and prolonged loss of both AC and Vital DC power. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heatremoval/pressure

control, spent fuel heat removal and the ultimate heat sink. A loss ofVital DC power compromises the ability to monitor and control SAFETY SYSTEMS.

Asustained loss of both AC and DC power will lead to multiple challenges to fissionproduct barriers.

Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses. The 15-minute emergency declaration clock begins at the point when both-allEALs threshelds-are met.Basis Reference(s):

1. NEI 99-01 Rev 6, SG82. UFSAR 8.3.23. Technical Specifications B.3.8.4Month 20XXQC 3-53EP-AA-1006 (Revision XX) fluisd Cities Annex Exelon Nuclea~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMonth 20XXQC 3-54EP-AA-1006 (Revision XX) fliinrl fMae Anngi-tr=vgmlrn Klimr-lAmor Al I ~tI i4la~ Aijnav ~vaIr~n MumIn~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSS28Initiating Condition:

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

1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the Site Area Emergency-vent promptlyupon determining that the applicable time 41-minutes-has been exceeded, or willlikely be exceeded.

is < 105 VDC less than (site specific.

bus voltage value) on125 VDC battery busses #1 and #2ALL (site specific V--ital D, busses) for >15minutes OF.4Gnge'Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.

This IC addresses a loss of Vital DC power which compromises the ability to monitorand 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 powerlosses.Escalation of the emergency classification level would be via ICs RAG1, FG1 orMSG28.'Basis Reference(s):

1. NEI 99-01 Rev 6, SS82. UFSAR 8.3.2.1.1
3. Technical Specifications B3.8.4Month 20XXQC 3-55EP-AA-1006 (Revision XX) fla.iesI (fifin AnniwvI:=v--Itn Nimil--nmr

%ftý ý185RýýRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSS35Initiating Condition:

Inability to shutdown the reactor causing a challenge to RPV water level or RCS heatremoval.Operating Mode Applicability:

1,2Emergency Action Level (EAL):1. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 5%.AND2. All manual / ARI actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 5%.AND3. EITHER of the following conditions exist:* RPV water level cannot be restored and maintained

> -166 inchesOR" Heat Capacity Limit (QGA 200, Figure M) exceeded.

(Site spec-ific-ind-ic-ation of an inability to adequately remov.e heat fromn the cree)(Site 6pecifi indication of an inability to adequately remo-ve he-at frm.-. t~he RC;S)Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, all subsequent operator manualactions, both inside and outside the Control Room including driving in control rods andboron injection,actins, to manually shutdown the reactor are unsuccessful, andcontinued power generation is challenging the capability to adequately remove heatfrom 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 AreaEmergency.

In some instances, the emergency classification resulting from this IC/EAL may behigher than that resulting from an assessment of the plant responses and symptomsagainst the Recognition Category F ICs/EALs.

This is appropriate in that theRecognition Category F ICs/EALs do not address the additional threat posed by afailure to shutdown the reactor.

The inclusion of this IC and EAL ensures the timelydeclaration of a Site Area Emergency in response to prolonged failure to shutdown thereactor.Month 20XXQC 3-56EP-AA-1006 (Revision XX)

Mine] Mao AnnovF:c-nn Nirl-nrUu~.

  • t* r~* ** *fl ~ ..U U~*~~*RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYA reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.

Escalation of the emergency classification level would be via IC RAG1 or FG1.Basis Reference(s):

1. NEI 99-01 Rev 6, SS5Month 20XXQC 3-57EP-AA-1006 (Revision XX)

ExAIon NuclearOusari ities Annex Exelon Nucla~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSA36Initiating Condition:

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

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

1. An-aAutomatic or manual scram did not shutdown the reactor as indicated byReactor Power > 5%.AND2. Manual / ARI actions taken at the reactr control cnc.s.clReactor Console are notsuccessful in shutting down the reactor as indicated by Reactor Power > 5%.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and subsequent operator manualactions taken at the reactor control consoles to shutdown the reactor are alsounsuccessful.

This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if thereactor is subsequently shutdown by an action taken away from the reactor controlconsoles since this event entails a significant failure of the RPS.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 amanual reactor scram. This action does not include manually driving in control rods orimplementation of boron injection strategies.

If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the reactorcontrol consoles (e.g., locally opening breakers).

Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the reactor control consoles".

Taking the Reactor Mode Switch to SHUTDOWN is considered to be a manual scramaction.The plant response to the failure of an automatic or manual reactor scram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged Month 20XXQC 3-58EP-AA-1006 (Revision XX)

Miorl difiwm AnnmrIPvalnn NPd"lmrA,, an (~*ia@ Annaiv Fva inn Miu-Iaar 5S1 5~S S* SS ~

  • U **RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYenough to cause a challenge to the RPV water level or RCS heat removal safetyfunctions, the emergency classification level will escalate to a Site Area Emergency viaIC MSS35. Depending upon plant responses and symptoms, escalation is also possiblevia IC FS1. Absent the plant conditions needed to meet either IC MSS35 or FS1, anAlert 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 areincluded to ensure a timely emergency declaration.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Basis Reference(s):

1. NEI 99-01 Rev 6, SA5Month 20XXQC 3-59EP-AA-1006 (Revision XX)

O.,ad Cities Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSU31Initiating Condition:

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

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

1. a. Ap,-aAutomatic scram -did not shutdown the reactor as indicated by ReactorPower > 5%..ANDb. A-sSubsequent manual action taken at the reactor control consl ReactorConsole is successful in shutting down the reactor.OR2. a. A-mManual scram / ARI did not shutdown the reactor as indicated byReactor Power > 5%.ANDb. EITHER of the following:
1. A-sSubsequent manual / ARI action taken at the reactor controlGeRseleeReactor Console is successful in shutting down the reactor.OR2. A-sSubsequent automatic scram / ARI -is successful in shutting downthe reactor.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and either a subsequent operatormanual action taken at the reactor control consoles or an automatic scram is successful in shutting down the reactor.

This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.EAL #1 BasisFollowing the failure on an automatic reactor scram, operators will promptly initiatemanual actions at the reactor control consoles to shutdown the reactor (e.g., initiate amanual reactor scram). If these manual actions are successful in shutting down thereactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.Month 20XXQC 3-60EP-AA-1006 (Revision XX)

I=xelon NuclearQ~mzrl iCigti Annex Exellon NucleanrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYEAL #2 BasisIf an initial manual reactor trip is unsuccessful, operators will promptly take manualaction at another location(s) on the reactor control consoles to shutdown the reactor(e.g., initiate a manual reactor scram / ARI using a different switch).

Depending uponseveral factors, the initial or subsequent effort to manually scram the reactor, or aconcurrent plant condition, may lead to the generation of an automatic reactor scramsignal. If a subsequent manual or automatic scram / ARI is successful in shutting downthe reactor, core heat generation will quickly fall to a level within the capabilities of theplant's 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 amanual reactor scram). This action does not include manually driving in control rods orimplementation of boron injection strategies.

Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the reactor control consoles".

Taking the Reactor Mode Switch to Shutdown is considered to be a manual scramaction.The plant response to the failure of an automatic or manual reactor tscram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If subsequent operator manual actions taken at thereactor control consoles are also unsuccessful in shutting down the reactor, then theemergency classification level will escalate to an Alert via IC MSA35. Depending uponthe plant response, escalation is also possible via IC FAI. Absent the plant conditions needed to meet either IC MSA35 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 scram signal be generated as a result of plant work (e.g., RPS setpointtesting),

the following classification guidance should be applied." If the signal generated as a result of plant work causes a plant transient that createda real condition that should have included an automatic reactor scram and the RPSfails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.

" If the signal generated as a result of plant work does not cause a plant transient butshould have generated an RPS scram signal and the scram failure is determined through other means (e.g., assessment of test results),

then this IC and the EALsare not applicable and no classification is warranted.

Month 20XXQC 3-61EP-AA-1006 (Revision XX)

Exelon NuclearQuad Cities Annex Eeo ulaRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis Reference(s):

1. NEI 99-01 Rev 6, SU5Month 20XXQC 3-62EP-AA-1006 (Revision XX)

QU2d Cities AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSA42Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.

Operating Mode Applicability:

1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the eventAle~

promptly upondetermining that the applicable time 45 minutes-has been exceeded, or will likelybe exceeded.

1. a. AR,-UNPLANNED event results in the inability to monitor one Or mRcANYTable Mlef parameters from within the Control Room for > 15minutes oF loRge-.[see table below]JB WR parameter

&41tReactor PoWerR"V Water- Level"VX PrcSSUrcPrimary Containment Suppression Pool LevelSUPPrcssion Pool Temperatur-e Table M1 Control Room Parameters

  • Reactor Power* RPV Water Level* RPV Pressure* Drywell Pressure* Torus Level* Torus Temperature ANDb. Any Table M2ef the, g transient events in progress.

A 4 m m I I IS:utmabG Or Manuai rlunroK reatr tn-Mar ;-499% toreRnal reactor pGWerZ =' aL;-. aLwr"

" EGGS (SI) actuation......................

Month 20XXQC 3-63EP-AA-1006 (Revision XX) flimori rtifigsa AnnovI:valnn Nngr-loar A.uaI (~i*ice Annciv Fvailnn hImur~Iihnr a-.. U. fl ~5t~ .... U U --*~~*RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYTable M2 Significant Transients

" Turbine Trip" Reactor Scram* ECCS Activation

" Recirc. Runback > 25% Reactor Power Change" Thermal Power oscillations

> 10% Reactor Power ChangeBasis:UNPLANNED:

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

The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring rapidly changing plantconditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fissionproduct 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 er mereany of Ithe listed parameters cannot be determined from within the Control Room. Thissituation would require a loss of all of the Control Room sources for the givenparameter(s).

For example, the reactor power level cannot be determined from anyanalog, computer point, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated 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 itsignificantly 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 actiondecision-making.

This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity

control, RPV-leve!RPV water level and RCS heat removal.Month 20XXQC 3-64EP-AA-1006 (Revision XX) f-l"tari t'ifigm AnnawIPvalnn Niiilloor A.u~~I (~*ine Aflflcv Fv~Inn MmuI~2r ~4 ... as. U. %fl n,... S U *.u**RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYThe loss of the ability to determine neo Or mereany of these parameters from within theControl Room is considered to be more significant than simply a reportable condition.

In addition, if all indication sources for ene or-moreany of the listed parameters are lost,then the ability to determine the values of other SAFETY SYSTEM parameters may beimpacted as well. For example, if the value for RPV water level cannot be determined from the indications and recorders on a main control board, the SPDS or the plantcomputer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.

Escalation of the emergency classification level would be via ICs FS1 or IC RAS1.Basis Reference(s):

1. NEI 99-01 Rev 6, SA2Month 20XXQC 3-65EP-AA-1006 (Revision XX) eliinrf r-ifina AnnavI=walnn M, r~lakrA u i~rI (~i*iaa Ann~v FvMnn Ma.,,Igimr RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYMSU421Initiating Condition:

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

1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Eventevent promptly upondetermining that the applicable time 15 minutes-has been exceeded, or will likelybe exceeded.

a- An-UNPLANNED event results in the inability to monitor one orFmoRe.ANY Table M1parameters from within the Control Room for > 15 minutes.Table M1 Control Room Parameters

  • Reactor Power" RPV Water Level* RPV Pressure* Drywell Pressure" Torus Level" Torus Temperature
1. of the fglloWin.

Dq...ar.A.t rs, from. Within the Control Room. for 15 m;inuiteorloge-II2. [BWRpomaranwtc

3.

IiS4 Wi~4. Reactor Power- 6. Reactor.

Pow57--8.RVWater-L" 9. &RCS Leve110-.RPX' Pressur-e

11. -R-CSF P-r-essur e12. Prniw 12. In Corv./Come Containment Exit Temp,,rt,-
14. uppessin P15. Levels in at leastLeve (site-speetie
17. Steam Cencrator Temper-ataf AffliliniffOf

___ Wate-F NOWMonth 20XXQC 3-66EP-AA-1006 (Revision XX)

Exallon NuclearOuad Cities Annex Eeo ulaRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:UNPLANNED:

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

The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the ControlRoom. This condition is a precursor to a more significant event and represents apotential degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for one OF moreany ofthe listed parameters cannot be determined from within the Control Room. Thissituation would require a loss of all of the Control Room sources for the givenparameter(s).

For example, the reactor power level cannot be determined from anyanalog, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)to determine if an NRC event report is required.

The event would be reported if itsignificantly 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 actiondecision-making.

This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity

control, core cooling and RCS heat removal.

The loss ofthe ability to determine eoe or mereany of these parameters from within the ControlRoom is considered to be more significant than simply a reportable condition.

Inaddition, if all indication sources for one er mereany of the listed parameters are lost,then the ability to determine the values of other SAFETY SYSTEM parameters may beimpacted as well. For example, if the value for reactor vessel level cannot bedetermined from the indications and recorders on a main control board, the SPDS or theplant computer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.

Escalation of the emergency classification level would be via IC MSA42-.Month 20XXQC 3-67EP-AA-1006 (Revision XX) rl"nrl ifine AnnavFPylnn umlrlnrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis Reference(s):

1. NEI 99-01 Rev 6, SU2Month 20XXQC 3-68EP-AA-1006 (Revision XX)
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