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Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3A, 3B, Cover - by 3-74
	ML14164A060
Person / Time
Site:	Byron
Issue date:	05/30/2014
From:	; Exelon Generation Co
To:	; NRC/FSME, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML14164A053	List: ML14164A054; ML14164A055; ML14164A056; ML14164A058; ML14164A060; ML14164A061; ML14164A062; ML14164A063; ML14164A064; ML14164A065; ML14164A066; ML14164A067; ML14164A068; ML14164A069; ML14164A071; ML14164A073; ML14164A076; ML14164A079; NEI 99-01, Braidwood, Units 1 and 2, Attachment 2, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1001, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 2A, and 2B, Cover Through Pa; NEI 99-01, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3A, 3B, Cover - by 3-74; NEI 99-01, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3B, 3C, by 3-75 - by 3-157; NEI 99-01, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4A and 4B, Cover - Cl 3-73; NEI 99-01, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4B and 4C, Cl 3-74 - Cl 3-151; NEI 99-01, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5A and 5B, Cover - Dr 3-76; NEI 99-01, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5B and 5C, Dr 3-77 - Dr 3-160; NEI 99-01, LaSalle, Units 1 & 3, Attachment 6, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1005, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 6A and 6B, Cover - LS 3-74; NEI 99-01, License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.; RA-14-032, Attachment 10: Discussion of Revision to the Radiological Emergency Plan Annex for Quad Cities Nuclear Power Station, Page QC 3-69 Through End; RA-14-032, Attachment 11: Discussion of Revision to the Radiological Emergency Plan Annex for Three Mile Island Nuclear Station, Page TMI 3-80 Through End; RA-14-032, Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. Cover Through Page LGS 3-69; RA-14-032, Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. LGS 3-70 Page LGS 3-155; RA-14-032, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station, Page Ocgs 3-76 Through End; RA-14-032, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station. Cover Through Page Ocgs 3-75; RA-14-032, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Cover Through Page PBAPS 3-76; RA-14-032, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Page PBAPS 3-77 Through End; RA-14-032, Braidwood, Units 1 and 2, Attachment 2, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1001, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 2A, and 2B, Cover Through Pa; RA-14-032, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3A, 3B, Cover - by 3-74; RA-14-032, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3B, 3C, by 3-75 - by 3-157; RA-14-032, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4A and 4B, Cover - Cl 3-73; RA-14-032, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4B and 4C, Cl 3-74 - Cl 3-151; RA-14-032, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5A and 5B, Cover - Dr 3-76; RA-14-032, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5B and 5C, Dr 3-77 - Dr 3-160; RA-14-032, LaSalle, Units 1 & 3, Attachment 6, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1005, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 6A and 6B, Cover - LS 3-74; RA-14-032, License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.; RS-14-115, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Page PBAPS 3-77 Through End; TMI-14-046, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station, Page Ocgs 3-76 Through End;
References
	NEI 99-01, Rev 6, RA-14-032, RS-14-115, TMI-14-046 EP-AA-1002
	Download: ML14164A060 (142)
	v • d • e

ATTACHMENT 3DISCUSSION OF REVISIONTO THERADIOLOGICAL EMERGENCY PLAN ANNEXFORBYRON STATIONEP-AA-1002 Enclosures

Enclosure 3A -EAL Comparison Matrix Document* Enclosure 3B -EAL Red-Line Basis Document* Enclosure 3C -EAL Basis Document NEI 99-01REVISION 6DEVELOPMENT OF EMERGENCY ACTIONLEVELS FOR NON-PASSIVE REACTORSATTACHMENT 3DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FORBYRON STATIONExeton Generation.

00NEI 99-01 Rev 6 Proposed EAL Justification AGIInitiating 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 detenmining that the applicable lime 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:

1,2,3,4.5,6.D Emergency Action Levels (EAL):Notes:The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

If an ongoing release is detected and the release start time is unknown.assume that the release duration has exceeded 15 minutes.Classification based on effluent monitor readings assumes that a release 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 Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PRO3) > 9.99 E+09 pCi/sec for >_ 15 minutes (as determined from Unit 1 &2 PF430 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.

D No Change E 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 establisrhed."

In order10 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 therelorreadily available on the 1 lx17 procedure matrix used by the SM.Page I ol'66 NEI 99-01 Rev 6 [Proposed EAL IJustification ASIInitiating Condition

-SITE AREA EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 100 mremTEDE or 500 mrern 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 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:

1.2.3.4.5,6.D Emergency Action Levels (EAL):Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

If an ongoing release is detected and the release start time is unknown.assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release 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 91 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.

1. The sum of readings on the Unit I and 2 Aux BLDG Vent WRGMs (1/2RE-PRO30)

> 9.99 E+8 pCiisec for > 15 minutes (as determined fromUnit 1 & 2 PF430 or PPDS -Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyondthe site 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.

No Change I Difference li Deviation

1) Listed site-specific monitors and Threshold values to ensure timelyclassification.

2) Added the following to bullet 3 3" Classification based on effluent monitorreadings assumes that a release path to the environment is establisned."

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 IJustification AA1RAIInitiating Condition

-ALERTInitiating Condition:

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

AllExample Emergency Action Levels: (I 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 EAL #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.

Operating Mode Applicability:

1, 2. 3.4, 5, 6. DEmergency Action Levels (EAL):Note:The Emergency Director should declare the event 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.* Classification based on effluent monitor readings assumes that a releasepath to the environment is established.

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

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

The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2RE-PRO30)

> 9.99 E+07 pCilsec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS -Total Nobel Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyondthe site boundary of EITHER:a. > 10 mRemTEDEORb. > 50 mRem CDE ThyroidOR3. Analysis of a liquid effluent sample indicates a concentration or releaserate that would result in doses greater than EITHER of the following at orbeyond the site boundarya. 10 mRem TEDE for 60 minutes of exposureORb. 50 mRem CDE Thyroid for 60 minutes of exposureD No Change E Difference 1 Deviation

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

2) Added the following to bullet #3 " Classification based on effluent 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 matix used by the SM.3) Calculations were performed, in accordance with (IAW) guidance provided in NEI99-01 revision 6 EAL AAI, to determine the effluent monitor response for aradioactive liquid release and a WGDT release via the normal site release pathway.The release would contain activity equivalent to provide t0mrem TEDE or 50mremthyroid CDE at the site boundary.

The calculation determined the effluent monitorresponses would be >1 10% of the instruments maximum range and as such, lAWNEI 99-01 Rev 6 guidance, was not included in this EAL.4.ORField survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mRlhr are expected tocontinue for _ 60 minutes.ORb. Analyses of field survey samples indicate

> 50 mRemCDE Thyroid for 60 minutes of inhalation.

Page 3 of 66 NEI 99-01 Rev 6 Proposed EAL I 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:

AllExample Emergency Action Levels: (1 or 2 or 3)Note:* The Emergency Director should declare the Alert 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.RU1Initiating 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, 56, DEmergency Action Levels (EAL):Note:* The Emergency Director should declare the event 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 60 minutes.* Classification based on effluent monitor readings assumes that a releasepath to the environment is established.

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

1. Reading on any of the following effluent monitors

> 2 times alarmsetpoint established by a current radioactive release discharge permitfor a 60 minutes.O 0PROO1, Liquid Radwaste Effluent Monitor* 0PR002, Gas Decay Tank Effluent MonitorO 0PRO10, Station Blowdown Monitor112 PROWl, Containment Purge Effluent Monitor* Discharge Permit specified monitorOR2. The sum of readings on the Unit I and 2 Aux Bldg Vent WRGMs (1/2 RE-PRO3W) 1.14 E+06 iCi/sec for > 60 minutes (as determined from Unit 1& 2 PF430 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 Z 60 minutes.Change

.IJ Deviation

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

2) Added the following to bullet #3" Classification based on effluent monitorreadings assumes that a release path to me environment is eslablisned."

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 Wl 7 procedure mainx used by the SM.Page 4 of 66 0NEI 99-01 Rev 6 Proposed EAL Justification AG2RG2D No ChangeE Difference

[I] Deviation Initiating Condition

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

AllExample Emergency Action Levels:NOTES: The Emergency Director should declare the General Emergency promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded1. 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 enhancedspent fuel pool level instrumentation is available for use. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is beingtracked in accordance with Exeton Generation

Company, LLC's Initial StatusReport to March 12. 2012 Commission Order Modifying Licenses with Regard forReliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) datedOctober 25,2012.Page 5 of 66 0NEI 99-01 Rev 6 Proposed EAL Justification AbZRS2Initiating Condition

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

Operating Mode Applicability:

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

-D No Change E Difference 1 Deviation

1) EAL not used in accordance witr the discussion in Section 1.4. NRC OrderEA-1 2-051, it is recommended that this EAL be implemented when the enhancedspent fuel pool level instrumentation is available for use. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is beingtracked in accordance with Exelon Generation Company.

LLC's Initial StatusReport to March 12, 2012 Commission Order Modifying Licenses with Regard forReliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) datedOctober 25.2012.Page 6 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification Initiating Condition

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

AllAA2RA2Initiating Condition:

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

1.2, 3, 4, 5, 6.DEmergency Action Levels (EAL):1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR2. Damage to irradiated fuel resulting in a release of radioactivity from the fuelas indicated by ANY Table R1 Radiation Monitor reading >1000 mRernhr[I] No Change E Difference 1 Deviation

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

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

it is recommended that this EAL be implemented when the enhancedspent fuel pool level instrumentation is available for use. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is beingtracked in accordance with Exelon Generation Company.

LLC's Initial Status Reportto March 12, 2012 Commission Order Modifying Licenses with Regard for ReliableSpent Fuel Pool Instrumentation (Order Number EA-12-051) dated October25,2012.Example Emergency Action Levels: (1 or 2 or 3 )1. Uncovery of irradiated fuel in the REFUELING PATHWAY.2. Damage to irradiated fuel resulting in a release of radioactivity from thefuel as indicated by ANY of the following radiation monitors:

(site-specific listing of radiation

monitors, and the associated

readings, setpoints and/or alarms)3. Lowering of spent fuel pool level to (site-specific Level 2 value).Table RIFuel Handling Incident Radiation Monitors* Fuel Building Fuel Handling Incident Monitor ORE-AR055

Fuel Building Fuel Handling Incident Monitor ORE-AR056

Containment Fuel Handting Incident Monitor 1/2RE-AR01 1* Containment Fuel Handling Incident Monitor 1/2RE-AR012 Page 7 of 66 NEI 99-01 Rev 6 J Proposed EAL Justification AU2Initiating Condition:

UNUSUAL EVENTUNPLANNED loss of water level above irradiated fuelOperating Mode Applicability:

AllExample Emergency Action Levels:1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated 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, 5,6, DEmergency Action Levels (EAL):1. a. UNPLANNED water level drop in the REFUELING PATHWAY asindicated by ANY of the following:

Refueling Cavity water level <23 ft above the ReactorFlange (< 423 ft. indicated level)OR* Spent Fuel Pool water level < 23 ft. above the fuel(<422 ft 9 in indicated level)OR* Indication or report of a drop in water level in theREFUELING PATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitor in Table RI.I-H No Change [: Difference

[: Deviation

1) Listed site-specific level indication and monitors to ensure timely classification.

Table R1Fuel Handling Incident Radiation Monitors* Fuel Building Fuel Handling Incident Monitor ORE-AR055

Fuel Building Fuel Handling Incident Monitor ORE-AR056

Containment Fuel Handling Incident Monitor 1/2RE-AR01 1* Containment Fuel Handling Incident Monitor 1/2RE-AR012 Page 8 of 66 NEI 99-01 Rev 6 Proposed EAL = Justification 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, or out ofservice, before the event occurred, then no emergency classification iswarranted

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 or areas:(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 plantoperations, cooldown or shutdown.

Operating Mode Applicability:

1,2,3,4,5, 6,DEmergency Action Levels (EAL):Note: If the equipment in the room or area listed in Table R3 was alreadyinoperable, or out of service, before the event occurred, then noemergency classification is warranted

1. Dose rate greater than 15 mRlhr in ANY of the following areas:E- No Change D ence DeEJ1) Listed site specific plant rooms and areas with identified mode applicability toensure timely classification.

Table R2Areas Requiring Continuous Occupancy

" Main Control Room -1/2RE-AR010

" Central Alarm Station -(by survey)OR2. An UNPLANNED event results in radiation levels that prohibit orsignificantly impede access to any of the following plant rooms or areas:Table R3Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Auxiliary Building*

Mode 4, 5, and 6*Areas required to establish shutdown coolingPage 9 of 66 NEI 99-01 Rev 6 Proposed EAL [Justification SU3Initiating Condition:

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

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:1. (Site-specific radiation monitor) reading greater than (site-specific value).OR2. Sample analysis indicates that a reactor coolant activity value is greater thanan allowable limit specified in Technical Specifications.

RU3Initiating Condition:

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

1,2,3,4Emergency Action Levels (EAL):1. Gross Failed Fuel Monitor 1/2RE-PRO06 (1/2 PS206- High Energy) indicating 1-135 concentration

> 5 pCilcc.OR2. Sample analysis indicates that:a. Dose Equivalent 1-131 specific coolant activity

> 60.0 pCi/gm.ORb. Dose Equivalent XE-1 33 specific coolant activity

> 603.0 pCilgm.H No Change E Difference 1 Deviation

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

2) Listed this system category EAL in the radiological category EAL section tomaintain consistency with current and previous revisions of Exelon EALs. This willensure a timely classification since the threshold values are more aligned with theradiological category vice system category.

Page 10 of 66 NEI 99-01 rev 6 Fission Prod uct Barrier MatrixFisso Produc Bare MatixGEERLMEGECYSIEREEERENYLETotMari FG1 Loss of any two barriers AND Loss or Potential Loss of third barrier.1,2.3,4FS1 Loss or Potential Loss of ANY two barriers.

1,2,3,4FAI ANY Loss or ANY Potential Loss of either Fuel Clad or RCS1,2,3A4FC -Fuel Clad RC -Reactor Coolant System CT -Containment Loss Potential Loss Loss Potential Loss Loss Potential Loss2. The capacity of one charging pump inthe normal mode is exceeded due to1. An automatic or manual SI actuation the n olmodsng uCare Cooling CSF-Orange Path is required by EITHER of the EITHER of the following:

1. RCS or SG None conditions exist. followng:

a. UNISOLABLE RCS leakage A leaking or RUPTURED SG is NoneTube Leakage a. UNISOLABLE RCS leakage OROR b. SG tube leakage.

FAULTED outside of containment.

b. SG tube RUPTURE.

OR3. RCS Integrity CFS-Red Pathconditions exist1. Core Cooling CSF-Red Path 2. Core Cooling CSF-Orange Path2. Inadequate conditions exist. Heat Sink CSF-Red Path conditions Core Cooling CSF-Red Path conditions Heat Removal 3. Heat Sink CSF-Red Path conditions Podr exist.nctivesin exist. Procedures not effective in < 16 minutes.1. Containment radiation monitor(AR020(21))

reading > 1.95E+03Cotimnraainmntr 3.RCS Activity/

R/hr. Containment radiation monitor Containment radiation monitor (AR020(21))

Containment None (AR020(21))

reading None NoneRadiation OR2, .Coolant activity as sampled > 26 R/hr. reading > 4.40E+03 R/hr.> 300pCI/gm Dose Equivalent I-131.1.Containment isolation is required andEITHER of the following:

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

4. Hydrogen concentration inside4.Containment Directors judgment indicate a loss containment

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

ORBypass OR 5. a. Containment pressure

>20 psig.b. UNISOLABLE pathway from ANDcontainment to the environment exists. b. Less than one full train ofOR containment Spray is operating per design for >15 minutes.2 Indication of RCS leakage outside ofcontainment

5. Emergency 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 the A. Any Condition in the opinion of the A. Any Condition in the opinion of theDirector the Emergency Director that Emergency Director that indicates Emergency Director that indicates Loss Emergency Director that indicates Emergency Director that indicates Loss Emergency Director that indicates Potential Judgment indicates Loss of the Fuel Clad Potential Loss of the Fuel Clad Barrier.

of the RCS Barrier.

Potential Loss of the RCS Barrier.

of the Containment Barrier.

Loss of the Containment Barrier.Jug et Barrier.III Page 11 of66 Proposed Fission Product Barrier MatrixFission Product_

Barrier Matrix Hot MatrixI ____________________SITE

__AREA __EMERGENCY___ALERT FG1 Loss of any two barriers AND Loss or Potential Loss of third barrier.i][A[A3 I FSl Loss or Potential Loss of ANY two barriers.I FAI ANY Loss or ANY Potential Loss of either Fuel Clad or RCSrnrir1-,EE91AFC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Category Loss Potential Loss Loss Potential Loss Loss Potential Loss2. The capacity of one charging pump in thenormal mode is exceeded due to EITHERof the following:

1. An automatic or manual SI actuation is a. UNISOLABLE RCS leakagerequired by EITHER of the txllowing:

Cere-Cooling CSF -Orange Path OR1. RCS or SG Tube None c on ins est a. UNISOLArLE RCS leakage A leaking or RUPTURED SG is FAULTED NoneLeakage b. SG tube RUPTURE..

outside of containment.

ORORb. SG tube RUPTURE.3. RCS Integrity CFS -Red path conditions exist.2. Core-Cooling CSF -Orange Pathconditions exist. Core Cooling CSF-Red Path conditions exist2. Inadequate Heat 1. Core-Cooling CSF -Red Path None Heat Sink CSF -Red Path conditions exist. None AND Functional Restoration Procedures eot3. Heat Sink CSF -Red Path conditions effective in 015 minutes.exist.1. Containment radiation monitor3. Containment (AR020(21))

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

Containment radiation monitor(AR020(21))

Radiation I RCS OR None reading 0 25 R/hr. None Nxne reading > 4.t4E+03 R/hr.Activity

2. Coolant activity as sampled>300pCtlgm Dose Equivalent 1-131.1. Containment isolation is required andEITHER of the toltoving:

3. Containment CSF -Red path conditions

a. UNPLANNED lowering in exist.containment pressure or rise inradiation monitor readings outside ORof containment in the Emergency

4. Hydrogen concentration in Containment 0 5%.Directors judgment indicate a loss OR4. Containment None None None of containment integrity.

Integrity or Bypass None OR 5. a. Containment pressure

>20 pslg.ANDb. UNISOLABLE pathway fromcontainment to the environment

b. Less than one full train of Containment exists. Spray is operating per design for >15minutes.OR2 Indication of RCS leakage outside ofcontainment

5. Emergency

1. Any Condition in the opinion of the 2. Any Condition in the opinion of the 1. Any Condition in the opinion of the 2. Any Condition in the opinion of the 1. Any Condition in the opinion of the 2. Any Condition in the opinion of the Emergency Dirergent Emergency Director that indicates Lose Emergency Director that indicates Emergency Director that indicates Loss of Emergency Director that indicates Potential Emergency Director that indicates Loss of Director that indicates Potential Loss of theDirector Judgment of the Fuel Clad Barrier.

Potential Loss of the Fuel Clad Banter, the RCS Barrier.

Loss of the RCS Barrier.

the Containment Banrier.

Containment Barrier.Page 12 of66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC1 Category:

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

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

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

Fuel Clad Barrier FC2 Category:

Fuel Clad Barrier2 No Change Diffen Deviation Inadequate Heat Removal RCS Activity

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

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

Loss LossA. Core exit thermocouple readings greater than (site-specific temperature value). 1. Core-Cooling CSF -Red Path conditions exist.Potential LossA. Core exit thermocouple readings greater than (site-specific temperature value). Potential LossOR 2. Core-Cooling CSF -Orange Path conditions exist.B. Inadequate RCS heat removal capability via steam generators as indicated by OR(site-specific indications).

3. Heat Sink CSF -Red Path conditions exist.Page 14 of 66 NEI 99-"1 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC3 Category:

Fuel Clad Barrier FC3 E No Change Differce Deviation Containment Radiation

/ RCS Activity Containment Radiation

/ RCS Activity

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

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

Loss LossA. Containment radiation monitor reading greater than (site-specific value). 1. Containment radiation monitor (AR020(21))

reading > 1.95E+03 R/hr.OR ORB. (Site-specific indications that reactor coolant activity is greater than 300 PCi/gm 2. Coolant activity as sampled > 300pCilgm Dose Equivalent 1-131.dose equivalent 1-131).Page 15 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC6 Category:

Fuel Clad BarrierF No Change Differc 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 of66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RCI Category:

Reactor Coolant System Barrier RCI H No Change Differenc LI Deviation RCS or SG Tube Leakage RCS or SG Tube Leakage 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

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

following:

a. UNISOLABLE RCS leakage1. UNISOLABLE RCS leakageOR OR2. SG tube RUPTURE.

b. SG tube RUPTURE.Potential Loss Potential LossA. Operation of a standby charging (makeup) pump is required by EITHER of the 2. The capacity of one charging pump in the normal charging mode is exceededfollowing:

due to EITHER of the following:

1. UNISOLABLE RCS leakage a. UNISOLABLE RCS leakageOR2. SG tube leakage.

OROR b. SG tube RUPTURE.B. RCS cooldown rate greater than (site-specific pressurized thermal shock ORcriteria/limits defined by site-specific indications).

3. RCS Integrity CSF -Red path conditions exist.Page 17 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC2 Category:

Reactor Coolant System BarrierRC2 No Change Diff Deviation Inadequate Heat Removal Inadequate Heat Removal 1) Listed site-specific threshold value to ensure timely classification.

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

Page 18 of66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC3 Category:

Reactor Coolant System BarrierRC3 No Change Difrenc Deviation Containment Radiation I RCS Activity RCS Leak Rate 1) Listed site-specific systems and threshold values to ensure timely classification.

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

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

reading > 25 R/hr.Page 19 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC6 Category:

Reactor Coolant System BarrierRC No Change Diffrn 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 20 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CT1CT D No Change [j Difference U- Deviation Category:

Containment Barrier Category:

Containment BarrierRCS or SG Tube Leakage RCS or SG Tube Leakage 1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

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

A leaking or RUPTURED SG is FAULTED outside of containment.

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

Containment Barrier CT2 Category:

Containment Ba2er No Change Differene Deviation Inadequate Heat Removal Inadequate Heat Removal 1) Listed site-specific threshold values to ensure timely classification.

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

Core-Cooling CSF Red Path conditions exist AND Functional Restoration AND procedures not effective in < 15 minutes2. Restoration procedure not effective within 15 minutes.Page 22 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CTXT3 1-NO Change II Difference

['-1Deviation Category:

Containment Barrier Category:

Containment Barrier LJ EDContainment Radiation

/ RCS Activity Containment Radiation

/ RCS Activity

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

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

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

Containment Barrier Category:

Containment Barrier Lii No Change D Diffrence Deviation Containment Integrity or Bypass Containment Integrity or Bypass 1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability:

Power Operation,

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

Fission Product Barrier (FPB) Threshold:

Loss LossA. Containment isolation is required

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

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

monitor readings outside of containment in the Emergency Director1. Containment integrity has been lost based on Emergency Director judgment indicate a loss of containment integrity.

judgment.

OROR2. UNISOLABLE pathway from the containment to the environment exists. b. UNISOLABLE pathway from containment to the environment exists.OR ORB. Indications of RCS leakage outside of containment.

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

4. Hydrogen concentration in Containment

> 5%.OR ORC. 1. Containment pressure greater than (site-specific pressure setpoint)

AND 5. a. Containment pressure

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

Containment Barrier CT6 Category:

Containment BarrierCT No Change Diff nc 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

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

Loss of the Containment Barrier.Page 25 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification SulInitiating 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:

1,2,3,4Emergency Action Levels (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 ESF buses.AND2. Failure of DG 1A(2A) and DG 1B(2B) emergency diesel generators tosupply power to unit ESF buses.AND3 EITHER of the following:

Restoration of at least one unit ESF bus in e 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months isnot likely.OR* Core Cooling CFS -Red Path conditions existNo Change FIDifference 1-1 Deviation 1 ) Listed site specific equipment, site specific time based on station blackoutcoping analysis, and site specific indication to ensure timely classification.

Page 26 of 66 NEI 99-01 Rev 6 1Proposed EAL Justification 551Initiating 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 Unusual Event 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.MSIInitiating Condition:

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

1,2,3,4Emergency Action Levels (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 ESF buses.AND2. Failure of DG IA(2A) and DG 1B(2B) emergency diesel generators tosupply power to unit ESF buses.AND3. Failure to restore power to at lease one unit ESF bus in < 15 minutesfrom the time of loss of both offsite and onsite AC power.M No Change FIDifference 1 Deviation

1) Listed site specific equipment to ensure timely classification.

Page 27 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification SA1Initiating Condition:

ALERTLoss of all but one AC power source to emergency buses 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 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.MAIInitiating Condition:

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

1,2,3,4Emergency Action Levels (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 ESF buses reduced to only one of thefollowing power sources for > 15 minutes.* Affected unit SAT 142-1(242-1)

Affected unit SAT 142-2(242-2)

Emergency Diesel Generator DG 1A(2A)* Emergency Diesel Generator DG I B(2B)* Unit crosstie breakersAND2. Any additional single power source failure will result in a loss of ALL ACpower to SAFEY SYSTEMS.M No Change 1 Difference 1 Deviation 1 ) Listed site specific equipment to ensure timely classification.

Page 28 of 66 NEI 99-01 Rev 6 1 Proposed EAL [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 longerMUtInitiating Condition:

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

1,2,3,4Emergency Action Levels (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 ESF buses for_> 15 minutesNo Change FIDifference

[I- Deviation

1) Listed site specific equipment to ensure timely classification.

Page 29 of 66 NEI 99-01 Rev 6 Proposed EAL I 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 Ibuses) 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:

1,2,3,4Emergency Action Levels (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 ESF buses.AND2. Failure of DG 1A(2A) and DG 1B(2B) emergency diesel generators tosupply power to unit ESF buses.AND3. Voltage is < 108 VDC on unit 125 VDC battery buses 111(211) and112(212).

AND4. All AC and Vital DC power sources have been lost for > 15 minutes.D No Change M Difference FIDeviation

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

2) Removed the word "indicated" this will allow for an indication problem to notcause confusion on the need to declare.Page 30 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification SS88Initiating 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:

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

Voltage is < 108 VDC on unit 125 VDC battery buses 111(211) and 112(212) for >15 minutes.D No Change 1 Difference I Deviation

1) Listed site specific equipment and site specific value to ensure timelyclassification.

2) Removed the word "indicated" this will allow for an indication problem to notcause confusion on the need to declare.Page 31 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SS5Initiating Condition:

SITE AREA EMERGENCY Inability to shutdown the reactor causing a challenge to (core cooling [PWR] I 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 core cooling or RCS heatremoval.Operating Mode Applicability:

1,2Emergency Action Levels (EAL):1. Automatic or Manual Trip did not shutdown the reactor as indicated byReactor Power > 5%.AND2. ALL manual actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power >5%.AND3. EITHER of the following conditions exist:a. Core Cooling CSF-RED Path conditions exist.ORb. Heat Sink CSF-RED Path conditions exist.D No Change D Difference FIDeviation

1) Listed site specific indications to ensure timely classification.

2) Mode 2 included in operating mode applicability as per developer notes.Page 32 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA5Initiating 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 [BWR]) 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 trip 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 Levels (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. Automatic or manual Trip did not shutdown the reactor as indicated byReactor Power > 5%.AND2. Manual actions taken at the Main Control Board are not successful in shuttingdown the reactor as indicated by Reactor Power > 6%.D 1 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 33 of 66 NEI 99-01 Rev 6 1 Proposed EAL IJustification SU5Initiating Condition:

UNUSUAL EVENTAutomatic or manual (trip [PWRI / scram [BWRJ) 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] / scram [BWR]) 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 trip ([PWR] / scram [BWR]) did not shutdown the reactor.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 [PVVR] / scram [BWR]) is successful in shutting down the reactor.MU3Initiating Condition:

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

H No Change -]Difference FIDeviation

1) Listed site specific indications to ensure timely classification.

2) Mode 2 included in operating mode applicability as per developer notes.1,2Emergency Action Levels (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. Automatic Trip did not shutdown the reactor as indicated by Reactor Power> 5%.ANDb. Subsequent manual action taken at the Main Control Board is successful inshutting down the reactor.OR2. a. Manual Trip did not shutdown the reactor as indicated by Reactor Power> 5%.ANDb. EITHER of the following:

I. Subsequent manual action taken at the Main Control Board issuccessful in shutting down the reactor.OR2. Subsequent Automatic Trip is successful in shutting down thereactor.Page 34 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SAZInitiating Condition:

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

Operating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Alert promptly upon determining that15 minutes has been exceeded, or will likely be exceeded.

1. a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.[see table below](BWR parameter list) (PWR parameter list]Reactor Power Reactor PowerRPV Level RCS LevelRPV Pressure RCS PressurePrimary Containment Pressure In Core/Core Exit Temperature Suppression Pool Level Levels in at least (site specific number)steam generators Steam Generator Auxiliary orSuppression Pool Temperature Emergency 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)MA4Initiating Condition:

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

Operating Mode Applicability:

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

1. a An UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes.H-x No Change FIDifference FIDeviation

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

Table M1 -Control Room Parameters

Reactor Power* PZR Level* RCS PressureIn Core/Core Exit Temperature

Narrow Range level in at least one Steam Generator

Steam generator Auxiliary Feed Water FlowANDb. Any Table M2 transient in progress.

Table M2 -Significant Transients

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

>25% full electrical load* Reactor Trip* Safety Injection Actuation Page 35 of 66 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]BWR 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 Suppression Pool Temperature Steam Generator Auxiliary orEmergency Feed Water FlowMU4Initiating Condition:

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

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

An UNPLANNED event results in the inability to monitor ANY Table M1parameters from within the Control Room for > 15 minutes.F-I No Change D Difference FIDeviation

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

Table Ml -Control Room Parameters

" Reactor Power" PZR Level" RCS Pressure" In Core/Core Exit Temperature

" Narrow Range level in at least one Steam Generator

" Steam generator Auxiliary Feed Water FlowPage 36 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA9Initiating Condition:

ALERTHazardous event affecting a SAFETY SYSTEM needed for the currentoperating 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 degradedperformance in at least one train of a SAFETY SYSTEM needed for thecurrent operating mode.OR2. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure needed for the current operating mode.MA5Initiating Condition:

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

Power Operation,

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

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

Other events with similar hazard characteristics asdetermined by the Shift ManagerAND2.H No Change E Difference 1 Deviation

1) No additional site specific hazard noted2) Changed the word "needed" to "required" in the IC and to "required by Technical Specification" in the EAL, to be consistent with terminology used by operators andminimize confusion.

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 current operating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure required by Technical Specifications for the current operating mode.Page 37 of 66 0NEI 99-01 Rev 6 Proposed EAL IJustification 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:

1,2,3,4Emergency Action Levels (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 > 10 gpm for > 15minutesOR2. RCS identified leakage >25 gpm for > 15 minutesOR3. Leakage from the RCS to a location outside containment

>25 gpm for> 15 minutesM No Change D: Difference 1 Deviation

1) Listed site specific values to ensure timely classification.

Page 38 of 66 NEI 99-01 Rev 6 ] 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)SU6MU7Initiating Condition:

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

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

OR2. Loss of ALL Table M3 Offite 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 NRCRadios XPlant page XPlant Telephone System XCommercial Telephones X X XNARS XENS X XHPN X XSatellite phones X XM No Change I Difference

-- Deviation

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

Page 39 of 66 NEI 99-01 Rev 6SU7Initiating Condition:

UNUSUAL EVENTFailure to isolate containment or loss of containment pressure control.

[PWR]Operating Mode Applicability:

Power Operation,

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

ANDb. Less than one full train of (site-specific system or equipment) isoperating per design for 15 minutes or longer.Proposed EALJustification MU8Initiating Condition:

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

1,2,3,4Emergency Action Levels (EAL):1. a. Failure of containment to isolate when required by an actuation signal.ANDb. ANY required penetration remains open > 15 minutes of theactuation signal.OR2. a. Containment pressure

> 20 psig.ANDb. Less than one full train of Containment Spray is operating per designfor > 15 minutes.D- No Change M Difference 7 Deviation

1) Listed site specific indications to ensure timely classification.

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

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

1. Loss of ALL off-site AC power to unit ESF buses.AND2. Failure of DG 1A(2A) and DG 1B(2B) emergency diesel generators to supplypower to unit ESF buses.AND3. Failure to restore power to at least one unit ESF bus in < 15 minutes fromthe time of loss of both offsite and onsite AC power.No Change Difference Deviation

1) Listed site specific equipment to ensure timely classification.

Page 41 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU2Initiating Condition:

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

Cold Shutdown, Refueling, DefueledExample 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.CUIInitiating Condition:

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

5,6, DEmergency Action Levels (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 ESF buses reduced to only one of the following power sources for> 15 minutes." Affected unit SAT 142-1(242-1)

" Affected unit SAT 142-2(242-2)

" Emergency Diesel Generator DG 1A(2A)" Emergency Diesel Generator DG 1B(2B)" Unit crosstie breakersAND2. Any additional single power source failure will result in a loss of ALL AC powerto SAFETY SYSTEMS.No Change -- Difference Deviation

1) Listed site specific equipment to ensure timely classification.

Page 42 of 66 NEI 99-01 Rev 6 Proposed EAL Justification 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:

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

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

Other events with similar hazard characteristics 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 -1 No Change E Difference Deviation

1) No additional site specific hazard noted2) Changed the word "needed" to "required" in the IC and to "required byTechnical Specification" in the EAL, to be consistent with terminology used byoperators and minimize confusion.

Page 43 of 66 NEI199-01 Rev 6Proposed EALJustification NEI 99-01 Rev 6 Proposed EAL Justification 4 4CU4Initiating Condition:

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

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

Indicated voltage is less than (site-specific bus voltage value) on required Vital DCbuses for 15 minutes or longer.CU3Initiating Condition:

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

5, 6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

Voltage is < 108 VDC on required unit 125 VDC battery buses 111(211) and112(212) for > 15 minutes.1 No Change E Difference

[: Deviation

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

2) Removed the word "indicated" this will allow for an indication problem to notcause confusion on the need to declare.Page 44 of 66 NEI 99.01 I ~ev 6 Proposed EAL Justification Rev 6Proposed EALJustification 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:

5,6, DEmergency Action Levels (EAL):1. Loss of ALL Table Cl Onsite communications capability affecting theability to perform routine operations.

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

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

Table Cl -Communications Capability System Onsite Offsite NRCRadios XPlant page XPlant Telephone System XCommercial Telephones X X XNARS XENS X XHPN X XSatellite phones X XW No Change D Difference

[: Deviation

1) Listed site specific communications methods to ensure timely classification Page 45 of 66 NEI 99-01 Rev 6 f 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.

[PWR])CA5Initiating Condition:

Inability to maintain plant in cold shutdown.

Operating Mode Applicability:

5, 6Emergency Action Levels (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

> 200*F due to loss of decayheat removal for > Table C2 duration.

OR2. UNPLANNED RCS pressure rise > 10 pslg as a result of temperature rise due to loss of decay heat removal.

(This EAL does not apply duringwater- solid plant conditions.)

D: No Change E Difference 1 -1 Deviation

1) Listed site specific Technical Specification cold shutdown temperature limit toensure timely classification.

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

3) Added wording relating the temp and press rise to a loss of decay heat removalcapability as per the developer notes for PWR'sTable: 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

[PVVR]) 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*Not IntactEstablished 20 minutes*ORReducedInventory Not Established 0 minutes(<397 ft.)If an RCS heat removal system is in operation within this timeframe and RCS temperature is being reduced, then EAL #1 is notapplicable.

Page 46 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification CU3Initiating Condition:

UNUSUAL EVENTUNPLANNED increase in RCS temperature.

Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptlyupon determining that 15 minutes time has been exceeded, or will likelybe exceeded.

1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit).2. Loss of ALL RCS temperature and (reactor vessel/RCS

[PWR] or RPV[BR]) level indication for 15 minutes or longer.CU5Initiating Condition:

UNPLANNED rise in RCS temperature.

Operating Mode Applicability:

5,6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likelybe exceeded.

1. UNPLANNED rise in RCS temperature

> 200*F due to loss of decayheat removal.OR2. Loss of the following for > 15 minutes.* ALL RCS temperature indications AND* ALL RPV level indications D No Change W Difference Deviation

1) Listed site specific Technical Specification cold shutdown temperature limitto ensure timely classification.

2) Changed the word increase to rise in the initiating condition to be consistent with operations language and training.

Page 47 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CGIInitiating Condition:

GENERAL EMERGENCY Loss of (reactor vessel/RCS

[PWR] 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 Unusual Event promptlyupon determining that 30 minutes time has been exceeded, or will likelybe exceeded.

1. a. (Reactor vessel/RCS

[PWR9 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

[PI/VR] or RPV [BWR]) 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

[PWR]* 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).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.

CG6Initiating Condition:

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

Operating Mode Applicability:

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

1. a. RVLIS indicates 0% Plenum for > 30 minutes.ORReactor Vessel Refueling Level Indicators LT-046 and LT-049 < 392 ft. el. for> 30 minutes.ANDb. ANY Containment Challenge Indication (Table C4)OR2. Reactor vessel level unknown for_> 30 minutes.AND3. Core uncovery is indicated by ANY of the following:

a. Table C3 indications.

ORb. Erratic Source Range Neutron Monitor indication.

ORc. 1/2 RE-AR011 or 1/2 RE-AR12 Containment Fuel Handling Incidentradiation monitors> 3000 mR/hr.AND4. Any Containment Challenge Indication (Table C4)Table C3 Indications of RCS Leakage* UNPLANNED Containment Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED Tank level rise** UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.

H No Change W Difference

"-" Deviation

1) Listed site specific values for level, developer notes indicate the level to beapproximately Top of Active Fuel. The min indicated level of the transmitters LT-046 and 049 is 392 ft el. A level of 392 ft el along with RVLIS indicating 0%is being used as the lowest readable level. And allows for an escalation fromCS6.2) Listed site specific levels, radiation

monitors, and sumps and tanks to ensuretimely classification.

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

4) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Table C4 -Containment Challenge Indications

Hydrogen Concentration in Containment>

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

if CONTAINMENT CLOSURE is re-established prior toexceeding the 30-minute core uncovery time limit, thenescalation to a General Emergency is not required.

Page 48 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CS1Initiating 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 Unusual Event promptlyupon determining that 30 minutes time has been exceeded, or will likelybe 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

[PWR] or RPV [BW4R]) level less than (site-specific level).3. a. (Reactor vessel/RCS

[PW'] or RPV [SWR]) 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

[PWM]* 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:

5,6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likelybe exceeded.

1. With CONTAINMENT CLOSURE established EITHER:a. RVLIS indicates 0% PlenumORb. Reactor Vessel Refueling Level Indicators LT-046 and LT-049 <392 ft el.OR2. With CONTAINMENT CLOSURE not established EITHER:a. RVLIS < 15% Plenum.ORb. Reactor Vessel Refueling Level Indicators LT-046 and LT-049 <393 ft. el.OR3. a. Reactor vessel level unknowvn for >30 minutes.ANDb. Core uncovery is indicated by any of the following:

Table C3 indications.

OR* Erratic Source Range Neutron Monitor indication.

OR* 1/2 RE-AR011 or 1/2 RE-AR12 Containment FuelHandling Incident radiation monitors

> 3000 mR/hr.H: No Change W Difference 1 Deviation

1) Listed site specific values for level, developer notes indicate the level to beapproximately Top of Active Fuel. The min indicated level of the transmitters LT-046 and 049 is 392 ft el. A level of 392 ft el along with RVLIS indicating 0%is being used as the lowest readable level. And allows for an escalation fromCA6.2) For Containment closure not established developer notes indicate the levelto be 6" below the bottom ID of the RCS loop where it enters the vessel. Thislevel is 391.9' and is below the min indicated level of the transmitters LT-046and 049, which is 392 ft el. a level of 393 ft el. was chosen as well as < 15%Plenum ( the bottom of the hot leg) this is within the indicated range of theinstrument, it also represents a substantial degradation of the condition fromthe CA6 level criteria and allows for escalation to CG6 as well as lowing for aContainment closure established level,3) Listed site specific radiation monitors to ensure timely classification

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

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

Page 49 of 66 0NEI 99-01 Rev 6Proposed EALJustification F -ICA1Initiating Condition:

ALERTLoss of (reactor vessel/RCS

[PqR] or RPV [BIAWR])

inventory Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptlyupon determining that 15 minutes time has been exceeded, or will likelybe exceeded.

1. Loss of (reactor vessel/RCS

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

[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 [BWRj) inventory.

CASInitiating Condition:

Loss of reactor vessel / RCS inventory Operating Mode Applicability:

5,6Emergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likelybe exceeded.

1. a. Loss of reactor vessel I RCS inventory as indicated RVLIS <37% Plenum.ORb. Loss of reactor vessel / RSC inventory as indicated by LT-046 andLT-049 < 393.5 ft. el.OR2. a. Reactor vessel / RCS level unknown for > 15 minutes.ANDb. Loss of reactor vessel / RCS inventory per Table C3 indications.

D: No Change E Difference 1-1 Deviation

1) Listed site specific levels to ensure timely classification.

The developer notesindicate the levels to correspond to the level required to support RHR pumpoperation, lAW BOA PRI-1 0 (LOSS OF RH COOLING)

RCS levels of > 37% or393.5' on LT-046 and LT -049 as necessary to maintain RH pumps operating atreduced inventory conditions.

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

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

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

Page 50 of 66 NEI 99-01 Rev 6 1 Proposed EAL ]Justification CulInitiating Condition:

UNUSUAL EVENTUNPLANNED loss of (reactor vessel/RCS

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

[PWR] or RPV [BW'R) 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:

5, 6Emergency Action Levels (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 restoreand maintain reactor vessel I RCS level to> procedurally established lower limit for >15 minutes.OR2. a. Reactor vessel / RCS level unknown.ANDb. Loss of reactor vessel / RCS inventory per Table C3 indications.

H No Change W Difference 1 Deviation

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

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

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

Page 51 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HG1HG1Initiating Condition:

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

Operating Mode Applicability:

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

ANDb. EITHER of the following:

1. ANY of the following safety functions cannot be controlled ormaintained.

Reactivity control* Core cooling [PWVR] / RPV water level [BVWR]RCS heat removalOR2. Damage to spent fuel has occurred or is IMMINENTInitiating Condition:

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

Operating Mode Applicability:

1, 2, 3, 4, 5, 6, DEmergency Action Levels (EAL):1. A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.AND2. a. ANY Table H1 safety function cannot be controlled or maintained.

ORb. Damage to spent fuel has occurred or is IMMINENTD] No Change F Difference

--Deviation

1) List site security shift supervision as Security Force.2) Added descriptors to better explain each safety function and allow for a timelyclassification.

Table HI -Safety Functions

" Reactivity Control(ability to shutdown the reactor and keep it shutdown)

" Core Cooling (ability to cool the core)* RCS Heat Removal (ability to maintain a heatsink)

Page 52 of 66 NEI 99-01 Rev 6 Proposed EAL [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).

HS1Initiating Condition:

HOSTILE ACTION within the Protected Area.Operating Mode Applicability:

1,2,3,4,5,6, DEmergency Action Levels (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.F No Change FIDifference FIDeviation

1) List site security shift supervision as Security Force.Page 53 of 66 NEI 99-01 Rev 6 1 Proposed EAL ] Justification HA1Initiating Condition:

ALERTHOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attackthreat within 30 minutes.Operating Mode Applicability:

AllExample Emergency Action Levels: (1 or 2)1. A HOSTILE ACTION is occurring or has occurred within the OWNERCONTROLLED AREA as reported by the (site-specific security shiftsupervision).

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

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

1, 2, 3,4, 5,6, DEmergency Action Levels (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutesfrom the site.OR2. Notification by the Security Force that a HOSTILE ACTION is occurring orhas occurred within the OWNER CONTROLED AREA.M No Change FIDifference Deviation

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

UNUSUAL EVENTConfirmed SECURITY CONDITION or threat.Operating Mode Applicability:

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

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

Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:

1, 2, 3,4, 5,6, DEmergency Action Levels (EAL):1. Notification of a credible security threat directed at the site as determined perSY-AA-101-132, Security Assessment and Response to Unusual Activities.

OR2. A validated notification from the NRC providing information of an aircraftthreat.OR3. Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.M No Change FIDifference FIDeviation

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

Page 55 of 66 NEI 99-01 Rev 6 Proposed EAL ] Justification HS6Initiating Condition:

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

AllExample Emergency Action Levels: (1 and 2)Note: The Emergency Director should declare the event promptly upon determining that(site-specific number of minutes) has been exceeded, or will likely be exceeded.

1. An event has resulted in plant control being transferred from the ControlRoom to (site-specific remote shutdown panels and local control stations).

2. Control of ANY of the following key safety functions is not reestablished within (site-specific number of minutes).

Reactivity controlCore cooling [PWR] / RPV water level [SWR]* RCS heat removalHS2Initiating Condition:

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

1,2, 3,4, 5, 6, DEmergency Action Levels (EAL):Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.

1. A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per 1/280A PRI-5, ControlRoom Inaccessibility.

AND2. Control of ANY Table H1 key safety function is not reestablished in < 15minutes.FH No Change W Difference 1 Deviation

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 anevent 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,2) Added descriptors to better explain each safety function and allow for a timelyclassification.

3) Changed "An event" to" A Control Room evacuation" to remove confusion ifpartial plant control was transferred to outside the control room with the controlroom still manned, due to testing or equipment failure.Table HI -Safety Functions

Reactivity Control(ability to shutdown the reactor and keep it shutdown)

Core Cooling (ability to cool the core)* RCS Heat Removal (ability to maintain a heatsink)

Page 56 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HA6Initiating Condition:

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

Operating Mode Applicability:

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

HA2Initiating Condition:

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

Operating Mode Applicability:

1, 2, 3, 4, 5,6, DEmergency Action Levels (EAL):A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per 1/2B0A PRI-5, Control RoomInaccessibility.

D- No Change F Difference FIDeviation

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 anevent 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,2) Changed "An event" to" A Control Room evacuation" to remove confusion ifpartial plant control was transferred to outside the control room with the controlroom still manned, due to testing or equipment failure.Page 57 of 66 NEI 99-01 Rev 6 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, 5,6, DM No Change F1 Difference F ]Deviation

1) Listed site specific list of plant rooms or areas that contain SAFETY SYSTEMequipment 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.

1. a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:

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

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

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

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

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

1. a. A FIRE in any Table H2 area is not extinguished in <15.-minutes of ANYof the following FIRE detection indications:

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

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

Field verification of a single fire alarmTable H2 -Vital Areas* Containment

Auxiliary Building* Fuel Handling Building* Main Steam Tunnels* RWST's* Condensate Storage Tanks* Essential Service Water Cooling TowersOR2. a. Receipt of a single fire alarm in any Table H2 area (i.e., no otherindications of a FIRE).ANDb. The existence of a FIRE is not verified in <30-minutes of alarm receipt.OR3. A FIRE within the plant PROTECTED AREA not extinguished in<60-minutes of the initial report, alarm or indication.

OR4. A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

Page 58 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENTSeismic event greater than OBE levels.Operating Mode Applicability:

HU2HU4Initiating Condition:

Seismic event greater than OBE levels.Operating Mode Applicability:

1,2, 3,4, 5,6, DEmergency Action Levels (EAL):Seismic event > Operating Basis Earthquake (OBE) as indicated by seismiccheck at panel OPA02J.AllExample Emergency Action Levels:Seismic event greater than Operating Basis Earthquake (OBE) as indicated by:a. (site-specific indication that a seismic event met or exceeded OBE limits)F] No Change FIDifference F Deviation

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

Page 59 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification HASInitiating Condition:

ALERTGaseous release impeding access to equipment necessary for normal plantoperations, cooldown or shutdown.

Operating Mode Applicability:

AllExample Emergency Action Levels:Note: If the equipment in the listed room or area was already inoperable, or outof service, before the event occurred, then no emergency classification iswarranted.

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

ANDb. Entry into the room or area is prohibited or impeded.HASInitiating Condition:

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

Operating Mode Applicability:

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

1. Release of a toxic, corrosive, asphyxiant or flammable gas in a Table H3 area.Table H3Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Auxiliary Building*

Mode 4, 5, and 6*Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impeded.F] No Change FIDifference FIDeviation

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

Page 60 of 66 NEI 99-01 Rev 6 Proposed EAL [Justification Initiating Condition:

UNUSUAL EVENTHazardous EventHU3HUBInitiating Condition:

Operating Mode Applicability:

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

I. A tornado strike within the PROTECTED AREA.2. Internal room or area flooding of a magnitude sufficient to require 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)Hazardous EventOperating Mode Applicability:

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

F No Change M Difference FIDeviation

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

1.2.Tornado strike within the PROTECTED AREA.ORInternal 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.

Page 61 of 66 NEI 99-01 Rev 6 f Proposed EAL Justification HG7HG7M No Change [ Difference 7 Deviation Initiating Condition:

GENERAL EMERGENCY Initiating Condition:

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

Operating Mode Applicability:

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

Releases can be reasonably expected to exceed EPA Protective ActionGuideline exposure levels off-site for more than the immediate site area.Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a General Emergency.

Operating Mode Applicability:

1,2, 3,4, 5, 6, DEmergency Action Levels (EAL):Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or IMMINENTsubstantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control ofthe 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 I Justification HS7HS7Initiating Condition:

SITE AREA EMERGENCY Initiating Condition:

W No Change I Difference F Deviation Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a Site Area Emergency.

Operating Mode Applicability:

AllExample Emergency Action Levels: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 ACTIONthat results in intentional damage or malicious acts; (1) toward site personnel orequipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are notexpected to result in exposure levels which exceed EPA Protective ActionGuideline exposure levels beyond the site boundary.

Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a Site Area Emergency.

Operating Mode Applicability:

1,2, 3, 4, 5, 6. DEmergency Action Levels (EAL):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 ACTIONthat results in intentional damage or malicious acts: (1) toward site personnel orequipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are notexpected 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 jProposed EAL I[Justification HA7HA7Initiating Condition:

ALERTInitiating Condition:

M No Change F"Difference FIDeviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an Alert. declaration of an Alert.Operating Mode Applicability:

AllExample Emergency Action Levels: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 substantial degradation of the level of safety of the plant or a security event thatinvolves probable life threatening risk to site personnel or damage to siteequipment because of HOSTILE ACTION. Any releases are expected to belimited to small fractions of the EPA Protective Action Guideline exposure levels.Operating Mode Applicability:

1, 2, 3, 4, 5, 6, DEmergency Action Levels (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 substantial degradation of the level of safety of the plant or a security event thatinvolves probable life threatening risk to site personnel or damage to siteequipment 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 HU7Initiating Condition:

UNUSUAL EVENTOther conditions existing which in the judgment of the Emergency director warrantdeclaration of an UNUSUAL EVENT.Operating Mode Applicability:

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

No releases of radioactive material requiring offsiteresponse or monitoring are expected unless further degradation of safety systemsoccurs.HU7Initiating Condition:

No Change EIDifference FI Deviation Other conditions existing which in the judgment of the Emergency director warrantdeclaration of an UNUSUAL EVENT.Operating Mode Applicability:

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

No releases of radioactive material requiring offsiteresponse or monitoring are expected unless further degradation of safety systemsoccurs.Page 65 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification E-HUIInitiating Condition:

UNUSUAL EVENTDamage to a loaded cask CONFINEMENT BOUNDARY.

Operating Mode Applicability:

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.E-HU1Initiating Condition:

Damage to a loaded cask CONFINEMENT BOUNDARY.

Operating Mode Applicability:

1, 2, 3,4, 5, 6, DEmergency Action Levels (EAL):Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading:* > 60 mr/hr (gamma + neutron) on the top of the spent fuel caskOR* > 600 mr/hr (gamma + neutron) on the side of the spent fuel cask,excluding inlet and outlet ducts.M No Change F Difference

--Deviation

1) Listed 2x the site specific cask specific allowable radiation level as per theCertificate of Compliance No. 1014 Appendix A Section 5.7Page 66 of 66 Bvron AnnexExelon NuclearByron Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARG1Initiating Condition:

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

1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.

" .The E=mergencY Director should declare the Genoral Emergency event promptly upondetermininig that the applicable time has boon oxcoodod, Or Well likely be excooded.

" 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 minutesor lOn Gger:(site specific monitor list. and thre~shold values)1. The sum of readings on the Unit 1 and 2 Aux BLDG Vent WRGMs (1/2 RE-PR030)

>9.99 E+09 uCi/sec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS-Total Noble Gas Release Rate).OR2. Dose assessment Using actual meteorology indicates doses at or beyond (site-specific dose r;epGt PoGrFot) the site boundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidMonth 20XXBY 3-1EP-AA-1002 (Revision XX)

Rvron AnnexI=yelnn Rvrn Annex" Exeln N.i t-larRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ORr-!rie uiu LU.wy retUIlts iIIUIUirW-ElITHER -4 th: 4LI41U iuing at 9F 99YU[IU ~tsit SpeGII:do9s8 rocoptor POWn)'ClotediWnAdow AWdo rates groator than 1,000 mR'hr expoctod to ti forF60 O longor.AnalysosA o-f fio-ld- urawpy samnples indicate thyroid GDE groator than 5,000 mrornfor ono hur Of inhalation.

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 mRerem while the 5000 mRfem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.nent is established.

if the effluent flow past an offluent is knoAn to havestopped due to actions to isolate the reloase path, then the effluent monitoar reading is nlonger Valid for noassifi Gate on purFposes.

Basis Reference(s):

1. NE 199-01 Rev 6, AG12. EP-AA-1 12-500 Emergency Environmental Monitoring Month 20XXBY 3-2EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

3. EP-EAL-0602 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Byron StationMonth 20XXBY 3-3EP-AA-1002 (Revision XX)

Rrnn AnnoyIP::alnn kiirloarRurr~n Annoy FvoIr~n hi. irlamr-V I ~* I F~~* *I *~~t ~ U * ~RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARSIInitiating Condition:

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

1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):Notes:--The Emergency Director should declare the Site Area Emtergepny eVent promgptlha tupon doteFArminig that the applicable time has boon oxcoedod, or wA.ill likely beeXGeeded*-The Emergency Director should declare the event promptly upon determining that theapplicable 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 A NY ofA the_ following raiainmoitors greater than the reading shownfor 15 FmiRnWte r longr:-(site monitor list -and- threshold-values)(2) Dose assessment using actual meteoFrolgy indic'ates gFeater than 1000m:romF TEDE or 500 mroem thyroid ODE= at Or be8yond (site spei8fic dose recepto(3) Field sUrVoy ro cults indicate EITHER of the following at or beyond (Site specifilos6s .eGeptor point):..

" Closed window dose rates greater-than 100 mP.hw expeeted to eentinlue for- 60 minutesor- loger-" Analyses of field survey samples indicate thyroid CDE gr-eater thant 500 inremf for- onehour Of inhhalation.

Month 20XXBY 3-4EP-AA-1002 (Revision XX)

Rr nn Anngav9:vgmlrn klma&-Inýr

-**UJ

fRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS

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

>9.99 E+08 uCilsec for > 15 minutes (as determined from Unit 1 & 2 PF430 or PPDS-Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboun 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.ORAnalyses 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 mRfem while the 500 mRremthyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDEand thyroid CDE.Classific~ation based on effluont moanitor readings assumos-that- -n ro-loase path totho onvironmont is ostablished.

if tho offluont flow part an efflue nt. monito-r is. known tohavo stopped due to actions to isolate the release path, then the effluent moniRtor roadingis no longor valid for classificatio pupSo.Month 20XXBY 3-5EP-AA-1002 (Revision XX)

Exalon NuclearBvrnn Annex Ex.....Nuclea.

RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Escalation of the emergency classification level would be via IC RAG1.Basis Reference(s):

1. NEI 99-01 Rev 6, AS12. EP-AA-1 12-500 Emergency Environmental Monitoring

3. EP-EAL-0602 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Byron StationMonth 20XXBY 3-6EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARAIInitiating Condition:

Release 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, 5,6, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.

" .The Emergency Director should declare the Alert event promptly upon determining that the applicable time has, been exceeded, Or 81 iHkely beooxcoodd

" 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.

for 15 minutes o r on r :r r.(site specifirc mnnontor lis and thresthold unh -9es(2) Dose assessment using actu6"al me"teoFrolgy s dses% greater than 10 mre.mFTEDE Or 50 mromF9 thyroid Er- at or OF beyond (site specific-dose re-eptor pint).(3) Analysis of a liquid effluent sample indicates al cocentratiomn o release rate thatwould result in doses greatter than 10 mrom TEDE Or 50 mromA thyroid -DE at OFbeyond (site specific deco receptor poin~t) for one hour of exposure(4) Field sur.ey results indicate EITHER of the follewing at or beyond (site specificdose receptor point);* Closed window dose rates greater-than 10 mR'hr- expected to continue for- 60 minutes or-* Analyses of field survey samples indieate thyroeid GDE greater-tha 50 mrnef for- oneMonth 20XXBY 3-7EP-AA-1 002 (Revision XX)

Exelon Nuclear.vr.n AnnexEe NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS hour of inhalation.

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

> 9.99 E+07 uCilsec for> 15 minutes (as determined from Unit 1 & 2 PF430 orPPDS -Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:Ia. > 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 10 mRem TEDE or 50 mRem CDE thyroid at orbeyond the site boundary for 60 minutes of exposure.

OR4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mR/hr are expected tocontinue for a 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 thisMonth 20XXBY 3-8EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS magnitude represent an actual or potential substantial degradation of the level of safety ofthe 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.C-lanes-dicatunn basd n e-fflue-nt mntr read-ings assumes-that- A- roloeaso path toDthe eniro-n~m~enti i If the effluent flow past an offluont mneito s known thave stopped duo to actions toý isolate the release path, then the effluont monitor rFain;r, rn Io9eF valid for c-lassification purp osEscalation of the emergency classification level would be via IC RAS1.Basis Reference(s):

1. NEI 99-01 Rev 6, AA12. UFSAR Section 11.5.2.33. OBISR 11 .a.3-002, Channel Operation Test of Liquid Radwaste Effluent Radiation Monitor OPR01J4. ODCM, CY-BY-170-301, Section 3.0, Liquid Effluents

5. EP-EAL-0602 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Byron Station6. EP-EAL-0619 Rev. 0, Byron Criteria for Choosing Radiological Liquid Effluents EAL Threshold Values.7. EP-EAL-0624 Rev. 0, Byron Criteria for Choosing Radiological Gaseous Effluents EAL Threshold Values for Waste Gas Decay TanksMonth 20XXBY 3-9EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARUIInitiating Condition:

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

1,2,3, 4,5,6, DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.

-The rimnergenR-G D'FlretGF sould, , eI a nr l the U nusa , rnt e,,ent ,-,-,m-ptl,,

,,upndotermininig that 60 mninutes has boon oXcooded, Or Will likely bo oxcoodod.

" 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 ANY effluent radiation mon~itor greater than 2 times the (site specificeffluent release ,-ntromling dOUMRnt)

Ilimits for 60 minutos Or longer(site specifc monior lIst and threshold ValUeS no-responding to 2 times thoco-ntrollin*Rg dcume-nnMt limit4)(2) Reading on any ofAeflulot radiatn monir greater than 2 times the alarm s tpointestablished by a current radioactivity deleharge pedrit for 60 mintutos Or longer.(3) Sample analysis for a gaseous or liquid releases indicates a concentration orelease rate greater than 2 timers the (site specilfic-effluenA-t release controlling documnent) limits0 4Fo 6-0 minutes Or longer.1 .Reading on any of the following effluent monitors

> 2 times alarm setpointestablished by a current radioactive release discharge permit for > 60 minutes." OPROQI, Liquid Radwaste Effluent Monitor" 0PR002, Gas Decay Tank Effluent Monitor" OPRO10, Station Blowdown Monitor" 1/2PROO1, Containment Purge Effluent MonitorMonth 20XXBY 3-10EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 0 Discharge Permit specified monitorOR2. The sum of readings on the Unit 1 and 2 Aux Bldg Vent WRGMs (1/2 RE-PR030)

> 1.14 E+06 uCilsec for > 60 minutes (as determined from Unit I & 2 PF430 orPPDS -Total Noble Gas Release Rate).OR3. 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.

Clasrsific,,.ation based on effluent monitor rading assumes that a roleaso pth atothe enyironment i6 establishod.

if the offluont flow past an effluent monitor is known tohave stepped due to acions to iselato tho roloaso path, thon the oeffiluont mon~itor roading6s no logRer valid for casfcto upssReleases should not be prorated or averaged.

For example, a release exceeding 4 timesrelease limits for 30 minutes does not meet the EAL.EAL #1 Basis:E-Al-#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 thoseMonth 20XXBY 3-11EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS listed (e.g., a portable or temporary effluent monitor),

then the declaration criteria will bebased on the monitor specified in the Discharge Permit.EAL #2 Basis:EAL-# 1--This EAL addresses normally occurring continuous radioactivity releases frommonitored gaseous OFri-ideffluent pathways.

EAL #3 Basis:RAL--#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 RAAl.Basis Reference(s):

1. NEI 99-01 Rev 6, AU2. UFSAR Section 11.5.2.33. OBISR 11 .a.3-002, Channel Operation Test of Liquid Radwaste Effluent Radiation Monitor OPRO1J4. ODCM, CY-BY-170-301, Section 3.0, Liquid Effluents

5. EP-EAL-0602 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Byron StationMonth 20XXBY 3-12EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA20Initiating Condition:

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

1, 2,3, 4,5,6, DEmergency Action Level (EAL):(1) UIIn,,ovo ofirradiated fue! in the REFUELING PATHWAIY.

ke) DaIIage LU IFILdiatUU fuel FesuIltrm iII a F9UIU~e Of FaU:~lIVIty HUG~He lue asIindicatod by ANY of the following radiation moeniteos; (Sate I pecific lieting of radiation mo nitors, and tho aSSOciatod

readings, setpoints and/or alaFrms)(3) LoGWering Of Spont fuol pool level to (site specific Level 2 value). [See Devloeiw1. 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 mRem/hrTable R1Fuel Handling Incident Radiation Monitors" Fuel Building Fuel Handling Incident Monitor ORE-AR055

Fuel Building Fuel Handling Incident Monitor ORE-AR056

" Containment Fuel Handling Incident Monitor 1/2RE-AR01 1* Containment Fuel Handling Incident Monitor 1/2RE-AR012 Month 20XXBY 3-13EP-AA-1002 (Revision XX) 12,rfj m. ' A r% mmwF~vmlin N: Jrl-,rRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis: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.

This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly.,

r a in ...g o, f Water. level ..thin the spent fuel pee! ,veeDevel. N.. es). 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-HUI.Escalation of the emergency would be based on either Recognition Category A or C ICs.EAL #1 Basis:EAL #!This 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 ae iGweaserise in a dose rate due to alowering of water level in some portion of the REFUELING

PATHWAY, the reading maynot be a reliable 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.Month 20XXBY 3-14EP-AA-1002 (Revision XX)

Ilr Io~ln AnngyIPvalnn NdiilAnnr A~rnAnvF'arnM RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS EAL #2 Basis:This 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.fuN pool water le..el at. this , value is w:thin the lower end of the level rangenecessary to ...V.nt cncoAuoGce fro.m' diFrGt rad-liati..n topersonnel Pe-erMIng opeatins in the Vicinity Of the spent fuel pool.T c irefect a ign;ifican~t loss of spent fuel pool water inetr'and thu i i also a precursor to Ra loss of the ability to adequately cool the irradiated fuel assembles stored On the polEscalation Of the IemerGy cIaIfIicatin Ielel WGIeud be vIa IQs ASI or AI2 (see I 2D..v..r.

.Aites).Basis Reference(s):

1. NEI 99-01 Rev 6, AA22. UFSAR 11.5.2.2.6, 11.5.2.2.7, 15.7.4, Table 12.3-33. Technical Specification Table 3.3.6-14. 1/2 BOA REFUEL-1 Fuel Handling Emergency Unit 1/25. 1/2 BOA REFUEL-2 Refueling Cavity or Spent Fuel Pool Level Loss Unit 1/26. TRM 3.9.A, Refueling Operations, Decay Time7. BAR 1-1-A2, 2-1-A2, CNMT DRAIN LEAK DETECT FLOW HIGH alarmMonth 20XXBY 3-15EP-AA-1002 (Revision XX)

Rrrnn AnnghvF:valnn Nnif-lnrRurnA nyFL~ kta~~RECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARU2Initiating Condition:

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

1, 2,3,4,5,6, DEmergency Action Level (EAL):(1) a. UNPLANNED wateFr level drp in the REFUELING PATHWAY as indi,-ted by ANY of the follo-ing:

(Site SpolfIc lol indications).

ANDtb. UNPLANNED rise i area radiation levels as indicatod by ANY of thefollowing radiation moneitors.

(site specific lost of area radiation moenitors)

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

" Refueling Cavity water level < 23 ft. above the Reactor Flange (< 423 ft.indicated level).OR* Spent Fuel Pool water level < 23 ft. above the fuel (< 422 ft. 9 in.indicated level).OR* Indication or report of a drop in water level in the REFUELING PATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R1.Table R1 -Fuel Handling Incident Radiation Monitors* Fuel Building Fuel Handling Incident Monitor ORE-AR055

Fuel Building Fuel Handling Incident Monitor ORE-AR056

Containment Fuel Handling Incident Monitor 1/2RE-AR01 1* Containment Fuel Handling Incident Monitor 1/2RE-AR012 Month 20XXBY 3-16EP-AA-1002 (Revision XX) rnI'l'ln AnnlolvI:valnn kiiiil,-n-r RuanAna vnenMiLna RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 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 deGrease-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 a4 ihGeaserise 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 iG-easerise due to planned evolutions such as liftingof the reactor vessel head or movement of a fuel assembly.

Note that this EAL isapplicable only in cases where the elevated reading is due to an UNPLANNED loss ofwater 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 Specifications 3.7.143. 1/2 BOA REFUEL-1 Fuel Handling Emergency Unit 1/24. 1/2 BOA REFUEL-2 Refueling Cavity Or Spent Fuel Pool Level Loss Unit 1/25. BAR 1-1-Cl SPENT FUEL PIT LEVEL HIGH LOW6. 1/2 BOSR 0.1-6 Unit One(Two)

Mode 6 Shiftly and Daily Operating Surveillance

7. BOP RH-8 Filling the Refueling Cavity for Refueling

8. BOP RH-9 Pump Down of the Refueling Cavity to the RWST9. BOP RC-4 Reactor Coolant System Drain10. BAR 1-6-C3 REFUELING CAVITY LVL HIGH/LOWMonth 20XXBY 3-17EP-AA-1002 (Revision XX)

Rrrnn AnnghvPvall~n Nhm,-laor RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA3Initiating Condition:

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

Operating Mode Applicability:

1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):Note: If the equipment in the listed-room or area listed in Table R3 was alreadyinoperable, or out of service, before the event occurred, then no emergency classification is warranted (1) Dose rate areator than 15 mRn'h in ANY of the following areas:C,Geigntal Alarm Stationp(other-site specific arceas/rooms)

(2) An UNPLANNE vernt results in rad-i4;at;ion levels that Prohi-it or i;mrodlo acess tor...(site list of Want rooms or areas with moaca aDri91iC)iIPt-/

eRed)I1. Dose rate gieateF-thaf>

15 mR/hr in ANY of the following Table R2 areas:Table R2Areas Requiring Continuous Occupancy 0 Main Control Room -1/2RE-AR010

Central Alarm Station -(by survey)ORMonth 20XXBY 3-18EP-AA-1002 (Revision XX)

Rvron AnnexFmalon Nuelparyro Ann.. x.............

.l... rRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS

2. 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 ModeApplicability Auxiliary Building*

Mode 4, 5 and 6*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 operatien, Or a normal plant coldown andshu-tdow.

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 serviceat the time of the radiation l-evels.

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 procedure, requiring use of non-routine protective equipment, requesting anMonth 20XXBY 3-19EP-AA-1002 (Revision XX)

Rrnn AnnoyRurnn nn~v' volinn N~rvlaa~sr RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS extension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the 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 R nrise 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. UFSAR Chapter 3.02, UFSAR Table 3.2-1Month 20XXBY 3-20EP-AA-1002 (Revision XX)

Rronn A nn,-vI:=alrtn RJrL n~ vi~ kira~RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS SRU3Initiating Condition:

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

1,2,3,4Emergency Action Level (EAL):(1) (SitW .epf.. radiation monitor) roading greater than (site .epifc ; ...(2) Sample analysis indicatoc that a reactor coolant actr.'ity value* eigr~aeF than anallwabo lmitSpocified in Toc.hnical Spocificatione.

1 .Gross Failed Fuel Monitor 1/2RE-PROQ6 (1/2 PS206-High Energy) indicating 1-135concentration

> 5 uCi/cc.OR2. Sample analysis indicates that:a. Dose Equivalent 1-131 specific coolant activity

> 60.0 uCi/gm.ORb. Dose Equivalent XE-i 33 specific coolant activity

> 603.0 uCilgm.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 FAl or the Recognition Category RA4 ICs.Month 20XXBY 3-21EP-AA-1002 (Revision XX)

Pre-rnn AnnovRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

.Basis Reference(s):

1. NEI 99-01 Rev 6, SU32. Technical Specifications 3.4.163. 1/2BOA PRI-4, High Reactor Coolant Activity Unit 1/24. PWR Letdown Rad Monitor Setpoint Calculation for Degraded Fuel Indication Month 20XXBY 3-22EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FG1Initiating Condition:

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

1,2,3,4Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.

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

1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXBY 3-23EP-AA-1002 (Revision XX) l3vron AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FS1Initiating Condition:

Loss or Potential Loss of ANY two barriers.

Operating Mode Applicability:

1,2,3,4Emergency 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-3Month 20XXBY 3-24EP-AA-1002 (Revision XX)

R rr~n AnnoyIPvalnn Nld~lanrRu mn Annav Fv~Inn MmIf~I~2r RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FA1Initiating Condition:

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

1,2,3,4Emergency 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-3Month 20XXBY 3-25EP-AA-1002 (Revision XX)

Rtrnn AnnavFvi:=,nn kl, f-lnnrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC1Initiating Condition:

RCS or SG Tube LeakageOperating Mode Applicability:

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

POTENTIAL LOSSA ~ ~ ~ & ---tO .... .. ..I 1- ... .L--- 1--:L_* ~a. ~Core Cooling CFSCSF-Orange Path conditions existBasis:There is no Loss threshold associated with RCS or SG Tube Leakage.Potential Loss Threshold BasisCore Cooling -ORANGE indicates subcooling has been lost and that some claddamage may occur.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. 1/2 BFR-C.2 Response to Degraded Core Cooling Unit 1/2Month 20XXBY 3-26EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC2Initiating Condition:

Inadequate Heat RemovalOperating Mode Applicability:

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

LOSSA. CoFo Ei-vt Thermoouple readings greatFr thaan (sito specifc temporaturo value)1. Core-Cooling CSF- Red Path conditions exist.Potential LossA. Coro exit theFrmocouple readings greater than (Sito Specific tomperaturo value).I'l I- -- ...flI"t'fl L ---Ll.!; 4 1. ; A;

A k* * * * ~* *

4* 4r" 361oiftc indiGcatioSa).

2. Core Cooling CSF-Orange Path conditions exist.II l UUI IUI ulna g UU II --J' * ....OR3. Heat Sink CSF- Red Path conditions exist.Basis:Loss Threshold

1 BasisL-es-2-A temperatures within the core are sufficient to cause significant superheating of reactor coolant.Core Cooling -RED indicates significant superheating and core uncovery and isconsidered to indicate loss of the Fuel Clad Barrier.Potential Loss Threshold

2 BasisPotential Lossr 2.A.This-Fead4i;94indicates temperatures within the core are sufficient to allow the onset ofheat-induced cladding damage.Core Cooling -ORANGE indicates subcooling has been lost and that some claddamage may occur.Potential Loss Threshold

3 BasisPotential Loss 2.13This condition indicates an extreme challenge to the ability to remove RCS heat usingthe steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier.

The Heat Sink Critical SafetyMonth 20XXBY 3-27EP-AA-1002 (Revision XX)

Anna-I=walnn NrlalnrA nn~~ Fvc inn IJaa~I~2r

-V U

U rn .. .stRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Function Red path condition exists if narrow range levels in all steam generators (S/Gs)are less than or equal to 10% -Unit 1 (31% adverse containment) and 14% -Unit 2(34% adverse containment) and total feedwater flow to all S/Gs is less than or equal to500 gpm. In accordance with EOPs, there may be unusual accident conditions duringwhich operators intentionally reduce the heat removal capability of the steam generators by reducing total feed flow to less than 500 gpm; during these conditions, classification using threshold is not warranted.

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

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. 1/2 BST-2 Core Cooling Unit 1/23. 1/2 BFR-C.1 Response to Inadequate Core Cooling Unit 1/24 1/2 BFR-C.2 Response to Degraded Core Cooling Unit 1/25. 1/2 BST-3 Heat Sink Unit 1/26. 1/2 BFR H.1, Response to Loss of Secondary Heat Sink Unit 1/2Month 20XXBY 3-28EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC3Initiating Conditlin:

Containment Radiation

/ RCS ActivityOperating Mode Applicability:

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

LOSS1A. Containment radiation monitor reading gr.ater than (site sp.cific value)(AR020(21))

reading > 1.95E+03 R/hr.OR28. (Site specific; indic-atio-mns reac-tor

-oo-lant aci.'i,;

is grator than 3QQG,;mdco i....al.nt

31) Coolant activity as sampled > 300uCi/gm Dose Equivalent 1-131Basis:Loss Threshold

1 BasisL The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the containment, assuming that reactor coolant activity equals300pCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greaterthan that expected for iodine spikes and corresponds to an approximate range of 2% to5% fuel clad damage. Since this condition indicates that a significant amount of fuelclad 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 RC3 Loss Tthreshold

&A since 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.

Loss Threshold

2 BasisBThis threshold indicates that RCS radioactivity concentration is greater than 300 pCi/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 Month 20XXBY 3-29EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION There is no Potential Loss threshold associated with RCS Activity

/ Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. S&L calculation BB-ER-02, Rev 03. Core Damage Assessment Methodology (CDAM)Month 20XXBY 3-30EP-AA-1002 (Revision XX)

Rvron AnnexExelon NuclearB-ron Annex...E.....n..Nuclear.

RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC56Initlating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1,2,3,4Fission 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 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold

2 Basis Lo,6 6. A.This 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 9-F-3Month 20XXBY 3-31EP-AA-1002 (Revision XX)

R rnn Annoyl=walnn NiiharerRun nJvFAn NiLamRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RCIInitiating Condition:

RCS or SG Tube LeakageOperating Mode Applicability:

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

LOSSN.l.An Aautomatic or manual EGGS (SI) actuation is required by EITHER of thefollowing:

aft. UNISOLABLE RCS leakageORb2. Steam Generator tube RUPTURE.POTENTIAL LOSSB-.2. The capacity of one charging pump in the normal charging mode is exceeded dueto EITHER of the following:

Operation of a standby .haging (makeup) pump isrquirod by EITHER of the aft. UNISOLABLE RCS leakageORb2-. Steam Generator tube-leakage tube RUPTURE.ORS. ROC coo'lrdown rate rFeater than (ite specific pressurizd therrmal hockrc490a/'limits.

defined by sit spci. indications)

3. RCS Integrity CSF- Red Path epiy conditions metexist.

Month 20XXBY 3-32EP-AA-1002 (Revision XX)

F~t rrn AnndsvFv::alnn kli"AaarRJrh nnL~nrn ma~~RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Basis:UNISOLABLE:

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

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

FAULTED:

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

Loss Threshold

1 BasisI-.-4AThis threshold is based on an UNISOLABLE RCS leak of sufficient size to require anautomatic or manual actuation of the Emergency Core Cooling System (ECCS). Thiscondition clearly represents a loss of the RCS Barrier.This threshold is applicable to unidentified and pressure boundary

leakage, as well asidentified leakage.

It is also applicable to UNISOLABLE RCS leakage through aninterfacing system. The mass loss may be into any location

-inside containment, to thesecondary-side (i.e., steam generator tube leakage) or outside of containment.

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

If a RUPTURED steam generator isalso FAULTED outside of containment, the declaration escalates to a Site AreaEmergency since the Containment Barrier CT1 Loss threshold 4-1A-will also be met.Potential Loss Threshold

2 BasisPotontial Lose. 1 .AThis threshold is based on an UNISOLABLE RCS leak that results in the inability tomaintain pressurizer level within specified limits by operation of a normally usedcharging (makeup) pump, but an ECCS (SI) actuation has not occurred.

The threshold is met when an operating procedure, or operating crew supervision, directs that astandby charging (makeup) pump be placed in service to restore and maintainpressurizer level.This threshold is applicable to unidentified and pressure boundary

leakage, as well asidentified leakage.

It is also applicable to UNISOLABLE RCS leakage through aninterfacing system. The mass loss may be into any location

-inside containment, to thesecondary-side (i.e., steam generator tube leakage) or outside of containment.

Month 20XXBY 3-33EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearByron Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier CT1 Loss Tthreshold 4-ý-will also be met.Potential Loss Threshold

3 BasisThis condition indicates an extreme challenge to the integrity of the RCS pressureboundary due to pressurized thermal shock -a transient that causes rapid RCScooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized).

RCS Integrity

-RED indicates an extreme challenge to the safety function derived fromappropriate instrument readings.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. NES-G-1 4.02, Calculation No. BYR99-010

/ BRW-99-0017-1

3. 1/2 BEP-0 Reactor Trip Or Safety Injection Unit 1/24. 1/2 BEP-3 Steam Generator Tube Rupture Unit 1/25. 1/2 BST-2 Core Cooling Unit 1/26. 1/2 BFR-C.1 Response to Inadequate Core Cooling Unit 1/27. NES-G-14.02, Calculation No. BYR99-010

/ BRW-99-0017-1

8. UFSAR Fig. 6.3-4Month 20XXBY 3-34EP-AA-1002 (Revision XX)

Rvron AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC2Initiating Condition:

Inadequate Heat RemovalOperating Mode Applicability:

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

POTENTIAL LOSSA. inadequate RCS heat romova! capability via steam gonerators as idctdby (sitespecific indicsations)

Heat Sink CSF- Red Path en" conditions existmet.

Basis:There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold BasisPotential Loss 2. A.Heat Sink -RED when heat sink is required indicates the ultimate heat sink function isunder extreme challenge.

This condition indicates an extreme challenge to the ability to remove RCS heat usingthe steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier.

The Heat Sink Critical Safety FunctionRed path condition exists if narrow range levels in all steam generators (S/Gs) are lessthan or equal to 10% -Unit 1 (31% adverse containment) and 14% -Unit 2 (34%adverse containment) and total feedwater flow to all S/Gs is less than or equal to 500gpm. In accordance with EOPs, there may be unusual accident conditions during whichoperators intentionally reduce the heat removal capability of the steam generators byreducing total feed flow to less than 500 gpm; during these conditions, classification using threshold is not warranted.

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

1. NEI 99-01 Rev 6, Table 9-F-32. 1/2 BST-3 Heat Sink Unit 1/2Month 20XXBY 3-35EP-AA-1002 (Revision XX)

Itrnn Annavl=vtmlnn k: "MalrRurr~n Annoy Fvolnn M.ir~Io~r RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC3Initiating Condition:

Containment Radiation

/ RCS ActivityOperating Mode Applicability:

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

LOSSA. Containment radiation monitor reading greater than (AR020(21))

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

13A since it indicates a loss of the RCS Barrieronly.There is no Potential Loss threshold associated with RCS Activity

/ Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXBY 3-36EP-AA-1002 (Revision XX) l3vron AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC56Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

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

LOSS1A. Any condition in the opinion of the Emergency Director that indicates Loss of theRCS Barrier.POTENTIAL LOSS2B. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Basis:Loss Threshold

1 BasisLOSS-"This threshold addresses any other factors that may be used by the Emergency Directorin determining whether the RCS Barrier is lost.Potential Loss Threshold

2 BasisPmtAntieAl I 6, A AThis 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 9-F-3Month 20XXBY 3-37EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearByron Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CTIInitiating Condition:

RCS or SG Tube LeakageOperating Mode Applicability:

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

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

Basis:RUPTURE(D):

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

FAULTED:

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

Loss Threshold BasisThis threshold addresses a leaking or RUPTURED Steam Generator (SG) that is alsoFAULTED outside of containment.

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

This condition represents a bypass of the containment barrier.FAULTED is a defined term within the NEI 99-01 methodology; this determination is notnecessarily dependent upon entry into, or diagnostic steps within, an EOP. Forexample, if the pressure in a steam generator is decreasing uncontrollably

[part of theFAULTED definition]

and the faulted steam generator isolation procedure is not enteredbecause EOP user rules are dictating implementation of another procedure to address ahigher priority condition, the steam generator is still considered FAULTED foremergency classification purposes.

The FAULTED criterion establishes an appropriate lower bound on the size of a steamrelease that may require an emergency classification.

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

The lower bound for thisaspect of the containment barrier is analogous to the lower bound criteria specified in ICRSU3 for the fuel clad barrier (i.e., RCS activity values) and IC MSU64 for the RCSbarrier (i.e., RCS leak rate values).This threshold also applies to prolonged steam releases necessitated by operational considerations such as the forced steaming of a leaking or RUPTURED steamgenerator directly to atmosphere to cooldown the plant, or to drive an auxiliary (emergency) feed water pump. These types of conditions will result in a significant andMonth 20XXBY 3-38EP-AA-1002 (Revision XX) umrn AnnoyFwailnn N.PIa rRurnn Ann~v FvMnn Nmir~I~~r RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION sustained release of radioactive steam to the environment (and are thus similar to aFAULTED condition).

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

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

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

Steam releases associated with theunexpected operation of a valve (e.g., a stuck-open safety valve) do meet thisthreshold.

Following an SG tube leak or rupture, there may be minor radiological releases througha secondary-side system component (e.g., air ejectors, glad seal exhausters, valvepacking, etc.). These types of releases do not constitute a loss or potential loss ofcontainment but should be evaluated using the Recognition Category RA ICs.The emergency classification levels resulting from primary-to-secondary

leakage, withor without a steam release from the FAULTED SG, are summarized below.Affected SG is FAULTEDOutside of Containment?

IIPrimary-to-Secondary Leak RateLess than or equal to 25gpm (Or .the. value p. .S6U-4 Do'.'olepor Notes)Greater than 25 gpm (efother v.aluo per SUJ4Developer Noes)The capacity of onecharging pump in thenormal charging mode isexceeded RequiFesoperation of a standbyGhakell maep) pumpp(RCS Barrier Potential Loss)Requires an automatic ormanual EGGS (SI) actuation (RCS Barrier Loss)YesNoNo classification No classification Unusual Event perS9J4MU6Site Area Emergency per FS1Unusual Event perSU4MU6Alert per FA1Site Area Emergency per FS1Alert per FA1IMonth 20XXBY 3-39EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION There is no Potential Loss threshold associated with RCS or SG Tube Leakage.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. 1/2 BEP-0 Reactor Trip Or Safety Injection Unit 1/23. 1/2 BEP-3 Steam Generator Tube Rupture Unit 1/24. 1/2 BOA SEC-8 Steam Generator Tube Leak Unit 1/2Month 20XXBY 3-40EP-AA-1002 (Revision XX)

Svron AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT2Initiating Condition:

Inadequate Heat RemovalOperating Mode Applicability:

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

POTENTIAL LOSSA. 1. (Site specifc criteria for Ontr', into co~ ro colig rostoration proceduro)

AND2. Rostoration prOcoduro not offoctivo within 15 minutes-1.

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

The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold BasisPotential Loss1 2.This condition represents an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure.

For thiscondition to occur, there must already have been a loss of the RCS Barrier and the FuelClad Barrier.

If implementation of a procedure(s) to restore adequate core cooling is noteffective (successful) within 15 minutes, it is assumed that the event trajectory will likelylead to core melting and a subsequent challenge of the Containment Barrier.The restoration procedure is considered "effective" if core exit thermocouple readingsare decreasing and/or if reactor vessel level is increasing.

Whether or not theprocedure(s) will be effective should be apparent within 15 minutes.

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

Severe accident analyses (e.g., NUREG-1 150) have concluded that function restoration procedures can arrest core degradation in a significant fraction of core damagescenarios, and that the likelihood of containment failure is very small in these events.Given this, it is appropriate to provide 15 minutes beyond the required entry point todetermine if procedural actions can reverse the core melt sequence.

Month 20XXBY 3-41EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. 1/2 BST-2 Core Cooling Unit 1/23. 1/2 BFR-C.1 Response to Inadequate Core Cooling Unit 1/2Month 20XXBY 3-42EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT3Initiating Condition:

Containment Radiation I RCS ActivityOperating Mode Applicability:

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

POTENTIAL LOSSA-. Containment radiation monitor r.ading gr.ator than (AR020(21))

reading > 4.40E+03R/hr.(6ite SPocif;c v.alue).Basis:There is no Loss threshold associated with RCS Activity I Containment Radiation.

Potential Loss Threshold BasisPotential Less 3A'The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the containment, assuming that 20% of the fuel cladding has failed.This level of fuel clad failure is well above that used to determine the analogous FuelClad 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-32. Core Damage Assessment Methodology (CDAM)Month 20XXBY 3-43EP-AA-1002 (Revision XX)

Rvrmn AnnayNuclearRvrnn An~v FYAon Nucla~rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT4Initiating Condition:

Containment Integrity or BypassOperating Mode Applicability:

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

LOSS1A. Containment isolation is required AND EITHER of the following:

al-. UNPLANNED deGeease-lowering in containment pressure or rise in radiation monitor readings outside of containment in the Emergency Directors judgmentthat indicate a loss of containment integrity.

ORb-2. UNISOLABLE pathway from containment to the environment exists.OR29. Indication of RCS leakage outside of containment POTENTIAL LOSS3A. Containment CSF Red Path eRty conditions metexistIIOR48. ExpIosi miXture exiStS i6nsido c,.tailnemot.1 Containment

> 5%.OR5G. a4. Containment pressure greater thaRn (Sit' sp...IcAND-lydrogen Concentration in I--I .. .H rV4b -6etPei;t)%

20 psigýnO~tContainment b2. Less than one full train of (site sp...fi sy.tem orSpray is operating per design for >15

-equ.IBasis:FAULTED:

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

UNISOLABLE:

An open or breached system line that cannot be isolated, remotely orlocally.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.LossThreshold

1 Basis:IL Aess4 AMonth 20XXBY 3-44EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION These thresholds address a situation where containment isolation is required and one oftwo conditions exists as discussed below. Users are reminded that there may beaccident and release conditions that simultaneously meet both loss thresholds 1.a4.-A-and 1.b4l.A2.

1 .a4.A.4 -Containment integrity has been lost, i.e., the actual containment atmospheric leak rate likely exceeds that associated with allowable leakage (or sometimes referredto as design leakage).

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

Recognizing the inherent difficulties in determining acontainment leak rate during accident conditions, it is expected that the Emergency Director will assess this threshold using judgment, and with due consideration given tocurrent plant conditions, and available operational and radiological data (e.g.,containment

pressure, readings on radiation monitors outside containment, operating status of containment pressure control equipment, etc.).Refer to the middle piping run of Figure 9-F-4. Two simplified examples are provided.

One is leakage from a penetration and the other is leakage from an in-service systemvalve. Depending upon radiation monitor locations and sensitivities, the leakage couldbe detected by any of the four monitors depicted in the figure.Another example would be a loss or potential loss of the RCS barrier, and thesimultaneous occurrence of two FAULTED locations on a steam generator where onefault is located inside containment (e.g., on a steam or feedwater line) and the otheroutside of containment.

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

Following the leakage of RCS mass into containment and a rise in containment

pressure, there may be minor radiological releases associated with allowable (design)containment leakage through various penetrations or system components.

Thesereleases do not constitute a loss or potential loss of containment but should beevaluated using the Recognition Category RA ICs.1.b4.A.2

-Conditions are such that there is an UNISOLABLE pathway for the migration of radioactive material from the containment atmosphere to the environment.

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

Depending upon a variety of factors, this condition may or may not be accompanied by a noticeable drop in containment pressure.

Refer to the top piping run of Figure 9-F-4. In this simplified

example, the inboard andoutboard isolation valves remained open after a containment isolation was required (i.e.,containment isolation was not successful).

There is now an UNISOLABLE pathwayfrom the containment to the environment.

Month 20XXBY 3-45EP-AA-1002 (Revision XX)

Rurnn AnnovFyplnn Nne-Ia~rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION 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.Leakage between two interfacing liquid systems, by itself, does not meet this threshold.

Refer to the bottom piping run of Figure 9-F-4. In this simplified

example, leakage in anRCP seal cooler is allowing radioactive material to enter the Auxiliary Building.

Theradioactivity would be detected by the Process Monitor.

If there is no leakage from theclosed water cooling system to the Auxiliary

Building, then no threshold has been met.If the pump or system piping developed a leak that allowed steam/water to enter theAuxiliary

Building, then loss threshold 24-.B would be met. Depending upon radiation monitor locations and sensitivities, this leakage could be detected by any of the fourmonitors depicted in the figure and cause threshold 1.a4.A4 to be met as well.Following the leakage of RCS mass into containment and a rise in containment

pressure, there may be minor radiological releases associated with allowable (design)containment leakage through various penetrations or system components.

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

Loss Threshold

2 Basis:L-es&4aContainment sump, temperature, pressure and/or radiation levels will iP, ifreactor coolant mass is leaking into the containment.

If these parameters have notincreased, then the reactor coolant mass may be leaking outside of containment (i.e., acontainment bypass sequence).

bGeaseRises in sump, temperature,

pressure, flowand/or radiation level readings outside of the containment may indicate that the RCSmass is being lost outside of containment.

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

If the fuel clad barrier has notbeen lost, radiation monitor readings outside of containment may not significantly;

however, other unexpected changes in sump levels, area temperatures orpressures, flow rates, etc. should be sufficient to determine if RCS mass is being lostoutside of the containment.

Refer to the middle piping run of Figure 9-F-4. In this simplified

example, a leak hasoccurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building.

Month 20XXBY 3-46EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Depending upon radiation monitor locations and sensitivities, the leakage could bedetected by any of the four monitors depicted in the figure and cause loss threshold l.a4--A4 to be met as well.To ensure proper escalation of the emergency classification, the RCS leakage outsideof containment must be related to the mass loss that is causing the RCS Barrier RC1Loss Threshold 1.a and/or Potential Loss threshold 2.a4--A to be met.Potential Loss Threshold

3 Basis Less 4. .Containment CSF RED path indicates an extreme challenge to the safety functionderived from appropriate instrument readings and/or sampling

results, and thusrepresents a potential loss of containment.

If containment pressure exceeds the design pressure, there exists a potential to lose theContainment Barrier.

To reach this level, there must be an inadequate core coolingcondition for an extended period of time; therefore, the RCS and Fuel Clad barrierswould already be lost. Thus, this threshold is a discriminator between a Site AreaEmergency and General Emergency since there is now a potential to lose the thirdbarrier.Potential Loss Threshold

4 BasisP .BThe existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity.

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

5 BasisPatontil I ro 4 r-This threshold describes a condition where containment pressure is greater than thesetpoint at which containment energy (heat) removal systems are designed toautomatically

actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually startequipment that may not have automatically

started, if possible.

This threshold represents a potential loss of containment in that containment heatremoval/depressurization systems (e.g., containment sprays, ice condenser fans, etc.,but not including containment venting strategies) are either lost or performing in adegraded mannerMonth 20XXBY 3-47EP-AA-1002 (Revision XX)

IR rnn A!-n nn-IP:vlnn Ik Il"A-arR~,rnn A nmt~v Fv~Inn M.ur4a~rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-32. UFSAR Section 15.6.5.2.1

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

/ BRW-99-0017-1

4. Technical Specifications B 3.6.6, Containment Spray and Cooling Systems5. 1/2BST-5 Containment Unit 1/2Month 20XXBY 3-48EP-AA-1002 (Revision XX) umn Awdlilliky Fmalmillillilhiur-11par RECOGNITIOYCATEGORY FISSION PRODUCT BARRIER DEGRADATION Figure 9-F-4: PWR Containment Integrity or Bypass Examples:... b ...44=21.b -Effluent

.Airborne releaseMnnstoitor.

from pathwayContainment Auxiliary Building

VentDamper --1FilterMonitorOpen valve Open valve ----------

Damper A.rbornePenetration t releasefrom valveAirborne* ~Monitorl Open valve O Open val ePumpaSytem RCP.. :2 CInerac eaag ::Airborne

i outside CNTpoint :. release from ---------

.:.: ~~penetration i::.: ,Po es----Cooling WaterOpen valve Open valve Pump SystemRCPSealCoolingMonth 20XXBY 3-49 EP-AA-1002 (Revision XX)

Rrnn AnnowYI:yelnn rR~,rnn An~v Fvuldn Nuclea.rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT561Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

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

LOSS1A. Any condition in the opinion of the Emergency Director that indicates Loss of the IContainment Barrier.POTENTIAL LOSS2B. Any condition in the opinion of the Emergency Director that indicates Potential ILoss of the Containment Barrier.Basis:Loss Threshold

1 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is lost.Potential Loss Threshold

2 BasisPotontial Less 6. AThis 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, Table 9-F-3Month 20XXBY 3-50EP-AA-1002 (Revision XX)

Rrnn AnnoyFEvalnn Nwr-loarRJ.rnn Ann,, FvIv RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSGIInitiating Condition:

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

Operating Mode Applicability:

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

Tk m C rn, I,,,,, , r ,,f i ..- k , ,h-rt,4 , v .I-, ,~ I r- .-,- mr,%, ._j _j I-I L ..... \ I-- I..A! ..... : ......dewrminmnu that ihi ouiu uuuw hast beeRi UAUUUU r %9111 It¶-UIV UeXGeeded.

--t1-a-. Loss of ALL offsite and ALL ocRto AC powerbuses)unit ESF buses.to (sate speGifir.

@

'bAND2. Failure of DG 1A(2A) and DG 1B(2B) emergency diesel generators to supplypower to unit ESF buses.AND3b. EITHER of the following:

a. Restoration of at least one emeFgeney-unit ESF bus in < 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is notlessthan (sito hourS) i not likely.ORb. Core Cooling CSF -Red Path conditions exist* I. #'(0ItNO 60ocmc inalcation or an inaDI9I1ty to aaociuatoiv romovo neat ;Fronm te coroPBasis: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 prolonged loss of all power sources to AC emergency buses. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiring Month 20XXBY 3-51EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearByron Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS electric power including those necessary for emergency core cooling, containment heatremoval/pressure

control, spent fuel heat removal and the ultimate heat sink. Aprolonged loss of these buses will lead to a loss of eRo OrF moreany 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 FGI. 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 emergency buses of the affected unit can be powered from the unaffected unitthrough the crosstie breakers.

Unit crosstie is considered an adequate source of offsitepower when evaluating this EAL.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. 20E-0-4001 Station One Line Diagram3. UFSAR 8.3.14. 1/2 BOA ELEC-3 Loss Of 4KV ESF Bus Unit 1/25. 1/2 BOA ELEC-4 Loss Of Offsite Power Unit 1/26. 1/2 BCA-0.0 Loss Of All AC Power Unit 1/27. 1/2 BCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/28. 1/2 BCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/29. 1/2 BCA-0.3 Response To Opposite Unit Loss Of All AC Power Unit 1/210. BOP AP-51, Isolating Unit 1 System AUX Transformer 142-1 & 142-2 While UnitIs At Power11. BOP AP-52, Restoring Unit 1 System AUX Transformer 142-1 & 142-2 DuringPower Operation Month 20XXBY 3-52EP-AA-1002 (Revision XX)

Rvron AnnexExellon NuclearBvron Annex Eeo ulaRECOGNITION CATEGORYSYSTEM MALFUNCTIONS

12. BOP AP-53, Isolating Unit 2 System AUX Transformer 242-1 & 242-2 While UnitIs At Power13. BOP AP-54, Restoring Unit 2 System AUX Transformer 242-1 & 242-2 DuringPower Operation

14. Safety Evaluations of the Byron Station and Byron Station Responses to theStation Blackout (SBO) Rule (TAC NOS. 68522, 68523 AND 68515, 68516)15. 1/2 BST-2 Core Cooling Unit 1/216. 1/2 BFR-C.1 Response to Inadequate Core Cooling Unit 1/217. 1/2 BFR-C.2 Response to Degraded Core Cooling Unit 1/2Month 20XXBY 3-53EP-AA-1002 (Revision XX) l:trnn AnnoyF::olnn k,,elonrRurnn A nnov Fv~Inn M.ii4m~ar

-.p ~. * *-~p .. .~n ~ p p -~~*n~*RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MsSIInitiating' Condition:

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

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

.The EmerFgency Direc-tor Should dcret-he Si6teA Area Emer8gency prom~ptly upondetermining that 15 r;inutos-has boon oX,,dod, o-r -wil likely be eXcee-ded.

1. Loss of ALL offsite and ALL "nsit- AC Power to (site specific emergency bus. )unitESF buses for 15 minute or lroger.AND2. Failure of DG IA(2A) and DG 1B(2B) emergency diesel generators to supply powerto unit ESF buses.AND3. Failure to restore power to at least one unit ESF 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.The emergency buses of the affected unit can be powered from the unaffected unitthrough the crosstie breakers.

Unit crosstie is considered an adequate source of offsitepower when evaluating this EAL.Month 20XXBY 3-54EP-AA-1002 (Revision XX)

Rvron AnnexFx#_lnn Bvrnn Annex FYAIon NucleIarRECOGNITION CATEGORYSYSTEM MALFUNCTIONS 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 MSG1.Basis Reference(s):

1. NEI 99-01 Rev 6, SS12. 20E-0-4001 Station One Line Diagram3. UFSAR 8.3.14. 1/2 BOA ELEC-3 Loss Of 4KV ESF Bus Unit 1/25. 1/2 BOA ELEC-4 Loss Of Offsite Power Unit 1/26. 1/2 BCA-0.0 Loss Of All AC Power Unit 1/27. 1/2 BCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/28. 1/2 BCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/29. 1/2 BCA-0.3 Response To Opposite Unit Loss Of All AC Power Unit 1/210. BOP AP-51, Isolating Unit 1 System AUX Transformer 142-1 & 142-2 While UnitIs At Power11. BOP AP-52, Restoring Unit 1 System AUX Transformer 142-1 & 142-2 DuringPower Operation

12. BOP AP-53, Isolating Unit 2 System AUX Transformer 242-1 & 242-2 While UnitIs At Power13. BOP AP-54, Restoring Unit 2 System AUX Transformer 242-1 & 242-2 DuringPower Operation

14. Safety Evaluations of the Byron Station and Byron Station Responses to theStation Blackout (SBO) Rule (TAC NOS. 68522, 68523 AND 68515, 68516)Month 20XXBY 3-55EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearByron Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSAIInitiating Condition:

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

1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded...The Di~rotr should doclaro the AIort promptly upon dotrmlning that 15minutes has boen xvodeod, OFr Will likely be 1. AC power capability to unit ESF buses reduced to only one of the following powersources for _> 15 minutes.* Affected unit SAT 142-1(242-1)

" Affected unit SAT 142-2(242-2)

Emergency Diesel Generator DG 1A(2A)* Emergency Diesel Generator DG 1 B(2B)* Unit crosstie breakersa. AG poWor capabilit,'

to (site sepoific omorgoncy busec) is reducod to a singleSOurc% for 15 minuteo Or longer.AND2b. Any additional single power source failure will result in a loss of ALLa# 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 ICMSUI.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 20XXBY 3-56EP-AA-1002 (Revision XX) ron AnnnvIy,wnlr~n almr-l--nr JN Erf.L,RECOGNITION CATEGORYSYSTEM MALFUNCTIONS

" 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 offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator.

" 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. 20E-0-4001 Station One Line Diagram3. UFSAR 8.3.14. 1/2 BOA ELEC-3 Loss Of 4KV ESF Bus Unit 1/25. 1/2 BOA ELEC-4 Loss Of Offsite Power Unit 1/26. 1/2 BCA-0.0 Loss Of All AC Power Unit 1/27. 1/2 BCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/28. 1/2 BCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/29. 1/2 BCA-0.3 Response To Opposite Unit Loss Of All AC Power Unit 1/210. BOP AP-51, Isolating Unit 1 System AUX Transformer 142-1 & 142-2 While UnitIs At Power11. BOP AP-52, Restoring Unit 1 System AUX Transformer 142-1 & 142-2 DuringPower Operation

12. BOP AP-53, Isolating Unit 2 System AUX Transformer 242-1 & 242-2 While UnitIs At Power13. BOP AP-54, Restoring Unit 2 System AUX Transformer 242-1 & 242-2 DuringPower Operation

14. Safety Evaluations of the Byron Station and Byron Station Responses to theStation Blackout (SBO) Rule (TAC NOS. 68522, 68523 AND 68515, 68516)Month 20XXBY 3-57EP-AA-1002 (Revision XX) umrn AnnoyRvrnn Ang~.v Fvlnn Nuclea~zr RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MsUIInitiating Condition:

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

1,2,3,4Emergency Action Level (EAL):-.Note: The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.Tho Emerg8,ency DiretOr should doc.ao the Unusual Event pro.ptlyupon determining that 15 mninutes har, boon exceeded, OFWill likely be exceeded4-. Loss of ALL offsite AC power capability to unit ESF buses (site specific ,,.buesefor

> 15 minutes-OF Iege .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)

The emergency buses of the affected unit can be powered from the unaffected unitthrough the crosstie breakers.

Unit crosstie is considered an adequate source of offsitepower when evaluating this EAL.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 MSA1.Basis Reference(s):

1. NEI 99-01 Rev 6, SU12. 20E-0-4001 Station One Line Diagram3. UFSAR 8.3.14. 1/2 BOA ELEC-3 Loss Of 4KV ESF Bus Unit 1/25. 1/2 BOA ELEC-4 Loss Of Offsite Power Unit 1/26. 1/2 BCA-0.0 Loss Of All AC Power Unit 1/27. 1/2 BCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/28. 1/2 BCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/2Month 20XXBY 3-58EP-AA-1002 (Revision XX)

Exellon NuclearBron Annex......n.

RECOGNITION CATEGORYSYSTEM MALFUNCTIONS

9. 1/2 BCA-0.3 Response To Opposite Unit Loss Of All AC Power Unit 1/210. BOP AP-51, Isolating Unit 1 System AUX Transformer 142-1 & 142-2 While UnitIs At Power11. BOP AP-52, Restoring Unit 1 System AUX Transformer 142-1 & 142-2 DuringPower Operation

12. BOP AP-53, Isolating Unit 2 System AUX Transformer 242-1 & 242-2 While UnitIs At Power13. BOP AP-54, Restoring Unit 2 System AUX Transformer 242-1 & 242-2 DuringPower Operation Month 20XXBY 3-59EP-AA-1002 (Revision XX)

Rvrnn Fvalnn Niu-IonrRvrnn AnnexF~inMIrI2 RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSG21 IInitiating Condition:

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

1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.T-he EmogcnGcy DirectGor Should declare t-h Genral EmFergencY proptly upon that 15 minutes boon ex..edod, or will likely be exceeded.

1. Loss of ALL offsite AC power to unit ESF buses.AND2. Failure of DG IA(2A) and DG 1 B(2B) emergency diesel generators to supplypower to unit ESF buses.AND3. Voltage is < 108 VDC on unit 125 VDC battery buses 111(211) and 112(212).

AND4. ALL AC and Vital DC power sources have been lost for > 15 minutes.1. a. L=os. o- ALL offsito and ALL onsite AG to (Site -s5p-fi-buses58) for 15 mionutes or longer.ANDb. Indicated vo'ltage is less than (Site SPoc6fiG bus voltage value) onAL(site specific Vital DCbussesAbuses) for 15 minutes Or longr.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 20XXBY 3-60EP-AA-1002 (Revision XX)

Rrnn Anno~yI=yalnn NMidlonrR~,rnn Annoy Fvolnn Mmav~Io2r RECOGNITION CATEGORYSYSTEM MALFUNCTIONS This 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 beth-allEAL conditions e are met.Basis Reference(s):

1. NEI 99-01 Rev 6, SG82. 20E-0-4001 Station One Line Diagram3. UFSAR 8.3.14. 1/2 BOA ELEC-3 Loss Of 4KV ESF Bus Unit 1/25. 1/2 BOA ELEC-4 Loss Of Offsite Power Unit 1/26. 1/2 BCA-0.0 Loss Of All AC Power Unit 1/27. 1/2 BCA-0.1 Loss Of All AC Power Recovery Without SI Required Unit 1/28. 1/2 BCA-0.2 Loss Of All AC Power Recovery With SI Required Unit 1/29. 1/2 BCA-0.3 Response To Opposite Unit Loss Of All AC Power Unit 1/210. BOP AP-51, Isolating Unit 1 System AUX Transformer 142-1 & 142-2 While UnitIs At Power11. BOP AP-52, Restoring Unit 1 System AUX Transformer 142-1 & 142-2 DuringPower Operation

12. BOP AP-53, Isolating Unit 2 System AUX Transformer 242-1 & 242-2 While UnitIs At Power13. BOP AP-54, Restoring Unit 2 System AUX Transformer 242-1 & 242-2 DuringPower Operation

14. Safety Evaluations of the Byron Station and Byron Station Responses to theStation Blackout (SBO) Rule (TAC NOS. 68522, 68523 AND 68515, 68516)15. UFSAR 8.3.2.1.1

16. 6E-0-4001 Station One Line Diagram17. BAR 1/2-21-E10 125V DC PNL 111/113 (211/213)

VOLT LOW18. BAR 1/2-22-ElO 125V DC PNL 112/114 (212/214)

VOLT LOW19. 1/2 BOA ELEC -1 Loss of DC Bus Unit 1/2Month 20XXBY 3-61EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearByron Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSS28Initiating Condition:

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

1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.T-he Em:Fergency D*roctor Should dcJAlare the Sito Area Ernergoncy promptly upon4determinin~g that 15 minutes has, boon eXceeded, or will likely be excooded.

ldiGated-vVoltage is < 108 VDC loss than (site specific bus voltage value) onunit 125 VDC battery buses 111(211) and 112(212)ALL (site speoiic Vital DGu6ssesbuses) for >15 minutes-elange

.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 orMSG38.Basis Reference(s):

1. NEI 99-01 Rev 6, SS82. UFSAR 8.3.2.1.1

3. 6E-0-4001 Station One Line Diagram4. BAR 1/2-21-ElO 125V DC PNL 111/113 (211/213)

VOLT LOW5. BAR 1/2-22-E10 125V DC PNL 112/114 (212/214)

VOLT LOW6. 1/2 BOA ELEC -1 Loss of DC Bus Unit 1/2Month 20XXBY 3-62EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSS35Initiating Condition:

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

1,2Emergency Action Level (EAL):.1. Automatic or Manual Ttrip did not shutdown the reactor as indicated by ReactorPower > 5%.AND2. ALLAh manual actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 5%.AND3. EITHER of the following conditions exist:a. Core Cooling CSF-RED Path conditions exist.(Site indication oaan inability to adequately romovo- hoa:t- fromF the core)ORb. Heat Sink CSF-RED Path conditions exist.(Site specific iRndiation of aninability to adequately neremo heat from the RCS)Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor trip that results in a reactor shutdown, all subsequent operator manual actions,both inside and outside the Control Room including driving in control rods and boroninjection,all G.ubseqUent operator action, .to shutdown the reacto areunsuccessful, and continued power generation is challenging the capability toadequately remove heat from the core and/or the RCS. This condition will lead to fueldamage if additional mitigation actions are unsuccessful and thus warrants thedeclaration of a Site Area Emergency.

If Core Cooling CSF Red Path or Heat Sink CSF Red Path conditions exist prior to asuccessful reactor shutdown (i.e. < 5% reactor power) then entry is required.

The Heat Sink Critical Safety Function Red path condition exists if narrow range levelsin all steam generators (S/Gs) are less than or equal to 10% -Unit 1 (31% adversecontainment) and 14% -Unit 2 (34% adverse containment) and total feedwater flow toMonth 20XXBY 3-63EP-AA-1002 (Revision XX)

R rnn AnnoyFyolnn Ni ie-lonrRJr.l rnnuv FvAvnn NivrIA.RECOGNITION CATEGORYSYSTEM MALFUNCTIONS all S/Gs is less than or equal to 500 gpm. If total feed flow is less than 500 gpm due toprocedurally directed operator actions then this condition does not apply.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.A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

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

1. NEI 99-01 Rev 6, SS52. 1/2 BST-1 Subcriticality Unit 1/23. 1/2 BST-2 Core Cooling Unit 1/24. 1/2 BST-3 Heat Sink Unit 1/25. 1/2 BFR-S.1 Response to Nuclear Power Generation/ATWS Unit 1/26. 1/2 BFR H.1 Response to Loss of Secondary Heat Sink Unit 1/27. 1/2 BFR C.1 Response to Inadequate Core Cooling Unit 1/2Month 20XXBY 3-64EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA35Initiating Condition:

Automatic or manual trip fails to shutdown the reactor, and subsequent manual actionstaken at the reactor control consoles are not successful in shutting down 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. Afi-aAutomatic or manual Ttrip did not shutdown the reactor as indicated by ReactorPower > 5%.AND2. Manual actions taken at the reactor cwntrol conoGGsMain Control Board 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 trip that results in a reactor shutdown, and subsequent operator manual actionstaken at the reactor control consoles to shutdown the reactor are also unsuccessful.

This condition represents an actual or potential substantial degradation of the level ofsafety of the plant. An emergency declaration is required even if the reactor issubsequently shutdown by an action taken away from the reactor control consoles sincethis event entails a significant failure of the RPS.A manual action at the Main Control Board roactor .ontrol cownole is any operatoraction, or set of actions, which causes the control rods to be rapidly inserted into thecore (e.g., initiating a manual reactor trip. This action does not include manually drivingin control rods or implementation of boron injection strategies.

If this action(s) isunsuccessful, operators would immediately pursue additional manual actions atlocations away from the reactor control consoles (e.g., locally opening breakers).

Actions taken at back-panels or other locations within the Control Room, or any locationoutside the Control Room, are not considered to be "at the reactor control cnc.-os9Main Control Board".The plant response to the failure of an automatic or manual reactor trip will vary basedupon several factors including the reactor power level prior to the event, availability ofthe condenser, performance of mitigation equipment and actions, other concurrent plantconditions, etc. If the failure to shutdown the reactor is prolonged enough to cause achallenge to the core cooling or RCS heat removal safety functions, the emergency Month 20XXBY 3-65EP-AA-1002 (Revision XX)

Byron AnnexExellon Nucleariron Annex Exe....Nuclear RECOGNITION CATEGORYSYSTEM MALFUNCTIONS classification level will escalate to a Site Area Emergency via IC MSS35. Depending upon plant responses and symptoms, escalation is also possible via IC FSI. Absentthe plant conditions needed to meet either IC MSS35 or FS1, an Alert declaration isappropriate 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, SA52. 1/2 BST-1 Subcriticality Unit 1/23. 1/2 BFR-S.1 Response to Nuclear Power Generation/ATWS Unit 1/24. 1/2 BOSR 0.1-1,2,3 Unit One(Two)

Mode 1, 2, & 3 Shiftly and Daily Operating Surveillance Month 20XXBY 3-66EP-AA-1002 (Revision XX)

RVro'n Annghll=wg%,,1orn km ntAgir-. S ** 4* **55~RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU35iInitiating Condition:

Automatic or manual trip 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. AnaAutomatic Ttrip did not shutdown the reactor as indicated by ReactorPower > 5%.ANDb. A-sSubsequent manual action taken at the ractor "cntrol consolocMain Control Board is successful in shutting down the reactor.OR2. a. A-4pManual Ttrip did not shutdown the reactor as indicated by ReactorPower > 5%.ANDb. EITHER of the following:

1. A-sSubsequent manual action taken at the roactOr coGntrol cnclcMain Control Board is successful in shutting down the reactor.OR2. A-sSubsequent autemati'GAutomatic Ttrip is successful in shutting downthe reactor.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor trip that results in a reactor shutdown, and either a subsequent operator manualaction taken at the reactor control consoles or an automatic trip is successful in shuttingMonth 20XXBY 3-67EP-AA-1002 (Revision XX)

R Vrnn Anno Rurr~n n n~v valinn Nuclea~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONS down the reactor.

This event is a precursor to a more significant condition and thusrepresents a potential degradation of the level of safety of the plant.EAL #1 BasisFollowing the failure on an automatic reactor trip, operators will promptly initiate manualactions at the reactor control consoles to shutdown the reactor (e.g., initiate a manualreactor trip). If these manual actions are successful in shutting down the reactor, coreheat generation will quickly fall to a level within the capabilities of the plant's decay heatremoval systems.EAL #2 BasisIf an initial manual reactor trip is unsuccessful, operators will promptly take manualaction at another location(s) on the Main Control BoardeactrF ceGtre! s on- ee toshutdown the reactor (e.g., initiate a manual reactor trip using a different switch).Depending upon several factors, the initial or subsequent effort to manually trip thereactor, or a concurrent plant condition, may lead to the generation of an automatic reactor trip signal. If a subsequent manual or automatic trip is successful in shuttingdown the reactor, core heat generation will quickly fall to a level within the capabilities ofthe plant's decay heat removal systems.A manual action at the Main Control Boardr.a.tO.

con-.trol conQ ol is any operatoraction, or set of actions, which causes the control rods to be rapidly inserted into thecore (e.g., initiating a manual reactor trip). This action does not include manually drivingin control rods or implementation of boron injection strategies.

Actions taken at back-panels or other locations within the Control Room, or any location outside the ControlRoom, are not considered to be "at the Main Control BoardroactOr control consoloc".

The plant response to the failure of an automatic or manual reactor trip will vary basedupon several factors including the reactor power level prior to the event, availability ofthe condenser, performance of mitigation equipment and actions, other concurrent plantconditions, etc. If subsequent operator manual actions taken at the Main ControlBoardrpactOr control consolo are also unsuccessful in shutting down the reactor, thenthe emergency classification level will escalate to an Alert via IC MSA35. Depending upon the plant response, escalation is also possible via IC FAI. Absent the plantconditions needed to meet either IC MSA35 or FA1, an Unusual Event declaration isappropriate for this event.A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Should a reactor trip signal be generated as a result of plant work (e.g., RPS setpointtesting),

the following classification guidance should be applied.* If the signal generated as a result of plant work causes a plant transient that createsa real condition that should have included an automatic reactor trip and the RPS failsto automatically shutdown the reactor, then this IC and the EALs are applicable, andshould be evaluated.

Month 20XXBY 3-68EP-AA-1002 (Revision XX)

Rlrrn AnnavI=Ymlnn F-zainn Nile-joar RECOGNITION CATEGORYSYSTEM MALFUNCTIONS If the signal generated as a result of plant work does not cause a plant transient butshould have generated an RPS trip signal and the trip failure is determined throughother means (e.g., assessment of test results),

then this IC and the EALs are notapplicable and no classification is warranted.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU52. 1/2 BST-1 Subcriticality Unit 1/23. 1/2 BFR-S.1 Response to Nuclear Power Generation/ATWS Unit 1/2Month 20XXBY 3-69EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearByron Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA42Initiating Condition:

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

Operating Mode Applicability:

1,2,3,4Emergency 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.Thie Emorgoncsy Diroctor should declare the Alort promptly upon detormfninig that1minutes has boon exceeded, Or Will likely be eXceeded.

1. a. AR--UNPLANNED event results in the inability to monitor one Or moroANYTable M14 the feie-wi,.

parameters from within the Control Room for >15minutes OFlG~qe .(see table below]PAR parameter lIst]Table M1 -Control Room Parameters Rat Reactor Power*2e* PZR Level0 RCS PressureRCS- PFressure In Core/Core Exit Temperature

_________________________

Narrow Range level in at least oneIn.Core.Core Exit Steam Generator

_T-empeFaf

__-e

Steam generator Auxiliary FeedLevels in at least (site specific Water Flownu-mberF) stea.m gAenerators Ste-am Generator Auxiliary orEmnergenc~y Feed Water FlowI JANDb. Any Table M24f transient events in progress.

" Automatic Or Manual runback greater than 25% theral reactor " El!ectrical lead FejertieR greater than 25% full electr#ical loardR -Rea rte F4ý -Month 20XXBY 3-70EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearByron Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Table M2 -Significant Transients

" Automatic Turbine Runback >25% thermalreactor power* Electrical Load Rejection

>25% full electrical load* Reactor Trip" Safety Injection Actuation Basis:UNPLANNED:

A parameter change or an event that is not 1) the result of an 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 oeno r-meroeany 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, 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, core cooling and RCS heat removal.

The loss ofthe ability to determine oen oFer-meany of these parameters from within the ControlMonth 20XXBY 3-71EP-AA-1002 (Revision XX)

Rrnn AnniayI::alnn N, mrllnrRurr~n Anncv Fv~Inn IJuirIc~r

~U UU SSUSUUS ~ U ~U U

U U*RECOGNITION CATEGORYSYSTEM MALFUNCTIONS Room is considered to be more significant than simply a reportable condition.

Inaddition, if all indication sources for eReOF or-meany 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 ICs FS1 or IC RAS1.Basis Reference(s):

1. NEI 99-01 Rev 6, SA2Month 20XXBY 3-72EP-AA-1002 (Revision XX)

Bvron AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU421Initiating Condition:

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

1,2,3,4Emergency Action Level (EAL):Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.The l I';p,,,,r aok d ,I,1 n , .r, I , me, ..i1mun , r1.-ranrtrl Il, , ,ir- .-. .i .7I tl- MH 9 t~ 5f f I U t* UUM V5~~ild O-F- WI 11V... e G 88a- AR-UNPLANNED event results in the inability to monitor one Or moreANY Table M1parameters from within the Control Room for > 15 minutes.Table M1 -Control Room Parameters

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

" Narrow Range level in at least one Steam Generator

Steam generator Auxiliary Feed Water Flow2. IRW-Rprvafw i 3. 1PW-Rparamte~

4. Reactor:

Power 6. Reacter-Power8.RMWater Lcvcl 9. RGS Lei~d10. "A' Pressure

11. RCS Prcsure1-2 R-l*m 13.In Carp. Core~efl4iftfefttExit Temperature

14. Suppression Poo 15. ]Levels in at leasLeve (site speeiflnumiber-seam16. uppessin P17. Steam GCenerator Temfpe~atur-e A~iiyEme~geneyFed

___pr MaewMonth 20XXBY 3-73EP-AA-1002 (Revision XX)

Itrnn A n n,.IFvalnn ki,,ilonr AurnA ~ vI~ ~tI~RECOGNITION CATEGORYSYSTEM MALFUNCTIONS 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.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 onoe eo mreany 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-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, core cooling and RCS heat removal.

The loss ofthe ability to determine one oFr-merany of these parameters from within the ControlRoom is considered to be more significant than simply a reportable condition.

Inaddition, if all indication sources for eoe OrF mroany 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.Basis Reference(s):

1. NEI 99-01 Rev 6, SU2Month 20XXBY 3-74EP-AA-1002 (Revision XX)

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