ML11216A055: Difference between revisions

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{{Adams
#REDIRECT [[RBG-47165, Proposed Emergency Action Levels Using NEI 99-01 Revision 5 Scheme]]
| number = ML11216A055
| issue date = 08/01/2011
| title = Proposed Emergency Action Levels Using NEI 99-01 Revision 5 Scheme
| author name = Clark J A
| author affiliation = Entergy Operations, Inc
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000458
| license number = NPF-047
| contact person =
| case reference number = NEI 99-01, Rev 5, RBF1-11-0108, RBG-47165
| document type = Letter, Report, Miscellaneous
| page count = 409
}}
 
=Text=
{{#Wiki_filter:Entergy Operations, Inc.River Bend Station 5485 U.S. Highway 61N St. Francisville, LA 70775 Tel 225 381 4177 EntffflýFax 225 635 5068 jclark@entergy.com Joseph A. Clark Manager-Licensing River Bend Station August 1,2011 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 RBG-47165 RBF1-11-0108
 
==Subject:==
Proposed Emergency Action Levels Using NEI 99-01 Revision 5 Scheme River Bend Station -Unit 1 Docket No. 50-458 License No. NPF-47
 
==Reference:==
 
Letter from Christopher G. Miller (U.S. Nuclear Regulatory Commission) to Alan Nelson (Nuclear Energy Institute)
-"U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 5, dated February 2008", dated February 22, 2008 (ML080430535)
 
==Dear Sir or Madam:==
Pursuant to 10 CFR 50, Appendix E, Section IV.B(1), Entergy Operations Incorporated (Entergy) hereby requests NRC review and approval of the River Bend Station proposed revision to the Emergency Plan (EP) Emergency Action Levels (EALs). The proposed changes involve revisions to River Bend's currently approved EP EAL scheme which is based on Nuclear Energy Institute (NEI) 99-01, Revision 4, "Methodology for Development of Emergency Action Levels" guidance.
Entergy is proposing to adopt the EAL scheme based on the guidance provided in NEI 99-01, Revision 5, which has been endorsed by the NRC (Reference 1).In this submittal, Entergy uses two values for RC3 Loss 1.a and Table F2 for main steam tunnel temperature.
The current value is 144 0 F; however, Entergy has submitted a Technical Specification change to the NRC in letter RBG-47146 dated 7/27/11 to change this value to 173 0 F. Further information is provided in Attachment 1, NEI 99-01 Revision 5 Deviation-Differences Document.These changes have been reviewed by the Onsite Safety Review Committee and discussed with the applicable State of Louisiana and local government authorities.
Submittal of Emergency Implementing Procedure RBG-47165 RBFI-1 1-0108 Page 2 of 3 Upon NRC approval of the EAL change, the revision will be implemented no later than December 5, 2012. This implementation period will allow for flexibility in the schedule for operator training which will be conducted following annual exams.This letter contains no new commitments.
If you have any questions or require additional information, please contact Kristi Huffstatler at (225) 378-3305.ly, JAC/krh Attachments:
1.2.3.4.5.NEI 99-01 Revision 5 Deviation-Differences Document Proposed Technical Basis Document (Markup)Proposed Technical Basis Document (Clean)Proposed EAL Matrix Chart and Review Table (For Information)
Supporting Referenced Document Pages Submittal of Emergency Implementing Procedure RBG-47165 RBF1-1 1-0108 Page 3 of 3 cc: Mr. Elmo E. Collins, Jr.Regional Administrator U.S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector River Bend Station P. 0. Box 1050 St. Francisville, LA 70775 Mr. Alan Wang, Project Manager U.S. Nuclear Regulatory Commission MS 0-8 B1 Washington, DC 20555-0001 Mr. P. J. Elkmann U.S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Department of Environmental Quality Office of Environmental Compliance
-Radiological Emergency Planning and Response Section JiYoung Wiley P. 0. Box 4312 Baton Rouge, LA 70821-4312 Attachment 1 To RBG-47165 NEI 99-01 Revision 5 Deviation-Differences Document Entergy RIVERBEND NUCLEAR STATION (RBS)DEVIATIONS AND DIFFERENCES FROM NEI 99-01, REV 5 EMERGENCY ACTION LEVELS Attachment 1 Page 1 of 136 RBS NEI Revision-5 EAL Deviation-Differences Document Introduction This document presents the RBS site-specific deviations and differences from the NEI 99-01, Revision 5 Emergency Action Levels (EALs).RBS used the following definitions from Supplements 1 and 2 to RIS 2003-18 when determining the categorization of differences between the NEI 99-01, Revision 5 Initiating Conditions (ICs) and Example EALs and the proposed RBS ICs and EALs: Deviation:
An EAL change where the basis scheme guidance (NUREG, NUMARC, NEI) differs in wording and is altered in meaning or intent, such that the classification of the event could be different between the basis scheme guidance and the site-specific proposed EAL. Examples of deviations include the use of altered mode applicability, altering key words or time limits, or changing words of physical reference (protected area, safety-related equipment, etc.).There are no deviations in the RBS proposed EAL scheme.A difference is an EAL change where the basis scheme guidance differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the site-specific proposed EAL. Examples of differences include the use of site-specific terminology or administrative re-formatting of site-specific EALs.Difference:
Administrative changes that do not actually change the text are neither differences nor deviations.
Likewise, any format change that does not alter the wording of the IC or EAL is considered neither a difference nor a deviation.
RBS uses formatting such as ALL CAPS, bold and underline to aid the user in applying these EALs; particularly to set apart units, time frames or quality of a value or data (such as the term "valid").
Such formatting is neither a deviation nor a difference in accordance with the definitions provided above because it does not alter the wording of the IC or EAL.4.Attachment 1 Page 2 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document The following differences are generic in nature and apply throughout the proposed RBS EALs: 1. In general, NEI 99-01, Revision 5 bases developer notes are not included in the RBS bases, but were used in their development.
NEI 99-01, Revision 5 developer note basis information was selectively provided in the RBS bases where it was viewed that the developer notes would provide useful training information or aid the decision maker in evaluating the event. In some cases, these developer notes are reworded from the NEI 99-01 EALs, but the intent is retained.2. Formatting choices may also involve minor grammatical differences between the RBS EALs and NEI 99-01 such as "that exceeds" vice"exceeding", use of "If, then" statements for conditional statements, or the use of symbols (>, <). Such formatting differences between the RBS EALs and NEI 99-01 will not be noted in this document as differences or deviations when they represent format choices alone and do not change the intent or materially change the content of NEI 99-01 Initiating Conditions or EALs.3. At RBS, the emergency classification of Notification of Unusual Event is indicated by "Notification of Unusual Event," "NOUE" or "Unusual Event." 4. At RBS, all Radiological Effluent Technical Specifications are included in the ODCM, thus "ODCM" is used in place of references to Radiological Effluent Technical Specifications.
: 5. RBS does not always use the term "RCS/RPV" in the Cold Shutdown EALs. In general, the term "RCS" is used alone except when referring to a specific component of the RPV (i.e., flange).6. "Safeguards Contingency Plan" is the term used to encompass all security plans/documents.
: 7. In the Fission Product Barrier EALs, the EAL numbers are preceded by"FC" for the Fuel Clad barrier EALs, "RC" for the RCS barrier EALs and"PC" for the Containment barrier EALs.8. The term "threshold" is not used in every case as it is used in NEI 99-01.Replacement terms such as "EAL" or "EAL threshold" are used as necessary based on context.Attachment 1 Page 3 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: AU1 Any release of gaseous or liquid radioactivity to the environment greater than 2 times the Radiological Effluent Technical Specifications/ODCM for 60 minutes or longer.Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2 or 3 or 4 or 5)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded or will likely exceed, the applicable time.In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown.1. VALID reading on ANY of the following radiation monitors greater than the reading shown for 60 minutes or longer: (site specific monitor list and threshold values)2. VALID reading on any effluent monitor reading greater than 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.3. Confirmed sample analyses for gaseous or liquid releases indicates concentrations or release rates greater than 2 times (site specific RETS values) for 60 minutes or longer.4. VALID reading on perimeter radiation monitoring system greater than 0.10 mR/hr above normal* background for 60 minutes or longer. [for sites having telemetered perimeter monitors]5. VALID indication on automatic real-time dose assessment capability indicating greater than (site-specific value) for 60 minutes or longer. [for sites having such capability]
*Normal can be considered as the highest reading in the past twenty-four hours excluding the current peak value.Attachment 1 Page 4 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: AU1 Any release of gaseous or liquid radioactivity to the environment
> 2 times the ODCM limit for > 60 minutes Operating Mode Applicability:
Emergency Action Level(s): All (1 or 2 or 3)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown.1. VALID reading on any of the radiation monitors in Table R1 > the NOUE reading for > 60 minutes OR 2. VALID reading on RMS-RE107 effluent monitor > 2 times the alarm setpoint established by a current radioactivity discharge permit for > 60 minutes OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times the ODCM limit for > 60 minutes, STable R1 E~ALTHRESHOLD Method 7.$j ,NOVE_______________________________DRMS Grid 6 /Threshold 7 Main Plant Vent Primary 4GE125 3.06E+05 Ci/sec~jSecondary 1GE126 5.26E-03 p.iciml ----Fuel Building Vent Primaryi 4GE005 2.19E+04 pCilsec Secondary 5GE005 4.65E-03  rRadwaste Building Vent G E..Primary 4GE006 '2.58E+04 pCilsec Secondary 5'GEO006 6.84E-04 ,tCilml.Attachment 1 Page 5 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: AUM (Cont'd)Deviations:
None Differences:
RBS uses a table to list the applicable radiation monitors and threshold values for EAL #1, referencing the values to the classification level, creating a minor difference in EAL language.RBS differs from NEI 99-01 Revision 5 in the description for EAL #2 and the associated bases. Discharge permits are normally written for liquid radioactive releases.
RBS does not have a normal gaseous release path that requires a batch discharge permit. Therefore, the EAL is specific to the liquid release pathway monitored by RMS-IRE107.
The second (superfluous) "reading" is deleted in the RBS EAL #2.NEI 99-01 Revision 5 AU1 EAL #4 is not included in the RBS proposed EAL scheme. RBS does not have a telemetered perimeter radiation monitoring system. This is an acceptable difference under NEI 99-01 because the document indicates this EAL is applicable "for sites having telemetered perimeter monitors," therefore not applicable to RBS.NEI 99-01 Revision 5 AU1 EAL #5 is not included in the RBS proposed EAL scheme. RBS does not have an automatic real-time dose assessment capability.
This is an acceptable difference under NEI 99-01 because the document indicates this EAL is applicable "for sites having such capability," therefore not applicable to RBS.RBS provides parenthetical reference to the ODCM in the 3 rd paragraph of the bases.RBS provides additional information in the bases regarding "non-routine" releases and the protocol for the use of the radiation monitors in RBS Table RI.Attachment 1 Page 6 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: AU2 UNPLANNED rise in plant radiation levels.Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2)1. a. UNPLANNED water level drop in a reactor refueling pathway as indicated by (site specific level or indication).
AND b. VALID Area Radiation Monitor reading rise on (site specific list).2. UNPLANNED VALID Area Radiation Monitor readings or survey results indicate a rise by a factor of 1000 over normal* levels.*Normal can be considered as the highest reading in the past twenty-four hours excluding the current peak value.Attachment 1 Page 7 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: AU2 UNPLANNED rise in plant radiation levels Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2)1. a. UNPLANNED water level drop in a reactor refueling pathway as indicated by any of the following:
* Water level drop in the reactor refueling cavity, spent fuel pool or fuel transfer canal indication on Control Room Panel 870* Personnel observation by visual or remote means AND b. UNPLANNED VALID area radiation monitor alarm on any of the following:
RMS-RE140 RMS-RE141 RMS-RE192 RMS-RE193 OR 2. UNPLANNED VALID area radiation monitor readings or survey results indicate a rise by a factor of 1000 over normal* levels NOTE: For area radiation monitors with ranges incapable of measuring 1000 times normal* levels, classification shall be based on VALID full scale indications unless surveys confirm that area radiation levels are below 1000 times normal* within 15 minutes of the area radiation monitor indications going full scale.*Normal can be considered as the highest reading in the past twenty-four hours excluding the current peak value.Deviations:
None I Attachment 1 Page 8 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: AU2 (Cont'd)Differences:
RBS adds the term "UNPLANNED" to EAL 1.b. This maintains the NEI intent as expressed in the IC and EAL 1.a.RBS uses an alarm to indicate a rise in radiation monitor readings in EAL 1.b because of monitor location and sensitivity.
A note is added to EAL #2 to address the condition where 1,000 times normal levels may provide a value beyond the upper range of the applicable area radiation monitor.RBS provides the radiation monitor locations in the bases information.
Attachment 1 Page 9 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: AA1 Any release of gaseous or liquid radioactivity to the environment greater than 200 times the Radiological Effluent Technical Specifications/ODCM for 15 minutes or longer.Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2 or 3 or 4 or 5)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown.1. VALID reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer: (site specific monitor list and threshold values)2. VALID reading on any effluent monitor reading greater than 200 times the alarm setpoint established by a current radioactivity discharge permit for 15 minutes or longer.3. Confirmed sample analyses for gaseous or liquid releases indicates concentrations or release rates greater than 200 times (site specific RETS values) for 15 minutes or longer.4. VALID reading on perimeter radiation monitoring system reading greater than 10.0 mR/hr above normal* background for 15 minutes or longer. [for sites having telemetered perimeter monitors]5. VALID indication on automatic real-time dose assessment capability indicating greater than (site specific value) for 15 minutes or longer. [for sites having such capability]
*Normal can be considered as the highest reading in the past twenty-four hours excluding the current peak value.Attachment 1 Page 10 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: AA1 Any release of gaseous or liquid radioactivity to the environment
> 200 times the ODCM limit for> 15 minutes Operating Mode Applicability:
Emergency Action Level(s): All (1 or 2 or 3)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown.1. VALID reading on any of the radiation monitors in Table R1 > the ALERT reading for > 15 minutes OR 2. For RMS-RE107 effluent monitor: EITHER VALID reading > 200 times the alarm setpoint established by a current radioactivity discharge permit for > 15 minutes OR VALID reading > 1.27E-01 pCi/ml for > 15 minutes OR 3. Confirmed
'sample analyses for gaseous or liquid releases indicate concentrations or release rates > 200 times the ODCM limit for > 15 minutes Attachment 1 Page 11 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document Deviations:
None Differences:
RBS uses a table to list the applicable radiation monitors and threshold values, referencing the values to the classification level, creating a minor difference in EAL language.RBS differs from NEI 99-01 Revision 5 in the description for EAL #2 and the associated bases. Discharge permits are normally written for liquid radioactive releases.
RBS does not have a normal gaseous release path that requires a batch discharge permit. Therefore, the EAL is specific to the liquid release pathway monitored by RMS-RE107.
The second (superfluous) "reading" is deleted in the RBS EAL #2.EAL #2 and its associated basis information are revised to provide site specific information for effluent monitor RMS-RE107 that may not be capable of providing values within the monitor's calibrated range at or above the 200 multiple for an alarm setpoint established by a radioactivity discharge permit.NEI 99-01 Revision 5 AA1 EAL #4 is not included in the RBS proposed EAL scheme. RBS does not have a telemetered perimeter radiation monitoring system. This is an acceptable difference under NEI 99-01 because the document indicates this EAL is applicable "for sites having telemetered perimeter monitors," therefore not applicable to RBS.NEI 99-01 Revision 5 AAM EAL #5 is not included in the RBS proposed EAL scheme. RBS does not have an automatic real-time dose assessment capability.
This is an acceptable difference under NEI 99-01 because the document indicates this EAL is applicable "for sites having such capability," therefore not applicable to RBS.RBS provides additional information in the bases regarding "non-routine" releases and the protocol for the use of the radiation monitors in RBS Table RI.Attachment 1 Page 12 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: AA2 ,Damage to irradiated fuel or loss of water level that has resulted or will result in the uncovering of irradiated fuel outside the reactor vessel.Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2)1. A water level drop in the reactor refueling cavity, spent fuel pool or fuel transfer canal that will result in irradiated fuel becoming uncovered.
: 2. A VALID alarm or (site specific elevated reading) on ANY of the following due to damage to irradiated fuel or loss of water level.(site specific radiation monitors)Attachment 1 Page 13 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: AA2 Damage to irradiated fuel or loss of water level that has resulted or will result in uncovering of irradiated fuel outside the reactor vessel Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2)1. A water level drop in the reactor refueling cavity, spent fuel pool or fuel transfer canal that will result in irradiated fuel becoming uncovered OR 2. A VALID reading on any of the following radiation monitors due to damage to irradiated fuel or loss of water level: RMS-RE140 2000 mR/hr RMS-RE141 2000 mR/hr RMS-RE192 2000 mR/hr RMS-RE193 2000 mR/hr RMS-RE5A .1.64E+03 pCi/sec RMS-RE5B (GE) 5.29E-04 pCi/ml Deviations:
None Differences:
RBS provides the radiation monitor locations in the bases information.
RBS provides clarifying information in the bases regarding AOP entry and stored control rod blades.Attachment 1 Page 14 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: AA3 Rise in radiation levels within the facility that impedes operation of systems required to maintain plant safety functions.
Operating Mode Applicability:
All Example Emergency Action Levels: 1. Dose rate greater than 15 mR/hr in ANY of the following areas requiring continuous occupancy to maintain plant safety functions: (site specific area list)Attachment 1 Page 15 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: AA3 Rise in radiation levels within the facility that impedes operation of systems required to maintain plant safety functions Operating Mode Applicability:
All Emergency Action Level(s): 1. Dose rate > 15 mR/hr in any of the following areas requiring continuous occupancy to maintain plant safety functions:
Main Control Room CAS Deviations:
None.Differences:
RBS provides information in the bases regarding RP survey activities and the Control Room area radiation monitor when rising radiation levels are detected outside the RCA.Attachment 1 Page 16 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: ASI Off-site dose resulting from an actual or IMMINENT release of gaseous radioactivity greater than 100 mrem TEDE or 500 mrem Thyroid CDE for the actual or projected duration of the release.Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2 or 3 or 4)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. If dose assessment results are available, declaration should be based on dose assessment instead of radiation monitor values. Do not delay declaration awaiting dose assessment results.1. VALID reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer: (site specific monitor list and threshold values)2. Dose assessment using actual meteorology indicates doses greater than 100 mrem TEDE or 500 mrem thyroid CDE at or beyond the site boundary.3. VALID perimeter radiation monitoring system reading greater than 100 mR/hr for 15 minutes or longer. [for sites having telemetered perimeter monitors]4. Field survey results indicate closed window dose rates greater than 100 mR/hr expected to continue for 60 minutes or longer; or analyses of field survey samples indicate thyroid CDE greater than 500 mrem for one hour of inhalation, at or beyond the site boundary.Attachment 1 Page 17 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: ASI Offsite dose resulting from an actual or IMMINENT release of gaseous radioactivity
> 100 mR TEDE or 500 mR thyroid CDE for the actual or projected duration of the release Operating Mode Applicability:
Emergency Action Level(s): All (1 or 2 or 3)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. If dose assessment results are available, the classification should be based on EAL #2 instead of EAL #1.Do not delay declaration awaiting dose assessment results.1. VALID reading on any of the radiation monitors in Table R1 > the SITE AREA EMERGENCY reading for > 15 minutes OR 2. Dose assessment using actual meteorology indicatesdoses
> 100 mR TEDE or 500 mR thyroid CDE at or beyond the SITE BOUNDARY OR 3. Field survey results indicate closed window dose rates > 100 mR-hr expected to continue for > 60 minutes; or analyses of field survey samples indicate thyroid CDE> 500 mR for one hour of inhalation, at or beyond the SITE BOUNDARY Table RI EAL THRESHOLD, Method' SITE AREA EMERGENCY
,1''>'~DRMS Grid 6 Threshold'Main Plant Vent?7 /~.Primary~
4GE1 25' 4.70E+07 pCi/sec Secondary~
N/A~<'Fuel Building Vent~ i~~>~Prmary 4GE005 6.70E+06 pCiIsec--------Secondary, N/A Radwaste Building Vent NIA Attachment 1 Page 18 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: AS1 (Cont'd)Deviations:
None Differences:
The references to dose assessment and plant monitoring data are replaced in the EAL section NOTE with the corresponding specific EAL numbers. This change is provided for ease of use only and does not change the intent of the NOTE.RBS uses a table to list the applicable radiation monitors and threshold values, referencing the values to the classification level, creating a minor difference in EAL language.NEI 99-01 Revision 5 AS1 EAL #3 is not included in the RBS proposed EAL scheme. RBS does not have a telemetered perimeter radiation monitoring system. This is an acceptable difference under NEI 99-01 because the document indicates this EAL is applicable "for sites having telemetered perimeter monitors," therefore not applicable to RBS.Attachment 1 Page 19 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: AGI Off-site dose resulting from an actual or IMMINENT release of gaseous radioactivity greater than 1000 mrem TEDE or 5000 mrem Thyroid CDE for the actual or projected duration of the release using actual meteorology.
Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2 or 3 or 4)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. If dose assessment results are available, declaration should be based on dose assessment instead of radiation monitor values. Do not delay declaration awaiting dose assessment results.1. VALID reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer: (site specific monitor list and threshold values)2. Dose assessment using actual meteorology indicates doses greater than 1000 mrem TEDE or 5000 mrem thyroid CDE at or beyond the site boundary.3. VALID perimeter radiation monitoring system reading greater than 1000 mR/hr for 15 minutes or longer. [for sites having telemetered perimeter monitors]4. Field survey results indicate closed window dose rates greater than 1000 mR/hr expected to continue for 60 minutes or longer; or analyses of field survey samples indicate thyroid CDE greater than 5000 mrem for one hour of inhalation, at or beyond site boundary.Attachment 1 Page 20 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: AGI Offsite dose resulting from an actual or IMMINENT release of gaseous radioactivity
> 1000 mR TEDE or 5000 mR thyroid CDE for the actual or projected duration of the release using actual meteorology Operating Mode Applicability:
Emergency Action Level(s): All (1 or 2 or 3)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. If dose assessment results are available, the classification should be based on EAL #2 instead of EAL #1.Do not delay declaration awaiting dose assessment results.1. VALID reading on any of the radiation monitors in Table R1 > the GENERAL EMERGENCY reading for > 15 minutes OR 2. Dose assessment using actual meteorology indicates doses> 1000 mR TEDE or 5000 mR thyroid CDE at or beyond the SITE BOUNDARY OR 3. Field survey results indicate closed window dose rates > 1000 mR/hr expected to continue for > 60 minutes; or analyses of field survey samples indicate thyroid CDE> 5000 mR for one hour of inhalation, at or beyond the SITE BOUNDARY'TableR1'EAL THRESHOLD Method GENERALEMERGENCY
__ DRMS Grid 65, Threshold
.,Main Plant Vent'Piary, 4GE125 4.70E+08 jiCilsec,4q
~ "' ~ Secondary~
N/A ~Fuel Building Vent 7/
4GE005
:Secondary N/A Radwaste Building Vent I I N/A Deviations:
None Attachment 1 Page 21 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: AGI (Cont'd)Differences:
The references to dose assessment and plant monitoring data are replaced with the corresponding specific EAL numbers in the EAL section NOTE. This change is provided for ease of use only and does not change the intent of the NOTE.RBS uses a table to list the applicable radiation monitors and threshold values, referencing the values to the classification level, creating a minor difference in EAL language.NEI 99-01 Revision 5 AG1 EAL #3 is not included in the RBS proposed EAL scheme. RBS does not have a telemetered perimeter radiation monitoring system. This is an acceptable difference under NEI 99-01 because the document indicates this EAL is applicable "for sites having telemetered perimeter monitors," therefore not applicable to RBS.Attachment 1 Page 22 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: CUl RCS leakage.Operating Mode Applicability:
Cold Shutdown Example Emergency Action Levels: Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. RCS leakage r~esults in the inability to maintain or restore RPV level greater than (site specific low level RPS actuation setpoint) for 15 minutes or longer. [BWR]1. RCS leakage results in the inability to maintain or restore level within (site specific pressurizer or RCS/RPV level target band) for 15 minutes or longer. [PWR]Attachment 1 Page 23 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CUI RCS leakage Operating Mode Applicability:
Cold Shutdown (Mode 4)Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. RCS leakage results in the inability to maintain or restore RPV level > +9.7 inches (Level 3) for_> 15 minutes Deviations None Differences None other than previously noted.Attachment 1 Page 24 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: CU2 UNPLANNED loss of RCS/RPV inventory.
Operating Mode Applicability:
Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. UNPLANNED RCS/RPV level drop as indicated by either of the following:
* RCS/RPV water level drop below the RPV flange for 15 minutes or longer when the RCS/RPV level band is established above the RPV flange." RCS/RPV water level drop below the RCS level band for 15 minutes or longer when the RCS/RPV level band is established below the RPV flange.2. RCS/RPV level cannot be monitored with a loss of RCS/RPV inventory as indicated by an unexplained level rise in (site specific sump or tank).Attachment 1 Page 25 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CU2 UNPLANNED loss of RCS/RPV inventory Operating Mode Applicability:
Emergency Action Level(s): Refueling (Mode 5)(1 or 2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. UNPLANNED RCS level drop as indicated by either of the following:
: a. RCS water level drop below the RPV flange for > 15 minutes when the RCS level band is established above the RPV flange.OR b. RCS water level drop below the RPV level band for > 15 minutes when the RCS level band is established below the RPV flange OR 2. RCS level cannot be monitored with a loss of RCS inventory as indicated by an unexplained rise in floor or equipment sump level, Suppression Pool level, vessel make-up rate or observation of leakage or inventory loss Deviations:
None Differences:
None other than previously noted.Attachment 1 Page 26 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: CU4 UNPLANNED loss of decay heat removal capability with irradiated fuel in the RPV.Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. UNPLANNED event results. in RCS temperature exceeding the Technical Specification cold shutdown temperature limit.2. Loss of all RCS temperature and RCS/RPV level indication for 15 minutes or longer.Attachment 1 Page 27 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CU3 UNPLANNED loss of decay heat removal capability with irradiated fuel in the RPV Operating Mode Applicability:
Cold Shutdown (Mode 4)Refueling (Mode 5)Emergency Action Level(s):
(1 or 2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. UNPLANNED event results in RCS temperature exceeding 200 OF.OR 2. Loss of all RCS temperature and RCS/RPV level indication for > 15 minutes.Deviations:
None Differences:
RBS substitutes the actual value for Cold Shutdown temperature limit in EAL #1.NEI 99-01 CU4 is renumbered to RBS CU3 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 28 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: CU3 AC power capability to emergency busses reduced to a single power source for 15 minutes or longer such that any additional single failure would result in station blackout.Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Level: Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. a. AC power capability to (site specific emergency busses) reduced to a single power source for 15 minutes or longer.AND b. Any additional single power source failure will result in station blackout.Attachment 1 Page 29 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CU5 AC power capability to emergency busses reduced to a single power source for > 15 minutes such that any additional single failure would result in station blackout Operating Mode Applicability:
Cold Shutdown (Mode 4)Refueling (Mode 5)Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. a. AC power capability to Div I & Div II ENS busses reduced to a single power source for > 15 minutes AND b. Any additional single power source failure will result in station blackout Deviations:
None Differences:
NEI 99-01 CU3 is renumbered to RBS CU5 for formatting purposes based on site preference for order of ICs alone.RBS provides site specific information in the bases for preferred transformers.
RBS provides additional clarifying information in the bases for applicable loss of power conditions similar to that provided in NEI SA5.RBS provides site specific information in the bases for the Div III Diesel Generator and Bus E22-S004 and how they are not to be credited for EAL entry.Attachment 1 Page 30 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: CU7 Loss of required DC power for 15 minutes or longer.Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Level: Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. Less than (site specific bus voltage indication) on required (site specific Vital DC busses) for 15 minutes or longer.Attachment 1 Page 31 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CU6 Loss of required DC power for > 15 minutes Operating Mode Applicability:
Cold Shutdown (Mode 4)Refueling (Mode 5)Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. < 105 VDC on required Vital DC busses for > 15 minutes Deviations:
None Differences:
NEI 99-01 CU7 is renumbered to RBS CU6 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 32 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: CU8 Inadvertent criticality.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: 1. UNPLANNED sustained positive period observed on nuclear instrumentation.(BWR)1. UNPLANNED sustained positive startup rate observed on nuclear instrumentation. (PWR)Attachment 1 Page 33 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CU7 Inadvertent criticality Operating Mode Applicability:
Cold Shutdown (Mode 4)Refueling (Mode 5)Emergency Action Level(s): 1. UNPLANNED sustained positive period observed on nuclear instrumentation Deviations:
None Differences:
NEI 99-01 CU8 is renumbered to RBS CU7 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 34 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: CU6 Loss of all On-site or Off-site communications capabilities.
Operating Mode Applicability:
Cold Shutdown Refueling Defueled Example Emergency Action Levels: (1 or 2)1. Loss of all of the following on-site communication methods affecting the ability to perform routine operations: (site specific list of communications methods)2. Loss of all of the following off-site communication methods affecting the ability to perform offsite notifications: (site specific list of communications methods)Attachment 1 Page 35 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CU8 Loss of all onsite or offsite communications capabilities Operating Mode Applicability:
Cold Shutdown (Mode 4)Refueling (Mode 5)Defueled (Mode D)Emergency Action Level(s):
(1 or 2)1. Loss of all of the following onsite communication methods affecting the ability to perform routine operations:
Plant radio system Plant paging system Sound powered phones In-plant telephones OR 2. Loss of all of the following offsite communication methods affecting the ability to perform offsite notifications:
All telephones NRC phones State of Louisiana Radio Offsite notification system and hotline Deviations:
None Differences:
NEI 99-01 CU6 is renumbered to RBS CU8 for formatting purposes based on site preference for order of ICs alone.Attachrnient I Page 36 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: CA1 Loss of RCS/RPV inventory.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. Loss of RCS/RPV inventory as indicated by level less than (site specific level).[Low-Low ECCS actuation setpoint /Level 2 (BWR)][Bottom ID of the RCS loop (PWR)]2. RCS/RPV level cannot be monitored for 15 minutes or longer with a loss of RCS/RPV inventory as indicated by an unexplained level rise in (site specific sump or tank).Attachment 1 Page 37 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CA1 Loss of RCS/RPV inventory Operating Mode Applicability:
Cold Shutdown (Mode 4)Refueling (Mode 5)Emergency Action Level(s):
(1 or 2)Note: The Emergency Director should not wait until the applicable time has elapsed but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. UNPLANNED loss of RCS inventory as indicated by RPV level < -43 inches (Level 2)OR 2. RCS level cannot be monitored for > 15 minutes with a loss of RCS inventory as indicated by an unexplained rise in floor or equipment sump level, Suppression Pool level, vessel make-up rate or observation of leakage or inventory loss Deviations:
None Differences:
RBS uses the term "UNPLANNED" in EAL #1. This does not change the NEI intent as the term "loss" implies that the reduction in RCS inventory is unplanned.
RBS includes vessel make-up rate and the observation of leakage or inventory loss as indications other than "level rise in site specific sump or tank" for loss of RCS inventory in EAL #2.RBS adds information in the bases to further emphasize that the EALs are not applicable when the reactor is defueled.Attachment 1 Page 38 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: CA4 Inability to maintain plant in cold shutdown.Operating Mode Applicability:
Example Emergency Action Levels: Cold Shutdown, Refueling (1 or 2)1. An UNPLANNED event results in RCS temperature greater than (site specific Technical Specification cold shutdown temperature limit) for greater than the specified duration on table.Table: RCS Reheat Duration Thresholds RCS Containment Duration Closure Intact (but not RCS Reduced N/A 60 minutes*Inventory
[PWR])Not intact or RCS Reduced Established 20 minutes*Inventory (PWR)Not Established 0 minutes* If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.
: 2. An UNPLANNED event results in RCS pressure increase greater than 10 psi due to a loss of RCS cooling. (PWR-This EAL does not apply in Solid Plant conditions.)
Attachment 1 Page 39 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CA3 Inability to maintain plant in Cold Shutdown Operating Mode Applicability:
Emergency Action Level(s): Cold Shutdown (Mode 4)Refueling (Mode 5)(1 or 2)1. An UNPLANNED event results in RCS temperature
> 200 OF for > the specified duration in Table C2 OR 2. An UNPLANNED event results in RCS pressure rise> 10 psig due to a loss of RCS cooling Table C2: RCS Reheat Duration Thresholds RCS Containment Closure Duration Intact N/A 60 minutes*Not intact Established 20 minutes*Not Established 0 minutes*If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then the EAL is not applicable.
Deviations:
None Differences:
NEI 99-01 CA4 is renumbered to RBS CA3 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 40 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: CA3 Loss of all Off-site and all On-Site AC power to emergency busses for 15 minutes or longer.Operating Mode Applicability:
Cold Shutdown, Refueling, Defueled Example Emergency Action Level: Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. Loss of all Off-Site and all On-Site AC Power to (site specific emergency busses) for 15 minutes or longer.Attachment 1 Page 41 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CA5 Loss of all offsite and all onsite AC power to emergency busses for > 15 minutes Operating Mode Applicability:
Cold Shutdown (Mode 4)Refueling (Mode 5)Defueled (Mode D)Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. Loss of all offsite and all on-site AC power to Div I & Div II ENS busses for > 15 minutes Deviations:
None Differences:
NEI 99-01 CA3 is renumbered to RBS CA5 for formatting purposes based on site preference for order of ICs alone.RBS provides site specific information in the bases for preferred transformers.
RBS provides additional bases information for the condition where power to the bus may be restored, but necessary loads are not functional on the energized bus.Attachment 1 Page 42 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: CS1 Loss of RCS/RPV inventory affecting core decay heat removal capability.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. With CONTAINMENT CLOSURE not established, RCS/RPV level less than (site specific level).[6" below the bottom ID of the RCS loop (PWR)][6" below the low-low ECCS actuation setpoint (BWR)]OR 2. With CONTAINMENT CLOSURE established, RCS/RPV level less than (site specific level for TOAF).OR 3. RCS/RPV level cannot be monitored for 30 minutes or longer with a loss of RCS/RPV inventory as indicated by ANY of the following:
* (Site specific radiation monitor) reading greater than (site specific value).* Erratic Source Range Monitor Indication.
* Unexplained level rise in (site specific sump or tank).Attachment 1 Page 43 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CSI Loss of RCS/RPV inventory affecting core decay heat removal capability Operating Mode Applicability:
Emergency Action Level(s): Cold Shutdown (Mode 4)Refueling (Mode 5)(1 or 2 or 3)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. With CONTAINMENT CLOSURE not established, RPV level < -49 inches OR 2. With CONTAINMENT CLOSURE established, RPV level < -162 inches (TAF)OR 3. RCS level cannot be monitored for > 30 minutes with a loss of RCS inventory as indicated by any of the following:
* RMS-RE16 reading > 100 R/hr* Erratic Source Range Monitor indication
* Unexplained rise in floor or equipment sump level, Suppression Pool level, vessel make-up rate or observation of leakage or inventory loss Deviations:
None Differences:
RBS includes vessel make-up rate and the observation of leakage or inventory loss as indications other than "level rise in site specific sump or tank" for loss of RCS inventory in EAL #3.RBS adds information in the bases to further emphasize that the EALs are not applicable when the reactor is defueled.Attachment 1 Page 44 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: CGI Loss of RCS/RPV inventory affecting fuel clad integrity with containment challenged.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Level: (1 or 2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. a. RCS/RPV level less than (site specific level for TOAF) for 30 minutes or longer.AND b. ANY containment challenge .indication (see Table): 2. a. RCS/RPV level cannot be monitored with core uncovery indicated by ANY of the following for 30 minutes or longer.* (Site specific radiation monitor) reading greater than (site specific setpoint).
* Erratic source range monitor indication
* UNPLANNED level rise in (site specific sump or tank)." [Other site specific indications]
AND b. ANY containment challenge indication (see Table): Table: Containment Challenge Indications
* CONTAINMENT CLOSURE not established.
* (Site specific explosive mixture) inside containment.
* UNPLANNED rise in containment pressure.* Secondary containment radiation monitor reading above (site specific value). [BWR only]Attachment 1 Page 45 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CGI Loss of RCS/RPV inventory affecting fuel clad integrity with containment challenged Operating Mode Applicability:
Cold Shutdown (Mode 4)Refueling (Mode 5)Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. a. RPV level < -162 inches (TAF) for_> 30 minutes AND b. Any containment challenge indication in Table C1 OR 2. a. RCS level cannot be monitored with core uncovery indicated by any of the following for > 30 minutes:* RMS-RE16 reading > 100 R/hr* Erratic Source Range Monitor indication
* Unexplained rise in floor or equipment sump level, Suppression Pool level, vessel make-up rate or observation of leakage or inventory loss AND b. Any containment challenge indication in Table C1 Attachment 1 Page 46 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CGI (Cont'd)Area DRMS Grid 2 Max!Safe Operating Value RHR Equip '1213 1.5E+03 mR/hr Rm A RHR Equip 1214, 4.5E+03 mR/hr Rm B'RHR Equip 1215 1.5E+03 mR/hr&#xfd;Rm C Deviations:
None Differences: ,RBS includes vessel make-up rate and the observation of leakage or inventory loss as indications other than "level rise in site specific sump or tank" for loss of RCS inventory in EAL #2.RBS includes reference to the EOP Max Safe Operating Value for area radiation monitor readings in the EAL containment challenge indications table. This is consistent with the associated developer note provided in the NEI document.RBS uses the term "unexplained" instead of "UNPLANNED" for the level rise indication in the 3 rd bullet of EAL 2.a. This is the same term used by NEI 99-01 for the SAE condition.
If level rise cannot be explained, then it encompasses the term "UNPLANNED" and therefore meets the NEI intent.RBS adds information in the bases to further emphasize that the EALs are not applicable when the reactor is defueled.Attachment 1 Page 47 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: 'E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.Operating Mode Applicability:
Not applicable Example Emergency Action Level: 1. Damage to a loaded cask CONFINEMENT BOUNDARY.Attachment 1 Page 48 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: E-HUI Damage to a loaded cask CONFINEMENT BOUNDARY Operating Mode Applicability:
All Emergency Action Level(s): 1. Damage to a loaded cask CONFINEMENT BOUNDARY Deviations:
None Differences:
RBS uses an operating mode applicability of "all" vice the NEI designation of"N/A." The net effect is that this event is applicable regardless of operating mode, therefore the same as the NEI intent.Attachment 1 Page 49 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: FUI ANY Loss or ANY Potential Loss of Containment Operating Mode Applicability:
Power Operations Startup Hot Standby Hot Shutdown RBS: FUI ANY loss or ANY potential loss of containment Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Hot Shutdown (Mode 3)Emergency Action Level(s): 1. Any loss or any potential loss of containment Deviations:
None Differences:
RBS adds EAL descriptions in some documentation (e.g., matrix user aid) for the barrier status for consistency in format.Attachment 1 Page 50 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: FAI ANY Loss or ANY Potential Loss of EITHER Fuel Clad OR RCS Operating Mode Applicability:
Power Operations Startup Hot Standby Hot Shutdown RBS: FAI ANY loss or ANY potential loss of EITHER fuel clad or RCS Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Hot Shutdown (Mode 3)Emergency Action Level(s): 1. Any loss or any potential loss of fuel clad OR Any loss or any potential loss of RCS Deviations:
None Differences:
RBS adds EAL descriptions in some documentation (e.g., matrix user aid) for the barrier status for consistency in format.Attachment 1 Page 51 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: FS1 Loss or Potential Loss of ANY Two Barriers Operating Mode Applicability:
Power Operations Startup Hot Standby Hot Shutdown RBS: FS1 Loss or potential loss of ANY two barriers Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode, 2)Hot Shutdown (Mode 3)Emerqencv Action Level(s): 1. Loss or potential loss of any two barriers Deviations:
None Differences:
RBS adds EAL descriptions in some documentation (e.g., matrix user aid) for the barrier status for consistency in format.Attachment 1 Page 52 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: FG1 Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier Operating Mode Applicability:
Power Operations Startup Hot Standby Hot Shutdown RBS: FG1 Loss of ANY two barriers AND loss or potential Loss of the third barrier Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Hot Shutdown (Mode 3)Emergency Action Level(s): 1. Loss of any two barriers AND Loss or potential loss of the third barrier Deviations:
None Differences:
RBS adds EAL descriptions and relevant bases information for the barrier status for consistency in format.Attachment 1 Page 53 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: FUEL CLAD BARRIER Fuel Clad Barrier Thresholds LOSS POTENTIAL LOSS 1. Primary Coolant Activity Level A. Primary coolant activity greater , Not Applicable than (site specific value).OR 2. Reactor Vessel Water Level A. RPV water level cannot be A. RPV water level cannot be restored and maintained above restored and maintained above (site specific RPV water level (site specific RPV water level corresponding to the corresponding to the top of active requirement for primary fuel) or cannot be determined.
containment flooding).
OR 3. Not Applicable Not Applicable Not Applicable OR 4. Primary Containment Radiation Monitoring A. Primary containment radiation Not Applicable monitor reading greater than (site specific value).OR 5. Other Site Specific Indications A. (site specific) as applicable.
A. (site specific) as applicable.
OR 8. Emergency Director Judgment A. Any condition in the opinion of A. Any condition in the opinion of the Emergency Director that the Emergency Director that indicates Loss of the Fuel Clad indicates Potential Loss of the Barrier. Fuel Clad Barrier.Attachment 1 Page 54 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: FUEL CLAD BARRIER Fuel Clad Barrier EAL Thresholds LOSS POTENTIAL LOSS 1. Primary Coolant Activity Level (FC1).. ... ..1 -1 ... ... ............. " " Coolant activity > 300 pCi/gm dose None equivalent 1-131 2. Reactor Vessel Water Level (FC2)RPV water level cannot be restored RPV water level cannot be restored and maintained above -186 inches and maintained above -162 inches or cannot be determined
: 3. Primary Containment Radiation Monitors (FC3)Containment radiation monitor None RMS-RE16 reading > 3,000 R/hr 4. Emergency Director Judgment (FC4)Any condition in the opinion of the Any condition in the opinion of the Emergency Director that indicates Emergency Director that indicates loss of the Fuel Clad barrier, potential loss of the Fuel Clad barrier.Deviations:
None Differences:
Reactor Vessel Water Level Category: RBS provides additional bases information for both the loss and potential loss thresholds to describe the RPV level used for the EAL threshold and associated corrective actions for EAL threshold
#2.Primary Containment Radiation Monitoring Category: RBS changes the NEI title of "Primary Containment Radiation Monitoring" to"Primary Containment Radiation Monitors" -a minor difference in terminology.
Attachment 1 Page 55 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: FUEL CLAD BARRIER (Cont'd)Differences (Cont'd): Other Site Specific Indications Category: Additional EALs that represent a loss or potential loss of the Fuel Clad barrier were not identified for inclusion in the EAL scheme for this IC. A review of Emergency Operating Procedures and station procedures was performed to ensure additional EAL thresholds should not be considered in the "Other" category.
This conforms to NEI guidance because an appropriately diverse mix of EALs is provided and the NEI 99-01 guidance does not specify that any particular additional EALs be provided, but specifies "as applicable." Attachment 1 Page 56 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: RCS BARRIER RCS Barrier Example Thresholds LOSS POTENTIAL LOSS......~~ ~~...................................
......................
..........
.. ...... .............
O T T , O S 1. Primary Containment Pressure A. Primary containment pressure Not Applicable greater than (site specific value)due to RCS leakage.OR 2. Reactor Vessel Water Level A. RPV water level cannot be restored and maintained above (site specific RPV water level corresponding to the top of active fuel) or cannot be determined.
OR 3. RCS Leak Rate A. (site specific indication of an UNISOLABLE Main Steamline, HPCI, Feedwater, RWCU, or RCIC break)OR B. Emergency RPV Depressurization is required.A. RCS leakage greater than 50 gpm inside the drywell.OR B. UNISOLABLE primary system leakage outside primary containment as indicated by exceeding EITHER of the following:
: a. Max Normal Operating Temperature.
OR b. Max Normal Area Radiation.
OR 4. Primary Containment Radiation Monitoring A. Primary containment radiation monitor reading greater than (site specific value)Not Applicable OR 5. Other Site Specific Indications A Ii~t s e ii~ s~ i~ b ............... .iste p -ii~ ~ p ic be ..... .............................
.... ...A. (site specific) as applicable.--- -A. (site specific) as applicable.
OR 6. Emergency Director Judgment............
............
..... ........ ....................
...... ... .. ...... .. .............
.............
.....A. Any condition in the opinion of A. Any condition in the opinion of the Emergency Director that the Emergency Director that indicates Loss of the RCS indicates Potential Loss of the Barrier. RCS Barrier.Attachment 1 Page 57 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: RCS BARRIER RCS Barrier EAL Thresholds LOSS POTENTIAL LOSS 1. Drvwell Pressure (RCI).... Ir .............
l ... .I Drywell pressure > 1.68 psid with indications of reactor coolant leak in drywell None 2. Reactor Vessel Water Level (RC2)RPV water level cannot be restored and maintained above -162 inches or cannot be determined None 3. RCS Leak Rate (RC3)---, C _ e k a e R 3 ..............
..............--
1 1 -..............
...1. a. UNISOLABLE main steam line break as indicated by the failure of both MSIVs in any one line to close AND High MSL flow annunciator (P601-19A-A2)
AND Main Steam Tunnel Temperature
> 144 0 F [173 0 F NRC TS submittal change]OR b. Indication of an UNISOLABLE HPCS, feedwater, RWCU or RCIC break OR 2. Emergency RPV depressurization is required 1. RCS leakage > 50 gpm inside the drywell OR 2. UNISOLABLE RCS leakage outside PC as indicated by exceeding either of the following:
: a. Max Normal Operating Temperature (Table F2)OR b. Max Normal Area Radiation (Table F2)4. Drywell Radiation (RC4)Drywell radiation monitor RMS-RE20 None reading > 100 R/hr due to reactor coolant leakage 5. Emergency Director Judgment (RC5)Any condition in the opinion of the Emergency Director that indicates loss of the RCS barrier.Any condition in the opinion of the Emergency Director that indicates potential loss of the RCS barrier.Deviations:
None Attachment 1 Page 58 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: RCS BARRIER (Cont'd)Differences:
Primary Containment Pressure Category: RBS uses drywell pressure for the EAL threshold indication and renames the parameter as "drywell pressure." This is consistent with the NEI basis that indicates use of the drywell high pressure setpoint for this threshold/parameter.
RBS also changes "...due to RCS leakage" in the EAL threshold to "...with indications of reactor coolant leak in drywell." RBS adds information in the bases that excludes the applicability of certain causes for the rise in drywell pressure.RCS Leak Rate Category: RBS breaks the first loss EAL threshold into two thresholds
-one for MSL break and one for other high energy line breaks such as feedwater, RWCU, etc. The NEI intent is retained.
RBS also changes the NEI term "HPCI" to the site specific term "HPCS" for the same system.RBS provides two values for Main Steam Line Tunnel Max Normal temperature.
The first value of 144 0 F reflects the existing Technical Specification information.
RBS has requested NRC approval in RBS letter RBG-47146 dated 7/26/11 for a Technical Specification revision to change this value to 173 0 F. RBS intends to use the NRC-approved Technical Specification value (either 144 or 173) that is current at the time of EAL implementation for the EAL value. This applies to the MSL Tunnel Temperature in Table F2.RBS uses a table to present the conditions for the second potential loss threshold resulting in a minor difference in EAL wording and format.RBS provides additional site specific bases information on leakage isolation attempts and quantification of leakage.Prim'ary Containment Radiation Monitoring Category: RBS changes the title of this category to "drywell radiation." RBS does not use the same radiation monitor(s) for the Fuel Clad, RCS and Containment barriers.The RBS RCS barrier EAL threshold refers to a drywell radiation monitor. The Fuel Clad and Containment barrier EAL thresholds use the Primary Containment high range radiation monitor. Although NEI 99-01 Revision 4 and NEI 99-01 Revision 5 refer to the use of different monitors between the two revisions, both revisions show the same monitor used for all three barriers.
The drywell post Attachment 1 Page 59 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: RCS BARRIER (Cont'd)Differences (Cont'd):
J accident radiation monitor was selected in lieu of the containment post accident radiation monitor due to the physical layout of RCS piping and the location of the monitors.
The drywell contains the RPV with the majority of RCS piping and its respective containment isolation valves. The RCS piping continues through the enclosed containment steam tunnel (accessed via pull plugs) to the annulus and then to the auxiliary building steam tunnel. Therefore, the drywell radiation monitors are the most likely monitors to initially detect an RCS leak within the containment building.
The RBS difference where the same monitor was not used for the Fuel Clad, RCS and Containment barriers was previously approved (NRC letter dated October 25, 2005 ADAMS Accession No. ML053010184) for the RBS application of the NEI 99-01 Revision 4 based EAL scheme. The site specific reasons for this difference remain the same as for that previously approved.RBS also adds "...due to reactor coolant leakage" to this threshold.
Other Site Specific Indications Category: Additional EALs that represent a loss or potential loss of the RCS barrier were not identified for inclusion in the EAL scheme for this IC. A review of Emergency Operating Procedures and station procedures was performed to ensure additional EAL thresholds should not be considered in the "Other" category.
This conforms to NEI guidance because an appropriately diverse mix of EALs is provided and the NEI 99-01 guidance does not specify that any particular additional EALs be provided, but specifies "as applicable." Attachment 1 Page 60 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: CONTAINMENT BARRIER Containment Barrier Example Thresholds LOSS 1. Primary Containment Conditions A. Primary containment pressure rise followed by a rapid unexplained drop in primary containment pressure.OR B. Primary containment pressure response not consistent with LOCA conditions.
: 2. Reactor Vessel Water Level 1 T ExNTI I hAL L 0 SS A. Primary containment pressure greater than (site specific value) and rising.OR B. Explosive mixture exists inside primary containment.
OR C. RPV pressure and suppression pool temperature cannot be maintained below the HCTL.OR Not Applicable
-_A:Priaycnanetfodn eurd...o-.... _ _ ...........
.........
.............
.........
.... ..........
...... .... -..;' a .oi e ; o d n .....e..... ........ .. ....e ....... ...... ............
OR 3. Primary Containment Isolation Failure or Bypass A.Failure of all valves in any one line to Not Applicable close.AND Direct downstream pathway to the environment exists after primary containment isolation signal.OR B. Intentional primary containment venting per EOPs.OR C. UNISOLABLE primary system leakage outside primary containment as indicated by exceeding EITHER of the following:
: a. Max Safe Operating Temperature.
OR b. Max Safe Area Radiation.
C)R Attachment 1'Page 61 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: CONTAINMENT BARRIER (Cont'd)Containment Barrier Example Thresholds
: 4. Primary Containment Radiation Monitorinq Not Applicable A. Primary containment radiation monitor reading greater than (site specific value).OR 5. Other Site Specific)
Indications A. (site specific) as applicable.
__ -- 1A. (site specific) as applicable.
OR 6. Emeruencv Director Judqment A. Any condition in the opinion of the Emergency Director that indicates Loss of the>Containment Barrier.B.Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Attachment 1 Page 62 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CONTAINMENT BARRIER Containment Barrier EAL Thresholds LOSS ---OTNTIAL LOSS....... .... ........ ...........
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........1. Primary Containment Conditions (PC1)1. Rapid unexplained loss of PC 1. PC pressure > 15 psig and rising pressure following an initial pressure OR rise 2.a. PC hydrogen in the unsafe zone of HDOL curve OR OR 2. PC pressure response not consistent b.DW hydrogen concentration
> 9%OR with LOCA conditions O 3. RPV pressure and suppression pool temperature cannot be maintained below the HCTL 2. Reactor Vessel Water Level (PC2).... ....... ............
I.... ........ ... ........ I.............
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-ii-P --- ---dn- P cd U-e SAP .-n ...............................
None I Entr into PC flooding procedures SAP-I and SAP-2.... ..................
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...3. Primary Containment Isolation Failure or Bypass (PC3)1. a. Failure of all valves in any None one line to close AND b. Direct downstream pathway to the environment exists after PC isolation signal OR 2. Intentional PC venting per EOPs or SAPs OR 3. UNISOLABLE RCS leakage outside PC as indicated by exceeding either of the following:
: a. Max Safe Operating Temperature (Table Fl)OR b. Max Safe Area Radiation (Table Fl)4. Primary Containment Radiation Monitoring (PC4)None Containment radiation monitor RMS-RE16 reading> 10,000 R/hr 5. Emeraencv Director Judament WPC51-- ...... ... ....... ........ ..... .. ........ ... ....-.. .. .-- .......--......
.......Any condition in the opinion of the Any condition in the opinion of the Emergency Director Emergency Director that indicates loss of that indicates potential loss of the Primary Containment the Primary Containment barrier, barrier.Attachment 1 Page 63 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CONTAINMENT BARRIER (Cont'd)Deviations:
None Differences:
Primary Containment Conditions Category: RBS uses the wording "rapid unexplained loss of PC pressure following initial pressure rise" vice the NEI (inverse) wording of "primary containment pressure rise followed by a rapid. unexplained drop in primary containment pressure" for the loss EAL threshold.
This revised wording is provided for clarity and has the same meaning as the NEI wording.RBS removes reference to drywell spray in the bases for site specific reasons.RBS does not have a drywell spray system.RBS provides additional site specific bases information for the loss EAL threshold to further describe conditions that do not meet the EAL threshold and to clarify indications that may be used.RBS provides additional site specific bases information for the primary containment pressure potential loss EAL threshold.
RBS provides site specific explosive mixture information for the explosive mixture potential loss EAL threshold and in the associated bases.Reactor Vessel Water Level Category: RBS changes the EAL threshold and bases to refer to the site specific procedures for containment flooding resulting in no change to the NEI intent.Primary Containment Isolation Failure or Bypass RBS provides additional site specific bases information defining an "inability to isolate" and clarifying isolation attempts as they relate to the first EAL threshold.
RBS also provides site specific information in the bases on primary containment isolation valves and the application of the containment airlock to this EAL threshold.
RBS refers to site specific procedure designations (SAP) in the second EAL threshold.and associated bases., RBS uses a table to present the conditions for the third EAL threshold resulting in a minor difference in EAL wording and format. RBS also provides information on leakage into a closed system in bases for this EAL threshold..
Attachment 1 Page 64 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: CONTAINMENT BARRIER (Cont'd)Differences (Cont'd): Primary Containment Radiation Monitoring Category: RBS changes the NEI title of "Primary Containment Radiation Monitoring" to"Primary Containment Radiation Monitors" -a minor difference in terminology.
Other Site Specific Indications Category: Additional EALs that represent a loss or potential loss of the Containment barrier were not identified for inclusion in the EAL scheme for this IC. A review of Emergency Operating Procedures and station procedures was performed to ensure additional EAL thresholds should not be considered in the "Other" category.
This conforms to NEI guidance because an appropriately diverse mix of EALs is provided and the NEI 99-01 guidance does not specify that any particular additional EALs be provided, but specifies "as applicable." Attachment 1 Page 65 of 136 r-RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HU4 Confirmed SECURITY CONDITION or threat which indicates a potential degradation in the level of safety of the plant.Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2 or 3)1. A SECURITY CONDITION that does NOT involve a HOSTILE ACTION as reported by the (site specific security shift supervision).
: 2. A credible site specific security threat notification.
: 3. A validated notification from NRC providing information of an aircraft threat.Attachment 1 Page 66 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HU1 Confirmed SECURITY CONDITION or threat which indicates a potential degradation in the level of safety of the plant Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2 or 3)1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the RBS security shift supervision OR 2. A credible site specific security threat notification OR 3. A validated notification from NRC providing information of an aircraft threat Deviations:
None Differences:
NEI 99-01 HU4 is renumbered to RBS HU1 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 67 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HU5 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a NOUE.Operating Mode Applicability:
All Example Emergency Action Level: 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to , facility protection has been initiated.
No releases of radioactive material requiring off-site response or monitoring are expected unless further degradation of safety systems occurs.Attachment 1 Page 68 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HU2 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a NOUE Operating Mode Applicability:
All Emergency Action Level(s): 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.
No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.Deviations:
None Differences:
NEI 99-01 HU5 is renumbered to RBS HU2 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 69 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HU2 FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA.Operating Mode Applicability:
All Example Emergency Action Level: (1 or 2)Note: The Emergency Director should not wait until the ,applicable time has elapsed, but should declare the event as soon as' it is determined that the duration has exceeded, or will likely exceed, the applicable time.1. FIRE not extinguished within 15 minutes of control room notification or verification of a control room FIRE alarm in ANY of the following areas: (site specific area list)2. EXPLOSION within the PROTECTED AREA.Attachment 1 Page 70 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HU4 FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA Operating Mode Applicability:
Emergency Action Level(s): All (1 or 2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the duration has exceeded, or will likely exceed, the applicable time.1. FIRE not extinguished within 15 minutes of Control Room notification or verification of a Control Room FIRE alarm in any Table H2 structure or area I'WCd4,LUEI L)UIIUIIIJ 2~LCIIIUL~UY ,UI1tIU I uWv"E, Axiliary Building ;Diesel Generator Building ~'Control Buiding" <Turnnels (B, D, E, F, G,T)OR 2. EXPLOSION within the PROTECTED AREA Deviations:
None Differences:
NEI 99-01 HU2 is renumbered to RBS HU4 for formatting purposes based on site preference for order of ICs alone.RBS provides a table for the list of areas for EAL #1 and therefore differs from the NEI EAL terminology.
Attachment 1 Page.71 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HU3 Release of toxic, corrosive, asphyxiant, or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS.
Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2)1. Toxic, corrosive, asphyxiant or flammable gases in amounts that have or could adversely affect NORMAL PLANT OPERATIONS.
: 2. Report by local, county or state officials for evacuation or sheltering of site personnel based on an off-site event.Attachment 1 Page 72 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HU5 Release of toxic, corrosive, asphyxiant, or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2)1. Toxic, corrosive, asphyxiant or flammable gases in amounts that have or could adversely affect NORMAL PLANT OPERATIONS OR 2. Report by West Feliciana Parish for evacuation or sheltering of site personnel based on an offsite event Deviations:
None Differences:
NEI 99-01 HU3 is renumbered to RBS HU5 for formatting purposes based on site preference for order of ICs alone. In an attempt to group "families" of emergency classes together with the same last digit Arabic numeral designation (such as HU1, AU1, AS1, etc.), RBS does not provide an IC labeled HU3. All NEI 99-01 NOUE I(s for the Hazards and Other Conditions Affecting Plant Safety category are still addressed in the RBS EALs.RBS uses the term "Parish" in EAL #2. The term "parish" is synonymous with both "local" and "county" for the state of Louisiana.
Attachment 1 Page 73 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HUI Natural or destructive phenomena affecting the PROTECTED AREA Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2 or 3 or 4 or5)1. Seismic event identified by ANY 2 of the following:
Seismic event confirmed by (site specific indication or method)Earthquake felt in plant National Earthquake Center 2. Tornado striking within PROTECTED AREA boundary or high winds greater than (site specific mph)3. Internal flooding that has the potential to affect safety related equipment required by Technical Specifications for the current operating mode in ANY of the following areas: (site specific area list)4. Turbine failure resulting in casing penetration or damage to turbine or generator seals.5. (Site specific occurrences affecting the PROTECTED AREA).Attachment 1 Page 74 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HU6 Natural or destructive phenomena affecting the PROTECTED AREA Operating Mode Applicability:
Emergency Action Level(s): All (1 or2or3or4or5)
: 1. Seismic event identified by any 2 of the following:
* Seismic event confirmed by activated seismic switch as indicated by receipt of EITHER a OR b: a. Annunciator "Seismic Tape Recording SYS Starf' (P680-02A-D06)
: b. Event Indicator on ERS-NBI-102 is white S 0 Earthquake felt in plant National Earthquake Center OR 2. Tornado striking within the PROTECTED AREA boundary OR 3. Internal flooding that has the potential to affect safety related equipment required by Technical Specifications for the current operating mode in any Table H1 area OR 4. Turbine failure resulting in casing penetration or damage to turbine or generator seals OR 5. Severe weather or hurricane conditions with indication of SUSTAINED high winds > 74 mph within the PROTECTED AREA boundary Attachment 1 Page 75 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HU6 (Cont'd)IdU~ Crescn Ar~ea 70<' EL, 6. W 6inches above floor, (must be verified~HPCS Room 701EL 4 ~~ inches above 'floor (P870Q-5fA-G4), ,RIIRB oo 70'EL 4 ~ ~
* j~~ inches above floor<<(P870-51A-G4)j"kHRB<R~oom 70'EL 4 inches abiove floor~9(P870--51AtG4)
~LPCS Ro3om 70'EL 4< <inches abiove floorK~RCIC Room 70TE 1, 41 inches abo4vefl~oor (P870-51A-G4):
Deviations:
None Differences:
NEI 99-01 HU1 is renumbered to RBS HU6 for formatting purposes based on site preference for order of ICs alone.RBS adds bases information relating the station alarm response procedure for EAL #1.There is no site-specific value used for high winds in the RBS EAL #2. RBS provides a separate EAL (EAL #5) that addresses high (hurricane force) winds.FSAR design basis is that all Seismic Category I structures at RBS are designed to withstand 100 mph fastest mile of sustained wind 30 ft above ground, based upon a 100-yr period of recurrence.
Methods to measure wind speed in the PROTECTED AREA are not available, therefore a sustained indication of 74 mph on the Meteorological Tower lower elevation average wind speed indication will be used to determine that this EAL.(#5) is met.Attachment 1 Page 76 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HU6 (Cont'd)Differences (Cont'd): RBS presents site specific areas for EAL #3 in a table and references the table causing a minor difference in EAL language from that in NEI 99-01. Information is also added to the bases for this EAL, the associated table and its relationship to station Emergency Operating Procedures.
The reference to VISIBLE DAMAGE is removed from the bases for EAL #3 for escalation information because NEI 99-01 does not refer to VISIBLE DAMAGE for the corresponding Alert classification in HA1 EAL #3.Attachment 1 Page 77 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HA4 HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat.Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2)1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA as reported by the (site specific security shift supervision).
: 2. A validated notification from NRC of an airliner attack threat within 30 minutes of the site.Attachment 1 Page 78 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HAI HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2)1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the RBS security shift supervision OR 2. A validated notification from NRC of an airliner attack threat within 30 minutes of the site Deviations:
None Differences:
NEI 99-01 HA4 is renumbered to RBS HA1 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 79 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HA6 Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.Operating Mode Applicability:
All Example Emergency Action Level: 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Attachment 1 Page 80 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HA2 Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert Operating Mode Applicability:
All Emergency Action Level(s): 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels Deviations:
None Differences:
NEI 99-01 HA6 is renumbered to RBS HA2 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 81 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HA5 Control room evacuation has been initiated.
Operating Mode Applicability:
All Example Emergency Action Level: 1. (Site-specific procedure) requires control room evacuation.
Attachment 1 Page 82 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HA3 Control Room evacuation has been initiated Operating Mode Applicability:
All Emergency Action Level(s): 1. AOP-0031, Shutdown from Outside the Main Control Room requires Control Room evacuation Deviations:
None Differences:
NEI 99-01 HA5 is renumbered to RBS HA3 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 83 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HA2 FIRE or EXPLOSION affecting the operability of plant safety systems required to establish or maintain safe shutdown.Operating Mode Applicability:
All Example Emergency Action Level: 1. FIRE or EXPLOSION resulting in VISIBLE DAMAGE to ANY of the following structures containing safety systems or components OR control room indication of degraded performance of those safety systems: (site specific structure list)Attachment 1 Page 84 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HA4 FIRE or EXPLOSION affecting the operability of plant safety systems required to establish or maintain safe shutdown Operating Mode Applicability:
All Emergency Action Level(s): 1. FIRE or EXPLOSION resulting in VISIBLE DAMAGE to any of the structures or areas in Table H2 containing safety systems or components or Control Room indication of degraded performance of those safety systems Auxiliary Building IDiesel GeneratorA Building ,Control Building~
Tunnels (B, D, E, F, G, T)'Fueluidn PA- g ~ ~Deviations:
None Differences:
NEI 99-01 HA2 is renumbered to RBS HA4 for formatting purposes based on site preference for order of ICs alone.RBS provides a table for the list of areas for EAL #1 and therefore differs from the NEI EAL terminology.
Attachment 1 Page 85 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HA3 Access to a VITAL AREA is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of operable equipment required to maintain safe operations or safely shutdown the reactor.Operating Mode Applicability:
All Example Emergency Action Levels: Note: If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.1. Access to a VITAL AREA is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor.Attachment 1 Page 86 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HA5 Access to a VITAL AREA is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of operable equipment required to maintain safe operations or safely shutdown the reactor Operating Mode Applicability:
All Emergency Action Level(s): Note: If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.1. Access to a VITAL AREA (Table H2) is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor Deviations:
None Differences:
NEI 99-01 HA3 is renumbered to RBS HA5 for formatting purposes based on site preference for order of ICs alone.RBS uses a table in the EAL for a list of Vital Areas.Attachment 1 Page 87 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HAI Natural or Destructive Phenomena Affecting VITAL AREAs.Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2 or 3 or 4 or 5 or 6)1. a. Seismic event greater than Operating Basis Earthquake (OBE) as indicated by (site specific seismic instrumentation) reading (site specific OBE limit).AND b. Earthquake confirmed by ANY of the following: " Earthquake felt in plant" National Earthquake Center" Control Room indication of degraded performance of systems required for the-safe shutdown of the plant.2. Tornado striking or high winds greater than (site specific mph) resulting in VISIBLE DAMAGE to ANY of the following structures containing safety systems or components OR control room indication of degraded performance of those safety systems: (site specific structure list)3. Internal flooding in ANY of the following areas resulting in an electrical shock hazard that precludes access to operate or monitor safety equipment OR control room indication of degraded performance of those safety systems: (site specific area list)4. Turbine failure-generated PROJECTILES resulting in VISIBLE DAMAGE to or penetration of ANY of the following structures containing safety systems or components OR control room indication of degraded performance of those safety systems: (site specific structure list)5. Vehicle crash resulting in VISIBLE DAMAGE to ANY of the following structures containing safety systems or components OR control room indication of degraded performance of those safety systems: (site specific structure list)Attachment 1 Page 88 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HAI (Cont'd)Example Emergency Action Levels (Cont'd): 6. (Site specific occurrences) resulting in VISIBLE DAMAGE to ANY of the following structures containing safety systems or components OR control room indication of degraded performance of those safety systems: Attachment 1 Page 89 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HA6 Natural or destructive phenomena affecting VITAL AREAS Operating Mode Applicability:
All Emergency Action Level(s):
(1 or2 or3or4 or5 or6)1. a. Seismic event> Operating Basis Earthquake (OBE) as indicated by: Annunciator "Seismic Tape Recording System Start" (P680-02A-D06)
AND Event Indicator on ERS-NBI-102 is white AND Receipt of EITHER 1 OR 2: 1. Annunciator "Seismic Event High" (P680-02A-C06)
: 2. Annunciator "Seismic Event High-High" (P680-02A-B06)
AND amber light(s) on panel NBI-101 AND b. Earthquake confirmed by any of the following:
* Earthquake felt in plant* National Earthquake Center* Control Room indication of degraded performance of systems required for the safe shutdown of the plant OR 2. Tornado striking resulting in VISIBLE DAMAGE to any of the Table H2 structures or areas containing safety systems or components or Control Room indication of degraded performance of those safety systems OR 3. Internal flooding in Auxiliary Building 70 ft elevation resulting in an electrical shock hazard that precludes access to operate or monitor safety equipment or Control Room indication of degraded performance of those safety systems OR Attachment 1 Page 90 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HA6 (Cont'd)Emergency Action Level(s) (Cont'd)4. Turbine failure-generated PROJECTILES resulting in VISIBLE DAMAGE to or penetration of any of the Table H2 structures or areas containing safety systems or components or Control Room indication of degraded performance of those safety systems OR 5. Vehicle crash resulting in VISIBLE DAMAGE to any of the Table H2 structures or areas containing safety systems or components or Control Room indication of degraded performance of those safety systems OR 6. Hurricane or high SUSTAINED wind conditions
-74 mph within the PROTECTED AREA boundary and resulting in VISIBLE DAMAGE to any of the Table H2 structures or areas containing safety systems or components or Control Room indication of degraded performance of those safety systems.~Struictures Containing Functions or Systems Required~i Ifor Sa~feShutdown Aeactor Building.
Standby ooling Tower Auxiliary Building Diesel Gene~rator Building Control Building Tunnels (B3, D, E, F, G, T)FuelI Buildirg Deviations:
None Differences:
NEI 99-01 HA1 is renumbered to RBS HA6 for formatting purposes based on site preference for order of ICs alone.There is no site-specific value used for high winds in the RBS EAL #2. RBS provides a separate EAL (EAL #6) that addresses high (hurricane force) winds.FSAR design basis is that all Seismic Category I structures at RBS are designed to withstand 100 mph fastest mile of sustained wind 30 ft above ground, based upon a 100-yr period of recurrence.
Methods to measure wind speed in the PROTECTED AREA are not available, therefore a sustained indication of 74 mph Attachment 1 Page 91 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HA6 (Cont'd)Differences (Cont'd): on the Meteorological Tower lower elevation average wind speed indication will be used to determine that this EAL (#6) is met.RBS presents site specific areas for EALs #2, #4, #5 and #6 in a table and references the table in each EAL (and bases as applicable) causing a minor difference in EAL language from that in NEI 99-01.RBS adds information in the bases for Emergency Director consideration of the Fuel Building as necessary to address the impact of the event on the loss of spent fuel cooling or spent fuel.RBS adds information in the bases for EAL #3 relating EAL areas of concern to Emergency Operating Procedure information and clarifying indication of the condition.
RBS adds clarifying information in the bases for EAL #4 regarding the selection of areas of concern.Attachment 1 Page 92 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01:HS4 HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:
All Example Emergency Action Level: 1. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site security shift supervision).
Attachment 1 Page 93 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HS1 HOSTILE ACTION within the PROTECTED AREA Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2)1. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the RBS security shift supervision Deviations:
None Differences:
NEI 99-01 HS4 is renumbered to RBS HSI for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 94 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HS3 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency.
Operating Mode Applicability:
All Example Emergency Action Level: 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1)toward site personnel or equipment that could lead to the likely failure of or;(2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Attachment 1 Page 95 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HS2 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency Operating Mode Applicability:
All Emergency Action Level(s): 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1)toward site personnel or equipment that could lead to the likely failure of or;(2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary Deviations:
None Differences:
NEI 99-01 HS3 is renumbered to RBS HS2 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 96 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HS2 Control room evacuation has been initiated and plant control cannot be established.
Operating Mode Applicability:
All Example Emergency Action Level: 1. a. Control room evacuation has been initiated.
AND b. Control of the plant cannot be established within (site specific minutes).Attachment 1 Page 97 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HS3 Control Room evacuation has been initiated and plant control cannot be established Operating Mode Applicability:
All Emergency Action Level(s): 1. a. Control Room evacuation has been initiated AND b. Control of the plant cannot be established in accordance with AOP-0031, Shutdown from Outside the Main Control Room, within 15 minutes Deviations:
None Differences:
NEI 99-01 HS2 is renumbered to RBS HS3 for formatting purposes based on site preference for order of ICs alone.RBS includes the procedural reference in the EAL for consistency with HA3.Attachment 1 Page 98 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HG1 HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:
All Example Emergency Action Level: (1 or 2)1. A HOSTILE ACTION has occurred such that plant personnel are unable to operate equipment required to maintain safety functions.
: 2. A HOSTILE ACTION has caused failure of Spent Fuel Cooling Systems and IMMINENT fuel damage is likely for a freshly off-loaded reactor core in pool.Attachment 1 Page 99 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HG1 HOSTILE ACTION resulting in loss of physical control of the facility Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2)1. A HOSTILE ACTION has occurred such that plant personnel are unable to operate equipment required to maintain safety functions OR 2. A HOSTILE ACTION has caused failure of Spent Fuel Cooling Systems and IMMINENT fuel damage is likely for a freshly off-loaded reactor core in pool Deviations:
None Differences:
None other than previously noted.Attachment 1 Page 100 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: HG2 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency.
Operating Mode Applicability:
All Example Emergency Action Level: 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.
Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area.Attachment 1 Page 101 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: HG2 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency Operating Mode Applicability:
All Emergency Action Level(s): 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.
Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area Deviations:
None Differences:
None other than previously noted.Attachment 1 Page 102 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SUI Loss of all Off-site AC power to emergency busses for 15 minutes or longer.Operating Mode Applicability:
Power Operation Startup Hot Standby Hot Shutdown Example Emergency Action Level: Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. Loss of all off-site AC power to (site specific emergency busses) for 15 minutes or longer.Attachment 1 Page 103 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SUI Loss of all offsite AC power to emergency busses for > 15 minutes Operating Mode Applicability:
Emergency Actidn Level(s): Power Operation (Mode 1)Startup (Mode 2)Hot Shutdown (Mode 3)Note: The Emergency Director should notr-wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. Loss of all offsite AC power to Div I & II ENS busses for> 15 minutes Deviations:
None Differences:
RBS provides site specific information in the bases for preferred transformers.
Attachment 1 Page 104 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SU3 UNPLANNED loss of safety system annunciation or indication in the control room for 15 minutes or longer.Operating Mode Applicability:
Example Emergency Action Level: Power Operation Startup Hot Standby Hot Shutdown Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. UNPLANNED Loss of greater than approximately 75% of the following for 15 minutes or longer: a. (Site specific control room safety system annunciation)
OR b. (Site specific control room safety system indication)
Attachment 1 Page 105 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SU6 UNPLANNED loss of safety system annunciation or indication in the Control Room for > 15 minutes Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Hot Shutdown (Mode 3)Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. UNPLANNED loss of > approximately 75% of the following for > 15 minutes: a. Control Room safety system annunciation OR b. Control Room safety system indication Deviations:
None Differences:
NEI 99-01 SU3 is renumbered to RBS SU6 for formatting purposes based on site preference for order of ICs alone. In an attempt to group "families" of emergency classes together with the same last digit Arabic numeral designation (such as SU1, SAl, SS1, etc.), RBS does not provide ICs labeled SU2, SU3, SU4 and SU5. All NEI 99-01 NOUE ICs for the System Malfunction category are still addressed in the RBS EALs.RBS provides additional information in the bases to define those systems associated with safety system indication and the related Control Room panels.Attachment 1 Page 106 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SU5 RCS leakage.Operating Mode Applicability:
Power Operation Startup Hot Standby Hot Shutdown Example Emergency Action Levels: (1 or 2)1. Unidentified or pressure boundary leakage greater than 10 gpm.2. Identified leakage greater than 25 gpm.Attachment 1 Page 107 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SU7 RCS leakage Operating Mode Applicability:
Emergency Action Level(s): Power Operation (Mode 1)Startup (Mode 2)Hot Shutdown (Mode 3)(1 or 2)1. Unidentified or pressure boundary leakage > 10 gpm OR 2. Identified leakage > 35 gpm Deviations:
None Differences:
NEI 99-01 SU5 is renumbered to RBS SU7 for formatting purposes based on site preference for order of ICs alone.RBS uses 35 gpm as the value for identified leakage. The RBS Technical Specification limit is 5 gpm for unidentified leakage and 30 gpm total leakage averaged over the previous 24 hours. The NEI EAL is less than the allowable TS, therefore the RBS value for EAL #2 was set at 35 gpm to be above allowable limits. This difference was previously approved (NRC letter dated October 25, 2005 ADAMS Accession No. ML053010184) for the RBS application of the NEI 99-01 Revision 4 based EAL scheme. The site specific reasons for this difference remain the same as for that previously approved.Attachment 1 Page 108 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-07: SU6 Loss of All On-site or Off-site communications capabilities.
Operating Mode Applicability:
Power Operation Startup Hot Standby Hot Shutdown Example Emergency Action Levels: (1 or 2)1. Loss of all of the following on-site communication methods affecting the ability to perform routine operations.(site specific list of communications methods)1. Loss of all of the following off-site communication methods affecting the ability to perform offsite notifications.(site specific list of communications methods)Attachment 1 Page 109 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SU8 Loss of all onsite or offsite communications capabilities Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Hot Shutdown (Mode 3)Emergency Action Level(s):
(1 or 2)1. Loss of all of the following onsite communications methods affecting the ability to perform routine operations:
Plant radio system Plant paging system Sound powered phones In-plant telephones OR 2. Loss of all of the following communications methods affecting the ability to perform offsite notifications:
All telephones NRC phones State of Louisiana Radio Offsite notification system and hotline Deviations:
None Differences:
NEI 99-01 SU6 is renumbered to RBS SU8 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 110 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SU4 Fuel clad degradation.
Operating Mode Applicability:
Power Operation Startup Hot Standby Hot Shutdown Example Emergency Action Levels: (1 or 2)1. (Site specific radiation monitor readings indicating fuel clad degradation greater than Technical Specification allowable limits.)2. (Site specific coolant sample activity value indicating fuel clad degradation greater than Technical Specification allowable limits.)Attachment 1 Page 111 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SU9 Fuel clad degradation Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Hot Shutdown (Mode 3)Emergency Action Level(s): 1. Offgas pre-treatment radiation monitor reading > the Table S1 Dose Rate Limit for the actual indicated offgas flow indicating fuel clad degradation
> T.S. allowable limits OR 2. Reactor coolant sample activity value indicating fuel clad degradation
> T.S. allowable limits* >4.0 pCi/gm dose equivalent 1-131 OR* >0.2 pCi/gm dose equivalent 1-131 for > 48 hours I ,, Ta~ble S1~(FLOWV.Dose Rate- F,~~LOW iDose Rate Limit, (cm ii (cfm) (mR/hr)~/ m:/r 15 i ~~9579 70~ 1865___17.875 ' ~ 8064 80 1671 20 7 7219' 90 15,10&25 5788 ,100 , '1376~30 ~ 4829 110 1262 ~'S32.83 ' '28~49 <~>120~ j 1165'52810 -130 ~ 1082 40 2680 ~ 14 1009 45 >2 5 2 9  1'~ 50 ' 945 150 2377___ 1A75~ 815 SI 60' 2098 -200 *71,6 *Attachment 1 Page 112 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SU9 (Cont'd)Deviations:
None Differences:
NEI 99-01 SU4 is renumbered to RBS SU9 for formatting purposes based on site preference for order of ICs alone.RBS provides an "or" to separate EALs 1 and 2.RBS provides an EAL value and associated basis information for the nominal operating limit for dose equivalent 1-131 for RCS activity in addition to the transient iodine spiking limit described in NEI 99-01.RBS provides a table and additional clarifying information in the bases for applying offgas pre-treatment radiation monitor readings for EAL #1.Attachment 1 Page 113 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SU8 Inadvertent criticality.
OPERATING MODE APPLICABILITY Hot Standby Hot Shutdown Example Emergency Action Level: (1 or 2)1., UNPLANNED sustained positive period observed on nuclear instrumentation.
[BWR]2. UNPLANNED sustained positive startup rate observed on nuclear instrumentation.
[PWR]Attachment 1 Page 114 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SUI0 Inadvertent criticality Operating Mode Applicability:
Hot Shutdown (Mode 3)Emergency Action Level(s): 1. UNPLANNED sustained positive period observed on nuclear instrumentation Deviations:
None Differences:
NEI 99-01 SU8 is renumbered to RBS SU10 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 115 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SU2 Inability to reach required shutdown within Technical Specification limits.Operating Mode Applicability:
Power Operation Startup Hot Standby Hot Shutdown Example Emergency Action Level: 1. Plant is not brought to required operating mode within Technical Specifications LCO Action Statement Time.Attachment 1 Page 116 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SUI 1 Inability to reach required operating mode within Technical Specification limits Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Hot Shutdown (Mode 3)Emergency Action Level(s): 1. Plant is not brought to required operating mode within Technical Specifications LCO Action Statement time Deviations:
None Differences:
NEI 99-01 SU2 is renumbered to RBS SU11 for formatting purposes based on site preference for order of ICs alone.RBS changes the NEI Initiating Condition to refer to required "operating mode" vice "shutdown" to provide clarity and agreement with the associated NEI EAL and bases. This change does not alter the meaning or intent of the Initiating Condition.
Attachment 1 Page 117 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SA5 AC power capability to emergency busses reduced to a single power source for 15 minutes or longer such that any additional single failure would result in station blackout.Operating Mode Applicability:
Power Operation Startup Hot Standby Hot Shutdown Example Emergency Action Level: Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. a. AC power capability to (site-specific emergency busses) reduced to a single power source for 15 minutes or longer.AND b. Any additional single power source failure will result in station blackout.Attachment 1 Page 118 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SA1 AC power capability to emergency busses reduced to a single power source for> 15 minutes such that any additional single failure would result in station blackout Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Hot Shutdown (Mode 3)Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. a. AC power capability to Div I and II ENS busses reduced to a single power source for > 15 minutes AND b. Any additional single power source failure will result in station blackout Deviations:
None Differences:
NEI 99-01 SA5 is renumbered to RBS SA1 for formatting purposes based on site preference for order of ICs alone.RBS provides site specific information in the bases for preferred transformers.
RBS provides site specific information in the bases for the Div III Diesel Generator and Bus E22-S004 and how they are not to be credited for EAL entry.Attachment 1 Page 119 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SA2 Automatic Scram (Trip) fails to shutdown the reactor and the manual actions taken from the reactor control console are successful in shutting down the reactor.Operating Mode Applicability:
Power Operation Startup Example Emergency Action Level: 1. a. An automatic scram (trip) failed to shutdown the reactor.AND b. Manual actions taken at the reactor control console successfully shutdown the reactor as indicated by (site specific indications of plant shutdown).
Attachment 1 Page 120 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SA3 Automatic scram fails to shutdown the reactor and the manual actions taken from the reactor control console are successful in shutting down the reactor Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Emergency Action Level(s): 1. a. An automatic trip failed to shutdown the reactor AND b. Manual actions taken at the reactor control console successfully shutdown the reactor as indicated by reactor power < 5%.Deviations:
None Differences:
NEI 99-01 SA2 is renumbered to RBS SA3 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 121 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SA4 UNPLANNED Loss of safety system annunciation or indication in the control room with EITHER (1) a SIGNIFICANT TRANSIENT in progress, or (2)compensatory indicators unavailable.
Operating Mode Applicability:
Power Operation Startup Hot Standby Hot Shutdown Example Emergency Action Level: Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. a. UNPLANNED loss of greater than approximately 75% of the following for 15 minutes or longer: " (Site specific control room safety system annunciation)
OR* (Site specific control room safety system indication)
: b. EITHER of the following: " A SIGNIFICANT TRANSIENT is in progress.* Compensatory indications are unavailable.
Attachment 1 Page 122 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SA6 UNPLANNED loss of safety system annunciation or indication in the Control Room with either (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable.
Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Hot Shutdown (Mode 3)Emergency Action Levels(s):
Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. a. UNPLANNED loss of > approximately 75% of the following for_> 15 minutes:* Control Room safety system annunciation OR* Control Room safety system indication AND b. Either of the following:
* A SIGNIFICANT TRANSIENT is in progress OR* Compensatory indications are unavailable Deviations:
None Differences:
NEI 99-01 SA4 is renumbered to RBS SA6 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 123 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SA6 (Cont'd)Differences (cont'd): RBS uses an "and" and an additional "or" in the EAL for clarity.RBS provides additional information in the bases to define those systems associated with safety system indication and the related Control Room panels.Attachment 1 Page 124 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SSI Loss of all Off-site and all On-Site AC power to emergency busses for 15 minutes or longer.Operating Mode Applicability:
Power Operation Startup Hot Standby Hot Shutdown Example Emergency Action Level: Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. Loss of all Off-Site and all On-Site AC power to (site specific emergency busses) for 15 minutes or longer.Attachment 1 Page 125 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SSI Loss of all offsite and all onsite AC power to emergency busses for> 15 minutes Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Hot Shutdown (Mode 3)Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. Loss.of all offsite and all onsite AC power to Div 1, 11 and III ENS busses for> 15 minutes Deviations:
None Differences:
RBS provides site specific information in the bases for preferred transformers.
RBS provides additional bases information for the condition where power to the bus may be restored, but necessary loads are not functional on the energized bus.Attachment 1 Page, 126 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SS2 Automatic Scram (Trip) fails to shutdown the reactor and manual actions taken from the reactor control console are not successful in shutting down the reactor.Operating Mode Applicability:
Power Operation Startup Example Emergency Action Level: 1. a. An automatic scram (trip) failed to shutdown the reactor.AND b. Manual actions taken at the reactor control console do not shutdown the reactor as indicated by (site specific indications of reactor not shutdown).
Attachment 1 Page 127 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SS3 Automatic scram fails to shutdown the reactor and manual actions taken from the reactor control console are not successful in shutting down the reactor Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Emergency Action Level(s): 1. a. An automatic scram failed to shutdown the reactor AND b. Manual actions taken at the reactor control console do not shutdown the reactor as indicated by reactor power > 5%Deviations:
None Differences:
NEI 99-01 SS2 is renumbered to RBS SS3 for formatting purposes based on site preference for order of ICs alone.RBS adds additional information to the bases regarding manual scram actions taken away from the reactor control console and not crediting these actions for a successful scram.Attachment 1 Page 128 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SS3 Loss of all vital DC power for 15 minutes or longer.Operating Mode Applicability:
Power Operation Startup Hot Standby Hot Shutdown Example Emergency Action Level: Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. Less than (site specific bus voltage indication) on all (site specific Vital DC busses) for 15 minutes or longer.Attachment 1 Page 129 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SS4 Loss of all vital DC power > 15 minutes Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Hot Standby (Mode 3)Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. < 105 VDC on all vital DC busses for > 15 minutes Deviations:
None Differences:
NEI 99-01 SS3 is renumbered to RBS SS4 for formatting purposes based on site preference for order of ICs alone.Attachment 1 Page 130 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SS6 Inability to Monitor a SIGNIFICANT TRANSIENT in Progress.Operating Mode Applicability:
Power Operation Startup Hot Standby Hot Shutdown Example Emergency Action Level: Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. a. Loss of greater than approximately 75% of the following for 15 minutes or longer:* (Site specific control room safety system annunciation)
OR" (Site specific control room safety system indication)
AND b. A SIGNIFICANT TRANSIENT is in progress.AND c. Compensatory indications are unavailable.
Attachment 1 Page 131 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SS6 Inability to monitor a SIGNIFICANT TRANSIENT in progress Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Hot Shutdown (Mode 3)Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. a. Loss of > approximately 75% of the following for_> 15 minutes: " Control Room safety system annunciation OR* Control Room safety system indication AND b. A SIGNIFICANT TRANSIENT is in progress AND c. Compensatory indications are unavailable Deviations:
None Differences:
RBS provides additional information in the bases to define those systems associated with safety system indication and the related Control Room panels.Attachment 1 Page 132 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SG1 Prolonged loss of all Off-site and all On-Site AC power to emergency busses.Operating Mode Applicability:
Power Operation Startup Hot Standby Hot Shutdown Example Emergency Action Level: 1. a. Loss of all off-site and all on-site AC power to (site specific emergency busses).AND b. EITHER of the following:
* Restoration of at least one emergency bus in less than (site specific hours) is not likely.* (Site specific indication of continuing degradation of core cooling based on Fission Product Barrier monitoring.)
Attachment 1 Page 133 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SGI Prolonged loss of all offsite and all onsite AC power to emergency busses Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Hot Shutdown (Mode 3)Emergency Action Level(s): 1. a. Loss of all offsite and all onsite AC power to Div 1, 11 and III ENS busses AND b. Either or the following:
* Restoration of at least one emergency bus in < 4 hours is not likely OR* RPV level can not be maintained
> -162 inches Deviations:
None Differences:
RBS uses an "or" in the EAL for clarity.RBS provides site specific information in the bases for preferred transformers.
Attachment 1 Page 134 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document NEI 99-01: SG2 Automatic Scram (Trip) and all manual actions fail to shutdown the reactor and indication of an extreme challenge to the ability to cool the core exists.Operating Mode Applicability:
Power Operation Startup Example Emergency Action Level: 1. a. An automatic scram (trip) failed to shutdown the reactor.AND b. All manual actions do not shutdown the reactor as indicated by (site specific indications of reactor not shutdown).
AND c. EITHER of the following exist or have occurred due to continued power generation:
* (Site specific indication that core cooling is extremely challenged.)
* (Site specific indication that heat removal is extremely challenged.)
Attachment 1 Page 135 of 136 RBS NEI Revision 5 EAL Deviation-Differences Document RBS: SG3 Automatic scram and all manual actions fail to shutdown the reactor and indication of an extreme challenge to the ability to cool the core exists Operating Mode Applicability:
Power Operation (Mode 1)Startup (Mode 2)Emergency Action Level(s): 1. a. An automatic scram failed to shutdown the reactor AND b. All manual actions do not shutdown the reactor as indicated by reactor power > 5%AND c. Either of the following exist or have occurred due to continued power generation:
* Core cooling is extremely challenged as indicated by RPV level can not be maintained
> -186 inches OR Heat removal is extremely challenged as indicated by RPV pressure and Suppression Pool temperature cannot be maintained in the EOP Heat Capacity Temperature Limit (HCTL) Safe Zone Deviations:
None'Differences:
SG2 is renumbered to RBS IC SG3 for formatting purposes based on site preference for order of ICs alone.RBS uses an "or" in the EAL for clarity.Attachment 1 Page 136 of 136 Attachment 2 To RBG-47165 Proposed Technical Basis Document (Markup)
ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT AUI Any release of gaseous or liquid radioactivity to the environment,>
2 times theODCM limit for > 60 minutes, -----------------------------------------------
~1~Operating Mode Applicability: ,Emergency Action .Leve!si: All Deleted: greater tlhan Deleted: Radiological Effluent Technical Specifications/
Deleted: or longer.Formatted:
Font: 11 pt, Underline Deleted: Example__.
(1 or 2 or 3,)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown.1. VALID reading on any of the, radiation monitors in Table R1 > ,he NOUE reading for>60 rhinute; edigorj OR, 2. VALID reading on RMS-RE107 effluent monitor ,2 times the alarm setpoint I established by a current radioactivity discharge permit for_ 60 minutes, ..OR *. -, 3. Confirmed sample analyses for gaseous or liquid releases indicate, concentrations or release rates ?2 times the ODCM limitior;>
60- minutes, ..........-..
Deleted: or 4 or 5......................................
.Primary Secondary 4GE125 3_06E+05 iCi/sn, c..Deleted: following" Deleted: greater than SDeleted:
shown\ ...........
.... ......... .. .........
...... ..... .t. d s ...h .o .. , w .............
n-,. ... .Formatted:
underline 4" Deleted: or longer: Deleted: (site specific monitor list and threshold values)Deleted: any effluent monitor" reading Deleted: greater than Deleted: or longer.. ...Formatted:
Underline Deleted: s Deleted: greater than Deleted: (site specific RETS values)Formatted:
underline Deleted: or longer.-----------
)Formatted:
French (France)1GE126 5.26E-03 .Ci/ml Fuel Building Vent Primary 4GE005 2.19E+04 iLCi/sec Secondary 5GE005 4.65E-03 &Ci/ml Radwaste Building Vent Primary 4GE006 2.58E+04 LtCi/sec Secondary 5GE006 6.84E-04 &Ci/ml Attachment 2 Page 1 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AU1 I i Formatted:
French (France)BPasis:s , a s s : ... .... ............ ... .. ......... .. ... ... ... .... ... .. ... .. ... .... ... .. .. .. ........ .. ... ... .........The Emergency Director should not wait until the applicable time has elapsed, but should declare the eventas soon as it is determined that the condition will likely exceed the applicable time.This IC addresses a potential reduction, in the level of safetyof the plant as indicated by-a radiological release that exceeds regulatory commitments for an extended period of time.RBS _incorporates features intended to control the release of radioactive effluents to the environment.
Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases (Offsite Dose Calculation Manual -ODCM),The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls.The ODCM, multiples are specified in AU1 and AA1 only to distinguish between non-emergency conditions, and from each other. While these multiples obviously correspond to an offsite dose or dose rate, the emphasis in classifying these events is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate.JReleases should.not be prorated or averaged over 60 minutes. For example, a release exceeding 4 X, the ODCM limit for 30 minutes doesnot meet the threshold for this IC, This Initiating Conditior includes any release for which a. radioactivity discharge.permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit.,"
=- 4"i"'vALi'o';
.....i.g.On ........Deleted: 4. VALID reading on perimeter radiation monitoring system reading greater than 0.10 mR/hr above normal* background for 60 minutes or longer. [for sites having telemetered perimeter monitors]
&#xb6;5. VALID indication on automatic real-time dose assessment capability indicating greater than (site specific value) for 60 minutes or longer. [for sites having such capability]
q 1 *Normal can be considered as the highest readingin the past twenty-i four hours excluding the current peak value. &#xb6;Deleted [Refer to Appendix A for a detailed basis of the radiological i effluent IC/EALs.]" Deleted: decrease Deleted: Nuclear power plants Deleted: [These controls are located in the Off-site Dose Calculation Manual (ODCM), and for plants that have not implemented Generic Letter 89-01, in the Radiological Effluent Technical Specifications (RETS).]Deleted: [Some sites may find it advantageous to address gaseous and liquid releases with separate i EALs.]Deleted: RETS Deleted: Formatted:
Font: (Default)
Arial, Not Italic Formatted:
Font: (Default)
Arial," I' Not talicFormatted:
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Anial, Not Italic U Formatted:
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Arial, N t Not Italic, Underline S Formatted:
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Arial( Deleted: I " Formatted:
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Arial,* Not Italic Deleted:I[ Normatted:ac Font: (Default)
Arial, Formatted:
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Arial, Ietalict EA Deleted: EAL Attachment 2 Page 2 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AUI EAL #1 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in the Initiating Condition, This EAL is intended for sites that have established effluent monitoring on non-routine release pathways for which a discharge permit would not normally be prepared.Any release on the routine effluent monitors in excess of the TRM limit is considered a non-routine release. Table R1 provides the monitors' EAL setpoint values. Values are e t C...........e..
!.Deleted:
IC. .. ...orovided for a nrimarv and secondary source for NOUE and Alert EAL determination.
The Division I safety related monitors (DRMS 4GE125 and 4GE005) are the preferred source for main plant exhaust and fuel building EAL determination.
Radwaste building preferred value is the effluent monitor (4GE006).
The secondary monitors in Table R1 should be used to determine EALs if the preferred monitors are inoperable, EAL #2 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in thisnitiatiqn Condition established by the radioactivity discharge permit. This value iassociated with a planned batch release,.AL #3.............................
This EAL addresses uncontrolled releases that are detected by sample analyses, particularly on unmonitored pathways, e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.
 
==References:==
 
T.R. 3.11 RSP-0008.
Offsite Dose Calculation Manual (ODCMt Deleted: [The ODCM establishes a methodology for determining effluent radiation monitor setpoints.
The ODCM specifies default source terms and, for gaseous releases, prescribes the use of pre-determined annual average meteorology in the most limiting downwind sector for showing compliance with the regulatory commitments.
This EAL should be determined using this methodology.]
Deleted: the ,Deleted:
may be,.Deleted:, or a continuous release path Deleted: [In either case, the value is established by the ODCM to warn of a release that is not in compliance with the RETS. Indexing the EAL to the ODCM setpoints in this manner insures that the EAL will never be less than the setpoint established by a specific discharge permit.]&#xb6;G.13.18.9.6*012 Rev 0, Effect of Core Uprate on the DRMS Process Safety Limit/ Conversion Factors / PR-C-495 Rev 2 p 4 ESK-RMS05 ESK-RMS25 1 Formatted:
Font: 11 pt, Font color: Auto (Deleted: EALs #4 and #5 1[The 0.10 mR/hr value in EAL #4, and the site specific value for EAL #5.is based on a release rate not exceeding 500 mrem per.year.
q[[As provided in the ODCM / RETS, prorated over 8766 hours, multiplied by two, and rounded. (500 -8766 x 2 0.114).] T EAL #1 and #2 directly correlate with the IC since annual average meteorology is required to be used in showing compliance with the ODCM i and is used in calculating the alarm setpoints.
EALs #4 and #5 are a function of actual meteorology, which will likely be different from the limiting annual average value. Thus, there will likely be a numerical inconsistency.
T]The underlying basis of this EAL involves the degradation in the level of safety of the plant implied by the uncontrolled release. Exceeding EAL#4 or #5 is an indication of an uncontrolled release Attachment 2 Page 3 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT UNPLANNED rise in plant radiation levels, AU2 Operating Mode Applicability: ,Ermergency Action Levelisl:
_ _All_(lAor 2)_ _1 a. -UNPLANNED water level drop in a reactor refuelingpathway as indicated by gany of the following;
* Water level droo in the reactor refuelinq cavity. spent fuel ool or fuel transfer canal indication on Control Room Panel 870." Personnel observation by visual or remote means...bA.N"b. UNP&#xfd;L7ANNED Vb~ALIDa-re-a a-d-iat-io-n-m-o-nit-or -al-a-rm, Lo-n a-nyof t-h-e 4--f1_RMS-RE140 RMS-RE141,.
_RMS-RE192.,RMS-RE193, OR 2. UNPLANNED VALID area radiation monitor readings or survey results indicate a rise-, by a factor of 1000 over normal* levels,_ NOTE: For area radiation monitors with ranqes incapable of measuring 1000 times normal* levels, classification shall be based on VALID full scale indications unless surveys confirm that area radiation levels are below 1000 times normal* within 15 minutes of the area radiation monitor indications going full scale.*Normal can be considered as the highest reading in the past twenty-four hours excluding the current peak value.Basis: This IC addresses elevated radiation levels as a result of a water level dro__above irradiated fuel or events that have resulted, or may result, in UNPLANNED Ets in radiation dose rates within plant buildings.
These radiation represent a loss of control over radioactive material and represent a potential degradation in the level of safety of the plant.'Deleted:-* Formatted:
Indent: Left: 0", Hanging: 0.63", Right: 0", No bullets or numbering, Widow/Orphan
\ control, Don't keep lines together I Deleted:-Formatted:
Font color: Black, Check spelling and grammar I, ... ..et.................................
'IDeleted: " Formatted:
Font color: Black, Check spelling and grammar Deleted: (site specific level or indication).
\ k ..............................
..._....... ___. ..........
.Formatted:
Font: 11 pt, Underline Formatted:
Space After: O pt Formatted:
Font: 11 pt, Underline Formatted:
Indent: Left: 0.38", Hanging: 0.25", Space After: 0 pt Deleted: reading rise-',\ ( ... ...... ...... ... ... ..-... .. '.'... ....... .......Deleted: (site specific list)F .F. .......ormatted:
Font:-Formatted:
Font: Arial, 11 pt Fomttd Fornt: Arial, 11 pt, Not 0 All caps Formatted:
Font: Arial, 11 pt Formatted:
Font: Arial, 11 pt, Not All caps Formatted:
Font: A=al, 11 pt Formatted:
Font: Arial, 11 pt, Not All caps Formatted:
Font: Bold, Underline Formatted:
Space After: 0 pt Deleted:.........
.... ...............
Formatted:
Font: Italic Deleted: increased Deleted: decreases Deleted: increas Deleted: increas_____
Attachment 2 Page 4 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AU2 EAL #1 The locations of the EAL specific area radiation monitors are: Containment RMS-RE140, North Refuelinq Floor RMS-RE141, South Refueling Floor Fuel Buildinq RMS-RE192, South Operating Floor RMS-RE193, North Operating Floor.Deleted: [Site specific indications may include instrumentation such as water level and local area radiation monitors, and personnel (e.g., refueling crew) reports. If available, video cameras may allow remote observation.
Depending on available level instrumentation, the declaration 1 threshold may need to be based on indications of water makeup rate or decrease in water storage tank level.]Deleted: &#xb6;[In light of Reactor Cavity Seal failure incidents at two different PWRs and loss of water in the Spent Fuel Pit/Fuel Transfer Canal at a BWR, explicit coverage of these types of i events via threshold
#1 is appropriate given their potential for increased 11 doses to plant staff]Deleted: I Deleted: n increase The refueling pathway is a site specific combination of cavities, tubes, canals and pools.While a radiation monitor could detect a rise in dose rate due to a drop in the water level, it might not be a reliable indication of whether or not the fuel is covered.for example, a refueling bridge ARM reading may increase due to planned evolutions such as head lift, or even a fuel assembly being raised in the manipulator mast. Also, a monitor could in fact be properly responding to a known event involving transfer or relocation of a source, stored in or near the fuel pool or responding to a planned evolution such as removal of the reactor head. Generally, increased radiation monitor indications will need to be combined with another indicator (or personnel report) of water loss&#xfd;Yt ... .. .. ... ... ... ... ... ... ..... ...... ....... ...... ........ ... ... ... ... ... ... .... ...... .........for refueling events where the water level drops below the RPV flange classification would be via CU2. This event escalates to an Alert per AA2 if irradiated fuel outside the reactor vessel is uncovered.
For events involving irradiated fuel in the reactor vessel, escalation would be via the Fission Product Barrier Matrixfor events in operating modes 1 ... -1. .... ... ... ... ... ... .... ... ... ..EAL #2 This EAL addresses Es in plant radiation levels that represent
*a los&#xfd; of control of radioactive material resulting in a potential degradation in the level of safety of the plant.This EAL excludes radiation level Ljgs that resu!t from planned activities such as use of radiographic sources and movement of radioactive waste materials.
A specific list of ARMs is not required as it would restrict the applicability of the Threshold.
The intent is to identify loss of control of radioactive material in any monitored area.i1.Deleted: ]Deleted: [Application of this EAL requires understanding of the actual radiological conditions present in the vicinity of the monitor. Information Notice No. 90-08, "KR-85 Hazards from Decayed Fuel" should be i considered in establishing radiation monitor EALs.]Deleted: &#xb6;, Deleted: Table D e. .... c r ea..........
....................
s.....................
...iDeleted:
4nra Deleted: increas ,
 
==References:==
 
Attachment 2[ --Formatted:
Font: Bold Page 5 of 121~1 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AA1 Initiating Condition
-ALERT Any release of gaseous or liquid radioactivity to the environment
?_.2OO times the PDCM limit for > 15 minute,---------------------------------------------
Operating Mode Applicability:
jEmergency Action Level!sl: All (1 or 2 or 3)P! Deleted.:
g~reater than 3M...........
........................
.... ........................
..............
Deleted: Radiological Effluent Technical Specifications/
Deleted: or longer.Formatted:
Font: 11 pt, Underline Deleted: Example Deleted: or4or5 Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown _1. VALID reading on any of theradiation monitors in Table R1 > the ALERT reading Itor>15 minutes O,,_ R R 'F. .. .. .. .. .. ... ... .... ... .. .. ... ... .. ... .. .... ..... ...... .. .. .. .. ... .... .. .. ... ... .. .. .. ... ..OR 2. For RMS-RE107 effluent monitor: EITHER VALID reading,>,2OO times.the.
.......................
.......................
alarm setpoint established by a current radioactivity discharge permit for> 15 minutes, OR Formatted:
Font: 11 pt, Italic IDeleted:
following Deleted: greater than\ ....................
.:= = = , = = =, .1&#xfd; ....=, ,,,= =,, =..... .. .............
,, ,\ 'Deleted:
shown (FormattedFont:
11 pt, Underline Deleted: or longer: ', Deleted: (site specific monitor list and threshold values)Formatted:
Indent: Left: 0", First line: 0.25", Space After: 0 pt Formatted:
Right: 0.08", Space After: O pt, No bullets or i numbering, Keep lines together, Don't allow hanging punctuation, Font Alignment:
Top, Tabs: 0.41", Left + 2.32", Left + 3.14", Left Formatted:
Indent: First line: 0.25", Right: 0.08", Space After: 0 pt, No bullets or numbering, Keep lines together, Don't allow hanging punctuation, Font Alignment:
Top, Tabs: 0.41", Left + 2.32", Left +3.14", Left d on any effluent monitor Deleted: reading greater than., \ 9 .........
..............................
.....................
.....................
Formatted:
Font: 11 pt, Underline Deleted: or longer.Formatted:
Indent: First line: 0" Deleted: s;.0 Deleted: greater than-.. .....I -...........
D Deleted: (site specific RETS values).Formatted:
Font: 11 pt, Underline Deleted: or longer.VALID reading > 1.27E-01 uCi/ml for > 15 minutes OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates --2.0 times the ODCM limitfor`>15 minutes, Attachment 2 Page 6 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AA1-I Formatted:
Space After: 0 pt I iviain tian! vent Primary St-cnnnd(rx 4GE125 3.06E+07 uCilsec 1GE126 2.82E-01 uCi/ml Fuel Building Vent Primary 4GE005 2.19E+06 ICi/sec Secondary 5GE005 2.82E-01 uCi/ml Radwaste Building Vent Primary 4GE006 2.58E+06 UCi/sec Secondary 5GE006 6.84E-02 tCi/mI Basis: ,The Em.egency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.This IC addresses an actual or substantial potential reduction in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. RBS incorporates features radioactive effluents to the environment.
Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases.The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls.Deleted: 4. VALID reading on perimeter radiation monitoring system reading greater than 10.0 mR/hr above normal* background for 15 minutes or longer. [for sites having telemetered perimeter monitors]
[5. VALID indication on automatic real-time dose assessment capability indicating greater than (site specific value) for 15 minutes or longer. [for sites having such capability]
&#xb6;Normal can be considered as the highest reading in the past twenty-four hours excluding the current peak value.Deleted: [Refer to Appendix A for a detailed basis of the radiological 4 effluent lc/EALs.]
[Deleted: decrease ,Deleted:
Nuclear power plants Deleted: [These controls are located in the Off-site Dose Calculation Manual (ODCM), and for plants that have not implemented Generic Letter 89-01, in the Radiological Effluent Technical Specifications, (RETS).] J Formatted:
Font: (Default)
Anal Attachment 2 Page 7 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AA1~Deleted:
[Some sites may find it advantageous to address gaseous and liquid releases with separate EALs.] j Deleted: RETS........................
.... .... .. ...... .. .....The ODCM m~ultiples are specified in AUl ancl AA only to distinguish between .emergency conditions, and from each other. While these multiples obviously correspond to an off-site dose or dose rate, the emphasis in classifying these events is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate.1 ' .............. .. ... ..... ... .. ... .. ... .... ... .. ... ...................................Releases should not be prorated or averaged.
For example, a release exceeding 600 times the ODCM limit for 5 minutes does not meet the threshold for this IC_This Initiating Condition, includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit.EAL #1 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in the Initiating Condition,, .......................................................
This EAL is intended for sites that have established effluent monitoring on non-routine release pathways for which a discharge permit would not normally be prepared.Any release on the routine effluent monitors in excess of the TRM limit is considered a non-routine release. Table R1 provides the monitors' EAL setpoint values. Values are provided for a primary and secondary source for NOUE and Alert EAL determination.
The Division I safety related monitors (DRMS 4GE 125 and 4GE005/ are the nreferred f Deleted;:
To ensure a realistic near-linear escalation path, a value should be selected roughly half-way between the AU1 value and the value calculated for AS1 value. The value will be based on radiation monitor i readings to exceed 200 times the Technical Specification limit and releases are not terminated within 15 minutes. The ODCM establishes a IF' methodology for determining effluent radiation monitor setpoints.
The ODCM specifies default source terms and, for gaseous releases, prescribes the use of pre-determined annual average meteorology in the most limiting downwind sector for showing compliance with the regulatory"i' commitments.
This EAL can be determined using this methodology if appropriate.]
Deleted: [
Underline Deleted: I Deleted: EAL JDel,1e~ted,:,, Deleted: IC Del..e ted: ..... .....Deleted: source for main plant exhaust and fuel building EAL determination.
Radwaste building preferred value is the effluent monitor (4GE006).
The secondary monitors in Table R1 should be used to determine EALs if the preferred monitors are inoperable.
Deleted: [The ODCM establishes a I methodology for determining effluent radiation monitor setpoints.
The ODCM specifies default source terms and, for gaseous releases, prescribes the use of pre-determined annual average meteorology in the most limiting downwind sector for showing I compliance with the regulatory commitments.
This EAL should be determined using this methodology.]
\ ..... ........... .... ..... ...... ..... ..... .... ...... ... ... .. .. .. .... .... ........ .......Attachment 2 Page 8 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AA1 EAL #2 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in thjInitiating Condition established by the radioactivity discharge permit. This value is. associated with a planned batch release.Historical release permits indicate that the Alert value of 200 times the radiation monitor setpoint established by the current permit may exceed the operating range of the RMS-RE107 effluent monitor in some instances.
This potentially affected monitor is listed in EAL #2 with a corresponding value for the top of its indicating Deleted: e Deleted: may be EAL #3 This EAL addresses uncontrolled releases that are detected by sample analyses, particularly on unmonitored pathways, e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.
 
==References:==
 
T.R. 3.11 RSP-0008, Offsite Dose Calculation Manual G.13.18.9.6*012 Rev 0, Effect of Core Uprate on the DRMS Process Safety Limit/ Conversion Factors / PR-C-495 Rev 2 p 4 ESK-RMS05 ESK-RMS25 Deleted: , or a continuous release path Deleted: [In either case, the value is established by the ODCM to wam of a release that is not in compliance with the RETS. Indexing the EAL to the ODCM selpoints in this manner........ ...........
-- ...........
.J Deleted. insures th never be less than the setpoint established by a specific discharge permit.]1 Deleted: EALs #4 and #5 T 1 The 10.0 mR/hr value in EAL #4 , and thesite specific value for EAL #5js based on a release rate not exceeding 500 mrem per year. I[As provided in the ODCM / RETS,'prorated over 8766 hours, multiplied by 200, and rounded. (500 + 8766 x 200 = 11. 4)]. 1 EAL #1 and #2 directly correlate with the IC since annual average meteorology is required to be used in showing compliance with the ODCM and is used in calculating the alarm setpoints.
EALs #4 and #5 are a function of actual meteorology, which will likely be different from the limiting annual average value. Thus, there will likely be a numerical inconsistency.
T The underlying basis of this EAL involves the degradation in the level of safety of the plant implied by the uncontrolled release. Exceeding EAL 4 #4 or #5 is an indication of an I Formatted:
Font: Arial, 11 pt j Attachment 2 Page 9 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Initiating Condition
-ALERT Damage to irradiated fuel or loss of water level that has resulted or will result in the uncovering of irradiated fuel outside the reactor vessel- -...........
AA2 Deleted:.-2 Operating Mode Applicability: ,Emergency Action Leveilsi: All J- or2)_IDeleted:
Example ....1. A water level drop in the reactor refueling cavity, spent fuel pool or fuel transfer canal that will result in irradiated fuel becoming uncovered.,iDeleted:.
OR 2. -A VALID readinglon any of the following radiation monitors due to damage to irradiated fuel or loss of water level,--Formatted:
Level 1, Space Before: 0 pt, After: 0 pt I Formatted:
Space After: 0 pt I.RMS-RE140 2000 mR/hr RMS-RE141 2000 mR/hr RMS-RE192 2000 mR/hr RMS-RE193 2000 mR/hr RMS-RE5A 1.64_E+03 UCi/sec RMS-RE5B (GE) 5.29E-04 LLCi/ml Deleted: alarm or Deleted: (site specific elevated reading)J..............
=.Deleted:.Deleted: (site specific radiation monitors)\ ,. .............. ... ........... .... .. .. ............. ..............
-Formatted:
Font: Arial, 11 pt I Formatted:
Font: Arial, 11 pt Basis: This IC addresses r__s in radiation dose rates within plant buildings, and may be a precursor to a radioactivity release to the environment.
These events represent a loss of control over radioactive material and represent an actual or substantial potential degradation in the level of safety of the plant..These events escalate from AU2 in that fuel activity has been released, or is anticipated_
due to fuel heatup. This IC applies to spent fuel requiring water coverage and is not intended to address sDent fuel which is licensed for dry storaae:.I Formatted:
Space After: 0 pt I The locations of the EAL specific area radiation monitors are: Containment RMS-RE140 North Refueling Floor RMS-RE141 South Refueling Floor Fuel Building RMS-RE192 South Operating Floor RMS-RE193 North Operating Floor Deleted: increas... ...... ......................................................................
-Deleted:]Formatted:
No underline Formatted:
Space After: 0 pt RMS-RE5A (B)Fuel Buildinq Ventilation Exhaust EAL #1 ,ndications may include instrumentation such as water level and local area radiation monitors, and personnel (e.g., refueling crew) reports. Depending on available level indication, the declaration may be based on indications of water makeup rate or Deleted: [---------J Attachment 2 Page 10 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AA2 decrease in Refuelinq Water Storage Fool level. Video cameras (Security or outage-related) may allow remote observation of level Deleted: ]%-\EAL #2 Deleted: [In light of Reactor Cavity Seal failure incidents at two different PWRs and loss of water in the Spent Fuel Pit/Fuel Transfer Canal at a BWR, explicit coverage of these types' of events via threshold
#1 is appropriate given their potential for ,increased doses to plant staff.]This EAL addresses radiation monitor indications of fuel uncovery and/or fuel damage. *, Eleqvad ventilation monitor readings may be an indication of a radioactivity release from the fuel, confirming that damage has occurred.
Elevated background at the ventilation monitor due to water level dr+/-Mj may mask eead ventilation exhaust airborne activity and needs to be considered.
While a radiation monitor could detect arse, in dose rate due to a drop in the water level, it might n be a reliable indication_
ofwhether ornjthe fuel is covered. .............
For example, a refueling bridge ARM reading may increase due to planned evolutions
, such as head lift, or even a fuel assembly being raised in the manipulator mast. Also, a monitor could in fact be properly responding to a known event involving transfer or relocation of a source, stored in or near the fuel pool or responding to a planned evolution such as removal of the reactor head. _Generally.
elevated radiation monitor indications will need to be combined with another indicator (or personnel report)of water loss.Y ... ... ......... .... ...... ..... ..... ..............
.... ... .........
... ... .. .... ... ............
... ... ..... ....... ... ... , .... ... .. ..... ...... ..... .... ...... ..... ..... ---... ... ... ... .. ... .,The Abnormal Operating Procedure (AOP) provides a table for guidance on pool level _ , and of potential scenarios and the expected pool level assuming no operator action. The AOP is also entered for UNPLANNED lowering of refueling cavity or lower fuel pool water level during refueling operations.
When control rod blades are stored in the Spent Fuel Pool, dose rate rise in the area may be attributed to the stored items instead of uncovered fuel assemblies.
Escalation of this emergency classification level, if appropriate, would be based on AS1 or AG1...Formatted:
Space After: 0 pt Formatted:
Space After: 0 pt Deleted: SpcreAf Deleted: Increas Deleted: Increas f~~~~~~~~~~~~~
~~~~~~ .... ...... ..... ............
..... ..............
Deleted: decrease SDeleted:
increas Deleted: n increase (Formatted:
Underline (Formatted:
Underline Deleted: Formatted:
Font: Bold Deleted:]Formatted:
Font: Bold Deleted: [Application of this EAL requires understanding of the actual radiological conditions present in the vicinity of the monitor. Information Notice No. 90-08, KR-85 Hazards from Decayed Fuel" should be\considered in establishing radiation monitor EALs.j Formatted:
Font: Arial, lipt i Formatted:
Space After: 0 pt
 
==References:==
 
TS Table 3.3.6.2-1 Calculation G13.18.9.4*10 Attachment 2 Page 11 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Initiating Condition
-ALERT AA3 Rise in radiation levels within the facility that impedes operation of systems required to maintain plant safety functions, i Deleted: Operating Mode Applicability:
All ,Emnergency_
Action Levelis):
Deleted: Example ----------------------------- ---------.. ............. ................ ..... ..........
.... .... ................
... .... ..... .. ..................
f-6.r eleted: (1 or .... --......-.-----.----
Dose rate >.15 m.R/hin yof the followirg areas requiring continuous occupancy to Deleted: co tr n maintain plant safety functions:
.e r Formatted:
Font: 11 pt, Not Bold Main Control Room CAS Deleted: (site specific area lIst)_ 1 Basis: This IC addresses elevated radiation levels that: impact continued operation in areas.requiring continuous occupancy to maintain safe operation or to perform a safe shutdown.The cause and/or magnitude of the rie in radiation levels isnpt a concern of this IC. The Emergency Director must consider the source or cause of the eleate radiation levels-and determine if any other IC may be involved.JThis IC is not meant to applv to increases in the containment dome radiation monitors as these are events which are addressed in the fission product barrier matrix EALs RP surveys should be performed in the CAS area if radiation above the program limit is detected outside the RCA. The Control Room area radiation monitor should be observed for EAL conditions if rising radiation levels are detected outside the RCA.The Main Control Room and CAS are the areas at RB, requiring continuous occupancy,
 
==References:==
 
' Deleted: increas Deleted: increas LF Fomatted:
Underline i Deleted: increas.............
=...=... ... === .....=,,=,... ..Deleted: [At multiple-unit sites, the EALs could result in declaration of an Alert at one unit due to a radioactivity release or radiation shine resulting from a major accident at the other unit. This is appropriate if the increase impairs operations at the[ operating unit.]&#xb6;Deleted: I Deleted:]Deleted: [The value of 15mR/hris derived from the GDC 19 value of 5 rem in 30 days with adjustment for!i expected occupancy times. Although Section Il/ D. 3 of NUREG-0 73 7,"Clarification of TMI Action Plan Requirements", provides that the 15 mR/hr value can be averaged over the 30 days, the value is used here 1 without averaging, as a 30 day duration implies an event potentially more significant than an Alert.]&#xb6;Deleted: Areas Deleted: include the control room Deleted: and, as appropriate to theany other control stations that I are staffed continuously, such as a;&#xfd;&#xfd; radwaste control room, or a Deleted: security alarm station.Deleted: [Typically these areas are i the Control Room and the Central Alarm Station (CAS).]Attachment 2 Page 12 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Initiating Condition
-- SITE AREA EMERGENCY AS1 Off&#xfd;site dose resulting from an actual or IMMINENT release of gaseous radioactivity>
1 00_rn&TEDE or 500 mrnglyroid CDE for the actual or projected duration of the release,-Deleted:
-Deleted: greater than Deleted rem Operating Mode Applicability: ,Emergency Action Level(sJ: All_.(1 or 2 or 3j)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. If dose assessment results are available, the classification should be based on EAL #2jnstead of EAL #1 Do not delay declaration awaiting dose assessment results,_....
: 1. VALID readlng on an_.v of the jadia~tio.n monitors in TaebleR1 >.the SITE AREA EMERGENCY readingfoqr.>
15 minutes .............................
-1 OR ,2. Dose ass essmrnent .u.sing..
actual. metreoroIog y indi~cates doses ..nTEDE 9r 500., mRthyroid.CDE at or beyond theSITE BOUNDARY, OR Deleted: rem Deleted:.7 Deleted: ExampleJ...........
..... ..... ...................
D Deleted: or 4 S Deleted: dealaation mntrvle Deleted: dose assessment ( .........
... .. ....... .............
...... ......I...... .... .. .1 Deleted: radiation mon&#xfd;tor vle fFormatted:
Font: 11 pt, Italic Formatted:
Font: 11 pt, Italic Deleted: following'~Deleted:
greater than... ........ ....................
.............
L-.4........
........ ... ...........
... ... .... ...........
De t d : g a e r h n " Deleted: shown Formatted:
Font: 11 pt, Underline Deleted: or longer: Deleted: I..~ ~~~~~~~ ~~~~ : .................
= .-.= ........,-.. -. = , = : .......Deleted: greater than'. :&#xfd;:4, i4:::.:.........................
&#xfd;.................
.. .......I.................
--.......................
......iDeleted:
rem Deleted: rem All caps Deleted:.o Deleted: 3. VALID perimeter d radiation monitoring system reading greater than 100 mRlhr for 15 i' minutes or longer. [for sites having telemetered perimeter monitors].i'!,!,Deleted:
4.Deleted: greater than SFormatted:
Font: 11 pt, Underline 1 Deleted: or longer I Deleted: greater than it. Deleted: rem Deleted:.Formatted:
All caps I Field survey results indicate closed window dose rates > 100 mRlhr expected to continue for > 60 minutes- or analyses of field survey samples indicate thyroid ODE >,00 mfor one hour of inhalation, at or beyond theSITE BOUNDARY __.Pimjnarv K;j ' 125 1i.70F' 1)07 i~i/tec SeCodaI N./A Fuel B~ni diln_ Ven Primrary 4G0 bOO 6.70E- 06 uC'i/scc Secondarv N,,, Radwasic lBuildinr:
Vctl NA Attachment 2 Page 13 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AS1 Basis: ,This IC addresses radioactivity.releases that result in -doses at or beyond the site .1 boundary that exceed 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.EAL #1 The,monitor list in EAL #1 includes monitors on all potential release pathways..
K Deleted: [Refer to Appendix A for a detailed basis of the radiological effluent IC/EALs.]
&#xb6;Deleted: [While these failures are addressed by other ICs, this IC provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone. It is important to note that for the more severe accidents the release may be unmonitored or there may be large uncertainties associated with the source term and/or meteorology.]
[[The EPA PAGs are expressed in terms of the sum of the effective dose Sequivalent (EDE) and the committed effective dose equivalent (CEDE), or as the thyroid committed dose equivalent (CDE). For the purpose of these IC/EALs, the dose quantity total effective dose equivalent (TEDE), as defined in 10 CFR 20, is used in lieu of"...sumofEDE andCEDE..."The EPA PAG guidance provides for the use adult thyroid dose conversion factors. However, some states have decided to calculate child thyroid CDE. Utility IC/EALs need to be consistent with those of the states involved in the facility's emergency planning zone.] [[The TEDE dose is set at 10% of the EPA PAG, while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.] [Deleted: site specific Deleted: should.=.. = ...........
..==. ...............
.... ....... .... .. ..... ...........
..Deleted: effluent'Deleted:
[The monitor reading EALs should be determined using a dose assessment method that back calculates from the dose values specified in the IC. Since doses are generally not monitored in real-time, it is suggested that a release duration of one hour be assumed, and that the EALs be based on a site specific boundary (or beyond) dose of 100 mrem whole body or 500 mrem thyroid in one hour, whichever is more limiting (as was done for EALs#2 and #4). If individual site analyses indicate a longer or shorter duration for the period in which the substantial portion of the activity is released, the longer duration should be used.] &#xb6;[The meteorology used should be the same as those used for determining AU1 and AA 1 monitor reading EALs.The same source term (noble gases, particulates, and halogens)
&#xb6;]Attachment 2 Page 14 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AS1 I Since dose assessment in EAL #2 is based on actual meteorology, whereas the monitor readings in EAL #1 ar not, the results from these assessments may indicate that the classification is not warranted, or may indicate that a higher classification is warranted.
For this reason, emergency implementing procedures should call for the timely performance of dose assessments using actual meteorology and release information.
If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor reading EALs.,References
'Deleted:
may also be used as long as it maintains a realistic and near linear escalation between the EALs for the four classifications.
If proper escalations do not result from the use of the same source term, if the calculated values are unrealistically high, or if correlation between the values and dose assessment values does not exist, then consider using an accident source term for ASI and AG1 calculations.]
j Formatted:
Font: 11 pt, Underline Deleted: is-Formatted:
Font: Bold Delet.ed: Attachment 2 Page 15 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Initiating Condition
-- GENERAL EMERGENCY AG1 Offsite dose resulting from an actual or IMMINENT release of gaseous radioactivity>
,1000 mgTEDE or 5000_mjthyroid cDE for the actual or projected -duration of the release using actual meteorology, Operating Mode Applicability: ,Emergency Action Leve!is): All (1 or 2 or 3,)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. If dose assessment results are available, the classification ,hould be based on EAL #2jnstead of EAL #1 Do not delay declaration awaiting dose assessment results.1. VALID reading on any of the~radiation monitors in Table R1 >the GENERAL EMERGENCY reading jqor_>15 minues E M E R G E N C Y ~~~~~ ~~ ~~~~ ~ ...in ..o .... .. .. ... i ..... e....... ....... ... .................
........................
i O R 2. Dose assessment using actual meteorology indicates doses >..1000 mBTEDE or..5000 mgthyroid CDE.at.orbeyond theSITE BOUNDARY, .......T .... .. .. ..... .. .. .. ..... .. .. .. ... .. .. .... ...... ..... ... ............
... ... ... ... ...... .... .. .... ...... ... ... .... ... ... ... .... ... ... ... -... .... ... ... .. ........ ...... .. .OR_I Field survey results indicate closed window dose rates > 1000 mR/hr expected to continue for >,60 minutes; or analyses of field survey sampl.es indicate-thyroid CDE>',5000 m.,for one hour of inhalation, at or beyond theSITE BOUNDARY,_......
It D eleted: -........ ..............
.... .... ... ...........
......................
.Deleted: greater than Deleted: rem Deleted: rem Deleted:.Deleted: Example........ _ ... =.....&deg;r ............
.... ..........................
Deleted: or 4 Deleted: declaratio Deleted: dose assessment
.........
I ...........
..............
................
........ ..iDeleted:
radiation monitor values Deleted: following Deleted: greater than iDeleted:
shown 2 , " ~ ~ t d .n..............................................
..Formatted:
Font: 11 pt, Underline , Deleted: or longer: 'iDeleted: (site specific monitor list and threshold values)Deleted: greater than3.................
.__........
..r e. h a .........
..................
....... ............
Deleted: rem.,,
~ ................
3 .,", Formatted:
All caps Deleted:.Deleted: 3..( ...............................................................................
................................
Deleted: VALID perimeter radiation monitoring system reading greater than 1000 mR/hr for 15 minutes or longer. [for sites having telemetered perimeter monitors]rmatted: Level 1, Indent: Hanging: 0.01" Deleted: 4 Deleted: greater than Formatted:
Font: 11 pt, Underline Deleted: or longer----- .................-
--............
............
Deleted: greater than.Deleted:
rem Deleted:.QFormatted:
All caps Primarv 4GEI25 4.70E-i-OS LCi/svc Secondary N/Fuel tgLuIdinu Vent t'rimarv 4(.EIOOS 6.70E;07 LICi.'see Secondairy N/A Radwvaste Building Venti N/ A Attachment 2 Page 16 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AG1 Basis: ,This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed the EPA Protective Action Guides (PAGs). Public protective actions will be necessary.
Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and likely involve fuel damage.EAL #1 The jnonitor list in EAL-#1 jnclude-,aonitors on all potential release pathways.1 Deleted: [Refer to Appendix A for a detailed basis of the radiological 1 effluent IC/EALs.]
&#xb6;Deleted: [While these failures are addressed by other ICs, this IC provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone. It is important to note that for the more severe accidents the release may be unmonitored or there may be large uncertainties associated with the source term and/or meteorology.][
[The EPA PAGs are expressed in terms of the sum of the effective dose equivalent (EDE) and the committed effective dose equivalent (CEDE), or as the thyroid committed dose equivalent (CDE). For the purpose of these IC/EALs, the dose quantity total effective dose equivalent (TEDE), as defined in 10 CFR 20, is used in lieu of'"...sum of EDE and CEDE..." The EPA PAG guidance provides for the use adult thyroid dose conversion factors. However, some states have decided to calculate child thyroid CDE. Utility IC/EALs need to be I consistent with those of the states 1 involved in the facilities emergency planning zone.] [[The TEDE dose is set at the EPA PAG, while the 5000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.]Deleted: should Deleted. effluent Deleted: [The monitor reading EALs should be determined using a dose assessment method that back calculates from the dose values specified in the IC. Since doses are generally not monitored in real-time, it is suggested that a release duration of one hour be assumed, and that the EALs be based on a site specific boundary (or beyond) dose of 1000 mrem whole body or 5000 mrem thyroid in one hour, whichever is more limiting (as was done for EALs#2 and #4). If individual site analyses indicate a longer or shorter duration for the period in which the substantial portion of the activity is released, the longer duration should be used.] &#xb6;[[The meteorology used should be the same as those used for determining AU1 and AA I monitor reading EALs.The same source term (noble gases, particulates, and halogens)&#xb6; may also be used as long as it maintains a realistic and near linear escalation between the EALs  Attachment 2 Page 17 of 121 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AGI Since dose assessment in EAL #2 is based on actual meteorology, whereas the monitor readings in EAL #1 re, not, the results from-these assessments may indicate that the classification is not warranted, For this reason, emergency implementing procedures should call for the timely performance of dose assessments using actual meteorology and release information.
If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor reading EALs.,
 
==References:==
 
--Formatted:
Font: 11 pt, Underline.' ...... .... ........ ...........
..." Deleted: is=, : :., : =: ::,= = .. ..........
.. ............
.: = = .. ..........
Deleted: or may indicate that a-- .higher classification is warr-Formatted:
Font: Bold Attachment 2 Page 18 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION Initiating Condition
-- NOTIFICATION OF UNUSUAL EVENT RCS leakage,................
CU1 A Deleted:.Deleted: Example Operating Mode Applicability: ,Emergency, Action Level(s.:.
Mode 4 ....... Cold Shutdown Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. RCS leakage results in the inability to maintain or restore RPV level > +9.7 inches (Lve 3 for> >.15 minutes,.Qaesis ............. u. .. .... ........... ...... .... ... ... ..... .. .. .... .... ........ ... ...... ..........,B as-is: ------- --------This IC is considered to be a potential degradation of the level of safety of the plant. The inability to maintain or restore level is indicative of loss of RCS inventory.
Relief valve normal operation should be excluded from this IC. However, a relief valve that operates and fails to close per design should be considered applicable to this IC if the relief valve cannot be isolated.Prolonged loss of RCS Inventory may result in escalation to the Alert emergency classification level via either CA1 or CA2.Deleted: greater than Deleted: (site specific low level RPS , actuation setpoint)FradUnderline I Deleted: or longer [BWR]*~~~~~~~~~~~
.==,= .........
.......= == ; ...= =.. .... .........Deleted: 1. RCS leakage results in the inability to maintain or restore level within (site specific pressurizer or RCS/RPV level target band) for 15_minutes or longer. [PWR] &#xb6;Deleted: 4 i (~~~~~~~~~~~~~~~
~~~~~~~. ........................................
...........
..... ...............
'r Deleted: [The difference between Cui and CU2 deals with the RCS conditions that exist between cold shutdown and refueling modes. In the refueling mode the RCS is not intact and RPV level and inventory are monitored by different means. In cold shutdown the RCS will normally be intact and standard RCS inventory and level monitoring means are available.]
1: Deleted: &#xb6;Formatted:
Font: Bold.Rferences:
Attachment 2 Page 19 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION Initiating Condition
-- NOTIFICATION OF UNUSUAL EVENT UNPLANNED loss of RCS/RPV inventory, CU2 Deleted:.-Deleted: Example Operating Mode Applicability:
JEmergency Action Levelisj: Mode 5 ...... Refueling (1 or 2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.Deleted:..RP
..RV ...............
....1. UNPLANNED RCS, level drop as indicated by either .of the. followin-g:.
..............................
: a. RCS, water level drop below the RPV flange for> _15 minutesjwhen the RCS, level band is established above the RPV flange OR b. RCSwater level drop below the _PV level band for?>_15 minutes when the RCS, level band is established below the RPV flange,----------------------
OR 2. RCS, level. cannot be mornitored .with a loss of RCS, inventory as indicated by an.unexplained ,rise in floor or equipment sump level, Suppression Pool level, vessel.make-up rate or observation of leakage or inventory loss, Basis: This IC is a precursor of more serious conditions and considered to be a potential degradation of the level of safety of the plant.Refueling evolutions that lower RCS water level below the RPV flange are carefully planned and procedurally controlled.
An UNPLANNED event that results in water level lowenrng be!o.w the RPV flange, or below the planned RCS water level for the given evolution (if the planned RCS water level is already below the RPV flange), warrants declaration of a NOUE due to the reduced RCS inventory that is available to keep the core covered.The allowance of 15 minutes was chosen because it is reasonable to assume that level can be restored within this time frame using one or more of the redundant means of makeuo that should be available.
If level cannot be restored in this time frame then it may indicate a more serious condition exists.Continued loss of RCS Inventory will result in escalation to the Alert emergency classification level via either CA1 or CAI,...... I S, " oDeleted:
orBlonger Deleted: /RPV SFormatted:
Indent: Left: 0.25", ,* C Hanging: 0.38" Formatted:
Bullets and Numbering.7 '' Deleted: IRPV Formatted:
Underline.eFormatted:
Indent: Left: 0.25"' Formatted:
Indent: Left: 0.38", 0 Hanging: 0.25" Deleted: /RPV Deleted: RCSlv Formatted:
underline.,'\".Deleted:
ort loneir sup o Deleted: IRPV Deleted: FFormatted:
Level 1, Indent: Hanmging:
0.01" Deleted: IRPV Deleted: IRPV 0,-eee:level ,Deleted: (site specific sump o a t D~el~e~ted.:
d~ecre~a.se.........
Deleted: decreas-Deleted: refill~Deleted:
4 Attachment 2 Page 20 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CU2 CU 2. ...........................
................-
..............
I Deleted- [The difference between I CU1 and CU2 deals with the RCS conditions that exist between cold I shutdown and refueling modes. In EAL #1 cold shutdown the RCS will normally be intact and standard RCS inventory____tha cotines or~ and le vel monitoring means are This EAL involves a droa in RCS level below the top of the.RPV flange that continues for- aalev nitring me e"...1.---
....... ...I .. 1. 11..- ..\ iavailable.
In the refueling mode the 15 minutes due to an UNPLANNED event. This EAL is not applicable to reductions'in T RCS is not intact and RPV level and flooded reactor cavity level, which is addressed by AU2 EAL1, until such time as the .entor are monitored by di ferent level drops to the level of the vessel-flange.
.means].Deleted: If RPV level continues to droagand reaches the -Low-Low ECCS Actuation Sietpoint then ,Formatted:
Left escalation to CA1 would be appropriate.
De I.'D eleted: decrease EAL #2 This EAL addresses conditions in the refueling mode when normal means of core temperature indication and RCS level indication may not be available.
Redundant means of RPV level indication will normally be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted.
However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RPV inventory loss was occurring by observing sump and tank level changes. Sump and tank level risg must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.Escalation to the Alert emergency classification level would be via either CA1 or CAI,._
 
==References:==
 
......................................................" ....: ............
....... .... .... ......... .........Deleted: decreases.Deleted: decreases 1 Deleted: [ForBWRs]
_Deleted: decrease 3 Deleted: [For PWRs] If RPV level continues to decrease and reaches the Bottom ID of the RCS Loop then escalation to CA1 would be appropriate.
Deleted: increases[Formatted:
Font: Bold .Attachment 2 Page 21 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION Initiating Condition
-- NOTIFICATION OF UNUSUAL EVENT CU_!&#xfd;I-Deleted:
3 Formatted:
Underline Deleted: or longer AC power capability to emergency busses reduced to a single power source for > 15 minutes uch that any additional single failure would result in station blackout __- -1.Operating Mode Applicability: ,E-mergency Action Leve!s): Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling i Deleted:.Deleted: Example.-2% J Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. a. AC power capability to Div I and Div II ENS~busses
..reduced to a single power Formatted:
Indent: Left: 0", source _for _>_15 _ Hanging: 0.5", Numbered + Level: 1________+
Numbering Style: 1, 2, 3, ... +Start at: 1 + Alignment:
Left +AND-- "" Aligned at: 0" + Tab after: 0" +Indent at: 0", Tabs: 0.25", Left b. Any additional single power source failure will result in station blackout Deleted: (site specific emergency''Deleted:)
0 .........
........ .... ....Basis:I Ba :Formatted:
Underline 4 K Deleted: or longer.Preferred station transformers are: 1RTX-XSR1C, 1RTX-XSR1D, 1RTX-XSRIE and \;' "'_ _-...1 RTX-XSRl.F.
' ] Formatted:
Underline Formatted:
Level 1, Indent: The condition indicated by this IC is the degradation of the offsite and or0)site AC power , Hanging: 0.83" systems such that any additional single failure would result in a station blackout.
This , Formatted:
Space After: 0 pt condition could occur due to a loss of offsite power with a concurrent failure of all but. .'i' Deleted: ..one emergency generator to supply power to its emergency busses. Another related .'" Formatted:
Level 1, Space After: 0 condition could be the loss of onsite emergency diesels generators with only one train of ' pt emergency busses being fed from offsite power (or backfed from offsite power through ' Formatted:
Space After: 0 pt the main transformer).
The subsequent loss of this single power source would escalate Formatted:
Spa the event to an Alert in accordance with CA_5 Foemted:,-
S Fahee, Deleted: -Fifteen minutes was selected as a threshold to exclude transient or momentary losses of* Delte:, power. , Deleted: -Deleted: 3 Div Ill DIG and bus E22-S004 are not discussed explicitly in this IC. The loss of Div I and '-\ Formatted:
Space After: 0 pt Div II are considered a station blackout.
If Div IIl DIG or E22-S004 is available, entry into 'rDelted:
pat mutiut s t th sDeleted:
[At multi-unit stations, t this IC ishn applilcable.~t
~rt~~r he
 
==References:==
 
of installed design features, such as cross-ties or swing diesels, provided that abnormal or emergency operating procedures address their use. However, these stations must also consider the impact of this condition on other shared safety functions in developing the site specific EAL.] I[Plants that have a proceduralized capability to cross-tie AC power from an off-site power supply of a companion unit may take credit for the redundant power source in the associated EAL for this IC.]Attachment 2 Page 22 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION Initiating Condition
-- NOTIFICATION OF UNUSUAL EVENT UNPLANNED loss of decay heat removal capability with irradiated fuel in the RPV, CU I{Deleted:
4 Deleted:.Operating Mode Applicability:
gEmergency Action Leve!fsl: Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling*(1 or 2)Deleted: Example Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. UNPLANNED event results in RCS temperature exceeding 200 OR 2. Loss of all RCS temperature and RCS/RPV level indication for>,> 15 minutes.Basis: This IC isa precursor of more serious conditions and, as a result, is considered to be a potential degradation of the level of safety of the plant. In cold shutdown the ability to remove decay heat relies primarily on forced cooling flow. Operation of the systems that provide this forced cooling may be jeopardized due to the unlikely loss of electrical power or RCS inventory.
Since the RCS usually remains intact in the cold shutdown mode a large inventory of water is available to keep the core covered.Puring refueling the level in the RPV will normally be maintained above the RPV flange.Refueling evolutions that lower water level below the RPV flange are carefully -and procedurally controlled.
Loss of forced decay heat removal at reduced inventory may result in more rapid risesiR.CS/R.PV temperatures depending on the time since shutdown.Nprmal means of core temperature indication and RCS level indication may not be available in the refueling mode. Redundant means of RPV level indication are therefore procedurally installed to assure that the ability to monitor level will not be interrupted.
However, if all level and temperature indication were to be lost in either the cold shutdown of refueling modes, EAL 2 would result in Deleted: the Technical Specification cold shutdown temperature limit I Formatted:
Numbered + Level: +Numbering Style: 1, 2, 3, ... + Start at: 1 + Alignment:
Left + Aligned at: 0" + Tab after: 0" + Indent at: 0" Formatted:
Underline Deleted: or longer Deleted: be Deleted: [Entry into cold shutdown conditions may be attained within hours of operating at power. Entry into the refueling mode procedurally may not occur for typically 100 hours (site specific) or longer after the reactor has been shutdown.
Thus the heatup threat and therefore the threat to damaging the fuel clad may be lower for events that occur in the refueling mode with irradiated fuel in the RPV (note that the heatup threat could be lower for cold shutdown conditions if the entry into cold shutdown was following a refueling).
i In addition, the operators should be able to monitor RCS temperature and RPV level so that escalation to the 1 alert level via CA4 or CAI will occur if required.]&#xb6; Deleted: decrease Deleted: increases Deleted: [Unlike the cold shutdown mode,] n .....___Attachment 2 Page 23 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION
,' Deleted: 4 !C U _3 ... , &#xfd; -' --------.......
.. .*.. ......... ...... -declaration of a NOUE if both temperature and level indication cannot be restored within 15 minutes from the loss of both means of indication.
Escalation to Alert would be via CA1 based on an inventory loss or CAI based on .Deleted:
4 exceeding its temperature criteria
 
==References:==
 
Formatted:
Font: Bold Attachment 2 Page 24 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION Initiating Condition
-- NOTIFICATION OF UNUSUAL EVENT Loss of all -Wisite or qfl~ite communications capabilities'.
CUgD,.....IT Operating Mode Applicability: ,Emergency Action Level, s: Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling Mode D ...... Defueled Deleted: 6 Deleted: 0 Deleted: 0 Deleted:-........ ...................
.... ..........
....... ..................
..., .....................................
I .................................
.............................
.....Deleted:." Deleted: Example Deleted: -Deleted:.... .... ... .... ... .... ... .... .... ... .... ... .... ... .... .... ... .... ... .... ... .... .... ... .... .........d Deleted: (site specific list of communications methods) 3 (1 or2)1. Loss of all of the following onsite communication methods affecting the ability to perform routine operations:
Plant radio system Plant paging system Sound powered phones In-plant telephones OR 2. Loss of all of the following offsite communication methods affecting the ability to perform offsite notifications:
All telephones NRC phones State of Louisiana Radio Offsite notification system and hotline S :.........
iDeleted:
-I Basis: The purpose of this IC and its associated EALs is to recognize a loss of communications capability that either defeats the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate issues with offsite authorities.
The loss of offsite communications a-bility is expected to be significantly more comprehensive than the condition addressed by 10 CFR 50.72.The availability of one method of ordinary offsite co'nmmuni cations is -ssufficient to -inform federal, state, and local authorities of plant issues. This EAL is intended to be used only when extraordinary means (e.g., relaying of information from radio transmissions, individuals being sent to offsite .locations, etc.).are being.uti!ized to make communications possible.,
 
==References:==
 
Deleted: (site specific list of communications methods)&#xb6;,,......................
..I.Formatted:
Indent: Left: 0.25", Hanging: 0.63".Deleted: -Deleted:-..... .. ..... ......................................................................-I-i --.---------.-.-.-
---.-.........
.......... ... ... .........
.... ..ee e .. .Deleted: -.Deleted: [Site specific list for on-site communications loss must encompass the loss of all means of routine communications (e.g., commercial telephones, sound powered phone systems, page panty system and radios / walkie talkies).
&#xb6;T Site specific list for off-site communications loss must encompass the loss of all means of communications with off-site authorities.
This should include the ENS, commercial telephone lines, telecopy transmissions, and dedicated phone systems.]Formatted:
Font: Not Italic Attachment 2 Page 25 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION Initiating Condition
-- NOTIFICATION OF UNUSUAL EVENT Loss of required DC power for > 15 minutes.1 Deleted: 7.1 CUA'Operating Mode Applicability: ,Emergency Action Level(s): Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling Formatted:
Underline~Del ete d o r long er Deleted: Example Note: The-Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. < 105 VDC.on. required V.ital DC USSJeor >,15 minutes Basis: The purpose of this IC and its associated EAL,, is to recognize a loss of DC power compromising the ability to monitor and control the removal of decay heat during Cold Shutdown or Refueling operations.
jt is intended that the loss of the operating (operable) train is to be considered.
If this loss results in the inability to maintain cold shutdown, the escalation to an Alert will be p e r C A ................,Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.
 
==References:==
 
'ii I e Deleted: Less than (site specific bus voltage indication)
Deleted: (site specific Vital DC De e ......ed........:."iDeleted; Formatted:
Underline SDeleted:
or longer.Deleted: s Deleted: [This EAL is intended to be anticipatory in as much as the operating crew may not have 1 necessary indication and control of equipment needed to respond to the loss.]&#xb6;2 [Plants will routinely perform maintenance on a Train related basis during shutdown periods The required busses are the minimum allowed by Technical Specifications for the mode of operation.]
...................
.... .. ..............
.. .... ....... ........ .Deleted: 4 Deleted: [(Site specific) bus voltage should be based on the minimum bus voltage necessary for the operation of safety related equipment.
This voltage value should incorporate a margin of at least 15 minutes of operation before the onset of inability to operate those loads. This voltage is usually near the minimum voltage selected when battery sizing is performed.
Typically the value for the entire battery set is approximately 105 VDC. For a 60 cell string of batteries the cell voltage is typically 1 75 Volts per cell. For a 58 string battery set the minimum voltage is Stypically 1.81 Volts per cell .[l&#xb6;{Formatted:
Space After: 0 pt (Formatted:
Font: Bold Attachment 2 Page 26 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION Initiating Condition
-- NOTIFICATION OF UNUSUAL EVENT Inadvertent criticality,.........
CUL.I Deleted: 8 Deleted:.Operating Mode Applicability:
Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling Deleted: Example ,Emergency Action Levelisl: 1. UNPLANNED sustained positive period observed on nuclear instrumentation, Basis: This IC addresses criticality events that occur in Cold Shutdown or Refueling modes ,such as fuelmis-loading events, This IC indicates a potential degradation of thte level of.safety of the plant, warranting a NOUE classification..This condition can be identified using period monitors.
The term "sustained" is used in order to allow exclusion of expected short term positive periods from planned fuel bundle or control rod movements during core alteration.
These short term positive periods are the result of the rise in neutron population due to subcritical multiplication Deleted:. (BWR)..J Deleted: 1. UNPLANNED sustained positive startup rate observed on nuclear instrumentation.
Deleted: (PWR) ]Deleted: [(NUREG 1449, Shutdown and Low-Power Operation at i Commercial Nuclear Power Plants in the United States)]Deleted: and inadvertent dilution events Deleted: Deleted:]Formatted:
Font: Bold Escalation would be by Emergency Director Judgment..
 
==References:==
 
----Attachment 2 Page 27 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CA1 Initiating Condition
-ALERT Loss of RCS/RPV inventory, Deleted:.Operating Mode Applicability:
Mode 4 ....... Cold Shutdown Mode 5 ....... Refueling ,Emergency Action L.evelsj:
(1. or..2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. UNPLANNEDjoss of RCSinventory as indicated by RPV level < -43 inches (Level 2'i O R 2. _RCS,level cannot be monitored for> 15 minutes with a loss of RCS. inventory as indicated by an unexplained fise in floor or eguipment sump level, Suppression Pool1 level, vessel make-up rate or observation of leakage or inventory los,.Basis: These EALs are not applicable when the RPV is defueled an, serve as precursors-to a loss of ability to adequately cool the fuel. The magnitude of this loss of water indicates that makeup systems have not been effective and may not be capable of preventing further RPV level lowerinq and potential core uncovery.
This condition will result in a minimum emergency classification level of an Alert.EAL #1 ,The inability to restore and maintain level after reaching this setpoint would be indicative..
of a failure of the RCS barrier. .Deleted: Example* Deleted: L Deleted. IRPV Deleted: less than (site specific il-e~vel).
Formatted:
Indent: Left: 0", S.Hanging:
0.25" Deleted: [Low-Low ECCS actuation setpoint/Level 2 (BWR)] %j. [Bottom ID of the RCS loop (PWR)], orQmt:n Hanging: 0.79" Deleted:/RPV" Formatted:
Underline" Deleted: or longer Deleted: /RPV I .............................................................
....................., .ee e d..D el eted. l.. evel ..............................................
..... .Deleted: (site specific sump or tank)"" Deleted: These EALs Deleted: decrease Deleted: [The BWR Low-Low ECCS Actuation Setpoint/Level 2 was chosen because it is a standard setpoint at which some available injection systems automatically start.The PWR Bottom ID of the RCS Loop Setpoint was chosen because at this level remote RCS level indication may be lost and loss of suction to decay heat removal systems has occurred.The Bottom ID of the RCS Loop Setpoint should be the level equal to the bottom of the RPV loop penetration (not the low point of the loop).. ] ............
...... .. .........Attachment 2 Page 28 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CA1 EAL #2 In the cold shutdown mode, normal RCS level and RPV level instrumentation systems will usually be available.
In the refueling mode, normal means of RPV level indication may not be available.
Redundant means of reactor vessel level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted.
However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RPV inventory loss Deleted: was occurring by observing sump and tank level changes. Sump and tank level rise must be evaluated against other potential sources of Jeakage such as cooling water sources inside the containment to ensure they are indicative of RCS if RPV level continues to lower then escalation to Site Area Emergency will be via CS1.,
 
==References:==
 
-- Formatted:
Font color: Auto Deleted:]4 Formatted:
Font color: Auto Deleted: [The 15-minute duration for the loss of level indication was chosen because it is half of the CS1 Site Area Emergency EAL duration.Significant fuel damage is not expected to occur until the core has been uncovered for greater than I hour per the analysis referenced in the CGI basis. Therefore this EAL meets the definition for an Alert.]If Formatted:
Font: Bold Attachment 2 Page 29 of 121 COLD SHUTDOWN/IREFUELING SYSTEM MALFUNCTION Initiating Condition
-ALERT Loss of all ,ff,fsite and all opfjte AC power to emergency busses for > 15 _Minutes, CA5 Del et e d 3 Deleted: 0.Deleted:-Deleted: 0 Deleted: -Deleted: S KDeleted:
or longer.Formatted:
Underline
]Deleted: Example. .Operating Mode Applicability:
Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling Mode D ...... Defueled Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1.~ ~ ~ ~ ~~g Loso l t)eadal _-jte AC pjower to Div I & Div 11 ENS pussesfor
> 5 ___________
m in u tes , ... ... ...t .r.d .!.! ..-. ... ..wr.t ... .. -... ... E N ... u s... .. .. s... .. ..r ... 1_5_ .. ... .. .D e lete d : O .........................................
m tDeleted:
S B asis: , De.... ......Deleted: 0 Preferred station transformers are: 1RTX-XSRIC.
1RTX-XSRID, 1RTX-XSRIE and I'Deleted:S 1 RTX-XSR1 F. Deleted: P.........
....X ..F ..L' ' .. .....t ... .P.... ..........
...................
..........
.. I....... .........
.. I....... .......I ,o Deleted: (site spec~ific emergency
'Loss of all AC power to Div I & Div II compromises all plant safety systems requiring Deleted: e electric power including RHR, ECCS, Containment Heat Removal, Spent Fuel Heat .D .........e.e...Removal and the Ultimate Heat Sink. Formatted:
Underline Deleted: or longer. ..The event can be classified as an Alert when in cold shutdown, refueling, or defueled mode because of the significantly reduced decay heat and lower temperature and pressure, raisingithe time to restore one of-the-enmergency busses., relative to.that ............
Deleted: increasingl specified for the Site Area Emergency EAL.Consideration should be given to operable loads necessary to remove decay heat or provide Reactor Vessel makeup capability when evaluating loss of AC power to emergency busses. Even though an emergency bus may be re-energized, if necessary loads (i.e., loads that if lost would inhibit decay heat removal capability or Reactor Vessel makeup capability) are not functional on the energized bus, then the bus should not be considered restored for this EAL.Escalating to Site Area Emergency, if appropriate, is by Abnormal Rad Levels /Radiological Effluent lCs.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Deleted: [The companion-Formatted:
Font: Bold_
 
==References:==
 
Attachment 2 Page 30 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION Deleted: 4..... .....CA~j.Initiating Condition
-ALERT Inability to maintain plant in cold shutdown, Deleted:.I Operating Mode Applicability:
_Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling gmergency Action, Level(s): (1 or..2)1. An UNPLANNED event results in RCS temperature &deg;For >the specified d u ra tio n in T a b le , ..................................................
OR 2. An UNPLANNED event results in RCS pressure i>e,.10 psig due to R.S..c o o lin g , ." I ..... ... .. ...... ... ........ ... ...Table C2: RCS Reheat Duration Thresholds RCS Containment Closure Duration Intact, ...... .... N/A. .60 minutes, Not intact, Established 20 minutes-Not Established 0 minutes*If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then the EAL is not applicable.
Basis: EAL #1 The RCS Reheat Duration Threshold table addresses complete loss of functi.ons required for core cooling for greater than 60 minutes during refueling and cold shutdown modes when RCS integrity is established.
RCS integrity should be considered to be in place when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams). The 60 minute time frame should allow sufficient time to restore cooling without there being a substantial degradation in plant safety.The RCS Reheat Duration Threshold table also addresses the complete loss of functions required for core cooling for greater than 20 minutes during refueling and cold shutdown modes when CONTAINMENT CLOSURE is established but RCS integrity is not established,.
As discussed above, RCS integrity should be assumed to be in place when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams)Thealowed_20 minute.time frame was included to allow operator action to restore the heat removal function, if possible, Finally, the EAL addresses complete loss of functions required for core cooling during refueling and cold shutdown modes when neither CONTAINMENT CLOSURE nor RCS integrity are established Deleted: Example i Deleted: greater than (site specific Deleted: Technical Specification cold shutdown temperature.limit), .Deleted: for greater than z/ ====,====
.... .. .. .... ... ..... ............ .Deleted: o Deleted: t-Formatted:
Space After: 0 pt Formatted:
Indent: Left: 0", Numbered + Level: 1 + Numbering Style: 1, 2, 3, ... + Start at: 2 +Alignment:
Left + Aligned at: 0.25"+ Tab after: 0.5" + Indent at: 0.5", Tabs: 0.25", List tab + Not at 0.5" i Deleted: increase Deleted: greater than Deleted:. (PWR-This EAL does not\ , apply in Solid Plant conditions.)
.~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ..... .== = ...............
.: :...::; :: = =: = ::= = :=,= =Deleted: (but not RCS Reduced Inventory
[PWR])Deleted: or RCS Reduced Inventory L(PWR)'Deleted:
For EAL 1, t ,_Deleted:
..Deleted: The status of CONTAINMENT CLOSURE in this condition is immaterial given that the RCS is providing a high pressure barrier to fission product release to the environment.], 41 rmatted: Font: (Default)
Arial" eleted: or RCS inventory is reduced [(e.g., mid-loop operation in PWRs Deleted: ].A Formatted:
Font: (Default)
Arial, 11'1/ Deleted: " Deleted: ]Deleted: .[The allowed time frame is consistent with the guidance.provided by Generic Letter 88-17,"Loss of Decay Heat Removal" (discussed later in this basis) and is believed to be conservative given that a low pressure Containment barrier to fission product release is .... 2 Deleted: Finally, complete Bos 3 fFormatted:
Font color: Black Attachment 2 Page 31 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CA23 The,(*) indicates that this EAL is not applicable if actions are successful in restoring an RCS heat removal system to operation and RCS temperature is being reduced within the specified time frame.EAL #2 TDe 10 psig pressureise addresses situations where, due to high decay heat loads, the time provided to restore temperature control, should be less than 60 minutes. The RCS pressure setpoint chosen should be 10 psi or the lowest pressure that the site can read on installed Control Board instrumentation that is equal to or greater than 10 psig.Escalation to Site Area Emergency would be via CS1 should boiling result in significant RPV level loss leading to core uncovery.1 Deleted: 4 Deleted: note Deleted: In EAL 2, Deleted: increase Aloss of Technical Specification components alone is not intended to constitute an Aler.r: The same is true of a momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available.
The Emergency Director must remain alert to events or conditions that lead to the conclusion that exceeding the EAL is IMMINENT.
If, in the judgment of the Emergency Director, an IMMINENT situation is at hand, the classification should be made as if the threshold has been exceeded Deleted: [For PWRs, this IC and its associated EALs are based on concerns raised by Generic Letter 88-17, "Loss of Decay Heat Removal. "A number of phenomena such as pressurization, vortexing, steam generator U-tube draining, RCS level differences when operating at a mid-loop condition, decay heat removal system design, and level instrumentation problems can lead to conditions where decay heat removal is lost and core uncovery can occur.NRC analyses show that there are sequences that can cause core uncovery in 15 to 20 minutes and i severe core damage within an hour after decay heat removal is lost.] J Formatted:
Font: Bold..
 
==References:==
 
-I Attachment 2 Page 32 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CS1 Initiating Condition
-SITE AREA EMERGENCY Deleted:.Loss of RCS/RPV inventory affecting core decay heat removal capability, I Operating Mode Applicability: ,Emergency Action Levels): Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling (. ( or..2 or 3)"iDe lete d: E xa mplie t Deleted: RCS/*~~~~~~~ ~~~ ............
.=:= =: , .-,- ...... .............
=..,....Deleted: less than (site specific level).Note: The Emergency Director should not wait until the applicable time has elapsed, bu should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. With CONTAINMENT CLOSURE not established,,RPV level < -49 inches ........-OR 2. With CONTAINMENT CLOSURE established,,RPV level < -162 inches (TAF.OR 3. RCS. level canno *.t be monitored for> 30 minutesyith a, loss of RC$, inventory as .........indicated by .anv.pf the following:
* RMS-RE16 reading > 100 R/hr,* Erratic Source Range Monitor Ordicatio,..........
* Unexplained jise in floor or equipment sump level, Suppression Pool level.vessel make-up rate or observation of leakage or inventory loss, ...........
Basis: These EALs are not applicable when the RPV is defueled.Under the conditions specified by this IC, continued reduction in RPSN!evel.
is indicative of a loss of inventory control. Inventory loss may be due to an RCS breach, pressure boundary leakage, or continued boiling in the RPV. Thus, declaration of a Site Area Emergency is warranted.
Escalation to a General Emergency is via CG1 or AGI.t 1 -Formatted:
Underline I Deleted: [6V below the bottom ID of the RCS loop (PWR)1 V[6" below the low-low ECCS actuation setpoint (BWR)] &#xb6;.(Formatted:
Underline Formatted:
Level 1, Indent:{ Hanging: 0.5".Deleted:
RCS/.......
Deleted: level less than (site specific Formatted .Underline 0 "Formatted:
Level 1' Deleted: /RPV SFormatted:
Underline Deleted: or longer Deleted:/RPV il Formatted:
Font: Not Bold Deleted: ANY Formatted:
Indent: Left: 0.25", Bulleted + Level: 1 + Aligned at: 0.75" + Tab after: 1" + Indent at: 1", Tabs: 0.5", List tab + Not at 0.75" Deleted: (Site specific radiation monitor) reading greater than (site specific value).Formatted:
Indent: Hanging: 0.5", Bulleted + Level: 1 + Aligned at: 0&#xfd; 5" +Tab after: 0.75" + Indent at: 07 7 Ts: 0 .5", List tab + Not at 0 .75 " SDeleted:
I Deleted:.Deleted: level t Deleted: (site specific sump or tank).Deleted: decrease D ......................................
/ --V.....................
SDeleted:
/RPV Attachment 2 Page 33 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CS1 In the cold shutdown mode, normal RCS level and RPV level instrumentation systems will usually be available.
In the refueling mode, normal means of RPV level indication may not be available.
Redundant means of RPV level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted.
However, if all level indication were to be lost durinq a loss of RCS inventory event, the operators would need to determine that RPV inventory loss was occurring by observing sump and tank level changes. Sump and tank level rise.must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage. .The 30-minute duration allows sufficient time for actions to be performed to recover inventory control equipment.
I ..........................
.........
........j Deleted: EAL #1 q[6" below the bottom ID of the RCS Loop should be the level equal to 6" below the bottom of the RPV loop penetration (not the low point of the loop). PWRs unable to measure this level should choose the first observable point below the bottom ID of the loop as the EAL value. If a water level instrument is not available such that the PWR EAL value cannot be determined, then EAL 3 should be used to determine if the IC has been met.]Deleted: [Since BWRs have RCS penetrations below the EAL value, continued level decrease may be indicative of pressure boundary leakage.]
[Deleted: Formatted:
Font: Not Italic Formatted:
Font: Not Italic Deleted:]As water level in the RPV lowers, the dose rate above the core will rise,. The dose rate due to this core shine should result in site specific monitor indication and possible alarm.
 
==References:==
,COP-105Q NEDC-33045P Calculation G 13.18.9.4-047 Rev. 0 Deleted: increase Deleted: [This EAL should conservatively estimate a site specific dose rate setpoint indicative of core-i uncovery (i.e., level at TOAF). For BWRs that do not have installed radiation monitors capable of indicating core uncovery, alternate site specific level indications of core uncovery should be used.] &#xb6;[Post-TMI studies indicated that the installed nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations.]
Formatted:
Font: Bold I Formatted:
Font: Not Bold Deleted: &#xb6;Attachment 2 Page 34 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CGI Initiating Condition
-GENERAL EMERGENCY Loss of RCS/RPV inventory affecting fuel clad integrity with containment challenged, Deleted:.Deleted: Example Deleted: RCS/i Deleted: less than (site specific leve for TOAF)&#xfd;. ..........
z.. II ,,I H n Operating Mode Applicability:
Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling ,Emergency Action Level(s).
(1 or 2) Deleted: or longer.Note: The Emergency Director should not wait until the applicable time has elapsed, but !Formatted:Underline should declare the event as soon as it is determined that the condition will likely exceed Formatted:
Leve 1, Indent: Left: 0. .25", Hanging: 0.25", Tabs: 0.25", the applicable time. U"," Left 1. a. RPV level < -162 inches (TAF) jor> 30 minutes ,bs: Not at 0.5"/, Formatted:
Font: Not Bold AND ~Deleted:)(se
-------------------I / .. ...............
..............................
.........................
..A N D ',' ....
...........
.........
.................
.1 b. Any containment challenge indication in Table Cl OR 2. a. RCS, level cannot be monitored with core uncovery indicated by.any of the following for_30 minutes_Formatted:
Level 1, Indent: F Hanging: 1", Tabs: Not at 0.5" S.Formaed:
Indent: Left: 0", Hanging: 0.25", No bulletsor numbering, Tabs: Not at 0.25"
+I RMS-RE16 reading > 100 R/hr,* Erratic Spurce._R nge l. onitor indication
-------------------------
* Unexplained'ise in floor or eguipment sump level, Suppression Pool level, vessel make-up rate or observation of leakage or inventory loss, AND b. An containment challenge indicationin Table C1 F Formatted:
Font: Not Bold Formatted:
Underline'i Deleted: or longer.Formatted:
Indent: Left: 0.5", , .Bulleted + Level: 1 + Aligned at: 0.63" + Tab after: 0.88" + Indent at: 0.88", Tabs: Not at 0.88" iDeleted: (Site specific radiation monitor) reading greater than (site spcfcsetpoint).
Deleted: a W.Deleted:r Deleted: m I , Formatted:
Bulleted + Level: 1 +1.0 Aligned at: 0.5" + Tab after: 0.75"\ + Indent at: 0.75" i Deleted: UNPLANNED level Deleted: (site specific sump or tank).U' Deleted: [Other site specific ZF.7 Formatted:
Indent: Left: 0.5" Formatted:
Bullets and Numbering 1 Formatted:
Underlineormatted r .ri Formatted:
Font: Not Bold Deleted: (see Deleted:):
Attachment 2 Page 35 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CG1 S 0 0 0 UUN I AlINMlztN I
no_ esiaoiisne.
gxplosive mixtureinside containment-,....
UNPLANNED rise in containment pressure.Secondary containment area radiation monitor above EOP Max Safe Oneratino Value below: j Deleted: .Deleted: (Site specific Deleted:)Deleted:.All caps I Area DRMS Max Safe Operating Value Grid 2 RHR Equip 1213 9.5E+03 mRlhr Rm A RHR Equip 1214 9.5E+03 mR/hr Rm B RHR Equip 1215 9.5E+03 mR/hr Rm CC Deleted:.f Deleted: (site specific value) [BWR only]Deleted: [These EALs are based on concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal, SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues, NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States, and, NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.]
q Basis: These EALs are not applicable when the RPV is defueled.This IC represents the inability to restore and maintain RPV level to above the top of active fuel with containment challenged.
Fuel damage is probable if RPV level cannot be restored, as available decay heat will cause boiling, further reducing the RPV level. With the CONTAINMENT breached or challenged then the potential for unmonitored fission product release to the environment is high. This represents a direct path for radioactive inventory to be released to the environment.
This is consistent with the definition of a GE. The GE is declared on the occurrence of the loss or IMMINENT loss of function of all three barriers.,A number of variables can have a significant impact on heat removal capability
-challenging the fuel clad barrier. Examples inciude&#xfd; initial vessel level.ands hutdown 'hea[ t", removal system design....v a s y s te ... .. .. ..s.i....g n .... .. ... ... ... .. .... ... ....... .. ...... ... ... .... ... ...... ... ... ... ... .. ..../Analysis indicates that core damage may occur within an hour following continued core uncovery therefore, 30 minutes was conservatively chosen. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30 minute core uncovery time limit then escalation to GE would not occur.In of m mnrm inmvnvrv it ik jnlikp.Iv that hvdrnrien hiiildiin dtip/ to a 'Formatted:
Space After: 12 pt Deleted: : [BWRs]Deleted: Deleted: [PWRs] mid-loop, reduced level/flange level, head in place, cavity flooded, RCS venting strategy, decay heat removal system design, vortexing pre-disposition, steam generator u-tube draining J J{ Formatted:
Bullets and Numbering i Deleted: [Site shutdown contingency plans typically provide for re-establishing CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory functions.]
il Formatted:
Font: Not Ita j Deleted: I Deleted: [For BWRs, the use of secondary containment radiation monitors should provide indication of/ increased release that may be indicative of a challenge to secondary containment.
The site specific radiation monitor values should be based on the EOP "maximum safe values" because these values are easily recognizable and have an emergency basis.] I core uncovery could result in an explosive mixture of dissolved gasses in Containment.
However, Containment monitoring and/or sampling should be performed to verify this assumption and a General Emergency declared if it is determined that an explosive mixture exists..Attachment 2 Page 36 of 121 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CGI Sump and tank level rise must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.In the cold shutdown mode, normal RCS level and RPV level instrumentation systems will usually be available.
In the refueling mode, normal means of RPV level indication may not be available.
Redundant means of RPV level indication will usually be installed.. Deleted: increases (includingq the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted.
However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RPV inventory loss was occurring by observing sump and tank level changes. Sump and tank level rise_-must be evaluated against other potential sources of leakage such as cooling water Deleted: Formatted:
Font: Not Italic Formatted:
Font: Not Italic D eDeleted:
i'&#xfd;Dele~ted:
increase sources inside the containment to ensure they are indicative of RCS leakage, As water level in the RPV lowers, the dose rate above the core will rise. The dose rate due to this core shine should result in site specific monitor indication and possible alarm.
 
==References:==
 
_COP-1050
..NEDC-33045P' Calculation G13.18.9.4-047 Rev. 0 0 SDeleted:
[This EAL should conservatively estimate a site specific dose rate setpoint indicative of core I uncovery (ie., level at TOAF). For i BWRs that do not have installed radiation monitors capable of indicating core uncovery, alternate site specific level indications of core uncovery should be used.) &#xb6;[Post-TMI studies indicated that the installed nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations.]
'TFormatted:
Font: Bold t Formatted:
Font: Not Bold Attachment 2 Page 37 of 121 ISFSI MALFUNCTION E-HU1 Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Damage to a loaded cask CONFINEMENT BOUNDARY Operating Mode Applicability:
All, jEmergency Action Levels:................
-, Deleted: Not applicable
..: Deleted: Example 1. Damage to a loaded cask CONFINEMENT BOUNDARY.Basis: A NOUE in this IC is categorized on the basis of the occurrence of an event of sufficient magnitude that a loaded cask CONFINEMENT BOUNDARY is damaged or violated.This includes classification based on a loaded fuel storage cask CONFINEMENT BOUNDARY loss leading to the degradation of the fuel during storage or posing an operational safety problem with respect to its removal from storage.JThis EAL addresses a dropped cask, a tipped over cask, EXPLOSION, PROJECTILE-damage, FIRE damage or natural phenomena affecting a cask (e.g., seismic event, tornado, etc.).Deleted: [The results of the ISFSI i Safety Analysis Report (SAR) per NUREG 1536 or SAR referenced in the cask(s) Certificate of Compliance and the related NRC Safety Evaluation Report identify natural phenomena events and accident conditions that could potentially effect the CONFINEMENT BOUNDARY]
J Attachment 2 Page 38 of 121 FISSION PRODUCT BARRIER DEGRADATION General Bases D ee ............................ .NOT...iDeleted:
NOTES....... J The logic used for these initiating conditions reflects the following considerations:
: 1. The Fuel Clad a@rrier and the RCS _prrier are weighted m.ore .heavily than.the Containment barrier, NOUE ICs associated with RCS and Fuel Clad brriers are ..addressed under System Malfunction SajICs. t 2. At the Site Area Emergency level, there must be some ability to dynamically assess how far present conditions are from the threshold for a General Emergency.
For example, if Fuel Clad and RCS t.h.at, in addcition to .off site dose assessments, would require continual assessments of radioactive inventory and containment integrity.
Alternatively, if both Fuel Clad and RCS _rrier "Potential-I Loss" EALs existed, the Emergency Director would have more assurance that there was no immediate need to escalate to a General Emergency.
: 3. The ability to escalate to higher emergency classes as an event deteriorates must be maintained.
For example, RCS leakage steadily increasing would represent an increasing risk to public health and safety.4. The Containment ,prrier should not beldec.!a.re.lost or potentially lost..based n......exceeding Technical Specification action statement criteria, unless there is an event in progress requiring mitigation by the Containment barrier. When no event is in progress (Loss or Potential Loss of either Fuel Clad and/or RCS) the Containment bprrier status is addressed by Technical Specifi.ca9tions...
........................
Deleted: B...Deleted: B Deleted: B Deleted: (See Sections 3.4 and 3.8)1 Deleted: B i Deleted: B Deleted: B S........................................................................................................................
: k. ..-........ .. ..........
.................
.)Deleted: B... ... ....Deleted: B.Attachment 2 Page 39 of 121 FISSION PRODUCT BARRIER DEGRADATION , ission Product Barrier-Table-
------------------------------------
EAL for LOSS or POTENTIAL LOSS of Barriers**Determine which combination of the three barriers are lost or have a potential loss and use the following key to classify the event.Also, multiple events could occur which result in the conclusion that exceeding the loss or potential loss EALS is IMMINENT.
In this IMMINENT loss situation use judgment and classify as if the EALs are exceeded.*1 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT NOUIF&#xfd;Loss of ANY two barriers AND Loss of or Potential Loss of ANY Loss or ANY Potential ANY Loss or ANY Potential Loss or Potential Loss of third ANY two barriers.
Loss of EITHER Fuel Clad or Loss of Containment.
barrier. RCS.Fue CadBarir FC EURCS Barrier (RC) EA s I Containmrent Barrier (PCI EAl~s LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS 1. Primary Coolant Activity Level (FC1) 1. DrVwel Pressure (RCII) 1. Primary Containment Conditions (PC1), CCpolant N N-ne.-- -P-C oa nt v t y > ... .. .........
........................................
....... DNw ep, p .o n .s u .............
... ....... ..........
.... ........ .....................
..... ..........
...... .........
.........................
..............................
activity > 1. ...pre ssu re............
T- > .................................
1.68 pressure >300 pCi/qm dose psid with indications equivalent 1-131 of reactor coolant 15 .. ...leak in the drywell 1. Rapid unexplained
..... ...............
loss of PC pressure following initial and rising pressure rise _OR __.OR---------
response not .consistent with LOCA conditions,.
2.a.PC hydrogen in the unsafe zone of Deleted: Table 5-F-2: BWREL 3 LDeleted:
Threshold
_, Deleted: threshold.. .threshol 6 Del.eted UNUSUAL EVENT*Forated....tted ... r", (Formatted Formatted
.7. [1 Formatted ril-Formatted C -(Formatted 4.131> '(Formatted
: r. [141 Formatted r.... ... 151.4 Deleted: Primary Containment i ,Delte -A.. Primary c../...De.eted:-..
.. .. ......." Deleted: A. Primary containC J Deleted: greater than...AppliFr 91 IDeleted__.._
Applicable F.-.[0-]-.tDeleted:
pressure rise .......Deleted' (site specific value)., Deleted: greater than' Deleted: by a rapid unexplained Deleted: drop in primary...
gr(=2=2' Deleted: containment I Deleted: specific , Deleted; (site specific val [t. Deleted: value)C{\ Formatted
([25]](Formatted r26...[",. ,Deleted.
BExplosive Deleted: B.. rimary contain-Deleted: ment... .inside ... r28]1 Dltdpimary Deleted containment Deleted: ._Attachment 2 Page 40 of 121 FISSION PRODUCT BARRIER DEGRADATION gfission Product Barrier Table E tqfop r tLOSS or POTENTIAL LOSS of Barriers*------------------------------
*Determine which combination of the three barriers are lost or have a.potential loss and use the followina key to classify the event.Deleted: Table 5-F-2: BWR EAL i Deleted: Threshold.Deleted:
threshold.. .thresho fI Also, multiple events could occur which result in the conclusion that exceeding the loss or potential loss ALs .is..IMMNENT[....In._t!is
...I....n...
.IMMINENT loss situation use judgment and classify as if the EAts are exceeded.GENERAL EMERGENCY SITE AREA EMERGENCY ALERT NOUE Loss of ANY two barriers AND Loss of or Potential Loss of ANY Loss or ANY Potential ANY Loss or ANY Potential
-," Loss or Potential Loss of third ANY two barriers.
Loss of EITHER Fuel Clad or Loss of Containment.
barrier. RCS.....Fuel Clad Barrier .FC F .-... RCS Barrier RC. .EA.. Conta..ime.nt Barrier P..EA.Ls.LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS T T HDOL curve_____________
: b. DW hydrogen concentration
> 9%_OR I RPV pressure..
and suppression pool temperature cannot be maintained below the HCTL--Formatted
... 40 Deleted: C 2. Reactor Vessel Water Level LFC2) 2. Reactor Vessel Water Level LRC2) 2. Reactor Vessel Water Level C2 *',RPV water level JPV water level RPV water level Non?, ....{..............................
None cannot be restored cannot be restored cannot be restored and maintained and maintained and maintained above, above, above&#xfd; Entry into PC f Deleted:.Formatted 4.1Deleted A....A. [1 I Deleted A. ..Not [43]..leedNot Applicable...PrJ
/ .t Deleted: Applicable I Deleted: containment S-(Deleted:
flooding required.J Deleted: (site specific... (sit..4 Deleted- (site specific Attachment 2 Page 41 of 121 FISSION PRODUCT BARRIER DEGRADATION ,Fission Product Barrier Table --EALA for LOSS or POTENTIAL LOSS of Barriers**Determine which combination of the three barriers are lost or have a potential loss and use the following key to classify the event.Also, multiple events could occur which result in the conclusion that exceeding the loss or potential loss EALs is IMMINENT.
In this IMMINENT loss situation use judgment and classify as if the EALs are exceeded.GENERAL EMERGENCY SITE AREA EMERGENCY ALERT NOUE .Loss of ANY two barriers AND Loss of or Potential Loss of ANY Loss or ANY Potential ANY Loss or ANY Potential
, Loss or Potential Loss of third ANY two barriers.
Loss of EITHER Fuel Clad or Loss of Containment.
barrier. RCS.Fuel Clad Barrier (EF i ,A.1. 1. RCS Barrier Containment Barrier PC EAfs LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS flo o d in g ................................................
procedures
-162 inches or -162 inches SAP-1 and SAP-2.............
.......................
.. .o r c a n b e.em .- .........
...............
-186 inches cannot be .or can not b determined.
determined, I Primary Containment Radiation
-3. RCS Leak Rate (RC3) P3. rimary Contaip.me.nt
..Isola.ti.o......
Monitor~s(FC3)
Failure or Bypass (PC3),Rpntainment Nong 1 RCS 1, a. Failure of all valves None radiation monitor ....leakage in any one line RMS-RE16 UNISOLABLE main > ..............
to clos .reading, steam-line break as 50 gprn AND.. ... ........ ... .. ... ...... ...... .. ... ..>3,000 R/hr indicated by the inside the b. Direct downstream 3 0 0 R h ...... .............
...... ...... ... ....... ..... .. ..... ... ... ... ...... -n-c a t...b. .. ..in s id e .th e ...... --.... ...ec d w s t e r ... ...... ...... ...... ... ........ ...failure of both MSIVs drywel ...........
pathway tothe th in any one line to environment exists after close OR_AND, 2UNISO- isolation signal, High MSL flow LABLE, .. ... O annunciator R -S-_ ..1ntentional-PC
---------------------
;&#xfd;(P601-19A-A2)
AND leakage---------
g .p. ...E........ADlaaeventing per EOPs Deleted: Table 5-F-2: BWR EAL .* L .e e.. ~ed!.T~ r e~h&deg;.... .! ... .............
.. ......i Deleted: Threshold ,.I Deleted: threshold
...thresho77&#xfd; Formatted t Deleted: UNUSUAL EVENT[Formatted F[481" '. Formatted L 49;, {Formatted
... [501590;"- -( Formatted
[51]-Formatted t{Formatted
... r521 Formatted
..... 54{Formatted r 5]4 Deleted: RPV water level...&#xb6;E 7 Del_!&#xfd;eted:
corresponding[58" Deleted: the top of active fuel)-(Deleted:
primary containme
[Deleted: flooding).
'.Deleted:.
-..Deleted. :. .." Deleted: 3. Not Applicable
_ Deleted: Not Applicable
[Deeed....In
&#xfd;.rl IDeleted:
A.... Primary c... Nc{[2 I Deleted: A. (site specific Deleted: A FDelete A.. .Not' Deleted: Applicable LDeleted:
Indicationofn ,Deleted:
Applicable
"' Deleted: greater...(Deleted:
greater than.,Delete-than
[Formatted
[65], .Deleted: (site specific value).(l: Deleted".ele primary containment-1 01 Formatted 66 S1". -, ...... ...............................
..............
.......................
..............
Formatted
... [67]Formatted F7 r&deg;e Attachment 2 Page 42 of 121 I' ............
FISSION PRODUCT BARRIER DEGRADATION Fission Product Barrier Table ...EALs for LOSS or POTENTIAL LOSS of Barriers*
..................
..........
*Determine which combination of the three barriers are lost or have a potential loss and use the following key to classify the event.Also, multiple events could occur which result in the conclusion that exceeding the loss or potential loss EALp is IMMINE.NET.
In this IMMINENT loss situation use iudament and classify as if the EALs are exceeded.GENERAL EMERGENCY SITE AREA EMERGENCY ALERT NOUFE..............
&#xfd;" Loss of ANY two barriers AND Loss of or Potential Loss of ANY Loss or ANY Potential ANY Loss or ANY Potential
, Loss or Potential Loss of third ANY two barriers.
Loss of EITHER Fuel Clad or Loss of Containment., barrier. RCS.LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS Main Steam Tunnel outside PC or SAPs Temperature>
OR 1440F [173&deg;F NRC TS subm ittal as indicated
..U N ....A B .E.changel by exceeding ,RCS leakage OR..............
either of the outside Pg.b. Indication of following:- ,as indicated.
an UNISOLABLE
_Max Normal -- -by exceeding either-of
--- ---HPC, Feedwater,__
Operating the following:
RWCU or RCIC Temperature
: a. Max Safe break (Table F2) Operating_OR ..............
OR, Temperature.
.Emergency
.b.Max Normal (Tab F-1)RP*~pressuri--
Areab.WaSfeAa zation is required, Radiatior
.b. Max SafeArea (Table F2) .Rad.ationR.
.(Table Fl)-4. Dr~weIlRadiatioRjRC4)
-- 4. Primary Containment Radiation Monitors. (PC4)1&#xfd;w e l ra ia io m o i o , ..........................
.... ...... ..... ...... ...........................
.............
n a m e t..... ...... ..R.......-..E 20.. ................
..... I .... ..............
...... a i t~ ~ ~ o~Drywell radiation monitor~ pntai *nment V RMS-RE20 radiation monitor'Deleted: Table 5-F-2: BWR EAL Deleted: Threshold ,. -----------
--. ......o. ......Deleted: threshold
..._thresho.
j Formatted
.721 Deleted: UNUSUAL EVENT Formatted
.. 73 ,'g Formatted
.. 74.-Formatted r77]SFormatted
>1 Formatted*Formatted
...........
Formatted
[814[Formatted I Formatted Deleted: primary Deleted: containment Deleted: C... primary [831 (Deleted:
system" Deleted: primary Formatted p41' Deleted: containment
\: j Formatted
[851 I Formatted
[861)I Formatted
[871)Deleted: 1 I Formatted 88 Deleted: I (Deleted:.
Formatted F..89 Deleted: B ... 2.Deleted: 0 Deleted:....
.. Deleted:.Deleted: 5. Other Site Spe 2 I Deleted- ing"'\1 Deleted: A. (site specific) Formatted
[94 IDeleted:
A. Primary Attachment 2 Page 43 of 121 FISSION PRODUCT BARRIER DEGRADATION ,Fission Product Barrier Table ---------EALs for LOSS or POTENTIAL LOSS of Barriers*.Deleted: Table 5-F-2: BWR EAL !....eleted: ..Thresh d ...................
*Determine which combination of the three barriers are lost or have a potential loss and use the following key to classify the event.Also, multiple events could occur which result in the conclusion that exceeding the loss or potential loss EAL_ is IMMINENT.
In this IMMINENT loss situation use iudciment and classify as if the EALs are exceeded.GENERAL EMERGENCY SITE AREA EMERGENCY ALERT NOUE.........
Loss of ANY two barriers AND Loss of or Potential Loss of ANY Loss or ANY Potential ANY Loss or ANY Potential Loss or Potential Loss of third ANY two barriers.
Loss of EITHER Fuel Clad or Loss of Containment.
barrier. RCS.Fuel CldRBarrier (FCS EALs RCS Barrier (RC EALs i Containment Barrier E'ALs LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS reading, .... ...........
.. RMS-RE1 6> 100 R/hr reading due to reactor coolant 1> 10 000 leakage R/hr.An Emergency Director Judgment (FC4) I-, .............
... ........ .........Any condition in Any condition in the opinion of the the opinion of the Emergency Director Emergency Director that indicates loss that indicates o f th e F u e l C la d -p te n ti a lI .........
.... -: : i L : : : : : : : -: : .: : : : : : ofte Fueof the Fuel Clad b~arn er,_, Emergency Director Judgment ..Emergeinrcy Director Judg.ment________________________BC51 LEC51 Any condition in Any condition in Any condition in Any condition in the opinion of the the opinion of the opinion of the the opinion of Emergency Director the Emergency Emergency Director the Emergency that indicates joss Director that indicates loss Director .of the RCS prri.erri..that indicates I of the Primary that indicates_ptential loss Containment
_ptential loss 4 Deleted: threshold...thresho 97 Formatted[Deleted:
UNUSUAL EVENT.- .. Formatted
...ii Formatted 100 Formatted
... 101 Formatted 102 Formatted
.... [101 Formatted 104'(Formatted 1051 Formatted
.106""Deleted:
greater than........ ( D% =;=t~~h~a~n.................
.. ...D~eleted:
than Deleted: (site.. =:=.................
.... ......................
= = : = ==,= = = = = = ."*Deleted:
specific' Deleted: value).~~D l t ................
[1.......1.
"\'[Formatted..10 Deleted: A. (site specific) a.Deleted: L Deleted: P ...L Deleted: B ....1 Deleted: B....( Deleted 6- ... .113 De -leted:L (Deleted:
L Delete ..[11 D~eleted : P.L ... L 1161 Attachment 2 Page 44 of 121 FISSION PRODUCT BARRIER DEGRADATION ,Fission Product Barrier Table .........EA6__for LOSS or POTENTIAL LOSS of Barriers**Deleted:
Table 5-F-2: BWR EAL"I D le ed Threshold*Determine which combination of the three barriers are lost or have a potential loss and use the following key to classify the event.Also, multiple events could occur which result in the conclusion that exceeding the loss or potential loss AL's is IMMINE-N.T....
In this-IMMINENT loss situation use jud ment and classify as if the EAs are exceeded.GENERAL EMERGENCY SITE AREA EMERGENCY ALERT NOUF Loss or Potential Loss of third ANY two barriers.
Loss of EITHER Fuel Clad or Loss of Containment.
barrier. RCS. __uel C B r EAL LS LORS i REALs L Conainment Barrier IPC ALs LOSPOTENTIAL LOSS_ LOSS POTENTIAL LOSS I LOSS POTENTIAL LOS-S-.Deleted: threshold...
threshCj-3jjl
--Formatted f Deleted: UNUSUAL EVENT'Formatted:
ILeft~'Formatted:Lf 1\01Formatted:
Left Formatted:
Left CLFormatted:
Left Formatted Formatted Formatted 11 of the RCS .rrier, of the Primary!~mrier Contain-m e nt barr ie r i:1 Formatted I*Deleted:.
Deleted: B.... Fl1 Deetd B....... ...... u Attachment 2 Page 45 of 121 FISSION PRODUCT BARRIER DEGRADATION Deleted: BWR TABLE 5-F-2 FU_INITIATING CONDITION
-NOTIFICATION OF UNUSUAL EVENT ANY loss or ANY Dotential loss of containment A nDr~ltinn Mnrh~ AnnIi~hiIitw npargfing Mode Applicability:
Mode 1 Power Operation Mode 2 Startup Mode 3 Hot Shutdown Emerqencv Action Level(s): 1. Any loss or any potential loss of containment
<k Bases: Comparison of conditions
/ values with those listed in Fission Product Barrier Matrix indicates a loss or any potential loss of containment.
The Fuel Cladding the Reactor Coolant System (RCS), are weighted more heavily than the Primary Containment P(. barrier. NOUE Csassociated
-----------------
0yste MlfucinCs..socaed.
with RCS and FCarriers are addressed under System Malfunction ICs.Loss of containment would be a potential degradation in the level of plant safety.The PC.arrier includes the drywell, the wetwell, their respective interconnecting paths, and other connections up to and including the outermost containment isolation valves. Containment Lbqrrier thresholds are used primarily as.......discriminators for escalation from an Alert to a Site Area Emergency or a General Emergency.
Formatted:
Font: Arial--4Formatted:
Indent: Hanging: 1", Tabs: 0.25", List tab + Not at 1''(Formatted:
Bullets and Numbering--i Formatted:
Font: Arial-- -Deleted:
-. .............
Deleted: Barrier-"Deleted:
B Deleted: (See Sections 3.4 and 3.8)Deleted: uel-', Deleted: lad'" Deleted: B Formatted:
Font: Arial Deleted: nimary Deleted: ontainment Deleted: B e...........l
............
e.. .B ....................
..............
SDeleted:
B Attachment 2 Page 46 of 121 FISSION PRODUCT BARRIER DEGRADATION
.............. -L. .;..... .....................
* i. Deleted: BWR TABLE5F2 FA1 INITIATING CONDITION
-ALERT Any loss or any potential loss of either fuel clad or RCS Operating Mode Applicability:
Mode 1 Power Operation Mode 2 Startup Mode 3 Hot Shutdown Emergency Action Level(s): 1, Any loss or any potential loss of fuel clad, OR Any loss or any potential loss of RCS Bases: Comparison of conditions
/ values with those listed in Fission Product Barrier Matrix indicates a loss or potential loss of a fuel clad barrier or a loss or potential loss of the RCS barrier.The Fuel CladdinM and the Reactor Coolant System are weighted more heavily than the Primary Containment bh rri-egr, ..................
....... .......Loss of either the Fuel Claddinq or the Reactor Coolant System would be a substantial degradation in the level of plant safety.The Fuel Clad barrier isthe zircalloy or stainless steel fuel. bundle. tubes. that contain the fuel pellets.The RCS b.rrier. is the reactor coolant system pressure boundary and includes the reactor vessel and all, reactor coolant system piping up to the isolation valves.&#xf7; .. [{ Formatted:
Bullets and Numbering.D-eleted:-Bar-er Deleted: Barrier'Deleted:
Barie Deleted: (See Sections 3.4 and 3.8)1 Deleted: NOUE ICs associated with RCS and Fuel Clad Barriers are addressed under System Malfunction F Ics.*Deleted:
consists of De e ed B............................
...iDeleted:
B Attachment 2 Page 47 of 121 FISSION PRODUCT BARRIER DEGRADATION Deleted: BW'R TAB*LE 5-F-2 I INITIATING CONDITION
-SITE AREA EMERGEN Loss or potential loss of any two barriers Operating Mode Applicability:
FS 1 Mode 1 Power Operation Mode 2 Startup Mode 3 Hot Shutdown Emergency Action Level(s): 1. Loss or potential loss of any two barriers Bases: Comparison of conditions
/ values with those listed in Fission Product Barrier Matrix indicates loss or potential loss of any two barriers.Loss of 2 Fission Product Barriers would be a major failure of plant systems needed for protection of the public.---1 Formatted:
Bullets and Numbering I Attachment 2 Page 48 of 121 FISSION PRODUCT BARRIER DEGRADATION I "Deleted:
BWR TABLE 5-F-2 FG1 INITIATING CONDITION
-GENERAL EMERGENCY Loss of any two barriers and loss or potential loss of third barrier Operating Mode Applicability:
Mode 1 Power Operation Mode 2 Startup Mode 3 Hot Shutdown Emergency Action Level(s): 1. Loss of any two barriers AND Loss or potential loss of the third barrier Bases: Comparison of conditions
/ values with those listed in Fission Product Barrier Matrix indicates a loss of any two barriers and the loss or potential loss of the third barrier.Conditions
/ events required to cause the loss of 2 Fission Product Barriers with the potential loss of the third could reasonably be expected to cause a release beyond the immediate site area exceedinq EPA Protective Action Guidelines.
--j Formatted:
Font:' Not Bold Attachment 2 Page 49 of 121 FISSION PRODUCT BARRIER DEGRADATION Deleted: BWR TABL5-2.. .. ...i ..FUEL CLAD Emergency Action Level: Primary coolant activity level EAL Threshold:
LOSS: ................ ,coo!ant.
activity > 300 tici/ dose equivalent 1-131 POTENTIAL LOSS: ..............
NON .Bases: LOSS -The site specific value is,300 pCi/gm dose equivalent 1-131, Assessment by the EAL Task Force indicates that this amount of coolant activity is well above that expected for iodine spikes and corresponds to less than 5% fuel clad damage. This amount of radioactivity indicates significant clad damage and thus the Fuel Clad .&#xfd;arrier is considered lost.Deleted: Primary Deleted: greater than (site specific value)Deleted: Not Applicable Deleted: corresponds to Deleted: equivalent
.........Deleted: B---------
....... ........ ....Deleted: [The value can be expressed either in mR/hr observed on the sample or as pCi/gm results from analysis.]
POTENTIAL LOSS -NONE-~~1.Deleted:
 
==References:==
 
Deleted: There is no Potential Loss threshold associated with this item.Attachment 2 Page 50 of 121 FISSION PRODUCT BARRIER DEGRADATION Deleted: 13WR TABLE 5-F-2 FC2 FUEL CLAD Emergency Action Level: Reactor vessel water level EAL Threshold:
LOSS: ..............................
RPV water level cannot be restored and maintained above, V ! i -i n- -.. ..... ... ...... ......- ...... ...... ..... .... ...... .... .. ..... ..... ..... ..... ...... ... ...... ...... .... ... .... ....-186 inches POTENTIAL LOSS: .............
RPV water level cannot be restored and maintained above,,-162 inches or cannot be determined Bases: LOSS -This site specific value corresponds to the level used in EOPs to indicate challenge of core cooling. This is the minimum value to assure core cooling without further degradation of the clad. Reactor vessel water level less than the minimum steam cooling RPV water level (-186") with injection is the lowest level with adequate core cooling to maintain peak clad temperature less than 1500'F where fuel clad damage (fuel rod perforation) may begin. Corrective actions as described in the Emergency Operating Procedures (EOPs) and Severe Accident Guidelines (SAGs) will be needed to mitigate fuel clad/core damage.Deleted: (site specific RPV water level corresponding to the Deleted: requirement for primary containment flooding)Deleted: (site specific RPV water level corresponding to the top of Deleted: active fuel).i Deleted: Loss Threshold A ',I .... .............. .. .. ..... .... ........ .... .. ..... ...... .. ..... ... .. .. .. .. ..... --------------- --, ----- -W d &#xfd;POTENTIAL LOSS -This threshold is the same as the RCS barrier D ssthreshholdRC2 and corresponds to the site specific water level at the top of the active fuel. Thus, this threshold indicates a ,potential Loss of the Fuel Clad barrier and a Loss of the RCS barrier that appropriately escalates the emergency classification level to a Site Area Emergency.
With Reactor vessel water level less than the top of active fuel (-162"), adequate core cooling is still assured but is sufficiently low that any further drop in water level could result in the significant degradation of the cladding.
Corrective actions as described in the Emergency Operating Procedures (EOPs) will be needed to mitigate fuel clad/core damage.
 
==References:==
 
Deleted: [Depending on the plant this may be the Minimum Steam Cooling RPV Water Level or the jet pump suction without the requisite i Core Spray cooling flow. BWROG EPGs/SAGs provide explicit direction when RPV water level cannot be determined.
Since the loss of ability to determine if adequate core cooling is being provided presents a significant challenge to the fuel clad barrier, a potential loss of the fuel clad barrier is specified.]&#xb6; Deleted: Potential Loss Threshold A(,Deleted:
L Deleted: L SDeleted:
L Attachment 2 Page 51 of 121 FISSION PRODUCT BARRIER DEGRADATION Deleted: BWR TABLE 5-F-2 FC3 FUEL CLAD Emergency Action Level: Primary containment radiation monitors EAL Threshold:
LOSS:..................
_ntainment radiation monitor RMS-RE16 reaing_>_, L O S S : PJ h r... ..... ...... .. ...... .. ..... ... ......................
..............
g 3,000 Ri h-- ---- ----POTENTIAL LOSS: .........
NONE, Bases: LOSS -Containment radiation monitors reading in excess of 3000 RPhr after Reactor Shutdown are indicative of both the loss of the reactor coolant system and 5% clad failure with the instantaneous release and dispersal of the reactor coolant noble gas and Iodine inventory into the drywell and containment atmosphere.-------
....Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations (including iodine spiking) allowed within Technical_Spec.fications and.are th.erefore .i.n.d.icati.ye..of fuel damage. .. ... ... ..... ........ .. .. .. .... ...... ............ .... ... ....... ... ... ... ... ... ... ... ... ... ... ., -1 ... ....... .--.... ......Deleted: Primary c Deleted: greater than (site specific value)SDeleted:.
l.........................................
.............................................
...Deleted: Not Applicable
'Deleted:
The site specific reading is a value which indicates the release of reactor coolant, with elevated activity indicative of fuel'damage, into the drywell. &#xb6;[The reading should be calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with a concentration of 300 pCi/gm dose equivalent 1-131 or the calculated concentration , equivalent to the clad damage used in threshold 1 into the drywell atmosphere.]l Lk .P ... 1. e t.e.............
.........................................................................................
: C Deleted: s Deleted: This value is higher than z that specified for RCS barrier Loss I threshold
#4. Thus, this threshold indicates a loss of both Fuel Clad barrier and RCS barrier that 1 appropriately escalates the emergency classification level to a Site Area Emergency.
I Deleted: [Caution:
it is important to recognize that in the event the POTENTIAL LOSS -NONE.
 
==References:==
 
Calculation G 13.18.9.4-045 Rev. 0 monitor is sensitive to shine from the reactor vessel or piping, spurious readings will be present and another indicator of fuel clad damage is necessary or compensated for in the threshold value.]Deleted: There is no Potential Loss threshold associated with this item.Formatted:
Font: (Default)
Arial, Bold Attachment 2 Page 52 of 121 FISSION PRODUCT BARRIER DEGRADATION Deleted: BWR TA BLE5-F-2 FC4 FUEL CLAD Emergency Action Level: Emergency Director judgment* Formatted:
Not Hidden Formatted:
Normal EAL Threshold:
LOSS: ..................................
Any condition in the opinion of the Emergency Director that indicates lpss of _the Fuel Clad brrier POTENTIAL LOSS: ..............
Any condition in the opinion of the Emergency Director that indicates gptential ipss of the Fuel Clad b rrier.Deleted:
L Deleted: B Deleted: P~1 Deleted: L Deleted: B...........................
Bases: LOSS or POTENTIAL LOSS -_This EAL addresses any other factors that are to be used by the Emergency Director in determining whether the ,[uel Jad barrier. i-s-lostor-
_potentially lost. In addition, th6 inability to monitor the barrier should also be considered in this gAL as a.factor in judgment that the barrier. may be considered lost or potentially lost.Deleted: These threhods&#xfd;.
Deleted: c I Deleted: threshold----------
 
==References:==
 
Attachment 2 Page 53 of 121 FISSION PRODUCT BARRIER DEGRADATION RC1 D .el. .e.t .e..d..: B .W..R T..A .B..L E 5-F .........2 Formatted:
Not Hidden Formatted:
Normal Formatted:
Font: Arial, 11 pt I REACTOR COOLANT SYSTEM Emergency Action Level: Drywell pressure EAL Threshold:
I fr%00: ....................................Drywell pressure >-1.68 psid-with in coolant leak in drywell POTENTIAL LOSS: ...........
NONE_Bases: LOSS -The site specific primary containment pressure is based o pressure set point which indicates a LOCA by automatically initiat equivalent makeup system.Pressure rise due solely to loss of containment or drywell heat rer testina. etc are not considered for this EAL threshold.
dications of reactor ..Deleted: Primary Containment t Formatted:
Font: Arial, 11 pt Deleted: greater than (site specific-- -value)SFormatted:
Font: Arial, 11 pt Deleted: due to RCS leakage'\ f Formatted:
Font: Arial, 11 pt on the drywell high Formatted:
Font: Arial, 11 pt ing the ECCS or Deleted: Not Applicable Formatted:
Font: Arial, 11 pt moval capability, Formatted:
Font: Arial, 11 pt.i Deleted: There is no Potential Loss 1 i threshold associated with this item.... ... ... ... ... ..... ...... ... ... ... ......................--.......................................
.........................................
.. .......Formatted:
Font: Arial, 11 pt, No underline Formatted:
Font: Arial, 11 pt--Formatted:
Right POTENTIAL LOSS -NONE ,References, Attachment 2 Page 54 of 121 FISSION PRODUCT BARRIER DEGRADATION eeted:BwR TABLE ......................
RC2 REACTOR COOLANT SYSTEM Emergency Action Level: ,Reactor vessel water level EAL Threshold:
LOSS: ....................................
RPV water level cannot be restored and maintained above_,-162 inches or cannot be determined POTENTIAL LOSS: ............
NON ............
.Bases: LOSS -The Jpss EAL threshold of site specific RPV water leveL corresponds to the level that is used in EOPs to indicate challenge of core cooling.This threshold is the same as the Fuel Clad potential joss EAL threshold FC2,and corresponds to a challenge to core cooling. Thus, this threshold indicates a lpss of the RCS barrier and potential lpss of the Fuel Clad barrier that appropriately escalates the emergency classification level to a Site Area Emergency.
POTENTIAL LOSS -NONE,
 
==References:==
 
Formatted:
Not Hidden Formatted:
Normal Formatted:
Font: Arial, 11 pt-D iDeleted: (site specific RPv water level corresponding to the top of" .........................
a4M.. ... .. ..... ....... .. .........
....... ........ .... .... ........ ...... ..Deleted: active-fuel).
Deleted:.
Not Applicable (Deleted:
L.......................................................................................................................
D Deleted: B De leted: L Deleted: L Deleted: #2.A.. ... ... ....... ..... ... .... ... ......Deleted: L Deleted: There is no Potential Loss threshold associated with this item.Attachment 2 Page 55 of 121 FISSION PRODUCT BARRIER DEGRADATION Deleted: BWR TABLE 5-F-2 RC3 REACTOR COOLANT SYSTEM Emergency Action Level: RCS leak rate EAL Threshold:
Formatted:
Not Hidden Formatted:
Normal Deleted: (site specific Indication of an D Deleted: M Deleted: S Deleted: HPCI, Feedwater, RWCU, or RC Deleted: )LOSS: .............
a 1_.a.NSOLABLE -ain temarline, break _as both MSIVs in any one line to indicated by the failure of close AND High MSL flow annunciator (P601-19A-A2)
AND Main Steam Tunnel Temperature
> 144,'F [173&deg;F NRC TS submittal change]OR P._ indication of an UNISOLABLE HPCS Feedwater, RWCU or RCIC break.OR 2. Emergency RPVdepressurization is requiiredl
......POTENTIAL LOSS: ...... 1. RCS leakage >50 gpm inside the drywell--Formatted:
Underline Formatted:
Indent: First line: 0.5"i Fmatted: Font: Not Bold, No',\ nderline Formatted:
Indent: Left: 2", I , Hanging: 0.25" Deleted: I Formatted:
Underline Formatted:
Not All caps Formatted:
Font: Not Bold Deleted greater than .Deleted: primary system .Deleted: primary Deleted: containment Formatted:
Not All caps L Formatted:
Underline OR 2. UNISOLABLE RCS leakage outside PC-as indicated by---------9 of the following
..exceeding~either
: a. Max Normal Operating Temperature (Table F2)OR b. Max Normal Area Radiation (Table F2)Attachment 2 Page 56 of 121 FISSION PRODUCT BARRIER DEGRADATION Deleted: BWR TABL5--RC3 TABLE F2* C RC1A,3 Potential Loss of RC.S ~ ~ a'Parameter Area Temperature Area Radiation Level (isolation temnperature D.)RMS Grid 2 Max Normal Ol)erating alarm). Value RHR A equipment area 117' F 1213 8.2E+01 mR/hr RHR B equipmen area 117' F 1214 8.2E+.04 mR/hr llP601-20 A-B4 N/AC1qu1i5..
...............
8.2:.:.. ..m R hr RC1C room 1S2' F 1219 1,20E.I02 mRitr (P601-21 A-1B6 MSL Tunnel .144 0 F r173&deg;F NRC TS N/A submittal chanvel (P601 -19A-AI /A3/BI /B3)R WCU pmnp room I (A) / 2 (B) 165" F N/A______________________
P680- IA-A2iB2)i
--Formatted:
Font: (Default)
Times New Roman, 10 pt Formatted:
Centered, Indent: Left:-0", First line: 0" Bases: LOSS -An UNISOLABLE MSL break is a breach of the RCS barrier. Thus, this EAL threshold is included for consistency with the Alert emergency classification level.Other large high-energy line breaks such as HPC_.. Feedwater, RWCU, or ROIC that are UNISOLABLE also represent a significant loss of the RCS barrier and should be considered as MSL breaks for purposes of classification.
The leak is NOT isolable from the Main Control Room OR an attempt for isolation from the Main Control Room panels has been made and was not successful.
An attempt for isolation should be made prior to the accident classification.
If isolable upon identification, this INITIATING CONDITION is not applicable.
Dispatch of operators outside the Control Room for manual attempts to close the valve is not considered.
Plant symptoms requiring Emergency RPV !Apressurization per the site specific EOPs are indicative of a loss of the RCS barrier. If Emergency RPV depressurization is required, the plant operators are directed to open safety relief valves (SRVs) and keep them open. Even though the RCS is being vented into the suppression pool, a loss of the RCS should be considered to exist due to the diminished effectiveness of the RCS pressure barrier to a release of fission products beyond its boundary.POTENTIAL LO.SS -This threshold is based on Ieakage~set t *a level indicative o f. a small breach of the RCS but which is well within the makeup capability of normal and emergency high pressure systems. Core uncovery is not a significant concern for a Deleted: Loss Threshold
#A ..CD eleted: I....................................
........ ............
..... ........ ..........
I Deleted: Loss Threshold
#B1 SDeleted:
D Deleted: Potential Loss Threshold S#A Deleted: is Attachment 2 Page 57 of 121 FISSION PRODUCT BARRIER DEGRADATION Deleted: BWR TABLE 5-F-2 RC3 50 gpm leak, however, break propagation leading to significantly larger loss of inventory is possible.If the leak detection system leak rate information is unavailable (i.e., LOCA isolation, loss of power), other indicators of RCS leakage should be used. Other indications include a rise in drywell temperature and pressure and a rise in the drywell radiation monitors.
If the leakage computer is unavailable, sump level and pump status may help determine if the leakage is greater than 50 gpm.If the DFR discharge line containment isolation valves have not isolated and a pump is running continuously without lowering sump level, the leakage may be assumed to exceed 50 qpm. The second pump can be started to verify that the first pump is not degraded.
It is not intended to conclude a potential loss of the RCS barrier exists if both pumps are degraded and the observed leak rate as noted by rate of rise of level in the sump or calculated by the computer is such that it clearly confirms leakage below 50 qprn.,
 
==References:==
 
........................-[iFormatted:
Font: Arial, 11 pt, Bold Attachment 2 Page 58 of 121 FISSION PRODUCT BARRIER DEGRADATION Deleted: BWR TABLE5-2 RC4 REACTOR COOLANT SYSTEM Emergency Action Level: DrVwell radiation EAL Threshold:
LOSS: .................................. radiation monitor RMS-RE20 reading 1&#xfd;R/ h r .... .... .... ... ... ....-....
... .... .... ... ... ..... .. ... .. ... ... .. ... ... .. ... .. ... ... ..POTENTIAL LOSS: .............
NONE Bases: LOSS -The site specific reading is a value which indicates the release of reactor coolant to the drywel .Deleted: Primary containm i Deleted: greater than (site value)specific et Deleted:.Deleted: Not Applicable Deleted: primary containment POTENTIAL LOSS -NONE,
 
==References:==
 
G1 3.18.9.4-051 Deleted: [The reading should be calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with normal operating concentrations (i.e., within TIS) into the drywell atmosphere.]
&#xb6;..... =:............
: ==. , =: ........,,,, ...........
Deleted: This reading will be less than that specified for Fuel Clad barrier Loss threshold
#4. Thus, this threshold would be indicative of a RCS leak only, If the radiation monitor reading increased to that value specified by Fuel Clad Barrier threshold, fuel damage would also be 1 indicated.
&#xb6;Deleted: [However, if the site specific physical location of the primary containment radiation monitor is such that radiation from a cloud of released RCS gases could not be distinguished from radiation from adjacent piping and components containing elevated reactor coolant activity, this threshold should be omitted and other site specific indications of RCS leakage.1 substituted.]
&#xb6;<Deleted:
There is no Potential Loss threshold associated with this item.Attachment 2 Page 59 of 121 FISSION PRODUCT BARRIER DEGRADATION Deleted: BWR TABLE 5-F-2 RC5 I Formatted:
Font: (Default)
Times New Roman, 18 pt, Underline REACTOR COOLANT SYSTEM Emergency Action Level: Emergency Director judgment EAL Threshold:
LOSS: ..................................
Any condition in the opinion of the Emergency Director that indicates 1lss of the RC.S brrier POTENTIAL LOSS: ..............
Any condition in the opinion of the Emergency Director that indicates pptential Jpss of the RCS barrier Bases: LOSS or POTENTIAL LOSS -This EAL addresses any other factors that are to be used by the Emergency Director in determining whether the RCS barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be considered in this._AL as a factor in Emergency Director judgment that the barrier may be considered lost or potentially lost.'1"t I Deleted: L Deleted: B Deleted: P SDeleted:
L Deleted: B.............
]....(..D ieted-..Th~
: e. ihi ;i~id ..............................
Deleted: These thresholds-iDeleted:
threshold3
 
==References:==
 
Attachment 2 Page 60 of 121 FISSION PRODUCT BARRIER DEGRADATION Deleted: BWR TABLE 5-F-2 PCI"PRIMARY CONTAINMENT Emergency Action Level: Primary containment conditions
-Formatted:
Not Hidden Formatted:
Normal J EAL threshold:
LOSS: ...............
TV 1. Rapid unexplained loss of PC pressure following initial pressure rise F 4 Formatted:
Tabs: 2.25", Left,Leader:
... + Not at 2" Deleted: Primary containment pressure rise followed by a rapid OR 2. PC pressure response not consistent with LOCA c o n it o n , ... .. .. .. .. ... .... .. .... .. .. ... ... ... .. .......conditions, POTENTIAL LOSS: ..............
1._ PC pressure>, 5 and rising, OR 2. a. PC hydrogen in the unsafe zone of HDOL curve 4.OR b. DW hydrogen concentration
> 9%Deleted: unexplained drop in 1 primary containment pressure..
1 Formatted:
Indent: Hanging: 2.75" Deleted: Primary containment"Deleted:
1..............
1...........
.., =. ..= = = .= =........
..... ..........
Deleted: Primary containment 3 Formatted:
Font: Not Bold" Deleted: greater than Deleted: (site -Deleted: specific value)''D leed:.................
Deleted:*Formatted:
Indent: First line: 2", No bullets or numbering, Tabs: 2.25", Left Formatted:
Indent: Left: 2", Tabs: 2.5", Left Deleted: Explosive mixture exists j inside primary Deleted: containment.
Formatted:
Indent: First line: 0", Numbered + Level: 1 + Numbering Style: a, b, c, ... + Start at: 1 +Alignment:
Left + Aligned at: 2" +Tab after: 2.25" + Indent at: 2.25" Formatted:
Indent: Hanging: 2.75" Formatted:
No underline 1 Deleted:-.
OR 3. RPV pressure and suppression pool temperature cannot be maintained below the HCTI, Attachment 2 Page 61 of 121 FISSION PRODUCT BARRIER DEGRADATION Deleted: BWR TABL E5F2 PCI Bases: LOSS -Rapid unexplained loss of pressure (i.e., not attributable to,,condensation....
effects or restoration of containment or drywell unit coolers) following an initial pressure rise-frqm a high energy line break indicates a-loss of. qornttainment integrity.
Primary containment pressure should risei asa result of mass and e..nergy released into ...........
containment from a LOCA. Thus, primary containment pressure not Ej9ng under these conditions indicates a loss of containment integrity._This indicator relies on operator recognition of an unexpected response for the condition and therefore does not have a specific value associated with it. The unexpected response is important because it is the indicator for a containment bypass condition.
Control room indicators may include ERIS data points, P808 CMS indication, or back-panel CMS pressure indication.(Deleted:Loss Thresholds A andB' Deleted: drywell spray or-[ Deleted: increase"1 Deleted: increase Deleted: increas.Deleted: Potential Loss Threshold A POTENTIAL LOSS-The site specific pressure is based on the primary containment design pressure.Primary Containment pressure greater than 15 psig and rising is based on the design pressure of the Primary Containment.
If the Containment pressure is exceeded.
this represents a condition outside the analyzed conditions.
This constitutes a potential loss of the Primary Containment barrier even if a failure to isolate has not occurred.The Emergency Procedure Guidelines and Severe Accident Guidelines identify that deflagration could occur if containment hydrogen concentration reaches the HDOL or drywell hydrogen concentration reaches 9%. The deflagration of Hydrogen represents a potential loss of the primary containment.
Indication of actual hydrogen concentration in the containment is affected by the environmental conditions (i.e., the presence of water vapor). The RBS hydrogen monitoring system removes water vapor from the sample before hydrogen concentration is measured and. thus, may provide readings that are higher than the actual hydrogen concentration.
The Heat Capacity Temperature Limit (HCTL) is the highest suppression pool temperature from which Pjnergency RPV depressurization will not raise: n uppess.on.chamber temperature above the maximum temperature capability of the suppression chamber and equipment within the suppression chamber which may be required to operate when the RPV is pressurized, Deleted: Potential Loss Threshold B T][BWRs specifically define the limits associated with explosive mixtures in terms of deflagration concentrations of hydrogen and oxygen. For Mk//1 containments the deflagration limits are "6% hydrogen and 5% oxygen in the drywell or suppression chamber".For Mk I/l containments, the limit is the "Hydrogen Deflagration Overpressure Limit". The term"explosive mixture" is synonymous with "deflagration limits" and is used as it is a more easily understood.
term.] I-------- --------Deleted: Potential Loss Threshold C 1 Deleted: E Deleted: D Deleted: S[ -Formatted:
Font: Bold, Underline_OR Attachment 2 Page 62 of 121 FISSION PRODUCT BARRIER DEGRADATION
'I Del.... ....e.ted:....
w TA..L..5-F-.............
1 PC1 Suppression chamber pressure above PC.essure jimit A,,while the rate of energy transfer from the RPV to the containment is greater than the capacity of the containment vent.The HCTL is a function of RPV pressure and suppression pool water level. It is utilized to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant and therefore, the inability to maintain plant parameters below the limit constitutes a potential loss of containment.
I Formatted:
Font: Bold, Underline
)"Deleted:
rimary Deleted: ontainment Deleted: P Deleted: L
 
==References:==
 
Attachment 2 Page 63 of 121 FISSION PRODUCT BARRIER DEGRADATION
.B.......................
...............
* B*WR TABLE 5-F-PC2 PRIMARY CONTAINMENT Emergency Action Level: Reactor vessel water level EAL Threshold:
LO S S : .. N O N E ..............................................
POTENTIAL LOSS: ...... Entry into PC flooding procedures SAP-1 and SAP-2 Bases: LOSS -NONE, POTENTIAL LOSS -The potential loss requirement for Primary Containment Flooding indicates adequate core cooling cannot be established and maintained and that core melt is possible.
Entry into SAP-1 and SAP-2is.a logical escalation in response to the inability to maintain adequate core cooling.The condition in this potential loss threshold represents a potential core melt sequence which, if not corrected, could lead to vessel failure and highe potential for containment failure. In conjunction with Reactor Vessel water level "toss" thresholds in the Fuel Clad and RCS barrier columns, this threshold will result in the declaration of a General Emergency
-- loss of two barriers and the potential loss of a third.
 
==References:==
 
-Formatted:
Not Hidden Formatted:
Normal* Deleted: Not Applicable i i, .. ..... ..... ..... .. .... .....-. Deleted: Primary containment flooding requ-ired
...........i Deleted: There is no Loss threshold.associated with this item.I.Deleted: Primary Containment Flooding procedures Deleted: Ise ve re A ccident Guidelines (SAGs) direct the operators to perform Containment Flooding when Reactor Vessel Level cannot be restored and maintained greater than a site specific value or RPV level cannot be determined with indication that core damage is occurring.]
&#xb6;Deleted: increased Deleted: L Attachment 2 Page 64 of 121 FISSION PRODUCT BARRIER DEGRADATION
'Deleted:
B3WR T A B-LE--PC3 PRIMARY CONTAINMENT Emergency Action Level:-Formatted:
Not Hidden Formatted:
Normal Primary containment isolation failure or bypass EAL Threshold:
LOSS: .................
: 1. a. Failure of all valves in any one line to close AND_b. Direct downstream pathway to the environment exists after PC, isolation signa! .OR 2. Intentional PCventing per EOPs or SAPs OR 3. UNISOLABLE RCS,.eakage outside Pas..indicated by exceeding either of the following-
: a. Max Safe Operating Temperature (Table F1,.OR b. Max Safe Area Radiation (Table F1.POTENTIAL LOSS: ..............
NONE.........
Formatted:
Space After: 0 pt, Tabs: 2.38", Left Formatted:
Space After: 0 pt Formatted:
Indent: First line: 0.38", Space After: 0 pt Formatted:
Font: Bold, Underline, SAll caps Fm t Font: Bld, Underline, All caps.Formatted:
Indent: Left: 2.25", Hanging: 0.13", Space After: 0 pt, , Tabs: 2.38", Left,Leader:
... + Not at.Deleted:primary containment I\IDeleted:.
tiomated ';'Indent:
First line: ,c'0,.25', Space After: 0 pt Formatted:
Indent: Left: 2", I Hanging: 0.25", Space After: 0 pt,--Tabs: 2.25", Left,Leader:
... + Not at 2'Deleted: primary containment
.Deleted:.0 Formatted:
Indent: First line: 0.25", Space After: Opt Formatted:
Indent: Left: 2", (.Hanging:
0.25", Space After: 0 pt primary system 0.1-Deleted:
primary containment Formatted:
Not All caps Formatted:.
......... ....o FormaDted:
Font: Bold, Underline Deleted:.Formatted:
Space After: 0 pt Deleted: Not Applicable Attachment 2 Page 65 of 121 FISSION PRODUCT BARRIER DEGRADATION PC3~TABLEF1>PC 3 Lossof Primary. Containment Parameter Area Temperature Area Radiation Level Max Safe Operating Value DRMS Grid 2 Max Safe Operating Value RHR A equipment 200 0 F 1213 9.5E+03 mR/hr area RHR B equipment 2000 F 1214 9.5E+03 mR/hr area RHR C equipment N/A 1215 9.5E+03 mR/hr area RCIC room 2000 F 1219 9.5E+03 mR/hr MSL Tunnel 2000 F N/A RWCU pump room 2000 F N/A 1 (A) / 2 (M)Deleted: BWR TABLE 5-F-2-I Formatted:
Space After: 0 pt ]Bases: These thresholds address incomplete containment isolation that allows direct release to the environment.,LOSS Failure to isolate_ -Inability to isolate means the primary containment isolation valve(s) did not fully close after a VALID automatic or manual isolation signal and is not isolable from the Main Control Room. or an attemot for isolation from the Main Control... Deleted: Loss Threshold A__ _______ .3 De et d Los Threshold....................
",
--{ Formatted:
Font: Bold, No Formatted:
Font: Not Bold\ Formatted:
Font: Not Bold,l FoUnderline F/ Fo'rmatted:
Font: Not Bold Room has been made and was unsuccessful.
An attempt for isolation should be made upon identification and prior to the accident classification.
If isolated from the Main Control Room upon identification, this INITIATING CONDITION is not applicable.
Dispatch of Operators outside the Control Room for manual attempts to close the valve is not considered.
Primary Containment isolation valves are described in the Technical Specifications bases for Primary Containment, Primary Containment Airlock and Primary Containment Isolation Valves (T.S. 3.6.1.1).
The Containment airlock is not considered in this EAL since airlock failure would be a notential failure mode to cause the EAL PC1 threshold.
The use of the modifier "direct" in defining the release path discriminates against release paths through interfacing liquid systems. The existence of an in-line charcoal filter does not make a release path indirect since the filter is not effective at removing fission product noble gases. Typical filters have an efficiency of 95-99% removal of iodine.Given the magnitude of the core inventory of iodine, significant releases could still occur.In addition, since the fission product release would be driven by boiling in the reactor vessel, the high humidity in the release stream can be expected to render the filters ineffective in a short period.Attachment 2 Page 66 of 121 FISSION PRODUCT BARRIER DEGRADATION
-1..............................
D e et d IW TA ...LE .5 -F -.. ....PC3 Containment Venting -Site specific EOPs and SAPs may direct containment isolation valve logic(s) to be intentionally bypassed, regardless of radioactivity release rates.Under these conditions with a valid containment isolation signal, the containment should also be considered lost if containment venting is actually performed.
Intentional venting of primary containment for primary containment pressureor combustible gas control per EOPs or SAPs to the secondary containment and/or the environment is considered a loss of containment.
Containment venting for pressure when not in an accident situation should not be considered.
Area temperature or radiation
-T -e presence of -area ral adition er tempe-ratur-e Max Safe Operating setpoints indicating unisolable primary system leakage outside the primary containment are addressed after a containment isolation.
The indicators should be confirmed to be caused by RCS leakage. Leakage into a closed system is to be considered a loss of primary containment only if the closed system is breached and thereby creates a path to the environment.
1Deleted:
Loss Threshold B Formatted:
Left, Space After: 0 pt' Deleted: Loss Threshold C Formatted:
Left, Space After: 0 pt Deleted: In addition, t POTENTIAL LOSS -None.
 
==References:==
 
-1.. e........
.... ....... ..............
... ........ ..........................
... ... .. .. .........Deleted: There is no Potential Loss Sthreshold associated with this item3 Formatted:
Font: Arial, 11 pt, Bold I[ Formatted:
Font: Arial, 11 pt I Attachment 2 Page 67 of 121 FISSION PRODUCT BARRIER DEGRADATION
'Deleted:
BWR TABLE 5F-PC4 ,PRIMARY CONTAINMENT Emergency Action Level: Primary containment radiation monitors, Formatted:
Not Hidden Formatted:
Normal SFormatted:
Font: Arial, 11 pt-Formatted:
Font: Arial, 11 pt J EAL Threshold:
LO SS : ..................................
NO NE -POTENTIAL LOSS: .............
Containment radiation monitor RMS-RE16 reading., 10,000 R/hr LBASIS LOSS -NONE.__Formatted:
Space After: 0 pt-',Deleted:
Not Applicable
_+_, i Formatted:
Font: Arial, 11 pt Formatted:
Font: Arial, 11 pt Formatted:
Space After: 0 pt Deleted: Primary c 1 De eted: greater than (site specific 0' value)J Formatted:
Font: Arial, 11 pt Formatted:
Left, Space After: 0 pt Deleted: There is no Loss threshold associated with this item" Formatted:
Font: Arial, 11 pt POTENTIAL LOSS -The site specific reading is a value that indicates significant fuel damage well in excess of that required for loss of RCS and Luel ..ad.................
Regardless of whether containment is challenged, this amount of activity in containment, if released, could have such severe consequences that it is prudent to treat this as a potential loss of containment, such that a General Emergency declaration is warranted.
 
==References:==
 
............
Calculation G13.18.9.4-045 Rev. 0 Deleted: F Deleted: C Deleted: [As stated in Section 3.8, a major release of radioactivity requiring off-site protective actions from core damage is not possible unless a major failure of fuel cladding 1 allows radioactive material to be released from the core into the reactor coolant.]
&#xb6;[NUREG-1228, "Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents," indicates that such conditions do not exist when the amount of clad damage is less than 20%. Unless there is a (site specific) analysis justifying a higher value, it is recommended that a radiation monitor reading corresponding to 20% fuel clad damage be specified here.]&#xb6;Attachment 2 Page 68 of 121 FISSION PRODUCT BARRIER DEGRADATION Deleted: BWR TABLE 5-F-2 PC5 REACTOR COOLANT SYSTEM Emergency Action Level: Emergencv Director iudlment EAL Threshold:
LOSS: ..................................
Any condition in the opinion of the Emergency Director that indicates
!pss of the Primary Containment 1tbrrier.POTENTIAL LOSS: ..............
Any condition in the opinion of the Emergency Director that indicates pptential Jpss of the Primary Containment barrier Bases: LOSS or POTENTIAL LOSS -_This EAL addresses any other factors that are to be used by the Emergency Director in determining whether the Primary Containment barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be considered in this.EAL as a factor in Emergency Director judgment that the barrier may be considered lost or potentially lost.The Primary Containment barrier should not be declared lost or potentially lost based on exceeding Technical Specification action statement criteria, unless there is an event in progress requiring mitigation by the Primary Containment barrier. When no event is in progress (toss or pptential.
Jpss of either Fuel Clad and/or RcS) the Primary Containment barrier status is addressed by Technical Specifications.
 
==References:==
 
t'ti Deleted: L I Deleted: B Deleted: P! Deleted: L ( :, = ,=== =
Deleted: B threshold k ..........
.. ... ........................
....... .... ...... .:iP ~e~y t......................
.......Deleted: threshold Deleted, L Deleted: P Deleted Attachment 2 Page 69 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU. I Deleted: I Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Natural or destructive phenomena affecting the PROTECTED AREA, Operating Mode Applicability:
All ,Emergency Action Leve!(s):
........... (lor2 or 3 or 4 or5) ................
)1. Seismic event identified by an.y2 of the fol!owing:
........................" Seismic event confirmed by activated seismic switch as indicated by receipt of.EITHER a OR b: a. Annunciator "Seismic Tape Recortincl SYS Start'- (P680-0-2AI6)
: b. Event Indicator on ERS-NBI-102 is white" Earthquake felt in plant* National Earthquake Center&#xa2; * *....... * ' .......... ......*** ............................................
..... ........,Deleted:.
De leted: E x ampl e (P,'_ete."-~
~~~ xa P_...........
..........
Formatted:
Font: Not Bold Deetd ANY SFormatted:
Font: Bold, Underline Formatted:
Font: Boldj Deleted: (site specific indication or method) J Ol {-L-4 Formatted:
Font: Bold, Underline Formatted:
Level 1, Indent: Left: 2. Tornado striking within PROTECTED AREA boundary,.,0, First line: 0" Deleted: O R "" "
....... ............
.... .....................
R "Deleted:
or high winds greater than 3. Internal flooding that has the potential to affect safety related equipment required by _________ (sit specifi mp Technical Specifications for the current operating mode in ApyTable H1 area -rmtted Font: Not Bold.... ... ... ... ... ......... ........ ..... .... ..... .....- -...... ..... ... ... ... .. .. .. ........ .. ... ... " D e le te d : A N Y OR *Deleted:
of the following areas: Deleted: (site specific area list) .4. Turbine failure resulting in casing penetration or damage to turbine or generator seals, Formatted:
Level 1, Indent:.Hanging: 0.5", Space After: 0 pt OR Deleted:-.
Deleted: 5. (Site specific S74thejudoccu rOTencTeD ARfeA).gth
: 5. Severe weather or hurricane conditions with indication of.SUSTAINED hig_h wnds -, occurrences affecting the mphwithin PROTECTEDAREA...
.............
AREA).. ....._......74 mph. within the PROTECTED AREA
---------------
en: ef: .O[,,-- ------- -- ------ Formatted:
Indent: Left: 0.01",[Hanging:
0.24", Space After: Opt X] Formatted:
All caps I Formatted:
Indent: Left: 0.25", Space After: 0 pt Formatted:
Not All caps Attachment 2 Page 70 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU I Deleted: I Aux Blde Crescent Area 70' EL 6 inches above floor (must be verified locally)HPCS Room 70'EL 4 inches above floor (P870-5 IA-G4)RHR A Room 70'1 L 4 inches above floor (P870-S IA-G4)RIMR B Room 70"EL 4 inches above floor (P870-5 I A-G4)RHR C Room 70'EL 4 inches above floor (P870-S5IA-G4)
LPCS Room 70'EL 4 inches above floor (P870-5 I A-G4)RCIC Room 70'EL 4 inches above floor (P870-51 A-G4)Basis: These EALs are categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators.
EAL #1 Damage may be caused to some portions of the site, but should not affect ability of safety functions to operate.As defined in the EPRI-sponsored Guidelines for Nuclear Plant Response to an Earthquake, dated October 1989, a "felt earthquake" is: An earthquake of sufficient intensity such that: (a) the vibratory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of control room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated.
The annunciators "Seismic Tape Recording SYS Start" and the "white" event indicator are listed in the Alarm Response Procedure as verification of an earthquake event.,The National Earthquake Center can confirm if an earthquake has occurred in the area of the plant.EAL #2 This EAL is based on a tornado striking (touching down)with.in .th..e ..PO..ECTETD AR!EA..Deleted: [For most plants with seismic instrumentation, the seismic switches are set at an acceleration of about O.01g: This EAL should be developed on site specific basis. The method of detection can be based on instrumentation, validated by a reliable source, or operator assessment.]
T1 Deleted: or high winds-t Attachment 2 Page 71 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HUq',t ~ ~ ~~ ~~~ ~~~ ~ ~~~~ .. ... .. ... ... .. .... .. ..... ..... .... .... ... .. .. ..... .. .. ...... ..... .... ........ ..... ... ... ..... ..... ... ... ... .... .. ... .. ... ... ... ... .. .Escalation of this emergency classification level, if appropriate, would be based on VISIBLE DAMAGE, or by other in plant conditions, via HAQ.......................
EAL #3 This EAL addresses the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps.-The EAL is only applicable to areas in Table H1 areas that contain systems required for safe shutdown of the plant and that are not designed to be partially or fully submerged.
The EAL is based on VALID indication that the area water level has reached the Maximum Safe Operating Values as identified in EOP-3. Exceeding the Maximum Safe Operating Value is interpreted as a potential degradation in the level of safety of the plant and is appropriately treated as an Unusual Event.Escalation of this emergency classification level, if appropriate, would beyia HA.. or.by other plant conditions.
EAL #4 This EAL addresses main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator.
Generator seal damage observed after generator purge does not meet the intent of this EAL because it did not impact normal operation of the plant.Of major concern is the potential for leakage of combustible fluids (lubricating oils) and gases (hydrogen cooling) to the plant environs.
Actual FIRES and flammable gas build up are appropriately classified via HU4,and HU.-.This EAL is consistent with the definition of a NOUE while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment.
Escalation of this emergency classification level, if appropriate, would be to HA, based on damage done by PROJECTILES generated by the failureor by the radiological releases, These latter events would be classified by the radiological (A)AICs or Fission Product Barrier (F.)ICs.Deleted: I Deleted: [The high wind value should be based on site specific FSAR design basis as long as it is within the range of the instrumentation available for wind speed.]Deleted: 1\ ......................................................................................................................
Deleted: [The site specific areas include those areas that contain systems required for safe shutdown of the plant, which are not designed to be partially or fully submerged.
The plant's IPEEE may provide insight into areas to be considered when developing this EAL.] &#xb6;D ...................................................................................................................
Deleted: 1...... J Deleted: 2...........
iDeleted:
3.. .. .. .... .( .... ........ ... ... ..... ...... ... .. ....... ....... .... .. ...rDeleted:
1 1 Deleted:, or in conjunction with a steam generator tube rupture, for a PWR Deleted: EAL #5 &#xb6;This EAL addresses other site specific phenomena (such as hurricane, flood, or seiche) that can also be precursors of more serious events.Attachment 2 Page 72 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU(_EAL #5 .......................................................
.. .This EAL is based on the assumption that high winds within the PROTECTED AREA may have potentially damaged plant structures, listed in Table H2, containing functions or systems required for safe shutdown of the plant. The high wind site specific value is based on the wind speed (74 mph) to classify severe weather conditions as a hurricane.,FSAR design basis is that all Seismic Category I structures at RBS are designed.to to --withstand 10.0 moh fastest mile of sustained wind 30 ft above ground, based upon a ....100-yr period of recurrence.
Methods to measure wind speed in the PROTECTED AREA are not availableu, therefore,.
a sustained indication of 74 mph on the Meteorological Tower lower elevation average wind speed indication will be used to determine that this EAL is met. The upper scale for the lower elevation average, meter wind speed on the MET Tower is 100. mph If the MET Tower Jower average wind speed__sensors are not operable, other tower sensors or sources may be considered for estimating wind speed at RBS such as NOAA or Baton Rouge regional Airport ... .If damage is confirmed visually or by other in-plant indications, the event may be escalated to Alert.
 
==References:==
 
D e le t e d : I -. ..............................................
....................................
1 Deleted: [Sites subject to severe weather as defined in the NUMARC station blackout initiatives should include an EAL based on activation of-the severe weather mitigation procedures (e.g., precautionary i shutdowns, diesel testing, staff call-1 outs, etc.).]J Formatted:
Font: 11 pt" Formatted:
Space After: 0 pt_' '_, Formatted:
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Arial, 11" F a : p tt', { Formatted:
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Font: Bold Attachment 2 Page 73 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT H UJ Dleted: 2 FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA, Operating Mode Applicability:
All ,Emergency Action L.Level(s):
(1lor.2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the duration has exceeded, or will likely exceed, the applicable time.1. FIRE notextinguished within 15 minutes of Control R om notification or verification of a _Cntrol porn FIRE alarm in &ny, Table H2 structure or area.1Deleted:.
U e.e. ...... .. .. ....'I Deleted: Example K ...... .... .---------....
... .. .. ...Deletd .....c Deleted: c... ........ .......... I.......... .. ..... ........Deleted: c Deleted: r , Formatted:
Font: Not Bold Deleter d ANY IDeleted:
of the following areas I.Deletd s itspcific area list) 9 Tower Auxiliary Building, Diesel Generator Building CFontiol Building Fuel Building OR 2. -EXP&#xfd;LO(SION-wit-hi-n the P-RO-T-E-CTE-D-A-RE-A-,------------Formatted:
Indent: Hanging: 0.5", Space After: 0 pt{- Formatted:
Font: Bold, Underline Formatted:
Level 1, Indent:\ Hanging: 0.5", Space After: 0 pt' Formatted:
Font: Bold, Underline Formatted:
Indent: Hanging: 0.5", I Deleted:.Basis: This LC. addresses the magnitude and exte.nt of FI.RES or.EXP.LOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the FIRE /EXPLOSION, and not the degradation in performance of affected systems that may result.As used here, detection is visual observation and report by plant personnel or sensor alarm indication.
EAL #1 The 15 minute time period begins with a credible notification that a FIRE is occurring, or indication of a fire detection system alarm/actuation.
Verification of a fire detection system alarm/actuation includes actions that can be taken within the control room or Deleted: EAL Attachment 2 Page 74 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU I .Deleted:.
2.other nearby site specific location to ensure that it is not spurious.
An alarm is assumed to be an indication of a FIRE unless it is disproved within the 15 minute period by personnel dispatched to the scene. In other words, a personnel report from the scene may be used to disprove a sensor alarm if received within 15 minutes of the alarm, but shall not be required to verify the alarm.The intent of this 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket).EgAL #2 This EAL addresses only those EXPLOSIONS of sufficient force to damage permanent structures or equipment within the PROTECTED AREA.No attempt is made to assess the actual magnitude of the damage. The occurrence of the EXPLOSION is sufficient for declaration.
The Emergency Director also needs to consider any security aspects of the EXPLOSION, if applicable.
Escalation of this emergency classification level, if appropriate, would be based on HA4,
 
==References:==
 
Deleted: [The site specific list should be limited and applies to buildings and areas in actual contact with or immediately adjacent to VITAL AREAS or other significant buildings or areas. The intent of this /C is not to include buildings (i.e., warehouses) or areas that are not in actual contact with or immediately adjacent to VITAL 1 AREAS. This excludes FIRES within administration buildings, waste-basket FIRES, and other small FIRES of no safety consequence.
Immediately adjacent implies that the area immediately adjacent contains or ay contain equipment or cabling S that could impact equipment located in VITAL AREAS or the fire could damage equipment inside VITAL AREAS or that precludes access to , VITAL AREAS.][Formatted:" All caps Deleted: 2 Formatted:
Font: Bold Attachment 2 Page 75 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Release of toxic, corrosive, asphyxiant, or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS, .HU5 ' Dlted:3i::
Deleted:.Operating Mode Applicability:
gEmergency Act0ion Levelj.sl:
All.(1 or 2)-. Deleted: Example Deleted:.Ij 1. Toxic, corrosive, asphyxiant or flammable gases in amounts that have or could adversely affect NORMAL PLANT OPERATIONS,_
OR 2. Report by.West Feliciana Parish for evacuation or sheltering of site personnel based, on an off-site event, Basis: This n.,is based on the release of toxic, corrosive, asphyxiant or flammable gases of sufficient quantity to affect NORMAL PLANT OPERATIONS.
.. .....................
--.................
I I Formatted:
Font: Bold, Underline j Deleted: local, county 9 Deleted: or state officials Deleted:.I Deleted: _ _L The fact that SCBAs may be worn does not eliminate the need to declare the event.This IC is not intended to require significant assessment or quantification.
It assumes an uncontrolled process that has the potential to affect plant operations.
This would preclude small or incidental releases, or releases that do not impact structures needed for plant operation.
An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment.
This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.Escalation of this emergency classification level, if appropriate, would be based on HA'_ -
 
==References:==
 
*!Deleted:
3 '\ ...... ~...... ...........
.....................................................
............
...Attachment 2 Page 76 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HUI Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Confirmed SECURITY CONDITION or threat which indicates a potential degradation in the level of safety of the plant, .......................Operating Mode Applicability: -All ,Emergency Action Leveisjs:
_ (1 or. 2. or. 3)1. A SECURITY CONDITION that does not involve a HO.STILE.E ACTION as report.e.d.by..
the RBS security shift supervision ,OR 2. A credible site specific security threat notification...........................,OR 3. A validated notification from NRC providing information of an aircraft threat Basis: I---r Dele ted: 4]-Deleted:
Example -" lT...............
"!Deleted:
NOT Deleted: (site specific security shift supervision).
l F- Formatted:
Font: Bold, Underl ine.-- -Formatted:
Font: Bold, Underline Deleted:.Formatted:
Font: Bold, Underline.,-" Deleted:.NOTE; Timely and accurate communication between SecurityShift Supervision and the Control Room is crucial for the implementation of effective Security EALs.Security events which do not represent a potential degradation in the level of safety of the plant are reported under 10 CFR 73.71 or in some cases under 10 CFR 50.72.Security events assessed as HOSTILE ACTIONS are classifiable under HAJ, HS_1and...
HG1.A higher initial classification could be made based upon the nature and timing of the security threat and potential consequences.
_gpnsideration shall be given to upgrading the emergency response status and emergency classification, in accordance with the ,Safeguards Contingency Plan and Emergency Plan.Deleted: Note_-_I.Deleted: 4 d"Deleted:4
\...........
..................
.. .... ..........
... ........J.Deleted:
The licensee shall c[Deleted;:
level Deleted: site's.. Deleted: Reference is made to site specific security shift supervision 1 because these individuals sre Deleted: personnel EAL #1 The Security Shift Supervisor igthe designated individualon-site qualified and trained to confirm that a security event is occurring or has occurred.
Training on security event classification confirmation is closely controlled due to the strict secrecy controls placed on the plant Safeguards Contingency Plan.This EALis based on the.Safeguards Contingency Plan The Safeguards Contingency~
Planis based on guidance provided ._NE_ 03-12.___:[i Dlted h~re~s~hold ,EFormatted:
Font: 11 pt Deleted: site specific security plans Deleted: Site specific Safeguards Contingency Plans are Deleted: by...........................
................
......Attachment 2 Page 77 of 121 HAZARDS ANDOTHER CONDITIONS AFFECTING PLANT SAFETY HUI EAL #2 This EAL, is included to ensure that appropriate notifications for the security threat are made in a timely manner. This includes information of a credible threat. Only the plant to which the specific threat is made need declare the Notification of,.U.nusual Event....The determination of "credible" is made through use of information found in the, Safeguards Contingency Plan.EAL #3 The intent of this EAL is to ensure that notifications for the aircraft threat are made in a timely manner and that Offsite Response Organizations and plant personnel are at a state of heightened awareness regarding the credible threat. It is not the intent of this EAL to replace existing non-hostile related EALs involving aircraft.Deleted: 4 Deleted: threshold S........
.................................
.-iDeleted:
an.-~...I.....
_ ----.-........
........... .............
1 Deleted: site specific This EAL is met when a plant receives information regarding an aircraft threat from NRC.Validation is performed by calling the NRC or by other approved methods of authentication.
Only the plant to which the specific threat is made need declare the Unusual Event.The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an airliner (airliner is meant to be a large aircraft with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC.Escalation to Alert via HA1 wwould be appropriate if .the threat.. inyvolves. .an airlirler within.30 minutes of the plant.De eted: emerge n ncy classification level would be viaHAJ......v./.. ....... a H 4 ..... ........Formatted:
Font: Bold Formatted:
Font: Not Bold.
 
==References:==
 
Attachment 2 Page 78 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Other conditions exist which in the judgment of the Emergency Director warrant declaration of aNOUE.HUal Deee: 1. ....... .Deleted: Operating Mode Applicability: -All-Deleted: Example ,Emergency Action  1. -Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.
No releases of radioactive material requiring offtsite response or monitoring are expected unless further degradation of safety systems occurs.Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the NOUE emergency classification level.Deleted: -Formatted:
Font: Bold------- I ,
 
==References:==
-
Attachment 2 Page 79 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA&sect;, l .Deleted:*1 Initiating Condition
-ALERT Natural or destructive phenomena affecting VITAL AREAS, Operating Mode Applicability:
Emergegncy Action Leve!fsl:_
_All (lor 2 or 3 or 4 or 5 or 6)1. a. Seismic event >Operating Basis Earthquake (OBE) as  Annunciator "Seismic Tape Recording System Start" (P680-02A-D06)
AND Event Indicator on ERS-NBI-102 is white AND Receipt of EITHER 1 OR 2: 1. Annunciator "Seismic Event High" (P680-02A-C06)
: 2. Annunciator "Seismic Event High-High" (P680-02A-B06)
AND amber light(s) on panel NBI-101 AND*1 A.b. Earthquake confirmed by.anvof the following:
* Earthquake felt in plant* National Earthquake Center* Control Room indication of degraded performance of systems required for the-safe shutdown of the plant..... ... .... ... ... .... ... ... ............................
: 2. Tornado striking, resulting in VISIBLE DAMAGE to _anv of the Table H2.structures or areas containing safety systems or components or.C&#xfd;ntro/_l pom indication of .-degraded performance of those safety systems, .. .... .. ... .. .... ... ... ....***' ..... ... .. ..................
...........
............
... ....... ........,i Deleted: ..,Deleted:
Example 3 Fm t Space After: Opt Deleted: greater than r/ r ...............
I= ... :::::= : :: : :...................--
..........
: = = .........Deleted: (site specific seismic instrumentation) reading (site specific OBE limit)Formatted:
Font: Not Bold Formatted:
Space After: 0 pt Formatted:
Underline Formatted:
Level 1, Indent: Hanging: 1.5", Space After: 0 pt Formatted:
Underline Formatted:
Indent: Hanging: 1.5", Space After: Opt Formatted:
Space After: 0 pt Formatted:
Font: Not Bold'- Deleted: ANY-4 Formatted Formatted r1221 Formatted 1 Deleted:..............................................................................
...Deleted:.,--Formatted:
Font: Bold, Underline-Deleted: or high winds gre ]Formatted:
Font: Not Bold-Deleted:
ANY.Deleted: following Deleted: OR 3..............
".,.'Deleted:
c 3 S Deleted: r -' Deleted: Deleted: (site specific structure list)t Formatted:
Indent: Hanging: 0.25"3' ' Formatted:
Font: Bold, Underline ,' Formatted:
Font: Bold, Underline\j Deleted: ANY of the following areas Formatted:
Font: Not Bold , Deleted: OR Deleted: c J, Deleted: r Deleted: Deleted: (site specific area list) d 1,t OQR ....... ....... ....... .----........
....... ....... ......3. Internal flooding in Auxiliary Building 70 ft elevation resulIting in an electrical shock hazard that precludes access to operate or monitor safety equipment orgntro.indication of degraded performance of those safety systems...
OR Formatted:
Font: Bold, Underline
)Attachment 2 Page 80 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA I kDeleted:
I 4. Turbine failure-generated PROJECTILES resulting in VISIBLE DAMAGE to or penetration of ayqof the Table H2 structures or areas containing safety systems or components
_oC, ontro! Room indication of degraded performance of those safety systems.....e s , ... ... ... .. .. ... .. ...... ... ... ... .............. ........ ... ... ... .. .. ....._O R ........ ....... .........
....... ..........
..................................................
... ......,OR 5. Vehicle crash resulting in VISIBLE DAMAGE to.anvyof the Table H2 structures or areas containing safety systems or components r &#xfd;.pntrog Room indication of degraded performance of those safety systems...
OR 6. Hurricane or high SUSTAINED wind conditions
> 74 mph within the PROTECTED AREA boundary and resulting in VISIBLE DAMAGE to any of the Table H2 OLIUkU~COh U.. Sr CntJF inint tA fSOLYtv OCIt tm .t tnr i tkfmonl.t , IC r I nt rn.UI Iil RonmIJ I indication of degraded performance of those safety systems Reactor Building Standby Cooling i ower Auxiliary Building Diesel Generator Building Control Building Tunnels (B, D. E, 1, G, T)Fuel Building Deleted: ANY 4 Formatted:
Font: Not Bold -1 Deleted: following\ Deleted: r /Formatted:
Font: Not Bold Deleted: OR ,Deleted:
c !1 Deleted: Deleted: (site specific structure list) 3 Formatted:
Font: Bold, Underline Formtte: Lvel1, Space After: 0 ,Eromatted:
Space After: 0 pt .Formatted:
Font: Not Bold Deleted: ANY Deleted: following Formatted:
Font: Not Bold Deleted: OR Deleted: c r ----0 ' Deleted:':
... .. ....11 Deleted: (site specific structure list)*' Formatted:
Level 1, Space After: 0 Spt SFormatted:
Font: Bold, Underline Formatted:
Font: Bold, Underline Deleted: 6. (Site specific occurrences) resulting in VISIBLE DAMAGE to ANY of the following structures containing safety systems or components OR control room indication of degraded performance of c. those safety systems: Deleted: (site specific structure list)( Formatted Table n_,asls: These EALs escalate from HU6,in that the occurrence of the event has resulted in VISIBLE DAMAGE to plant structures or areas containing equipment necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by Cpntrol .porn indications.of degraded.system .response.or pe.f.rmance..
The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discriminate against lesser events. The initial report-should not be interpreted as mandating a lengthy damage assessment prior to classification.
No attempt is made in the~se EA.Ls toassess t.he actual mag.n.itude of.th..e.
damage. The significance here is-not..Deleted: &#xb6;-Deleted: 1 iDeleted:
c Deleted: r-J... .........Deleted: i..-T..- --.Attachment 2 Page 81 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA., I .Deleted: I that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation.
Escalation of this emergency classification level, if appropriate, would be based on System Malfunction (S)LICs.The Emergency Director may consider the Fuel Building as necessary to address the impact of the event on the loss of spent fuel cooling or spent fuel (e.g.. freshly off-loaded reactor core in ool0). At RBS. the term "freshly off-loaded reactor core" refers to fuel that has been discharged from the core and stored in the spent fuel pool for a period of LESS THAN one year.t .. .. ..... ...........................
..........
... ....... ... ............
... ...... .... ...... ..... .. 0 .. ... ... ... ... .. ... .. ... .... ... ... ... .... ... ..... ......EAL #1 Seismic events of this magnitude can result in a VITAL AREA being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems.rhe National Earthquake Center can confirm if an earthquake has occurred in the area of the plant.EAL #2 This EAL is based on a tornado striking (touching down)that has caused VISIBLE DAMAGE to structures or areas containing functions or systems required for safe shutdown of the plant.EL#3 This EAL addresses the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps. It is based on the degraded performance of systems, or has created industrial safety hazards (e.g., electrical shock) that preclude necessary access to operate or monitor safety equipment.
The inability to access, operate or monitor safety equipment represents an actual or substantial potential degradation of the level of safety of the plant. The areas of concern are the areas identifed in Table 4 of EOP 3 that contain systems required Deleted: EALs #2 -#5.11 F~~~~~ ~~~ ... .. ..... .......... ...........
........ .. ...Deleted: (These EALs should specify site specific structures or areas that contain safety system, or component and functions required for safe shutdown of the plant. Site specific Safe\t.Deleted: Shutdown Analysis should be consulted for equipment and plant areas required to establish or maintain safe shutdown.]
'(Deleted;
[This threshold should be based on site specific FSAR design basis. See EPRI-sponsored"Guidelines for Nuclear Plant Response to an Earthquake", dated October 1989, for information on seismic event categories.]
TJ Deleted: or high winds Deleted: ve Deleted: [The high wind value should be based on site specific FSAR design basis as long as it is within the range of the instrumentation available for wind speed.] &#xb6;Attachment 2 Page 82 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY H Ag &#xfd; I De -et.e.d :- ....................................
i for safe shutdown of the plant that are not desianed to be nartiallv or f'ullv submeraed.
Indication may be by local verification, control room indication, or in degraded performance of systems affected by the flooding.Flooding as used in this EAL describes a condition where water is entering the room faster than installed equipment is capable of removal, resulting in a rise of water level within the room. Classification of this EAL should not be delayed While corrective actions are being taken to isolate the water source.AL#4 This EAL addresses the threat to safety related equipment imposed by PROJECTILEs generated by main turbine rotating component failures.
Therefore, this EAL is consistent with the definition of an ALERT in that the potential exists for actual or substantial potential degradation of the level of safety of the plant. Some structures on the list may not be at risk for the turbine generated missile but are included for consistency in identifying structures or areas containinq systems and functions required for safe shutdown of the plant.EAL #5 This EAL addresses vehicle crashes within the PROTECTED AREA that result, in VISIBLE DAMAGE to VITAL AREAS (as shown in Table H2) or indication of damage to safety structures, systems, or components containing functions and systems required for safe shutdown of the plant.Deleted: [The site specific areas include those areas that contain systems required for safe shutdown of the plant, which are not designed to be partially or fully submerged.
The plant's IPEEE may provide insight into areas to be considered when developing this EAL.] &#xb6;Deleted: [The site specific list of iareas should include all areas containing safety structure, system, or component, their controls, and their power supplies .................
.Deleted: s EAL #6 This EAL is based on high winds within the PROTECTED AREA that have caused VISIBLE DAMAGE to structures or areas containing functions or systems required for safe shutdown of the plant. The high wind site specific value is based on the wind speed (74 mph) to classify severe weather conditions as a hurricane.
FSAR design basis is that all Seismic Category I structures at RBS are designed to withstand 100 mph fastest mile of sustained wind 30 ft above ground, based upon a 100-yr period of recurrence.
Methods to measure wind speed in the PROTECTED AREA are not available:
therefore, a sustained indication of 74 mph on the Meteorological Tower lower elevation average wind speed indication will be used to determine that this EAL is met.The unoer scale for the lower elevation averaoe wind soeed on the MET Tower is 100 k 14: +k t, A C -r -r ; 14 A 11i hJ .i~L i Vi uye I V jI.uvve, aveiaue vvI U opJee auio i I aIi c no i oL pIeCIia , Ut eri LUVVer-sensors or sources may be considered for estimating wind speed at RBS such as NOAA or Baton Rouge regional Airport.-- Formatted:
Font color: Auto---Formatted:
Font color: Auto" Formatted:
Font color: Auto Attachment 2 Page 83 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY f e... r........:..
HA6 -Deleted: I i Deleted: This EAL addresses other site specific phenomena that result in VISIBLE DAMAGE to VITAL AREAS or results in indication of damage to safety structures, systems, or.. ...........................................
Deleted: components containing functions and systems required for I safe shutdown of the plant (such as hurricane, flood, or seiche) that can also be precursors of more serious events. [[Sites subject to severe weather as defined in the NUMARC station blackout initiatives should include an EAL based on activation of the severe weather mitigation procedures (e.g., precautionary shutdowns, diesel 0 testing, staff call-outs, etc.).]if Formatted:
Font: Bold Formatted:
Font: Bold Deleted:;j J'N Attachment 2 Page 84 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Initiating Condition
-ALERT FIRE or EXPLOSION affecting the operability of plant safety systems required to establish or maintain safe shutdowR H1A4I 2 Dltd 1 Operating Mode Applicability:
All ,Emergency Action LevelW: 1. _FIRE or EXPLOSION resulting in VISIBLE DAMAGE to anywof thestructures or areas in Table H2 containing safety systems or components r Cpntro _pom indication of degraded performance of those safety systems, l............ted:
D .e.i.e.t.e.d.:..........
.........................................................
.....SDeleted:
Example Rea~gc.tor&#xfd; Buildin-g Stall C Ato Tower Auxiliarv Building Diesel Generator Buildinp Control Blidlding Tunnels (B, D, E, F, Fuel Buildint Formatted:
Indent: Left: 0", Hanging: 0.25" Formatted:
Font: Not Bold Deleted: ANY Deleted: following Formatted:
Font: Not Bold Deleted: OR Deleted: c Deleted: (site spicific structure list)Formatted:
Indent: Hanging: 0.25" ,Basis.;1 Deleted: VISIBLE DAMAGE is used to identify the magnitude of the FIRE or EXPLOSION and to discriminate against minor FIRES and EXPLOSIONS.
The reference to structures containing safety systems or components is included to discriminate against FIRES or EXPLOSIONS in areas having a low probability of affecting safe operation.
The significance here is not that a safety system was degraded but the fact that the FIRE or EXPLOSION was large enough to cause damage to these systems.The use of VISIBLE DAMAGE should not be interpreted as mandating a lengthy damage assessment prior to classification.
The declaration of an Alert and the activation of the Technical Support Center will provide the Emergency Director with the resources needed to perform detailed damage assessments.
The Emergency Director also needs to consider any security aspects of the EXPLOSION.
Deleted: [This EAL should specify I site specific structures or areas that contain safety system, or component and functions required for safe shutdown of the plant. Site specific Safe Attachment 2 Page 85 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA -! -Deleted:
2 ,Escalation of this emergency classification level, if appropriate, will be based on System Malfunction-"S)
Fission Product Barrier Degradation (F) or Abnormal Radiation Levels I Radiological Effiuent_.A ICs.
 
==References:==
 
-Deleted: Shutdown Analysis should be consulted for equipment and plant areas required to establish or i maintain safe shutdown.]
&#xb6;Deleted: s Attachment 2 Page 86 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 Deleted:.3 Initiating Condition
-ALERT Access to a VITAL AREA is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of operable equipment required to maintain safe operations or safely shutdown the reactor,." Operating Mode Applicability:
All ,Em e rg e n cy A c tio n Le ve !I _s : _... .........................
..........................................
Note: If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.1. Access to a VITAL AREA (Table H2) is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor, Basis: Gases in a VITAL AREA can affect the ability to safely operate or safely shutdown the reactor.The fact that SCBAs may be worn does not eliminate the need to declare the event.Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere poses an immediate threat to life and health or an immediate threat of severe exposure to gases. This could be based upon documented analysis, indication of personal ill effects from exposure, or operating experience with the hazards.If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment.
This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.An uncontrolled release of flammable gasses within a facility structure has the potential to affect safe operation of the plant by limiting either operator or equipment operations due to the potential for ignition and resulting equipment damage/personnel injury.Flammable gasses, such as hydrogen and acetylene, are routinely used to maintain plant systems (hydrogen) or to repair equipment/components (acetylene
-used in welding).
This EAL assumes concentrations of flammable gasses which can ignite/support combustion.
"'Deleted:.
E Example... .............
.... .............
... .........
.............
..1I SDeleted:.
J Attachment 2 Page 87 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA J Escalation of this emergency classification level, if appropriate, will be based on System Malfunction-S._Fission Product Barrier Degradation j)} or Abnormal Radiation Levels Radioactive Effluent__
Ids. -*................
.........R eferences
: ------------------------ejted: 3 1Deleted:
s Formatted:
Font: Bold Attachment 2 Page 88 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HAI Initiating Condition
-ALERT HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat&#xfd;Operating Mode Applicability:
AlliEmergency Action -ees: ...._ (1 or 2)1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the RBS security shift supervision.
.2. A validated notification from NRC of an airliner attack threat within 30 minutes of the site ..Deleted: 4.. .. ......................
..... .. ................
............................
............
1Deleted:.
Deleted: &#xb6;......atted... Leve..l"'[Formatted:
Level 1-Deleted: (site specific security shift supervision).
.1 Deleted: Basis:,Timely and accurate communication between Security ShiftSupervision and the Control Room is crucial for the implementation of effective Security EALs.These EALs address the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. They are not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements.The fact that the site is under serious attack or is an identified attack target with minimal time available for further preparation or additional assistance to arrive requires a heightened state of readiness and implementation of protective measures that can be effective (such as on-site evacuation, dispersal or sheltering).
EAL #1 This EAL addresses the potential for a very rapid progression of events due to a HOSTILE ACTION. It is not intended to address incidents that are accidental events or acts of civil disobedience, such as small aircraft impact, hunters, or physical disputes between employees within the OWNER CONTROLLED AREA. Those events are adequately addressed by other EALs.Note that this EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes Independent Spent Fuel Storage Installatior~s that may be outside the PROTECTED AREA but still jnthe OWNER CONTROLLED AREA.Deleted: Note Formatted:
Font: Italic I:.EAL#2.I This EAL addresses the immediacy of an expected threat arrival or impact on the site within a relatively short time.The intent of this EAL is to ensure that notifications for the airliner attack threat are made in a timely manner and that Offsite Response Organizations and plant personnel are at a Deleted:'"iDeleted:
with D.......i......
... ... ..: Deleted: [Although nuclear plant security officers are well trained and prepared to protect against HOSTILE ACTION, it is appropriate for OROs to be notified and encouraged to begin activation (if they do not normally) to be better prepared should it be necessary to consider further actions.]
&#xb6;[If not previously notified by the NRC that the airborne HOSTILE ACTION was intentional, then it would be expected, although not certain, that notification by an appropriate Federal agency would follow. In this case, appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. However, the declaration should not be unduly delayed awaiting Federal notification.]
]Attachment 2 Page 89 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HAl, I .Deleted:4 state of heightened awareness regarding the credible threat. Airliner is meant to be a large aircraft with the potential for causing significant damage to the plant.This EAL is met when a plant receives information regarding an airliner attack threat from NRC and the airliner is within 30 minutes of the plant. Only the plant to which the specific threat is made need declare the Alert.The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an airliner (airliner is meant to be a large aircraft with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC.,
 
==References:==
 
Formatted:
Font: Bold NEI 03-12 -Attachment 2 Page 90 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA, Initiating Condition
-ALERT Control room evacuation has been initiated
.Operating Mode Applicability: -All ,Ermergency Action Leve(s): .1. AOP-0031, Shutdown from Outside the Main Control Room requires-C&#xa3;ntrol Epom evacuatior&#xfd; Basis: With the Control Room evacuated, additional support, monitoring and direction through the Technical Support Center and/or other emergency response facilities may be necessary.
Inability to establish plant control from outside the _Cntrol pom will escalate this event to a Site Area Emergency.
 
==References:==
,J J.D~el~eted*:**5'
... .. .. ...........
;...............................
.........
.........
.. ..........................
Deleted: .e...........................................
* Deleted: Example)--Formatted:
Indent: Left: 0", Hanging: 0.25" p 1' -" *....... ......................
...... -.. -.. .... .IF Deleted: (Site-specific procedure Deleted: c 7 Deleted: r I Deleted: .. ..Deleted: c , Deleted: r *~Dleted'.c
--Deleted: r--Formatted:
Font: Bold Attachment 2 Page 91 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Initiating Condition
-ALERT Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.Operating Mode Applicability: -All ,Emergency Action Leve!s: ...:........H A .Z , iD e 6eted :6 ..........................
.....................................
Deleted:.D el tel..................e.........-iDeleted:
Example.. ... .1. -Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels, Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the Alert emergency classification level.r Del eted :.- ................
..........
.......
 
==References:==
 
Attachment 2 Page 92 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2I eleted: 2 Initiating Condition
-SITE AREA EMERGENCY Control _Room evacuation has been initiated and plant control cannot be established,h
..Deleted:.Forated: Left I Operating Mode Applicability:
All E-mergency Action Levy!!-s-).:_
: 1. a. Control room evacuation has been initiated,~Deleted:
r __Deleted: Example Deleted:.-Formatted:
Underline AND -----b. _Control of the plant cannot be established in accordance with AOP-0031,,.Shutdown from Outside the Main Control Room, within 15 _minutes, l Formatted:
Level 1, Indent: Left: 0.25", First line: 0" I&#xf7;Basis: Formatted:
Indent: Left: 0", Hanging: 0.25" Formatted:
Font: 11 pt Formatted:
Font: 11 pt Formatted:
Font: 11 pt Deleted: (site specific Deleted:).
The intent of this IC is to capture those events where control of the plant cannot be reestablished in a timely manner. In this case, expeditious transfer of control of safety systems has not occurred (although fission product barrier damage may not yet be indicated).
The intent of the EAL is to establish control of important plant equipment and knowledge of important plant parameters in a timely manner. Primary emphasis should be placed on those components and instruments that supply protection for and information about safety functions ,such as reactivity control (ability to shutdown the reactor and maintain it shutdown).
reactor water level (abilitv to cool the core). and decay heat removal (abilitv to-I maintain a heat sink)., The determination of whether or not control is established at the remote shutdown panel is based on Emergency Directorjudgment.
The Emergency Director is expected to make a reasonable, informed judgment within 15 minutes that the plant staf has control of the plant from the remote shutdown panel.fEscalation of this emergency classification level, if appropriate, would be by Fission Product Barrier Degradationj(F) or Abnormal Radiation Levels/Radiological EffluentL(AI EALs.
 
==References:==
 
eFormatted:
Font: 11 pt Formatted:
Font: 11 pt Formatted:
Font: 11 pt Deleted: Typically, these safety functions are reactivity control (ability to shutdown the reactor and maintain it shutdown), reactor water level (ability to cool the core), and decay heat removal (ability to maintain a heat sink) for a BWR. The equivalent functions for a PWR are reactivity.
control, RCS inventory, and Ssecondary heat removal.SDeleted: (ED) I l Deleted: the site specific time for transfer , Deleted: licensee Deleted: [The site specific time for transfer is based on analysis or assessments as to how quickly contro/ must be reestablished without core uncovering and/or core damage.This time should not exceed 15 minutes without additional i justification.]
Deleted: J Formatted:
Font: Bold Attachment 2 Page 93 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS,. I Deleted: 3 .1 Initiating Condition
-SITE AREA EMERGENCY Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency, Operating Mode Applicability: -All ,Emergency Action Level(s): 1. -Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary, Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for Site Area Emergency.
Deleted:..................
.... ..........
Deleted: Example....
.....Dyele ted:. .............
..........,
 
==References:==
 
[-Formatted:
Font: Bold Attachment 2 Page 94 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HSI Deleted: 4 Initiating Condition
-SITE AREA EMERGENCY HOSTILE ACTION within the PROTECTED AREA, Operating Mode Applicability:
All ,Emergency Action Leyel(~s:*Deleted:.
Deleted: Example -Deie ediiiie secu i~ shiff................................
Deleted: (site securitys supervision).
: 1. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the RBS security shift supervisio,.
Basis: This condition, represents an escalated threat to plant safety above that contained in the Alert in that a HOSTILE FORCE has progressed from the OWNER CONTROLLED AREA to the PROTECTED AREA.This EAL addresses the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. It is not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements.The fact that the site is under serious attack with minimal time available for further preparation or additional assistance to arrive requires Offsite Response Organization readiness and preparation for the implementation of protective measures.This EAL addresses the potential for a very rapid progression of events due to a HOSTILE ACTION. It is not intended to address incidents that are accidental events or acts of civil disobedience, such as small aircraft impact, hunters, or physical disputes between employees within the PROTECTED AREA. Those events are adequately addressed by other EALs.,Escalation of this emergency classification level, if appropriate, would be based on actual plant status after impact or progression of attack.
 
==References:==
 
NEI 03-12 Deleted: [Although nuclear plant security officers are well trained and prepared to protect against HOSTILE ACTION, it is appropriate for OROs to be notified and encouraged to begin preparations for public protective actions (if they do not normally) to be better prepared should it be i necessary to consider further actions.]
I[If not previously notified by NRC that the airborne HOSTILE ACTION was intentional, then it would be expected, Ialthough not certain, that notification by an appropriate Federal agency would follow. In this case, appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. However, the declaration should not be unduly , delayed awaiting Federal notification.]
'J Attachment 2 Page 95 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG1 Initiating Condition
-GENERAL EMERGENCY HOSTILE ACTION resulting in loss of physical control of the facility,, Operating Mode Applicability:
All ,Emergency Action Level{(s):
(1 or 2) .................
: 1. A HOSTILE ACTION has occurred such that plant personnel are unable to operate equipment required to maintain safety functions, OR 2. A HOSTILE ACTION has caused failure of Spent Fuel Cooling Systems and IMMINENTfuel damage is likely for a freshly off-loaded reactor core in pool, .......-Deleted:......................................................................
..............
.......De le e d.I Deleted: Example
... ...1-1 Deleted:.Basis: EAL #1 This EAL encompasses conditions under which a HOSTILE ACTION has resulted in a loss of physical control of VITAL AREAS (containing vital equipment or controls of vital equipment) required to maintain safety functions and control of that equipment cannot be transferred to and operated from another location.
These safety functions are reactivity control (ability to shut down the reactor and keep it shutdown), reactor water level. (ability to_cool the core), and decay heat removal (ability to maintain a heat sink).* Formatted:
Font: 11 pt Formatted:
Font: 11 pt I o~ss of physical conntroil of the~ Control ~Room nr remotei s~hutdorwn nanteI ca~nabilitv along may not prevent the ability to maintain safety functions per se. Design of the remote shutdown capability and the location of the transfer switches should be taken into -- account. Primary emphasis should be placed on those components and instruments that supply protection for and information about safety functions,..
If control of the plant equipment necessary to maintain safety functions can be transferred to another location, then the threshold is not met.EAL #2 Deleted: [Typically, these safety functions are reactivity control (ability to shut down the reactor and keep it shutdown) reactor water level (ability to cool the core), and decay heat removal (ability to maintain a heat sink) for a BWR. The equivalent' functions for a PWR are reactivity control, RCS inventory, and secondary heat removal.]
q 1 1 Formatted:
Font: Not Italic tO' I Formatted:
Font: Not Italic I omttd ; ~ t Not ;talic, This EAL addresses failure of spent fuel cooling systems as a result of HOSTILE Underlted ACTION if IMMINENT fuel damage is likely, such as when a freshly off-loaded reactor U.derlin core is in the spent fuel pool. At RBS, the term 'freshly off-loaded reactor core" refers to l Formatted:
Font: Not Italic fuel that has been discharged from the core and stored in the spent fuel pool for a period of Formatted:
Font: Not Italic LESS THAN one year., Formatted:
Font: Not Italic,
 
==References:==
 
J Underline NEI03-1Z----------------------------------------------------, \ Formatted:-Font:
Not Italic Deleted:]\, (Formatted:
Font: 11 pt Deleted: [A freshly off-loaded reactor core is defined by site specific criteria.--Formatte.:
.o.nt. : B.........old, Formatted:
Font: Bold Not Italic Formatted:
Font: Not Italic Attachment 2 Page 96 of 121 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG2 Initiating Condition
-GENERAL EMERGENCY Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency,.I -Operating Mode Applicability: -All ,Emergency Action Levels: 1. _Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite fo.-rmor.e the. immediate site area, Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for General Emergency.
-I Formatted:
Space After: 0 pt"..Deleted:
.Deleted: Example Deleted:--Deleted:
.-[Formatted:
Font: Bold ,
 
==References:==
 
11 Attachment 2 Page 97 of 121 SYSTEM MALFUNCTION Sul Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Loss of all offsite AC power to emergency busses for > 15 minutes t'.--Deleted:
0 Deleted:-
A Deleted: or longer.Operating Mode Applicability: ,Emergency Action Levelis[: Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown I Formatted:
Underline I Deleted: Example................................................................
......E.p .... .Note: The-Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. Loss of all offsite AC power to Div I & 11 ENS,,bussesfor
> 15 minutes,----
Basis: Preferred station transformers are: 1RTX-XSR1C.
1RTX-XSR1D, 1RTX-XSR1E and 1RTX-XSR1F.
Prolonged loss of offSite.AC power reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete loss of AC power to emergency busses.Deeted:-Deleted: (site specific emergency-Deleted:)__
{Formatted:
Underline Deleted: or longer.Deleted: -Fifteen minutes was selected as a threshold to exclude transient or momentary losses of off-site power.
 
==References:==
 
Deleted: [At multi-unit stations, the EALs should allow credit for operation of installed design features, such as cross-ties or swing diesels, provided that abnormal or emergency operating procedures address their use. However, these stations must also consider the impact of this condition on other shared safety functions in developing the site specific EAL] &#xb6;[Plants that have a proceduralized capability to cross-tie AC power from an off-site power supply of a companion unit may take credit for the redundant power source in the associated EAL for this IC.]Formatted:
Font: 11 pt, Bold Attachment 2 Page 98 of 1241 SYSTEM MALFUNCTION su... ..D...t... ...Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Inability to reach required operating mode within Technical Specification limits,letedi~~~
~ ~~~~ sudw......................
......................
D&#xfd;eleted:
shutdown'IDeleted:
.Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown..Deleted:
Example I ,Emergency Action Level  1. Plant is not brought to required operating mode within Technical Specifications LCO Action Statement!.im , ....Basis: Limiting Conditions of Operation (LCOs) require the plant to be brought to a required operating mode when the Technical Specification required configuration cannot be restored.
Depending on the circumstances, this may or may not be an emergency or precursorto a more severe condition.
In any case, the initiation of plant shutdown required by the site Technical Specifications requires a four hour report under 10 CFR 50.72 (b) Non-emergency events. The plant is within its safety envelope when being shut down within the allowable action statemenftime in the Technical Specifications.
An immediate NOUE is required when the plant is not brought to the required operating mode within the allowable action statement time in the Technical Specifications.
Declaration of a NOUE is based on the time at which the LCO-specified action statement time period elapses under the site Technical Specifications and is not related to how long a condition may have existed.De leted..LDeleted:
T.......................
........ .... ..* "Deleted:.
............
..........................
 
==References:==
 
Deleted: [Other required Technical Specification shutdowns that involve precursors to more serious events are---- -addressed by other System Malfunction, Hazards, or Fission Product Barrier Degradation lCs.]Formatted:
Font: Bold Attachment 2 Page 99 of 121 SYSTEM MALFUNCTION Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT SUg, I De.le.t ed: 3 UNPLANNED loss of safety system annunciation or indication in the _ControI _Pom for 1_5 minuter.I Deleted: c ADeleted&#xfd;r Foratednuderine Deleted: or longer........ ................
* Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown ,Emergency Action Leve!(s):.
Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or.will likely exceed, the applicable time.1. UNPLANNED Loss of > approximately 75% of the following for >,15 mfinute..a. &#xfd;&#xfd;pntrol..roomrrl safety system annunciation, a.C nR0 ro m a eysy t m nnun iatir..........................
...................................
......b. Cpntrol .pom safety system indicatior, ............
-.Basis: This IC and its associated EAL are intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment.
Recognition of the availability of computer based indication equipment is considered e.g., SPDS, _plantcomputer_, etc.."Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.
Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected.
It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions.
It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies.
While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions.
The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.
The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the Deleted: Example ,i Deleted: greater than F -ormatted:
Underline Deleted: or longer Deleted: (Site specificc-r-........
Z=.-- ...........
... ____ ...............
[ Deleted:)
Underline Formatted:
Indent: Hanging: 0.5"!Formatted:
Indent: Left: 0", Hanging: 0.25", Space After: 0 pt Deleted: (Site specific c Deleted: r Deleted:)D l.... e.t. e d :.. .......................................................................................
4Deleted:[
Formatted:
Font: Not Italic.....-.d ...............
......Attachment 2 Page 100 of 121 SYSTEM MALFUNCTION SUB.NOUE is based on SUIL 1 ."Inability to required operating modejthin Technical Specification Yin.its.............
Annunciators or indicators for this EAL include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures (EOPs and SAPs), and in other EALs (e.g., area process, and/or effluent rad monitors, etc.). Indicators associated with safety systems are those indicators for reactivity control, core cooling, RCS status and containment status. The panels to consider include: H 13-P601, H 13-P680, H 13-P808 (CMS and DRMS), H 13-P863 (DRMS), P870 and P877 safety related annunciators and indicators.,Fifteen m.minutes was selected as a threshold to exclude transient or momentary power losses.,This NOUE will be escalated..to..anA!ert.based.on a concurrent loss. of.compensatory indications or if a SIGNIFICANT TRANSIENT is in progress during the loss of annunciation or indication.,
 
==References:==
 
I Deleted: 3 --------------------------t ... ...... ..... .................
..... ........ ... ... ...!,Deleted:
2 Deleted: R Deleted: R Deleted: Shutdown Deleted:W W Deleted: L IDeleted:
[Site specific annunciators or indicators for this EAL must include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.).] I , t.)............
I] I..........................................
I Deleted: [Due to the limited number of safety systems in operation during cold shutdown, refueling, and defueled modes, no IC is indicated during these modes of operation.]
I Formatted:
Font: Bold Attachment 2 Page 101 of 121 SYSTEM MALFUNCTION Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Fuel .Jad degradation, SUa I t 'Del etied: 4~Deleted:
C Deleted: .I Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown ,Emergency Action Levelfs}:.
(1 or 2)1. Offgas pre-treatment radiation monitor reading > the Table S1 Dose Rate Limit for the actual indicated offgas flow indicating fuel clad degradation
> T.S. allowable limits FLOW DoseRatLel F LOW Dose Rate Lirmit 15 9579 70 1865 17.875 8064 80 1671 20 7219 90 1510 25 5788 100 1376 30 4829 110 1262 32.83 2849 120 1165 35 2810 130 1082 40 2680 140 1009 45 2529 150 945 50 2377 175 815 60 2098 200 716 Deleted: Example." ............................................................................................
......Deleted: 1. (Site specific radiation monitor readings indicating fuel clad degradation greater than Technical Specification allowable limits.)Formatted:
Indent: Left: -0", Hanging: 0.25", Numbered + Level: I + Numbering Style: 1, 2, 3, ... +Start at: 1 + Alignment:
Left +Aligned at: 0" + Tab after: 0.38" +',1Indent at: 0.38", Tabs: Not at 0.38"'Formatted Table OR S Formatted:
Font: Bold, Underline Formatted:
Indent: Hanging: 0.25" Deleted: 2. (Site specific coolant sample activity value indicating fuel clad degradation greater than Technical Specification allowable limits.)Formatted:
Space After: 0 pt Formatted:
Indent: Hanging: 0.25", Right: 0", Keep lines together Attachment 2 Page 102 of 121 SYSTEM MALFUNCTION Sug.Deleted: 4 2. Reactor coolant sample activitv value indicatinq fuel clad deqradation
> T.S.allowable limits o >4.0 pCi/.qm dose equivalent 1-131-U OR e >0.2 uCi/am dose eauivalent 1-131 for > 48 hours---Formatted:
Indent: Left: 0", First line: 0", Right: 0"* Formatted:
Indent: First line: 0" Formatted:
Level 1, Indent: First line: 0.5"" Formatted:
Indent: First line: 0" I Formatted:
Indent: Left: 0.25", Bulleted + Level: 1 + Aligned at: 0.64" + Tab after: 0.89" + Indent a at: 0.89", Tabs: Not at 0.5" +Basis: This 1C,is included because it is a precursor of more serious conditions and, as result, isi considered to be a potential degradation of the level of safety of the plant.EAL #1 This EAL_ addresses site-specific radiation monitor readings that provide indication of a degradation of fuel clad integrity.
Deleted: EAL...............................
-I I Deleted: threshold The Technical Specification limit of 290 mCi/sec Offqas pre-treatment release is equivalent to 11,210 mR/hr (assumes flow of 17.875 cfm without adjustment for instrument accuracy).
The Table S1 values account for instrument inaccuracy and changing offcqas flow rate. The dose rate in the table corresponds to the adjusted TS limit for that associated indicated flow. The table dose rate values may not reflect the H13-P601/22A/F03 alarm setpoint.
To determine if EAL conditions are met when the ore-treatment high radiation alarm (H13-P601/22A/F03) is lit, the operator must read the actual indicated offqas flow rate and indicated pre-treatment mR/hr value on H 13-P600.Compare the indicated mR/hr value with the Table S1 dose rate mR/hr for the indicated flow value. If the indicated mR/hr is oreater than the Table S1 value, the EAL condition is met.f. ................
....... ........ ... ........ ... ..... .........Deleted: [Such as BWR air ejector monitors, PWR failed fuel monitors, etc.]%L Deleted: threshold EAL #2 This EAL addresses coolant samples exceeding coolant technical specifications for transient iodine spiking limits and coolant samioles exceeding coolant Technical Soecifications for nominal oneratina iodine limits for the time neriod spec~ified in the Snecifications for nominal oneratinn iodine limits for the time neriod specified in the_Technical Specifications.
Escalation of this C.nto the Alert level is via the Fission Product Barriers ,(F..
 
==References:==
 
TS 3.4.8/B 3.4.8 ,TS 3.7.4 / B 3.7.4- -----------------------------,G13.18.9.6.*012 Rev 0_G1 3.18.9.5-019-3B ,G13.18.9.5-019-3C.S R15.7.1 Formatted:
Font: 11 pt{ Formatted:
Font: 11 pt ,"' Deleted: EAL Formatted:
Font: Arial, 11 pt , Formatted:
Font: Not Bold, English'(U.S.)Formatted:
Font: Arial, 11 pt, Not Bold{ormatted:
Font: Arial, 11 pt Formatted:
Font: Arial, 11 pt Formatted:
Font: Anal, 11 pt, English (U.S.)Formatted:
Font: Arial, 11 pt, 1 [ mEnglish (U.S.)IFormatted:
Font: Arial, 11 pt,[English (U.S.)Attachment 2 Page 103 of 121 SYSTEM MALFUNCTION Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT RCS leakage, SUI Deleted:5-s L ...... .. ...........
...................
...................
:...........................................
",,D.i ................
eleted: :...........................................
Operating Mode Applicability: ,Emergency Action .Level!s:
(1 or 2)Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown ( _ -.... .... ......... ...... ...... ... .. .-Deleted: Example......__...................................
Deleted: greater than iDeleted:.
.................................
...............
: 1. Unidentified or pressure boundary leakage >.10 gpm.OR 2. Identified leakage >. gpm, Basis:-D'e'leted:
greater than'*.Deleted: 2 DPeleted:
.-...... ... ...... _-This IC is included as a NOUE because it may be a precursor of more serious conditions and, as result, is considered to be a potential degradation of the level of safety of the plant. The 10 gpm value for the unidentified or pressure boundary leakage was selected as it is observable with normal _pntrol idications.
Lesser.values mustgenerally be determined through time-consuming surveillance tests (e.g., mass balances).
Relief valve normal operation should be excluded from this IC. However, a relief valve that operates and fails to close per design should be considered applicable to this IC if the relief valve cannot be isolated.The EAL for identified leakage is set at a higher value due to the lesser significance of identified leakage in comparison to unidentified or pressure boundary leakage. In either case, escalation of this IC to the Alert level is via Fission Product Barrier Degradation (F)ICs.
 
==References:==
 
RBS Technical Specification 3.4.5.Deleted: c.DelI.eted.
Attachment 2 Page 104 of 121 SYSTEM MALFUNCTION Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Loss of all -site or. gf~site..
communications capabilitie, SUg_ (Deted': 6..........
dDeleIt ed: 0 -I: Deleted: -Operating Mode Applicability: ,Emergency .A.ction .Level(s):
(1 or 2)Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Deleted: 0" Deleted: --.... ... .....................
...... .............
Deleted: Deleted: Example..........................
: 1. -Loss of all of the following ornite communications methods affecting the ability to perform routine operations-,"---Formatted:
Level 1, Indent: Left: 0", Hanging: 0.25" I Deleted: -................
....................
iDeleted:
.Plant radio system Plant paqinaq system Sound powered phones In-plant telephones 4-OR 2. Loss of all of the following offsite communications-methods affecting the. ability.to p e rfo rm o ff s ite n o tifica tio n s;, .................................................
.............................
All telephones NRC phones State of Louisiana Radio Offsite notification system and hotline-/Formatted:
Level 1, Indent: Left: 0", Hanging: 0.25", Space After: 0 ptJ Deleted: (site specific list of communications methods)Deleted:.... ..............
IDeleted: (site specific list of I communications methods)Formatted:
Indent: Left: 0.25", First line: 0" Basis: The purpose of this IC and its associated EALs is to recognize a loss of communications capability that either defeats the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate issues with offsite authorities.,The availability of one method of ordinary offsite communications .is. sufficient toinfo.rm federal, state, and local authorities of plant problems.
This EAL is intended to be used only when extraordinary means (e.g., relaying of information from non-routine radio transmissions, individuals being sent to off-site locations, etc.) are being used to make communications possible.Deleted:-Deleted: [The loss of off-site communications ability is expected to be significantly more comprehensive than the condition addressed by 10 , .CFR.5_72.]
q Deleted: -Deleted: [Site specific list for on-site-communications loss must encompass the loss of all means of communications (e.g., commercial telephones, sound powered phone systems, page_. ..Attachment 2 Page 105 of 121 SYSTEM MALFUNCTION SUg 1. D13eleted:
6.Deleted: party system (Gaitronics)
.... ....... .... ........................
.... .........
..... ..and radios / walkie talkies) routinely used for operations.]
... .. .... .... ..... ............................' Deleted: [Site specific list for off-site communications loss must References encompass the loss of all means of communications with off-site authorities.
This should include the ENS, commercial telephone lines, telecopy transmissions, and dedicated phone systems that are i routinely used for offsite emergency notifications.]
Formatted:
Font: Bold I Deleted: _.Attachment 2 Page 106 of 121 SYSTEM MALFUNCTION Sula I Deleted: 8............
... ......................
..................................
Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Inadvertent criticality, Operating Mode Applicability:
Mode 3 ...... Hot Shutdown ,Emergency Action Level(s):.
: 1. UNPLANNED sustained positive period observed on nuclear instrumentation, ,B a s is : ............ ... .. ....... ... ..... ....This IC addresses inadvertent criticality events. This IC indicates a potential degradation of the level of safety of the plant, warranting a NOUE classification.
This IC excludes inadvertent criticalities that occur during planned reactivity changes associated with reactor startups (e.g., criticality earlier than estimated).,This condition can be identified usingj period monitors.
The term "sustained" is used in order to allow exclusion of expected short term positive periods from planned fuel bundle or control rod movements during core alteration.
These short term positive periods are the result of the rise in neutron population due to subcritical multiplication, Escalation would be by the Fission Product Barrier Table (F), as appropriate to the operating mode at the time of the event."iDeleted:.) Deleted: Example Deleted:.Deleted: [BWRI....................
..........
D Deleted: 1. UNPLANNED sustained positive startup rate observed on j nuclear instrumentation.
[PWR] IT-K.Deleted:__
~Deleted:............................
-- .......................
I-- ......... ..........
.J Attachment 2 Page 107 of 121 SYSTEM MALFUNCTION SA.-Initiating Condition
-ALERT Automatic sram fails to shut.down.
the reactor and the manual actions taken.from the reactor control console are successful in shutting down the reactor,--Formatted:
Left, Tabs: 4.42", Left+ 6", Right I Deleted: 2 I Deleted:S Deleted: (Trip). .Deleted:.
--Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup ,Em~ergency .Action L-eve!(s):
..1. a. An automatic scramrfailed to shutdown the reactor IAk ---------------------------------------------------------------------
: b. Manual actions taken at the reactor control console successfully shutdown the reactor as indicated by reactor Rower < 5%!Basis: ,Manual scranRactions.
taken at tthe reactor control console are any set of actions by the-Ractor Operator(s) which causes or should causecontro....rods to be rapidly inserted into the core and shuts down the reactor.,This condition indicates failure of the automatic protection system to scramnthe reactor...
This condition is more than a potential degradation of a safety system in that a front line automatic protection system did not function in response to a plant transient.
Thus the plant safety has been compromised because design limits of the fuel may have been exceeded.
An Alert is indicated because conditions may exist that lead to potential loss of fuel clad or RCS and because of the failure of the Reactor Protection System to automatically shutdown the plant.If manual actions taken at the reactor control console fail to shutdown the reactor, the event would escalate to a Site Area Emergency.
 
==References:==
 
.1~-D eIeIt ed: E xamrnple Deleted: (trip)dFormatted:
Font: 11 pt-( Formatted:
Underline ( Formatted:
Underline d Formatted:
Font: 11 pt Deleted: (site specific indications of plant shutdown).
Deleted: [The reactor should be considered shutdown when it producing less heat than the maximum decay heat load for which the safety systems are designed (typically 3 to 5% power). For plants I using CSFSTs, this EAL equates to.the criteria used to determine a valid Subcriticality Red Path. For BWRs this EAL should be the APRM downscale trip selpoint.]
I ...:>Deleted: (trip)3 Deleted: r Deleted: o Deleted: [If the manual scram (trip)switches/pushbuttons on the control room console panels are considered an automatic input into the Reactor Protection System, a failure to scram (trip) without any other automatic input would make this threshold applicable.]
I.Deleted: (trip).. ..........
_ j Attachment 2 Page 108 of 121 SYSTEM MALFUNCTION S A .....................................................
ed:4 Initiating Condition
-ALERT UNPLANNED Ipss of safety system annunciation or indication in the Control -Room with eithe (1) a SIGNIFICANT TRANSIENT in progress,or (2) compensatory indicators unavailab
... ....Deleted: L I ;~- ----- -.........
... ..........
................
-== = .,,. ...................
.. ..............
I .......................
., IDel eIt e d: c _.~e ; ... ..... .... ........ ..................
....Deleted: r Deleted: EITHER Deleted:._____
D ltd Examp-le Operating Mode Applicability: ,Emergency Action Leve!(s): Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. a. UNPLANNED loss of >_approximately 75% of the following for.> 15 minute_;SQntrol room safety system annunciatioRn OQ R ..........................Deleted: greater than__pntrol _,opm safety system indication, AND b. ,Eer-of the followimng:-.
----* A SIGNIFICANT TRANSIENT is in progress.OR* Compensatory indications are unavailable, Basis: This IC is intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a SIGNIFICANT TRANSIENT.
-Formatted:
Underline..~ ~ ~ ~~~~. ." .[ .F"; ...- .... : ;i:; .............
Deleted: or longer ( Formatted:
Bullets and Numbering.Deleted: (Site specific C 4 .. ........ ...-....Deleted:)Formatted:
Underline' '(Formatted:
Indent: First line: 0.88"\ Formatted:
Underline Formatted:
Bulleted + Level: 1 +Aligned at: 0.64" + Tab after: 0.89"+ Indent at: 0.89", Don't keep lines together, Don't adjust space between Latin and Asian text, Don't adjust* space between Asian text and numbers Deleted: (Site specific c r Deleted: )Formatted:
Font: Not Bold D \ I e.e.......
EITHER Formatted:
Bullets and Numbering',~1L' ! Formatted:
Font: Bold, Underline.Recognition of the availability of computer based indication ecluipment is considered
-4" Formatted:
Level 1, Indent: Left: (e.g., S PD S , plant com puter, etc.), ,.. ... ... B.ull.e and ....................................
atted:' Bullets and Num bering"Planned" loss of annunciators or indicators includes scheduled maintenance and testing ' Deleted:.activities.
'' D .'A Formatted:
Font: Not Italic Deleted:]
.....Attachment 2 Page 109 of 121 SYSTEM MALFUNCTION SA_Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected.
It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions.
It is also not intended that the Shift Managerbe basked with ma.king a judgment to..whether additional personnel are required to provide increased monitoring of system operation.
It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies.
While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions.
The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.
The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the NOUE is based on SUl "Inability to reach e.quired operating mod thin Technical.
Specification im its." .........
.......Annujnciators or indicators for this EAL include those identified in the Ahnormal Deleted: 2upervisor Deleted: 2 , ,,!Deleted:
R[ i ....... ..........
..........
...........
.... ... .. .. .... ..................
.Deleted: Shutdown Deleted: W Deleted: L Deleted: [Site-specific annunciators or indicators for this EAL must include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.).] ~__Deleted: Deleted:]Deleted: [Due to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes, no IC is indicated during these modes of operation.] Formatted:
Font: 11 pt, Bold Operating Procedures, in the Emergency Operating Procedures (EOPs and SAPs), in other EALs (e.g., area process, and/or effluent rad monitors, etc.). Indicators associated with safety systems are those indicators for reactivity control, core coolir RCS status and containment status. The panels to consider include: H13-P601, H1 P680. H13-P808 (CMS and DRMS). H13-P863 (DRMS). P870 and P877 safety rela and ig%3-ted annunciators and indicators."Compensatory indications" in this context includes computer based information such as SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits If both a major portion of the annunciation system and all computer monitoring are unavailable, the Alert is required. ,Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor the transient in progress due to a concurrent loss of compensatory indications with a SIGNIFICANT TRANSIENT in progress during the loss of annunciation or indication.,
 
==References:==
 
Attachment 2 Page 110 of 121 SYSTEM MALFUNCTION SAI_. ;Te-eted:5 5 Initiating Condition
-ALERT AC power capability to emergency busses reduced to a single power source for >_15_minutes, such that any additional single failure would result in statio.n blackout,[ ormated: Uderline-I --Operating Mode Applicability:
jEmergency Action Level(s): Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Deleted: or longer"'Deleted:
.Deleted: Example-_____
Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. a. AC power capability to Div I and II ENS. bussereduced to a singlepwer source -for > 15 minutes -ANDND b. -Any additional single power source failure will result in station blackout.-4 Formatted:
Indent: Left: 0", Hanging: 0.5" , Deleted: (site-speci fi c e merg ency ,,~~~~~~~
~~~~~ ia et a ................................
...............................
SDeleted:;
Formatted:
Underline Deleted: or longer.Formatted:
underline Formatted:
Level 1, Indent: F orantte: 0.5""'IFormatted:
Indent: Hanging: 0.75" Basis: '.,\,Preferred station transformers are: 1RTX-XSRIC, 1RTX-XSR1D, 1RTX-XSR1E and 1 RTX-XSR1 F.The condition indicated by this IC is the degradation of the offsite and onrsite AC power systems such that any additional single failure would result in a station blackout.
This condition could occur due to a loss of offsite power with a concurrent failure of all but one emergency diesel generator to supply power to its emergency busses. Another related condition could be the loss of all offsite power and loss of emergency diesels generators with only one train of emergency busses being backfed from the unit main generator, or the loss of onrsite emergency diesel generators with only one train of emergency busses beingfed from power. The subsequent Ioss of this single power source would escalate the event to a Site Area Emergency in accordance with SS1.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.Div III D/G and bus E22-S004 are not discussed explicitly in this IC. The loss of Div I and Div II are considered a station blackout.
If Div III DIG or E22-S004 is available, entry into this IC is applicable.
* Deleted:.Deleted: [This IC and the associated EALs are intended to provide an escalation from IC Sul, "Loss of All Off-site AC Power To Emergency Busses for Greater Than 15 Minutes.1'
&#xb6;Deleted: -Deleted: -Deleted:-.........
Deleted: --'Deleted:
-F ... ...... ............
...... ...De t d "-'Deleted:
back Deleted: -.. ..Attachment 2 Page 111 of 121 SYSTEM MALFUNCTION SA. I Deleted: 5............................
 
==References:==
 
Deleted: [At multi-unit stations, the EALs should allow credit for operation of installed design features, such as cross-ties or swing diesels, provided that abnormal or emergency operating procedures address their use. However, these stations must also consider the impact of this condition on other shared safety functions in developing the site specific EAL.]Deleted: [Plants that have a proceduralized capability to cross-tie AC power from an off-site power supply of a companion unit may take credit for the redundant power source in the associated EAL for this IC.]Attachment 2 Page 112 of 121 SYSTEM MALFUNCTION SS1 Initiating Condition
-SITE AREA EMERGENCY Loss of all offsite and all _qr-te AC power to emergency busses for> 15_minyute-s
.........Operating Mode Applicability:
Mode 1 ..... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Deleted: 0 ti,, ......Deleted..-.
S ' ...............
....................
.........
....................................
Deleted: -&#xa2;".IDeleted:-
0 Deleted: -Deleted: S Deleted: or longer.,Em ergency Action Leyve!(s):
.... ...............
...............
Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. __Loss of all power to Div I, II and Ill ENS bussesfor 15 minutes, Basis: Preferred station transformers are: 1RTX-XSRlC.
1RTX-XSR1D, 1RTX-XSR1E and 1 RTX-XSR1 F.Loss of all AC power to emergency busses compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink. Prolonged loss of all AC power to emergency busses will lead to loss of Fuel Clad, RCS, and Containment, thus this event can escalate to a General Emergency.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of off,site power._Consideration should be given to operable loads necessary to remove decay heat or provide Reactor Vessel makeup capability when evaluating loss of AC power to emergency busses. Even though an emergency bus may be energized, if necessary loads (i.e., loads that if lost would inhibit decay heat removal capability or Reactor Vessel makeup capability) are not operable on the energized bus then the bus should not be considered operable.
If this bus was the only energized bus then a SAE per SS1 should be declared.t Formatted:
Underline Deleted: Example 3 Formatted:
Underline Formatted:
Indent: Left: 0", Hanging: 0.25"... ,. Deleted: O Deleted: -S D el eted: 03 Deleted: -S Deleted: (site specific emergen.cy, j.=:=...............=
= :: = :=.........
=,= , =,=Deleted:)Deleted: or longer.Deleted: -Deleted: [At multi-unit stations, the EALs should allow credit for operation of installed design features, such as cross-ties or swing diesels, provided that abnormal or emergency operating procedures address their use. However, these stations must also consider the impact of this condition on other shared safety functions in developing the site specific EAL.] I[Plants that have a procedura/ized capability to cross-tie AC power from an off-site power supply of a companion unit may take credit for the redundant power source in the associated EAL for this IC.] 1[Attachment 2 Page 113 of 121 SYSTEM MALFUNCTION SS1 Escalation to General Emergency is via Fission Product Barrier Degradation F or IC SG1, "Prolonged jpss of gI qfisite, and 41 _rite AC. opwer to emergency busses." Deleted: L'; ,' Deleted: A
 
==References:==
 
'[,:,'I Deleted: 0 Power ' " .
Prolonged Loss of A Deleted: 0 Deleted: -Deleted: P t Formatted:
Font: Bold Attachment 2 Page 114 of 121 SYSTEM MALFUNCTION ss~ .Dleted*: 2 Initiating Condition
-SITE AREA EMERGENCY Automatic scram fails to shutdown the reactor and manual actions taken from the reactor control console are not successful in shutting down the reactor.Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup ,Emergency Action Level(s): 1. _a. An automatic scraRt failed to shutdgown tthe reactor, Deleted: S Deleted: (Trip)Deleted: .1 SDeleted:
Example ,- Deleted: (trip)Deleted:.
.Formatted:
Underline Formatted:
Level 1, Indent: Hanging: 1" AND'T' -b. _Manual actions taken at the reactor control console do not shutdown the reactor as indicated byireactor power > 5%,......Basis: Automatic and manual scrams are not considered successful if action away from the reactor control console was required to scram the reactor.Under theseconditions, the reactor is producing more heat than the maximum decay heat load for which the safety systems are designed and efforts to bring the reactor subcritical are unsuccessful.
A Site Area Emergency is warranted because conditions exist that lead to IMMINENT loss or potential loss of both fuel clad and RCS.Formatted:
Indent: Left: 0.25", Hanging: 0.25" Formatted:
Font: 11 pt Deleted: (site specific indications of reactor not shutdown).
..,Manual scramractions taken at the reactor control console are any set of actions by the P~eactor Qpqrator(s), which causes or should cause control rods to be rapidly inserted into the core and shuts down the reactor.Manual scram, actions are not considered successful if action away from the reactor__control console is required to scrarnthe reactor. This EAL is still applicable even if actions taken away from the reactor control console are successful in shutting the reactor down because the design limits of the fuel may have been exceeded or because of the gross failure of the Reactor Protection System to shutdown the plant.,Escalation of this event to a General Emergency would be due to a prolonged condition leading to an extreme challenge to either core-cooling or heat removal.
 
==References:==
 
Deleted: [The reactor should be considered shutdown when it producing less heat than the maximum decay heat load for which the safety systems are designed (typically 3 to 5% power). For plants using CSFSTs, this EAL equates to the criteria used to determine a valid Subcriticality Red Path. For BWRs this EAL should be the APRM' downscale trip setpoint.]
&#xb6;1 Deleted: (trip)Deleted: Deleted: o Deleted: at, Formatted:
Space After: 0 pt%.1 Deleted: (trip)Deleted: (trip)Deleted: [Although this IC may be viewed as redundant to the Fission Product Barrier Degradation IC, its inclusion is necessary to better assure timely recognition and emergency response.]
I Formatted:
Font: Bold Attachment 2 Page 115 of 121 SYSTEM MALFUNCTION Initiating Condition
-SITE AREA EMERGENCY Loss of all vital DC power for > 15 minutes.SSAI Deleted: ________3 Deleted: or longer.I Operating Mode Applicability: ,Emergency Action LevelIs): Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Deleted: Example----- ...... -..........
........ .... ...... ............
.Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. :_, 105 VDC .on al I,.vital DC busses.for>,_1_5 minutes..Basis: Loss of all DC power compromises ability to monitor and control plant safety functions.
Prolonged loss of all DC power will cause core uncovering and loss of containment integrity when there is significant decay heat and sensible heat in the reactor system.,Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation to a General Emergency would occur by Abnormal Radiation Levels/Radiological Effluent (A), Fission Product Barrier Degradationj(F).
 
==References:==
 
-Deleted: Less than .Deleted: (site specific bus voltage" ' indication)
'I Deleted: (site specific..\~ ~~~~~~~~~~~~~~
~~~~~~~~ ,(.................
...............
.........
.................., Deleted:)j Formatted:
underline Deleted: or longer.Deleted: [Site specific bus voltage should be based on the minimum bus voltage necessary for the operation of safety related equipment.
This voltage value should incorporate a margin of at least 15 minutes of operation before the onset of inability to operate those loads. This voltage is usually near the minimum voltage selected when battery sizing is performed.
Typically the value for the entire battery set is approximately 105 VDC. For a 60 cell string of batteries the cell voltage is typically 1. 75 Volts per cell. For a 58 string battery set the minimum voltage is typically 1.81 Volts per cell.] ]Formatted:
Font: Bold Attachment 2 Page 116 of 121 SYSTEM MALFUNCTION SS6 Initiating Condition
-SITE AREA EMERGENCY Inability to monitor a SIGNIFICANT TRANSIENT in progress, D e.......l.........e..........
Operating Mode Applicability: ,Emergency Action Leveltsl: Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown-Deleted: Example S....................
....................................
......................
......Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. a. Loss of >_ approximately 75% of the following forj. 5_mrinuts_
_CpntrQo RP.oom safety- system annunciation.
OR 0 .__CCntroI Sporn safety system indication,*1 11 Deleted: greater than-Formatted:
Underline f Formatted:
Indent: Left: 0", Hanging: 0.38" i Deleted: or longer Deleted: (Site specific c J I ' ' ' .i ...........................................................................................
De l t e d.r.1 Deleted: r -Deleted:)\ \Formatted:
Font: Bold, Underline AND b. A SIGNIFICANT TRANSIENT is in progressi,Compensatory indicat.-ions .are unavailable, ..................
.Basis: This IC is intended to recognize the threat to plant safety associated with the complete loss of capability of the control room staff to monitor plant response to a SIGNIFICANT TRANSIENT."Planned" and "UNPLANNED" actions are not differentiated since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected.
It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions.
It is also not intended that the Shift Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation.
It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies.
While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions.
The loss of specific, or several, safety system indicators should remain a-II&#xb6;rormatted:
Inent: ranging: 0.39", Bulleted + Level: 1 + Aligned at: 0.64" + Tab after: 0.89" +Indent at: 0.89", Tabs: 0.75", List t tab + Not at 0.89" Formatted:
Indent: Left: 0.5", No bullets or numbering ki Formatted:
Underline Formatted:
Level 1, Indent: Hanging: 0.75"' Deleted: (Site specific c Deleted: r Deleted: I Formatted:
Indent: Hanging: 0.9,Bulleted
+ Level: 1 + Aligned at: 0.64" + Tab after: 0.89" +Indent at: 0.89", Tabs: 0.75", List tab + Not at 0.89" I. Formatted:
Underline F Formatted:
Level 1, Indent: angHanging:
0.75" Deleted: .J Formatted:
Underline Formatted:
Indent: Hanging: 0.75" SDeleted:
.SDeleted:.
Deleted: Supervisor Attachment 2 Page 117 of 121 SYSTEM MALFUNCTION SS6 function of that specific system or component operability status. This will be addressed by the specific Technical Specification.
The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the NOUE is based on SUl "Inability to Leach pquired operating modq wjthin Technical Specification Jimits." A Site Area Emergency is considered to exist if the _._ntrol Room staff cannot monitor safety functions needed for protection of the public while a significant transient is in progress.,Site specific indications needed to monitor safety functions necessary for protection of the public must include _Cntrol .rn indications, computer generated indications and dedicated annunciation capability.
Annunciators or indicators for this EAL include those identified in the Abnormal Operatingi Procedures, in the Emergency Operating Procedures (EOPs and SAPs), and in other EALs (e.g., area process, and/or effluent rad monitors, etc.). Indicators associated with safety systems are those indicators for reactivity control, core cooling, RCS status and containment status. The panels to consider include: H1 3-P601, H 13-P680. H13-P808 (CMS and DRMS). H 13-P863 (DRMS). P870 and P877 safety related Deleted: 2~Deleted:
R....... j .-,, ..........................
= ...............
.. .... ..= , ,= .... ...... ...............
=....., Deleted: R........ ., ..ee d ..Deleted: Shutdown'. Deljeted:--W--
---1 Deleted: L* Deleted: c.........I'Deleted:
r ~'I r .......................................................
.........................................
....Deleted: [Site specific annunciators I for this EAL should be limited to include those identified in the I Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (.g., i area, process, and/or effluent red monitors, etc.)] q .Deleted: c annunciators and indicators.
Deleted: r ,"Compensatory indicati.o.ns'." i.n...thi.s..
co.notet includes .computer based i.n.for.rmnatiornsu..h..
as SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits.
Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Deleted: [The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled, to maintain the reactor coolant system intact, maintain the spent fuel cooled, and to maintain containment intact.] &#xb6;,
 
==References:==
 
Deleted: [Due to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes, no IC is indicated during these modes of operation.]
Formatted:
Font: Bold Attachment 2 Page 118 of 121 SYSTEM MALFUNCTION SGI Initiating Condition
-GENERAL EMERGENCY Deleted: 0 Prolonged loss of all _fosite and all op.jte AC power to emergency busse,.1 Deleted: -...................Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Deleted: O Deleted: -S Deleted:.S.........................Delted E e.....................m..................
........ ....._ ..............x ..... ...................
.........
........ ......................,E.e.gency.Action.
Leye!f&sect;s:
-.. .. ...............
: 1. a. Loss of all offsite and all onsite AC power to Div I. II and III ENS.busses.
AND b. _terofthe following:------_.
..* Restoration of at least one emergency bus in < 4 hoursis not likely, OR* RPV level can not be maintained
> -162 inches, .. ....................
.........Basis: Preferred station transformers are: 1 RTX-XSR1 C, 1 RTX-XSR1 D, 1.RTX-XSR1 E and 1RTX-XSR1F..
Loss of all AC power to emergency busses compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink. Prolonged loss of all AC power to emergency busses will lead to loss of fuel clad, RCS, and containment, thus warranting declaration of a General Emergency.
*Deleted:
--Deleted: -Deleted: (site specific emergency K Deleted: )Formatted:
Underline I,\ Formatted:
Level 1, Indent: " Hanging. 0.5 Formatted:
Font: Not Bold Deleted: EITHER" Deleted: less than (site specific Deleted:., \ \ k[ ...................
......
..................
..................................
Formatted:
Font: Bold, Underline Formatted:
Indent: Left: 0.64", No bullets or numbering Formatted:
Bullets and Numbering Deleted: (Site specific indication of continuing degradation of core cooling based on Fission Product Barrier monitoring.),his IC is specified to assure that in the unlikely event of a prolonged station blackout, timely recognition of the seriousness of the event occurs and that declaration of a General Emergency occurs as early as is appropriate, based on a reasonable assessment of the event trajectory.
The likelihood of restoring at least one emergency bus should be based on a realistic appraisal of'the situation since a delay in an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions.In addition, under these conditions, fission product barrier monitoring capability may be degraded..Although it may be difficult to predict when power can be restored, it is necessary to give the Emergency reasonable idea of- how quickly_(s)hemay need to declare a-General Emergency based on two major considerations:
Deleted: [The (site-specific ho ursj to restore AC power can be based on a site blackout coping analysis performed in conformance with 10 CFR 50.63 and Regulatory Guide 1.155, "Station Blackout," as available.
Appropriate allowance for off-site emergency response including evacuation of surrounding areas should be considered.
Although this IC may be viewed as redundant to the Fission Product Barrier Degradation IC, its inclusion is necessary to better assure timely recognition and ,.e~mer~gen~c~yre~s~pons.e.]j%
....... n... y_... n -- ..... .-...........
Formatted:
Font: Not Italic Attachment 2 Page 119 of 121 SYSTEM MALFUNCTION SGI ,1. _Are there anypresent indications that core cooling is already degraded to theont-that loss or potential loss of Fission Product Barriers is IMMINENT?,2. If there are no present indications of such core cooling degradation, how likely is it_--that power can be restored in time to assure that a loss of two barriers with a potential loss of the third barrier can be prevented?,Thus, indication of continuing core coohling degjradation must be based on Fission Product Barrier monitoring with particular emphasis on Emergency Director judqgjment as it relates to IMMINENT loss or potential loss of fission product barriers and degraded ability to monitor fission product barriers, 4 Formatted:
Font: Not Italic Formatted:
Indent: Left: 0", Hanging: 0.25" Formatted:
Font: Not Italic Formatted:
Font: Not Italic Formatted:
Font: Not Italic...............................
..............
'1 Deleted: I j Attachment 2 Page 120 of 121 SYSTEM MALFUNCTION SG .3 Deete 2 ..................
... i _Initiating Condition
-GENERAL EMERGENCY Automatic acram, and all manual actions fail to shutdown the reactor and inclication of , an extreme challenge to the ability to cool the core exists.Deleted: S _Deleted: (Trip)....... L .......~~~~~ ~....... .... .........................
Deleted: ........ ...........
... = ..... .....................
..........
_ ..... ..... ........Deleted: Example Deleted: (trip)Deleted:.Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup ,Emergency Action Leve!W: 1. _a. An automatic scram jailed to.shutdown the reactor, 4~AND b. -All manual actions do not shutdown the reactor as indicated by reactor power > 5%, A N D '. ............F/ ormatted:nderline Formatted:
Level 1, Indent: Hanging: 1" Formatted:
Indent: Left: 0.5", First line: 0", Space After: 0 pt Deleted: (site specific indications of reactor not shutdown).
Formatted:
Font: 12 pt{Formatted:
Underline Formatted:
Level 1, Indent: Hanging: 1"-- *l c. _Eitherof the following exist or have occurred due'to continued power generation:
-Formatted:
Font: Not Bold Deleted: EITHER.1 Formatted:
Indent: Left: 0.25", Hanging: 0.25" I.Core coolinq is extremely challenaed as indicated by RPV level can not be maintained
> -186 inches OR* Heat removal is extremely challenged as indicated by RPV pressure and Suppression Pool temperature cannot be maintained in the EOP Heat Capacity Temperature Limit (HCTL) Safe Zone Basis: Under these conditions, the reactor is producing more heat than the maximum decay heat load for which the safety systems are designed and efforts to bring the reactor subcritical are unsuccessful.
jn the event either of these challenges exists at a time that the reactor has not been brought below the power associated with the safety system design a core melt sequence exists. In this situation, core degradation can occur rapidly. For this reason, the General Emergency declaration is intended to be anticipatory of the fission product barrier table declaration to permit maximum offlite intervention time...................
.. ...,
 
==References:==
 
Deleted: (Site specific indication that core cooling is extremely challenged.)
Formatted:
Indent: Left: 0.5", I Bulleted + Level: 1 + Aligned at: , 0.64" + Tab after: 0.89" + Indent at: 0.89", Tabs: 0.75", List tab +Not at 0.89" I Formatted:
Indent: Left: 0.5", No bullets or numbering Formatted:
Font: Bold, Underline Formatted:
Indent: Left: 0", First line: 0", Numbered + Level: 1 +Numbering Style: 1, 2, 3, ... + Start at: 1 + Alignment:
Left + Aligned at: 0" + Tab after: 0" + Indent at: 0" Deleted: (Site specific indication that heat removal is extremely challenged.)
Formatted:
Indent: Left: 0.5", Bulleted + Level: 1 + Aligned at: 0.64" + Tab after: 0.89" + Indent at: 0.89", Tabs: Not at 0.89" +2.25" Deleted: [The reactor should be considered shutdown when it producing less heat than the l maximum decay heat load for which i the safety systems are desi9=. 12s-'
-j Formatted:
Font: Bold Attachment 2 Page 121 of 121 Attachment 3 To RBG-47165 Proposed Technical Basis Document (Clean)
RIVERBEND STATION (RBS)EAL BASIS DOCUMENT Attachment 3 Page 1 of 122 RBS EAL BASIS DOCUMENT TABLE OF CONTENTS SECTION PAGE General Notes on Basis Document Use ....................................
5 D efinitions
...........................................................................
6 Abnormal Radiation Levels/Radiological Effluents
.......................
10 AU1 ..................................................................................
11 AU2 ..................................................................................
14 AA1 ..................................................................................
16 AA2 ..................................................................................
19 AA3 ..................................................................................
21 AS1 .....................................................................................
22 AGI ..................................................................................
24 Cold Shutdown/Refueling System Malfunction
...........................
26 CUl ..................................................................................
27 CU2 ..................................................................................
28 CU3 ..................................................................................
30 CU5 ...............................................................................
.. 31 CU6 ..................................................................................
32 CU7 ................................................
33 CU8 ..................................................................................
34 CA1 ...................................................................................
35 CA3 ..................................................................................
36 CA5 ..................................................................................
38 CSI ....................................................................................
39 CGI ..................................................................................
41 Attachment 3 Page 2 of 122 RBS EAL BASIS DOCUMENT TABLE OF CONTENTS SECTION PAGE Independent Spent Fuel Storage Installation (ISFSI) Malfunction
...... 43 E-HU1 ..............................................................................
44 Fission Product Barrier Degradation
............................................
45 General Bases ..................................................................
46 Fission Product Barrier Table .............................................
47 FUI ..................................................................................
52 FA1 ..................................................................................
53 FS1 ...................................................................................
54 FG1 ...................................................................................
55 Fuel Clad Barrier EALs (FC) ....................................................
56 RCS Barrier EALs (RC) .......................................................
.60 Containment Barrier EALS (PC) ...........................................
67 Hazards and Other Conditions Affecting Plant Safety ................
74 HUI ..................................................................................
75 HU2 ..................................................................................
77 HU4 ..................................................................................
78 HU5 ..................................................................................
80 HU6 ..................................................................................
81 HA1 ..................................................................................
85 HA2 ..................................................................................
87 HA3 .................................................................................
88 HA4 ..................................................................................
89 HA5 ..................................................................................
90 HA6 ..................................................................................
92 HS1 ..................................................................................
96 HS2 ..................................................................................
97 HS3 ..................................................................................
98 Attachment 3 Page 3 of 122 RBS EAL BASIS DOCUMENT TABLE OF CONTENTS SECTION PAGE HG1 ..................................................................................
99 H G 2 .....................................................................................
100 System Malfunction
.................................................................
101 S U l .....................................................................................
102 S U 6 .....................................................................................
103 S U 7 .....................................................................................
105 S U 8 .....................................................................................
106 S U 9 .....................................................................................
107 SU1o ...................................................................................
109 S u lI ....................................................................................
110 S A 1 .....................................................................................
111 S A 3 .....................................................................................
112 S A 6 .....................................................................................
113 S S I ............................
/ ........................................................
115 S S 3 .....................................................................................
116 S S 4 .....................................................................................
117 S S 6 ......................................................................................
118 S G I ......................................................................................
120 S G 3 ......................................................................................
122 Attachment 3 Page 4 of 122 General Notes on Basis Document Use Plant Operating Mode Usage for RBS EALs: MODE TITLE REACTOR MODE AVERAGE SWITH POSITION REACTOR COOLANT TEMPERATIURE (OF)1 Power Operation Run N/A 2 Startup Refuel (a) or N/A Startup/Hot Standby 3 Hot Shutdown(a)
Shutdown > 200 4 Cold Shutdown(a)
Shutdown <_ 200 5 Refueling("'
Shutdown or Refuel N/A (a) All reactor vessel head closure bolts fully tensioned.(b) One or more reactor vessel head closure bolts less than fully tensioned.
Defueled (D) -All reactor fuel removed from reactor pressure vessel (full core offload during refueling or extended outage). This is not an operating mode designation by Technical Specifications.
This basis document serves two basic functions:
* It provides background and explanatory information based on NEI 99-01 to present a basis for the origination of the RBS EALs for reviewers and users.* The second function this basis document may provide is an aid to decision makers when making a determination to classify an emergency event. It is intended that decision makers have all the information in Attachment 7.1 of this procedure that they need to make a sound classification decision.Information that may be useful to a decision maker in classifying emergency events is also contained in the Basis section for each IC in the Basis Document.The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present. A decision maker's use of this Basis Document for assistance is not intended to delay the classification.
Attachment 3 Page 5 of 122 The following definitions are taken from NEI 99-01 and the RBS Emergency Plan and applicable to the RBS emergency classification system: AFFECTING SAFE SHUTDOWN:
Event in progress has adversely affected functions that are necessary to bring the plant to and maintain it in the applicable HOT or COLD SHUTDOWN condition.
Plant condition applicability is determined by Technical Specification LCOs in effect.Example 1: Event causes damage that results in entry into an LCO that requires the plant to be placed in HOT SHUTDOWN.
HOT SHUTDOWN is achievable, but COLD SHUTDOWN is not. This event is not"AFFECTING SAFE SHUTDOWN." Example 2: Event causes damage that results in entry into an LCO that ,requires the plant to be placed in COLD SHUTDOWN.
HOT SHUTDOWN is achievable, but COLD SHUTDOWN is not. This event is "AFFECTING SAFE SHUTDOWN." ALERT: Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA PAG exposure levels.BOMB: Refers to an explosive device suspected of having sufficient force to damage plant systems or structures.
CIVIL DISTURBANCE:
A group of persons violently protesting station operations or activities at the site.CONFINEMENT BOUNDARY:
The barrier(s) between areas containing radioactive substances and the environment.
CONTAINMENT CLOSURE: The site specific procedurally defined actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
EXPLOSION:
A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components.
EXTORTION:
An attempt to cause an action at the station by threat of force.FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIREs.Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.Attachment 3 Page 6 of 122 GENERAL EMERGENCY:
Events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.
Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.HOSTILE ACTION: An act toward a Nuclear Power Plant or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities, (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA.).HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
IMMINENT:
Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur. Where IMMINENT timeframes are specified, they shall apply.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.INTRUSION:
A person(s) present in a specified area without authorization.
Discovery of a BOMB in a specified area is indication of INTRUSION into that area by a HOSTILE FORCE.NORMAL PLANT OPERATIONS:
Activities at the plant site associated with routine testing, maintenance, or equipment operations, in accordance with normal operating or administrative procedures.
Entry into offnormal or emergency operating procedures, or deviation from normal security or radiological controls posture, is a departure from NORMAL PLANT OPERATIONS.
Attachment 3 Page 7 of 122 NOTIFICATION OF UNUSUAL EVENT (NOUE): Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.
No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.PROJECTILE:
An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.PROTECTED AREA: Encompasses all controlled areas within the security protected area fence.SABOTAGE:
Deliberate damage, mis-alignment, or mis-operation of plant equipment with the intent to render the equipment inoperable.
Equipment found tampered with or damaged due to malicious mischief may not meet the definition of SABOTAGE until this determination is made by security supervision.
SECURITY CONDITION:
Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.SIGNIFICANT TRANSIENT:
An UNPLANNED event involving one or more of the following:
(1) automatic turbine runback >25% thermal reactor power, (2)electrical load rejection
>25% full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal power oscillations
>10%.SITE AREA EMERGENCY:
Events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; 1) toward site personnel or equipment that could lead to the likely failure of or; 2) that prevent effective access to, equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA PAG exposure levels beyond the site boundary.STRIKE ACTION: A work stoppage within the PROTECTED AREA by a body of workers to enforce compliance with demands made on Entergy or its affiliates.
The STRIKE ACTION must threaten to interrupt NORMAL PLANT OPERATIONS.
UNISOLABLE:
A breach or leak that cannot be promptly isolated.UNPLANNED:
a parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions.Attachment 3 Page 8 of 122 VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment.
VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analysis.
Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or component.
Example damage includes:
deformation due to heat or impact, denting, penetration, rupture, cracking, paint blistering.
Surface blemishes (e.g., paint chipping, scratches) should not be included.VITAL AREA: Any area, normally within the PROTECTED AREA, which contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation.
Attachment 3 Page 9 of 122 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT Attachment 3 Page 10 of 122 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AU1 Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Any release of gaseous or liquid radioactivity to the environment
> 2 times the ODCM limit for_> 60 minutes Operating Mode Applicability:
Emergency Action Level(s): All (1 or 2 or 3)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown.1. VALID reading on any of the radiation monitors in Table R1 > the NOUE reading for >60 minutes OR 2. VALID reading on RMS-RE107 effluent monitor > 2 times the alarm setpoint established by a current radioactivity discharge permit for > 60 minutes OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times the ODCM limit for > 60 minutes Primary 4GE125 Secondary 1GE126 3.06E+05 .lCi/sec 5.26E-03 jiCi/ml Fuel Building Vent Primary 4GE005 2.19E+04 iCi/sec Secondary 5GE005 4.65E-03 &#xfd;iCi/ml Radwaste Building Vent* Primary 4GE006 2.58E+04 &#xfd;iCi/sec Secondary 5GE006 6.84E-04 piCi/ml Attachment 3 Page 1 I of 122 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AU1 Basis: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.This IC addresses a potential reduction in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time.RBS incorporates features intended to control the release of radioactive effluents to the environment.
Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases (Offsite Dose Calculation Manual -ODCM). The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls.The ODCM multiples are specified in AU1 and AA1 only to distinguish between non-emergency conditions, and from each other. While these multiples obviously correspond to an offsite dose or dose rate, the emphasis in classifying these events is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate.Releases should not be prorated or averaged over 60 minutes. For example, a release exceeding 4 X the ODCM limit for 30 minutes does not meet the threshold for this IC.This Initiating Condition includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit.EAL #1 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in the Initiating Condition.
This EAL is intended for sites that have established effluent monitoring on non-routine release pathways for which a discharge permit would not normally be prepared.Any release on the routine effluent monitors in excess of the TRM limit is considered a non-routine release. Table R1 provides the monitors' EAL setpoint values. Values are provided for a primary and secondary source for NOUE and Alert EAL determination.
The Division I safety related monitors (DRMS 4GE125 and 4GE005) are the preferred source for main plant exhaust and fuel building EAL determination.
Radwaste building preferred value is the effluent monitor (4GE006).
The secondary monitors in Table R1 should be used to determine EALs if the preferred monitors are inoperable.
EAL #2 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in this Initiating Condition Attachment 3 A mPage 12 of 122 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AUI established by the radioactivity discharge permit. This value is associated with a planned batch release.EAL #3 This EAL addresses uncontrolled releases that are detected by sample analyses, particularly on unmonitored pathways, e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.
 
==References:==
 
T.R. 3.11 RSP-0008, Offsite Dose Calculation Manual (ODCM)G.1 3.18.9.6*012 Rev 0, Effect of Core Uprate on the DRMS Process Safety Limit/Conversion Factors/ PR-C-495 Rev 2 p 4 ESK-RMS05 ESK-RMS25 Attachment 3 Page 13 of 122 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AU2 Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT UNPLANNED rise in plant radiation levels Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2)1. a. UNPLANNED water level drop in a reactor refueling pathway as indicated by any of the following:
* Water level drop in the reactor refueling cavity, spent fuel pool or fuel transfer canal indication on Control Room Panel 870* Personnel observation by visual or remote means AND b. UNPLANNED VALID area radiation monitor alarm on any of the following:.
RMS-RE140 RMS-RE141 RMS-RE1 92 RMS-RE193 OR 2. UNPLANNED VALID area radiation monitor readings or survey results indicate a rise by a factor of 1000 over normal* levels NOTE: For area radiation monitors with ranges incapable of measuring 1000 times normal* levels, classification shall be based on VALID full scale indications unless surveys confirm that area radiation levels are below 1000 times normal* within 15 minutes of the area radiation monitor indications going full scale.*Normal can be considered as the highest reading in the past twenty-four hours excluding the current peak value.Basis: This IC addresses elevated radiation levels as a result of a water level drop above irradiated fuel or events that have resulted, or may result, in UNPLANNED rises in radiation dose rates within plant buildings.
These radiation rises represent a loss of control over radioactive material and represent a potential degradation in the level of safety of the plant.Attachment 3 Page 14 of 122 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AU2 EAL #1 The locations of the EAL specific area radiation monitors are: Containment RMS-RE140, North Refueling Floor RMS-RE141, South Refueling Floor Fuel Building RMS-RE192, South Operating Floor RMS-RE193, North Operating Floor The refueling pathway is a site specific combination of cavities, tubes, canals and pools.While a radiation monitor could detect a rise in dose rate due to a drop in the water level, it might not be a reliable indication of whether or not the fuel is covered.For example, a refueling bridge ARM reading may increase due to planned evolutions such as head lift, or even a fuel assembly being raised in the manipulator mast. Also, a monitor could infact be properly responding to a known event involving transfer or relocation of a source, stored in or near the fuel pool or responding to a planned evolution such as removal of the reactor head. Generally, increased radiation monitor indications will need to be combined with another indicator (or personnel report) of water loss.For refueling events where the water level drops below the RPV flange classification would be via CU2. This event escalates to ah Alert per AA2 if irradiated fuel outside the reactor vessel is uncovered.
For events involving irradiated fuel in the reactor vessel, escalation would be via the Fission Product Barrier Matrix for events in operating modes 1-3.EAL #2 This EAL addresses rises in plant radiation levels that represent a loss of control of radioactive material resulting in a potential degradation in the level of safety of the plant.This EAL excludes radiation level rises that result from planned activities such as use of radiographic sources and movement of radioactive waste materials.
A specific list of ARMs is not required as it would restrict the applicability of the Threshold.
The intent is to identify loss of control of radioactive material in any monitored area.
 
==References:==
 
Attachment 3 Page 15 of 122 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AA1 Initiating Condition
-ALERT Any release of gaseous or liquid radioactivity to the environment
> 200 times the ODCM limit for_> 15 minutes Operating Mode Applicability:
All Emergency Action Level(s):'
(1 or 2 or 3)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown.1. VALID reading on any of the radiation monitors in Table R1 > the ALERT reading for> 15 minutes OR 2. For RMS-RE107 effluent monitor: EITHER VALID reading > 200 times the alarm setpoint established by a current radioactivity discharge permit for> 15 minutes OR VALID reading > 1.27E-01 pCi/mI for > 15 minutes OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 200 times the ODCM limit for > 15 minutes Attachment 3 Page 16 of 122 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AA1 Primary Secondary 4GE125 1GE126 3.06E+07 pCi/sec 2.82E-01 p 1 Ci/ml Fuel Building Vent Primary 4GE005 2.19E+06 pCi/sec Secondary 5GE005 2.82E-01 1 iCi/ml Radwaste Building Vent Primary 4GE006 2.58E+06 jtCi/sec Secondary 5GE006 6.84E-02 pCi/ml Basis: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.This IC addresses an actual or substantial potential reduction in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. RBS incorporates features intended to control the release of radioactive effluents to the environment.
Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases.The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls.The ODCM multiples are specified in AU1 and AA1 only to distinguish between non-emergency conditions, and from each other. While these multiples obviously correspond to an off-site dose or dose rate, the emphasis in classifying these events is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate.Releases should not be prorated or averaged.
For example, a release exceeding 600 times the ODCM limit for 5 minutes does not meet the threshold for this IC.This Initiating Condition includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit.EAL #1 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in the Initiating Condition.
This EAL is intended for sites that have established-effluent monitoring on non-routine release pathways for which a discharge permit would not normally be prepared.Attachment 3 Page 17 of 122 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AA1 Any release on the routine effluent monitors in excess of the TRM limit is considered a non-routine release. Table R1 provides the monitors' EAL setpoint values. Values are provided for a primary and secondary source for NOUE and Alert EAL determination.
The Division I safety related monitors (DRMS 4GE125 and 4GE005) are the preferred source for main plant exhaust and fuel building EAL determination.
Radwaste building preferred value is the effluent monitor (4GE006).
The secondary monitors in Table R1 should be used to determine EALs if the preferred monitors are inoperable.
EAL #2 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in this Initiating Condition established by the radioactivity discharge permit. This value is associated with a planned batch release.Historical release permits indicate that the Alert value of 200 times the radiation monitor setpoint established by the current permit may exceed the operating range of the RMS-RE107 effluent monitor in some instances.
This potentially affected monitor is listed in EAL #2 with a corresponding value for the top of its indicating range.EAL #3 This EAL addresses uncontrolled releases that are detected by sample analyses, particularly on unmonitored pathways, e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.
 
==References:==
 
T.R. 3.11 RSP-0008, Offsite Dose Calculation Manual (ODCM)G. 13.18.9.6*012 Rev 0, Effect of Core Uprate on the DRMS Process Safety Limit/ Conversion Factors / PR-C-495 Rev 2 p 4 ESK-RMS05 ESK-RMS25 Attach'ment 3 Page 18 of 122 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AA2 Initiating Condition
-ALERT Damage to irradiated fuel or loss of water level that has resulted or will result in the uncovering of irradiated fuel outside the reactor vessel Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2)1. A water level drop in the reactor refueling cavity, spent fuel pool or fuel transfer canal that will result in irradiated fuel becoming uncovered OR 2. A VALID reading on any of the following radiation monitors due to damage to irradiated fuel or loss of water level: RMS-RE140 2000 mR/hr RMS-RE141 2000 mR/hr RMS-RE192 2000 mR/hr RMS-RE193 2000 mR/hr RMS-RE5A 1.64E+03 [tCi/sec RMS-RE5B (GE) 5.29E-04 &#xfd;tCi/ml Basis: This IC addresses rises in radiation dose rates within plant buildings, and may be a precursor to a radioactivity release to the environment.
These events represent a loss of control over radioactive material and represent an actual or substantial potential degradation in the level of safety of the plant.These events escalate from AU2 in that fuel activity has been released, or is anticipated due to fuel heatup. This IC applies to spent fuel requiring water coverage and is not intended to address spent fuel which is licensed for dry storage.The locations of the EAL specific area radiation monitors are: Containment RMS-RE140 North Refueling Floor RMS-RE141 South Refueling Floor Fuel Building RMS-RE192 South Operating Floor RMS-RE193 North Operating Floor RMS-RE5A (B) Fuel Building Ventilation Exhaust EAL #1 Indications may include instrumentation such as water level and local area radiation monitors, and personnel (e.g., refueling crew) reports. Depending on available level indication, the declaration may be based on indications of water makeup rate or I Attachment 3 Page 19 of 122 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AA2 decrease in Refueling Water Storage Pool level. Video cameras (Security or outage-related) may allow remote observation of level.EAL #2 This EAL addresses radiation monitor indications of fuel uncovery and/or fuel damage.Elevated ventilation monitor readings may be an indication of a radioactivity release from the fuel, confirming that damage has occurred.
Elevated background at the ventilation monitor due to water level drop may mask elevated ventilation exhaust airborne activity and needs to be considered.
While a radiation monitor could detect a rise in dose rate due to a drop in the water level, it might not be a reliable indication of whether or not the fuel is covered.For example, a refueling bridge ARM reading may increase due to planned evolutions such as head lift, or even a fuel assembly being raised in the manipulator mast. Also, a monitor could in fact be properly responding to a known event involving transfer or relocation of a source, stored in or near the fuel pool or responding to a planned evolution such' as removal of the reactor head. Generally, elevated radiation monitor indications will need to be combined with another indicator (or personnel report)of water loss.The Abnormal Operating Procedure (AOP) provides a table for guidance on pool level and of potential scenarios and the expected pool level assuming no operator action. The AOP is also entered for UNPLANNED lowering of refueling cavity or lower fuel pool water level during refueling operations.
When control rod blades are stored in the Spent Fuel Pool, dose rate rise in the area may be attributed to the stored items instead of uncovered fuel assemblies.
Escalation of this emergency classification level, if appropriate, would be based on AS1 or AG 1.
 
==References:==
 
TS Table 3.3.6.2-1 Calculation G13.18.9.4*10 Attachment 3 Page 20 of 122 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AA3 Initiating Condition
-ALERT Rise in radiation levels within the facility that impedes operation of systems required to maintain plant safety functions Operating Mode Applicability:
All Emergency Action Level(s): Dose rate > 15 mR/hr in any of the following areas requiring continuous occupancy to maintain plant safety functions:
Main Control Room CAS Basis: This IC addresses elevated radiation levels that: impact continued operation in areas requiring continuous occupancy to maintain safe operation or to perform a safe shutdown.The cause and/or magnitude of the rise in radiation levels is not a concern of this IC. The Emergency Director must consider the source or cause of the elevated radiation levels and determine if any other IC may be involved.This IC is not meant to apply to increases in the containment dome radiation monitors as these are events which are addressed in the fission product barrier matrix EALs.RP surveys should be performed in the CAS area if radiation above the program limit is detected outside the RCA. The Control Room area radiation monitor should be observed for EAL conditions if rising radiation levels are detected outside the RCA.The Main Control Room and CAS are the areas at RBS requiring continuous occupancy.
 
==References:==
 
Attachment 3 Page 21 of 122 ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENT AS1 Initiating Condition
-- SITE AREA EMERGENCY Offsite dose resulting from an actual or IMMINENT release of gaseous radioactivity
> 100 mR TEDE or 500 mR thyroid CDE for the actual or projected duration of the release Operating Mode Applicability:
Emergency Action Level(s): All (1 or2or3)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. If dose assessment results are available, the classification should be based on EAL #2 instead of EAL #1. Do not delay declaration awaiting dose assessment results.1. VALID reading on any of the radiation monitors in Table R1 > the SITE AREA EMERGENCY reading for > 15 minutes OR 2. Dose assessment using actual meteorology indicates doses > 100 mR TEDE or 500 mR thyroid CDE at or beyond the SITE BOUNDARY OR 3. Field survey results indicate closed window dose rates > 100 mR/hr expected to continue for > 60 minutes; or analyses of field survey samples indicate thyroid CDE >500 mR for one hour of inhalation, at or beyond the SITE BOUNDARY Primary Secondary 4GE125 N/A 4.70E+07 PCi/sec Fuel Building Vent Primary 4GE005 6.70E+06 1 iCi/sec Secondary N/A Radwaste Building Vent N/A Attachment 3 Page 22 of 122 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AS1 Basis: This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.EAL #1 The monitor list in EAL #1 includes monitors on all potential release pathways.EAL #2 Since dose assessment in EAL #2 is based on actual meteorology, whereas the monitor readings in EAL #1 are not, the results from these assessments may indicate that the classification is not warranted, or may indicate that a higher classification is warranted.
For this reason, emergency implementing procedures should call for the timely performance of dose assessments using actual meteorology and release information.
If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor reading EALs.
 
==References:==
 
Attachment 3 Page 23 of 122 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AG1 Initiating Condition
-- GENERAL EMERGENCY Offsite dose resulting from an actual or IMMINENT release of gaseous radioactivity
> 1000 mR TEDE or 5000 mR thyroid CDE for the actual or projected duration of the release using actual meteorology ,Operating Mode Applicability:
Emergency Action Level(s): All (1 or 2 or 3)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. If dose assessment results are available, the classification should be based on EAL #2 instead of EAL #1. Do not delay declaration awaiting dose assessment results.1. VALID reading on any of the radiation monitors in Table R1 > the GENERAL EMERGENCY reading for > 15 minutes OR 2. Dose assessment using actual meteorology indicates doses > 1000 mR TEDE or 5000 mR thyroid CDE at or beyond the SITE BOUNDARY OR 3. Field survey results indicate closed window dose rates > 1000 mR/hr expected to continue for > 60 minutes; or analyses of field survey samples indicate thyroid CDE >5000 mR for one hour of inhalation, at or beyond the SITE BOUNDARY Main Plant Vent Primary Secondary 4GE125 N/A 4.70E+08 pCi/sec Fuel Building Vent Primary 4GE005 6.70E+07 lICi/sec Secondary N/A Radwaste Building Vent N/A Attachment 3 Page 24 of 122 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT AG1 Basis: This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed the EPA Protective Action Guides (PAGs). Public protective actions will be necessary.
Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and likely involve fuel damage.EAL #1 The monitor list in EAL #1 includes monitors on all potential release pathways.EAL #2 Since dose assessment in EAL #2 is based on actual meteorology, whereas the monitor readings in EAL #1 are not, the results from these assessments may indicate that the classification is not warranted.
For this reason, emergency implementing procedures should call for the timely performance of dose assessments using actual meteorology and release information.
If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor reading EALs.
 
==References:==
 
Attachment 3 Page 25 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION Attachment 3 Page 26 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CU1 Initiating Condition
-- NOTIFICATION OF UNUSUAL EVENT RCS leakage Operating Mode Applicability:
Mode 4 ....... Cold Shutdown Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. RCS leakage results in the inability to maintain or restore RPV level > +9.7 inches (Level 3) for > 15 minutes Basis: This IC is considered to be a potential degradation of the level of safety of the plant. The inability to maintain or restore level is indicative of loss of RCS inventory.
Relief valve normal operation should be excluded from this IC. However, a relief valve that operates and fails to close per design should be considered applicable to this IC if the relief valve cannot be isolated.Prolonged loss of RCS Inventory may result in escalation to the Alert emergency classification level via either CA1 or CA3.
 
==References:==
 
Attachment 3 Page 27 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CU2 Initiating Condition
-- NOTIFICATION OF UNUSUAL EVENT UNPLANNED loss of RCS/RPV inventory Operating Mode Applicability:
Mode 5 ...... Refueling Emergency Action Level(s):
(1 or 2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. UNPLANNED RCS level drop as indicated by either of the following:
: a. RCS water level drop below the RPV flange for.> 15 minutes when the RCS level band is established above the RPV flange OR b. RCS water level drop below the RPV level band for > 15 minutes when the RCS level band is established below the RPV flange OR 2. RCS level cannot be monitored with a loss of RCS inventory as indicated by an unexplained rise in floor or equipment sump level, Suppression Pool level, vessel make-up rate or observation of leakage or inventory loss Basis: This IC is a precursor of more serious conditions and considered to be a potential degradation of the level of safety of the plant.Refueling evolutions that lower RCS water level below the RPV flange are carefully planned and procedurally controlled.
An UNPLANNED event that results in water level lowering below the RPV flange, or below the planned RCS water level for the given evolution (if the planned RCS water level is already below the RPV flange), warrants declaration of a NOUE due to the reduced RCS inventory that is available to keep the core covered.The allowance of 15 minutes was chosen because it is reasonable to assume that level can be restored within this time frame using one or more of the redundant means of makeup that should be available.
If level cannot be restored in this time frame then it may indicate a more serious condition exists.Continued loss of RCS Inventory will result in escalation to the Alert emergency classification level via either CA1 or CA3.Attachment 3 Page 28 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CU2 EAL #1 This EAL involves a drop in RCS level below the top of the RPV flange that continues for 15 minutes due to an UNPLANNED event. This EAL is not applicable to reductions in flooded reactor cavity level, which is addressed by AU2 EAL1, until such time as the level drops to the level of the vessel flange.If RPV level continues to drop and reaches the Low-Low ECCS Actuation Setpoint then escalation to CA1 would be appropriate.
EAL #2 This EAL addresses conditions in the refueling mode when normal means of core temperature indication and RCS level indication may not be available.
Redundant means of RPV level indication will normally be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted.
However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RPV inventory loss was occurring by observing sump and tank level changes. Sump and tank level rise must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.Escalation to the Alert emergency classification level would be via either CAl or CA3.
 
==References:==
 
Attachment 3 Page 29 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CU3 Initiating Condition NOTIFICATION OF UNUSUAL EVENT UNPLANNED loss of decay heat removal capability with irradiated fuel in the RPV Operating Mode Applicability:
Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling Emergency Action Level(s):
(1 or 2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. UNPLANNED event results in RCS temperature exceeding 200 IF.OR 1. Loss of all RCS temperature and RCS/RPV level indication for > 15 minutes.Basis: This IC is a precursor of more serious conditions and, as a result, is considered to be a potential degradation of the level of safety of the plant. In cold shutdown the ability to remove decay heat relies primarily on forced cooling flow. Operation of the systems that provide this forced cooling may be jeopardized due to the unlikely loss of electrical power or RCS inventory.
Since the RCS usually remains intact in the cold shutdown mode a large inventory of water is available to keep the core covered.During refueling the level in the RPV will normally be maintained above the RPV flange.Refueling evolutions that lower water level below the RPV flange are carefully planned and procedurally controlled.
Loss of forced decay heat removal at reduced inventory may result in more rapid rises in RCS/RPV temperatures depending on the time since shutdown.Normal means of core temperature indication and RCS level indication may not be available in the refueling mode. Redundant means of RPV level indication are therefore procedurally installed to assure that the ability to monitor level will not be interrupted.
However, if all level and temperature indication were to be lost in either the cold shutdown of refueling modes, EAL 2 would result in declaration of a NOUE if both temperature and level indication cannot be restored within 15 minutes from the loss of both means of indication.
Escalation to Alert would be via CA1 based on an inventory loss or CA3 based on exceeding its temperature criteria.
 
==References:==
 
Attachment 3 Page 30 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CU5 Initiating Condition
-- NOTIFICATION OF UNUSUAL EVENT AC power capability to emergency busses reduced to a single power source for > 15 minutes such that any additional single failure would result in station blackout Operating Mode Applicability:
Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.2. a. AC power capability to Div I and Div II ENS busses reduced to a single power source for > 15 minutes AND b. Any additional single power source failure will result in station blackout Basis: Preferred station transformers are: 1RTX-XSRIC, 1RTX-XSR1D, 1RTX-XSR1E and 1 RTX-XSR1 F.The condition indicated by this IC is the degradation of the offsite and onsite AC power systems such that any additional single failure would result in a station blackout.
This condition could occur due to a loss of offsite power with a concurrent failure of all but one emergency generator to supply power to its emergency busses. Another related condition could be the loss of onsite emergency diesels generators with only one train of emergency busses being fed from offsite power (or backfed from offsite power through the main transformer).
The subsequent loss of this single power source would escalate the event to an Alert in accordance with CA5.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.Div III D/G and bus E22-S004 are not discussed explicitly in this IC. The loss of Div I and Div II are considered a station blackout.
If Div III D/G or E22-S004 is available, entry into this IC is applicable.
 
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Attachment 3 Page 31 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CU6 Initiating Condition
-- NOTIFICATION OF UNUSUAL EVENT Loss of required DC power for > 15 minutes Operating Mode Applicability:
Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. < 105 VDC on required Vital DC busses for > 15 minutes Basis: The purpose of this IC and its associated EAL is to recognize a loss of DC power compromising the ability to monitor and control the removal of decay heat during Cold Shutdown or Refueling operations.
It is intended that the loss of the operating (operable) train is to be considered.
If this loss results in the inability to maintain cold shutdown, the escalation to an Alert will be per CA3.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.
 
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Attachment 3 Page 32 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CU7 Initiating Condition
-- NOTIFICATION OF UNUSUAL EVENT Inadvertent criticality Operating Mode Applicability:
Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling Emergency Action Level(s): 1. UNPLANNED sustained positive period observed on nuclear instrumentation Basis: This IC addresses criticality events that occur in Cold Shutdown or Refueling modes such as fuel mis-loading events .This IC indicates a potential degradation of the level of safety of the plant, warranting a NOUE classification.
This condition can be identified using period monitors.
The term "sustained" is used in order to allow exclusion of expected short term positive periods from planned fuel bundle or control rod movements during core alteration.
These short term positive periods are the result of the rise in neutron population due to subcritical multiplication.
Escalation would be by Emergency Director Judgment.
 
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Attachment 3 Page 33 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CU8 Initiating Condition
-- NOTIFICATION OF UNUSUAL EVENT Loss of all onsite or offsite communications capabilities Operating Mode Applicability:
Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling Mode D ...... Defueled Emergency Action Level(s):
(1 or 2)1. Loss of all of the following onsite communication methods affecting the ability to perform routine operations:
Plant radio system Plant paging system Sound powered phones In-plant telephones OR 2. Loss of all of the following offsite communication methods affecting the ability to perform offsite notifications:
All telephones NRC phones State of Louisiana Radio Offsite notification system and hotline Basis: The purpose of this IC and its associated EALs is to recognize a loss of communications capability that either defeats the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate issues with offsite authorities.
The loss of offsite communications ability is expected to be significantly more comprehensive than the condition addressed by 10 CFR 50.72.The availability of one method of ordinary offsite communications is sufficient to inform federal, state, and local authorities of plant issues. This EAL is intended to be used only when extraordinary means (e.g., relaying of information from radio transmissions, individuals being sent to offsite locations, etc.) are being utilized to make communications possible.
 
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Attachment 3.Page 34 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CA1 Initiating Condition
-ALERT Loss of RCS/RPV inventory Operating Mode Applicability:
Mode 4 ....... Cold Shutdown Mode 5 ....... Refueling Emergency Action Level(s):
(1 or 2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. UNPLANNED loss of RCS inventory as indicated by RPV level < -43 inches (Level 2)OR 2. RCS level cannot be monitored for > 15 minutes with a loss of RCS inventory as indicated by an unexplained rise in floor or equipment sump level, Suppression Pool level, vessel make-up rate or observation of leakage or inventory loss Basis: These EALs are not applicable when the RPV is defueled and serve as precursors to a loss of ability to adequately cool the fuel. The magnitude of this loss of water indicates that makeup systems have not been effective and may not be capable of preventing further RPV level lowering and potential core uncovery.
This condition will result in a minimum emergency classification level of an Alert.EAL #1 The inability to restore and maintain level after reaching this setpoint would be indicative of a failure of the RCS barrier.EAL #2 In the cold shutdown mode, normal RCS level and RPV level instrumentation systems will usually be available.
In the refueling mode, normal means of RPV level indication may not be available.
Redundant means of reactor vessel level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted.
However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RPV inventory loss was occurring by observing sump and tank level changes. Sump and tank level rise must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.If RPV level continues to lower then escalation to Site Area Emergency will be via CSI.
 
==References:==
 
Attachment 3 Page 35 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CA3 Initiating Condition
-ALERT Inability to maintain plant in cold shutdown Operating Mode Applicability:
Emergency Action Level(s): Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling (1 or 2)1. An UNPLANNED event results in RCS temperature
> 200 &deg;F for > the specified duration in Table C2 OR 2. An UNPLANNED event results in RCS pressure rise> 10 psig due to a loss of RCS cooling Table C2: RCS Reheat Duration Thresholds RCS Containment Closure Duration Intact N/A 60 minutes*Not intact Established 20 minutes-Not Established 0 minutes*If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then the EAL is not applicable.
Basis: EAL #1 The RCS Reheat Duration Threshold table addresses complete loss of functions required for core cooling for greater than 60 minutes during refueling and cold shutdown modes when RCS integrity is established.
RCS integrity should be considered to be in place when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams). The 60 minute time frame should allow sufficient time to restore cooling without there being a substantial degradation in plant safety.The RCS Reheat Duration Threshold table also addresses the complete loss of functions required for core cooling for greater than 20 minutes during refueling and cold shutdown modes when CONTAINMENT CLOSURE is established but RCS integrity is not established.)
As discussed above, RCS integrity should be assumed to be in place when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams) The allowed 20 minute time frame was included to allow operator action to restore the heat removal function, if possible Finally, the EAL addresses complete loss of functions required for core cooling during refueling and cold shutdown modes when neither CONTAINMENT CLOSURE nor RCS integrity are established.
Attachment 3 Page 36 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CA3 The (*) indicates that this EAL is not applicable if actions are successful in restoring an RCS heat removal system to operation and RCS temperature is being reduced within the specified time frame.EAL #2 The 10 psig pressure rise addresses situations where, due to high decay heat loads, the time provided to restore temperature control, should be less than 60 minutes. The RCS pressure setpoint chosen should be 10 psi or the lowest pressure that the site can read on installed Control Board instrumentation that is equal to or greater than 10 psig.Escalation to Site Area Emergency would be via CS1 should boiling result in significant RPV level loss leading to core uncovery.A loss of Technical Specification components alone is not intended to constitute an Alert.The same is true of a momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available.
The Emergency Director must remain alert to events or conditions that lead to the conclusion that exceeding the EAL is IMMINENT.
If, in the judgment of the Emergency Director, an IMMINENT situation is at hand, the classification should be made as if the threshold has been exceeded..
 
==References:==
 
Attachment 3 Page 37 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CA5 Initiating Condition
-ALERT Loss of all offsite and all onsite AC power to emergency busses for > 15 minutes Operating Mode Applicability:
Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling Mode D ...... Defueled Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. Loss of all offsite and all on-site AC power to Div I & Div II ENS busses for> 15 minutes Basis: Preferred station transformers are: 1RTX-XSR1C, 1RTX-XSR1D, 1RTX-XSR1E and 1 RTX-XS R 1 F.Loss of all AC power to Div I & Div II compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal, Spent Fuel Heat Removal and the Ultimate Heat Sink.The event can be classified as an Alert when in cold shutdown, refueling, or defueled mode because of the significantly reduced decay heat and lower temperature and pressure, raising the time to restore one of the emergency busses, relative to that specified for the Site Area Emergency EAL.Consideration should be given to operable loads necessary to remove decay heat or provide Reactor Vessel makeup capability when evaluating loss of AC power to emergency busses. Even though an emergency bus may be re-energized, if necessary loads (i.e., loads that if lost would inhibit decay heat removal capability or Reactor Vessel makeup capability) are not functional on the energized bus, then the bus should not be considered restored for this EAL.Escalating to Site Area Emergency, if appropriate, is by Abnormal Rad Levels /Radiological Effluent ICs.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.
 
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Attachment 3 Page 38 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CS1 Initiating Condition
-SITE AREA EMERGENCY Loss of RCS/RPV inventory affecting core decay heat removal capability Operating Mode Applicability:
Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling Emergency Action Level(s):
(1 or 2 or 3)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. With CONTAINMENT CLOSURE not established, RPV level < -49 inches OR 2. With CONTAINMENT CLOSURE established, RPV level < -162 inches (TAF)OR 3. RCS level cannot be monitored for > 30 minutes with a loss of RCS inventory as indicated by any of the following: " RMS-RE16 reading> 100 R/hr* Erratic Source Range Monitor indication" Unexplained rise in floor or equipment sump level, Suppression Pool level, vessel make-up rate or observation of leakage or inventory loss Basis: These EALs are not applicable when the RPV is defueled.Under the conditions specified by this IC, continued reduction in RCS level is indicative of a loss of inventory control. Inventory loss may be due to an RCS breach, pressure boundary leakage, or continued boiling in the RPV. Thus, declaration of a Site Area Emergency is warranted.
Escalation to a General Emergency is via CG1 or AG1.EAL #3 In the cold shutdown mode, normal RCS level and RPV level instrumentation systems will usually be available.
In the refueling mode, 'normal means of RPV level indication may not be available.
Redundant means of RPV level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted.
However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RPV inventory loss was occurring by observing sump and tank level changes. Sump and tank level rise Attachment 3 Page 39 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CS1 must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.The 30-minute duration allows sufficient time for actions to be performed to recover inventory control equipment.
As water level in the RPV lowers, the dose rate above the core will rise. The dose rate due to this core shine should result in site specific monitor indication and possible alarm.
 
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COP-1050 NEDC-33045P Calculation G13.18.9.4-047 Rev. 0 Attachment I Page 40 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CG1 Initiating Condition
-GENERAL EMERGENCY Loss of RCS/RPV inventory affecting fuel clad integrity with containment challenged Operating Mode Applicability:
Mode 4 ...... Cold Shutdown Mode 5 ...... Refueling Emergency Action Level(s):
(1 or 2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. a. RPV level < -162 inches (TAF) for_> 30 minutes AND b. Any containment challenge indication in Table C1 OR 2. a. RCS level cannot be monitored with core uncovery indicated by any of the following for_> 30 minutes:* RMS-RE16 reading > 100 R/hr* Erratic Source Range Monitor indication" Unexplained rise in floor or equipment sump level, Suppression Pool level, vessel make-up rate or observation of leakage or inventory loss AND b. Any containment challenge indication in Table C1 Table C1 Containment Challenge Indications
* CONTAINMENT CLOSURE not established
* Explosive mixture inside containment
* UNPLANNED rise in containment pressure* Secondary containment area radiation monitor above EOP Max Safe Operatinq Value below: Area DRMS Max Safe Operating Value Grid 2 RHR Equip 1213 9.5E+03 mR/hr RmA RHR Equip 1214 9.5E+03 mR/hr Rm B RHR Equip 1215 9.5E+03 mR/hr Rm C Attachment 3 Page 41 of 122 COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION CG1 Basis: These EALs are not applicable when the RPV is defueled.This IC represents the inability to restore and maintain RPV level to above the top of active fuel with containment challenged.
Fuel damage is probable if RPV level cannot be restored, as available decay heat will cause boiling, further reducing the RPV level. With the CONTAINMENT breached or challenged then the potential for unmonitored fission product release to the environment is high. This represents a direct path for radioactive inventory to be released to the environment.
This is consistent with the definition of a GE. The GE is declared on the occurrence of the loss or IMMINENT loss of function of all three barriers.A number of variables can have a significant impact on heat removal capability challenging the Fuel Clad barrier. Examples include initial vessel level and shutdown heat removal system design.Analysis indicates that core damage may occur within an hour following continued core uncovery therefore, 30 minutes was conservatively chosen. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30 minute core uncovery time limit then escalation to GE would not occur.In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive mixture of dissolved gasses in Containment.
However, Containment monitoring and/or sampling should be performed to verify this assumption and a General Emergency declared if it is determined that an explosive mixture exists.EAL #2 Sump and tank level rise must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.In the cold shutdown mode, normal RCS level and RPV level instrumentation systems will usually be available.
In the refueling mode, normal means of RPV level indication may not be available.
Redundant means of RPV level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted.
However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RPV inventory loss was occurring by observing sump and tank level changes. Sump and tank level rise must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.As water level in the RPV lowers, the dose rate above the core will rise. The dose rate due to this core shine should result in site specific monitor indication and possible alarm.
 
==References:==
 
COP-1050 NEDC-33045P Calculation G13.18.9.4-047 Rev. 0 Attachment 3 Page 42 of 122 IDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) MALFUNCTION Attachment 3 Page 43 of 122 ISFSI MALFUNCTION E-HU1 Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Damage to a loaded cask CONFINEMENT BOUNDARY Operating Mode Applicability:
All Emergency Action Level(s): 1. Damage to a loaded cask CONFINEMENT BOUNDARY.Basis: A NOUE in this IC is categorized on the basis of the occurrence of an event of sufficient magnitude that a loaded cask CONFINEMENT BOUNDARY is damaged or violated.This includes classification based on a loaded fuel storage cask CONFINEMENT BOUNDARY loss leading to the degradation of the fuel during storage or posing an operational safety problem with respect to its removal from storage.This EAL addresses a dropped cask, a tipped over cask, EXPLOSION, PROJECTILE damage, FIRE damage or natural phenomena affecting a cask (e.g., seismic event, tornado, etc.).Attachment 3 Page 44 of 122 FISSION PRODUCT BARRIER DEGRADATION Attachment 3 Page 45 of 122 FISSION PRODUCT BARRIER DEGRADATION General Bases The logic used for these initiating conditions reflects the following considerations:
: 1. The Fuel Clad barrier and the RCS barrier are weighted more heavily than the Containment barrier. NOUE ICs associated with RCS and Fuel Clad barriers are addressed under System Malfunction (S) ICs.2. At the Site Area Emergency level, there must be some ability to dynamically assess how far present conditions are from the threshold for a General Emergency.
For example, if Fuel Clad and RCS barrier "Loss" EALs existed,.
that, in addition to, off-site dose assessments, would require continual assessments of radioactive inventory and containment integrity.
Alternatively, if both Fuel Clad and RCS barrier "Potential Loss" EALs existed, the Emergency Director would have more assurance that there was no immediate need to escalate to a General Emergency.
: 3. The ability to escalate to higher emergency classes as an event deteriorates must be maintained.
For example, RCS leakage steadily increasing would represent an increasing risk to public health and safety.4. The Containment barrier should not be declared lost or potentially lost based on exceeding Technical Specification action statement criteria, unless there is an event in progress requiring mitigation by the Containment barrier. When no event is in progress (Loss or Potential Loss of either Fuel Clad and/or RCS) the Containment barrier status is addressed by Technical Specifications.
Attachment 3 Page 46 of 122 FISSION PRODUCT BARRIER DEGRADATION Fission Product Barrier Table EALs for LOSS or POTENTIAL LOSS of Barriers**Determine which combination of the three barriers are lost or have a potential loss and use the following key to classify the event.Also, multiple events could occur which result in the conclusion that exceeding the loss or potential loss EALs is IMMINENT.
In this IMMINENT loss situation use ju gment and classify as if the EALs are exceeded.GENERAL EMERGENCY SITE AREA EMERGENCY ALERT NOUE Loss of ANY two barriers AND Loss of or Potential Loss of ANY Loss or ANY Potential ANY Loss or ANY Potential Loss or Potential Loss of third ANY two barriers.
Loss of EITHER Fuel Clad or Loss of Containment.
barrier. RCS.Fuel CladaBarrier(FC) I RCS .Barrer(RC,)
EALs < Containment-BarrierI(PC)
EALs LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS 1. Primary Coolant Activity Level (FCI) 1. Drywell Pressure (RCI) 1. Primary Containment Conditions (PCI)Coolant None Drywell pressure None 1. Rapid unexplained
: 1. PC pressure activity > > 1.68 psid with loss of PC pressure > 15 psig 300 pCi/gm dose indications of reactor following initial and rising equivalent 1-131 coolant leak in the drywell pressure rise OR OR 2. a. PC 2. PC pressure hydrogen response not in the consistent with unsafe LOCA conditions zone of HDOL curve OR b. DW hydrogen concentra-tion > 9%OR 3. RPV pressure Attachment 3 Page 47 of 122 FISSION PRODUCT BARRIER DEGRADATION Fission Product Barrier Table EALs for LOSS or POTENTIAL LOSS of Barriers**Determine which combination of the three barriers are lost or have a potential loss and use the following key to classify the event.Also, multiple events could occur which result in the conclusion that exceeding the loss or potential loss EALs is IMMINENT.
In this IMMINENT loss situation use judgment and classify as if the EALs are exceeded.GENERAL EMERGENCY SITE AREA EMERGENCY ALERT NOUE Loss of ANY two barriers AND Loss of or Potential Loss of ANY Loss or ANY Potential ANY Loss or ANY Potential Loss or Potential Loss of third ANY two barriers.
Loss of EITHER Fuel Clad or Loss of Containment.
barrier. RCS.Fuehlad'Barrier.(EC)
EAtEs RCSBarrier e(RCVEALs I ...........
o(t ,. ........EALs LOSS, POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS and suppression pool temperature cannot be maintained below the \HCTL 2. Reactor Vessel Water Level (FC2) 2. Reactor Vessel Water Level (RC2) 2. Reactor Vessel Water Level (PC2)RPV water level RPV water level RPV water level None None Entry into PC cannot be restored cannot be cannot be restored flooding and maintained restored and and maintained procedures above -186 inches maintained above -162 inches SAP-1 and above -162 or cannot be determined SAP-2 inches or cannot be determined Attachment 3 Page 48 of 122 FISSION PRODUCT BARRIER DEGRADATION Fission Product Barrier Table EALs for LOSS or POTENTIAL LOSS of Barriers**Determine which combination of the three barriers are lost or have a potential loss and use the following key to classify the event.Also, multiple events could occur which result in the conclusion that exceeding the loss or potential loss EALs is IMMINENT.
In this IMMINENT loss situation use judgment and classify as if the EALs are exceeded.GENERAL EMERGENCY SITE AREA EMERGENCY ALERT NOUE Loss of ANY two barriers AND Loss of or Potential Loss of ANY Loss or ANY Potential ANY Loss or ANY Potential Loss or Potential Loss of third ANY two barriers.
Loss of EITHER Fuel Clad or Loss of Containment.
barrier. I RCS. *_II Fuel Clad Barrier FC) EALs I>K RCS Barrier 0RC) EALs I Containment Barrier,(PC)
EALs LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS 3. Primary Containment Radiation
: 3. RCS Leak Rate (RC3) 3. Primary Containment Isolation Monitors (FC3) Failure or Bypass (PC3)Containment None 1.a. UNISOLABLE
: 1. RCS 1. a. Failure of all valves None radiation monitor main steam line leakage in any one line RMS-RE16 break as indicated
> 50 gpm to close reading by the failure of both inside the AND> 3,000 R/hr MSIVs in any one drywell b. Direct downstream line to close OR pathway to the AND 2.UNISOLABLE environment exists after High MSL flow RCS leakage PC Annunciator outside PC isolation signal (P601-19A-A2) as indicated OR AND by exceeding
: 2. Intentional PC Main Steam Tunnel either of the venting per EOPs Temperature
> 1441F following:
or SAPs[173&deg;F NRC TS] a.Max OR Normal OR b. Indication of Operating
: 3. UNISOLABLE an UNISOLABLE Tempera- RCS leakage HPCS, Feedwater, ture outside PC RWCU or RCIC (Table F2) as indicated break OR by exceeding either of Attachment 3 Page 49 of 122 FISSION PRODUCT BARRIER DEGRADATION Fission Product Barrier Table EALs for LOSS or POTENTIAL LOSS of Barriers**Determine which combination of the three barriers are lost or have a potential loss and use the following key to classify the event.Also, multiple events could occur which result in the conclusion that exceeding the loss or potential loss EALs is IMMINENT.
In this IMMINENT loss situation use judqment and classify as if the EALs are exceeded.GENERAL EMERGENCY SITE AREA EMERGENCY ALERT NOUE Loss of ANY two barriers AND Loss of or Potential Loss of ANY Loss or ANY Potential ANY Loss or ANY Potential Loss or Potential Loss of third ANY two barriers.
Loss of EITHER Fuel Clad or Loss of Containment.
barrier. RCS.S.Fuel Clad Barrier: F41EtALs.
RCS Barrier 1RC EALs ,: ; Containment BarrierC EA~ s \LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS OR b. Max the following:
: 2. Emergency Normal a. Max Safe RPV depressuri-Area Operating zation is required Radiation Temperature (Table F2) (Table F1)OR b. Max Safe Area Radiation (Table Fl)4. Emergency Director Judgment (FC4) 4. Drywell Radiation (RC4) 4. Primary Containment Radiation Monitors (PC4)Any condition in Any condition in Drywell radiation monitor None Containment None the opinion of the the opinion of the RMS-RE20 radiation monitor Emergency Director Emergency Director reading RMS-RE16 that indicates loss that indicates
> 100 R/hr reading of the Fuel Clad potential loss due to reactor coolant > 10,000 barrier of the Fuel Clad leakage R/hr barrier Attachment 3 Page 50 of 122 FISSION PRODUCT BARRIER DEGRADATION Fission Product Barrier Table EALs for LOSS or POTENTIAL LOSS of Barriers**Determine which combination of the three barriers are lost or have a potential loss and use the following key to classify the event.Also, multiple events could occur which result in the conclusion that exceeding the loss or potential loss EALs is IMMINENT.
In this IMMINENT loss situation use jud ment and classify as if the EALs are exceeded.GENERAL EMERGENCY SITE AREA EMERGENCY ALERT NOUE Loss of ANY two barriers AND Loss of or Potential Loss of ANY Loss or ANY Potential ANY Loss or ANY Potential Loss or Potential Loss of third ANY two barriers.
Loss of EITHER Fuel Clad or Loss of Containment.
barrier. RCS.Fuel Clad Barrier I FC EALs RS .Barrier, (RC) EALs .Containment Barrier (PC) EALs.LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS 5. Emergency Director Judgment 5. Emergency Director Judgment (RC5) (PC5)Any condition in Any condition in Any condition in Any condition in the opinion of the the opinion of the opinion of the the opinion of Emergency Director the Emergency Emergency Director the Emergency that indicates loss Director that indicates loss Director of the RCS barrier that indicates of the Primary that indicates potential loss Containment potential loss of the RCS barrier of the Primary barrier Containment barrier Attachment 3 Page 51 of 122 FISSION PRODUCT BARRIER DEGRADATION FU1 INITIATING CONDITION
-NOTIFICATION OF UNUSUAL EVENT ANY loss or ANY potential loss of containment Operating Mode Applicability:
Mode 1 Power Operation Mode 2 Startup Mode 3 Hot Shutdown Emergency Action Level(s): 1. Any loss or any potential loss of containment Bases: Comparison of conditions
/ values with those listed in Fission Product Barrier Matrix indicates a loss or any potential loss of containment.
The Fuel Cladding (FC) and the Reactor Coolant System (RCS) are weighted more heavily than the Primary Containment (PC) barrier. NOUE ICs associated with RCS and FC barriers are addressed under System Malfunction ICs.Loss of containment would be a potential degradation in the level of plant safety.The PC barrier includes the drywell, the wetwell, their respective interconnecting paths, and other connections up to and including the outermost containment isolation valves. Containment barrier thresholds are used primarily as discriminators for escalation from an Alert to a Site Area Emergency or, a General Emergency.
Attachment 3 Page 52 of 122 FISSION PRODUCT BARRIER DEGRADATION FA1 INITIATING CONDITION
-ALERT Any loss or any potential loss of either fuel clad or RCS Operating Mode Applicability:
Mode 1 Mode 2 Mode 3 Power Operation Startup Hot Shutdown Emergency Action Level(s): 1. Any loss or any potential loss of fuel clad OR Any loss or any potential loss of RCS Bases: Comparison of conditions
/ values with those listed in Fission Product Barrier Matrix indicates a loss or potential loss of a Fuel Clad barrier or a loss or potential loss of the RCS barrier.The Fuel Cladding and the Reactor Coolant System are weighted more heavily than the Primary Containment barrier.Loss of either the Fuel Cladding or the Reactor Coolant System would be a substantial degradation in the level of plant safety.The Fuel Clad barrier is the zircalloy or stainless steel fuel bundle tubes that contain the fuel pellets.The RCS barrier is the reactor coolant system pressure boundary and includes the reactor vessel and all reactor coolant system piping up to the isolation valves.Attachment 3 Page 53 of 122 FISSION PRODUCT BARRIER DEGRADATION FS1 INITIATING CONDITION
-SITE AREA EMERGENCY Loss or potential loss of any two barriers Operating Mode Applicability:
Mode 1 Mode 2 Mode 3 Power Operation Startup Hot Shutdown Emergency Action Level(s): 1. Loss or potential loss of any two barriers Bases: Comparison of conditions
/ values with those listed in Fission Product Barrier Matrix indicates loss or potential loss of any two barriers.Loss of 2 Fission Product Barriers would be a major failure of plant systems needed for protection of the public.Attachment 3 Page 54 of 122 FISSION PRODUCT BARRIER DEGRADATION FG1 INITIATING CONDITION
-GENERAL EMERGENCY Loss of any two barriers and loss or potential loss of third barrier Operating Mode Applicability:
Mode 1 Mode 2 Mode 3 Power Operation Startup Hot Shutdown Emergency Action Level(s): 1. Loss of any two barriers AND Loss or potential loss of the third barrier Bases: Comparison of conditions
/ values with those listed in Fission Product Barrier Matrix indicates a loss of any two barriers and the loss or potential loss of the third barrier.Conditions
/ events required to cause the loss of 2 Fission Product Barriers with the potential loss of the third could reasonably be expected to cause a release beyond the immediate site area exceeding EPA Protective Action Guidelines.
Attachment 3 Page 55 of 122 FISSION PRODUCT BARRIER DEGRADATION FC1 FUEL CLAD Emergency Action Level: Primary coolant activity level EAL Threshold:
LOSS: ...................................
Coolant activity > 300 [iCi/g dose equivalent 1-131 POTENTIAL LOSS: ..............
NONE Bases: LOSS -The site specific value is 300 pCi/gm dose equivalent 1-131. Assessment by the EAL Task Force indicates that this amount of coolant activity is well above that expected for iodine spikes and corresponds to less than 5% fuel clad damage. This amount of radioactivity indicates significant clad damage and thus the Fuel Clad barrier is considered lost.POTENTIAL LOSS -NONE
 
==References:==
 
Attachment 3 Page 56 of 122 FISSION PRODUCT BARRIER DEGRADATION FC2 FUEL CLAD Emergency Action Level: Reactor vessel water level EAL Threshold:
LOSS: ..............................
RPV water level cannot be restored and maintained above-186 inches POTENTIAL LOSS: .............
RPV water level cannot be restored and maintained above-162 inches or cannot be determined Bases: LOSS -This site specific value corresponds to the level used in EOPs to indicate challenge of core cooling. This is the minimum value to assure core cooling without further degradation of the clad. Reactor vessel water level less than the minimum steam cooling RPV water level (-186") with injection is the lowest level with adequate core cooling to maintain peak clad temperature less than 1500'F where fuel clad damage (fuel rod perforation) may begin. Corrective actions as described in the Emergency Operating Procedures (EOPs) and Severe Accident Guidelines (SAGs) will be needed to mitigate fuel clad/core damage.POTENTIAL LOSS -This threshold is the same as the RCS barrier loss threshold RC2 and corresponds to the site specific water level at the top of the active fuel. Thus, this threshold indicates a potential loss of the Fuel Clad barrier and a loss of the RCS barrier that appropriately escalates the emergency classification level to a Site Area Emergency.
With Reactor vessel water level less than the top of active fuel (-162"), adequate core cooling is still assured but is sufficiently low that any further drop in water level could result in the significant degradation of the cladding.
Corrective actions as described in the Emergency Operating Procedures (EOPs) will be needed to mitigate fuel clad/core damage.
 
==References:==
 
Attachment 3 Page 57 of 122 FISSION PRODUCT BARRIER DEGRADATION FC3 FUEL CLAD Emergency Action Level: Primary containment radiation monitors EAL Threshold:
LOSS: ..............................
Containment radiation monitor RMS-RE16 reading> 3,000 R/hr POTENTIAL LOSS: .........
NONE Bases: LOSS-- Containment radiation monitors reading in excess of 3000 R/hr after Reactor Shutdown are indicative of both the loss of the reactor coolant system and 5% clad failure with the instantaneous release and dispersal of the reactor coolant noble gas and Iodine inventory into the drywell and containment atmosphere.
Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations (including iodine spiking) allowed within Technical Specifications and are therefore indicative of fuel damage.POTENTIAL LOSS -NONE
 
==References:==
 
Calculation G13.18.9.4-045 Rev. 0 Attachment 3 Page 58 of 122 FISSION PRODUCT BARRIER DEGRADATION FC4 FUEL CLAD Emergency Action Level: Emergency Director judgment EAL Threshold:
LOSS: ..................................
Any condition in the opinion of the Emergency Director that indicates loss of the Fuel Clad barrier POTENTIAL LOSS: ..............
Any condition in the opinion of the Emergency Director that indicates potential loss of the Fuel Clad barrier Bases: LOSS or POTENTIAL LOSS -This EAL addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be considered in this EAL as a factor in Emergency Director judgment that the barrier may be considered lost or potentially lost.
 
==References:==
 
Attachment 3 Page 59 of 122 FISSION PRODUCT BARRIER DEGRADATION RC1 REACTOR COOLANT SYSTEM Emergency Action Level: Drywell pressure EAL Threshold:
LOSS: ...................................
Drywell pressure > 1.68 psid with indications of reactor coolant leak in drywell POTENTIAL LOSS: .............
NONE Bases: LOSS -The site specific primary containment pressure is based on the drywell high pressure set point which indicates a LOCA by automatically initiating the ECCS or equivalent makeup system.Pressure rise due solely to loss of containment or drywell heat removal capability, testing, etc are not considered for this EAL threshold.
POTENTIAL LOSS -NONE.
 
==References:==
 
Attachment 3 Page 60 of 122 FISSION PRODUCT BARRIER DEGRADATION RC2 REACTOR COOLANT SYSTEM Emergency Action Level: Reactor vessel water level EAL Threshold:
LOSS: ....................................
RPV water level cannot be restored and maintained above-162 inches or cannot be determined POTENTIAL LOSS: ...............
NONE Bases: LOSS -The loss EAL threshold of site specific RPV water level corresponds to the level that is used in EOPs to indicate challenge of core cooling.This threshold is the same as the Fuel Clad barrier potential loss EAL threshold FC2 and corresponds to a challenge to core cooling. Thus, this threshold indicates a loss of the RCS barrier and potential loss of the Fuel Clad barrier that appropriately escalates the emergency classification level to a Site Area Emergency.
POTENTIAL LOSS -NONE
 
==References:==
 
Attachment 3 Page 61 of 122 FISSION PRODUCT BARRIER DEGRADATION RC3 REACTOR COOLANT SYSTEM Emergency Action Level: RCS leak rate EAL Threshold:
LOSS: ........................
l.a. UNISOLABLE main steam line break as indicated by the failure of both MSIVs in any one line to close AND High MSL flow annunciator (P601-19A-A2)
AND Main Steam Tunnel Temperature
> 144&deg;F'[173&deg;F NRC TS submittal change]OR b. indication of an UNISOLABLE HPCS, Feedwater, RWCU or RCIC break POTENTIAL LOSS: ....OR 2. Emergency RPV depressurization is required.1. RCS leakage > 50 gpm inside the drywell OR 2. UNISOLABLE RCS leakage outside PC as indicated by exceeding either of the following:
: a. Max Normal Operating Temperature (Table F2)OR b. Max Normal Area Radiation (Table F2)Attachment 3 Page 62 of 122 FISSION PRODUCT BARRIER DEGRADATION RC3__________________
RC 3 Potential Loss ofRCS.Parameter Area Temperature Area Radiation Level (isolation temperature DRMS Grid 2 Max Normal Operating alarm) Value RHR A equipment area 1170 F 1213 8.2E+01 mR/hr (P601-20A-B4)
RHR B equipment area 1170 F 1214 8.2E+01 mR/hr (P601-20A-B4)
RHR C' equipment area N/A 1215 8.2E+01 mR/hr RCIC room 1820 F 1219 1.20E+02 mR/hr (P601-21A-B6)
MSL Tunnel 144-F [173-F NRC TS N/A submittal change](P601-19A-A1/A3/B 1/B3)RWCU pump room I (A) / 2 (B) 1650 F N/A (P680-i A-A2/B2)Bases: LOSS -An UNISOLABLE MSL break is a breach of the RCS barrier. Thus, this EAL threshold is included for consistency with the Alert emergency classification level.Other large high-energy line breaks such as HPCS, Feedwater, RWCU, or RCIC that are UNISOLABLE also represent a significant loss of the RCS barrier and should be considered as MSL breaks for purposes of classification.
The leak is NOT isolable from the Main Control Room OR an attempt for isolation from the Main Control Room panels has been made and was not successful.
An attempt for isolation should be made prior to the accident classification.
If isolable upon identification, this INITIATING CONDITION is not applicable.
Dispatch of operators outside the Control Room for manual attempts to close the valve is not considered.
Plant symptoms requiring Emergency RPV depressurization per the site specific EOPs are indicative of a loss of the RCS barrier. If Emergency RPV depressurization is required, the plant operators are directed to open safety relief valves (SRVs) and keep them open. Even though the RCS is being vented into the suppression pool, a loss of the RCS should be considered to exist due to the diminished effectiveness of the RCS pressure barrier to a release of fission products beyond its boundary.POTENTIAL LOSS -This threshold is based on leakage set at a level indicative of a small breach of the RCS but which is well within the makeup capability of normal and emergency high pressure systems. Core uncovery is not a significant concern for a Attachment 3 Page 63 of 122 FISSION PRODUCT BARRIER DEGRADATION RC3 50 gpm leak, however, break propagation leading to significantly larger loss of inventory is possible.If the leak detection system leak rate information is unavailable (i.e., LOCA isolation, loss of power), other indicators of RCS leakage should be used. Other indications include a rise in drywell temperature and pressure and a rise in the drywell radiation monitors.
If the leakage computer is unavailable, sump level and pump status may help determine if the leakage is greater than 50 gpm.If the DFR discharge line containment isolation valves have not isolated and a pump is running continuously without lowering sump level, the leakage may be assumed to exceed 50 gpm. The second pump can be started to verify that the first pump is not degraded.
It is not intended to conclude a potential loss of the RCS barrier exists if both pumps are degraded and the observed leak rate as noted by rate of rise of level in the sump or calculated by the computer is such that it clearly confirms leakage below 50 gpm.
 
==References:==
 
Attachment 3 Page 64 of 122 FISSION PRODUCT BARRIER DEGRADATION RC4 REACTOR COOLANT SYSTEM Emergency Action Level: Drywell radiation EAL Threshold:
LOSS: ..................................
Drywell radiation monitor RMS-RE20 reading > 100 R/hr POTENTIAL LOSS: .............
NONE Bases: LOSS -The site specific reading is a value which indicates the release of reactor coolant to the drywell.POTENTIAL LOSS -NONE
 
==References:==
 
G13.18.9.4-051 Attachment 3 Page 65 of 122 FISSION PRODUCT BARRIER DEGRADATION RC5 REACTOR COOLANT SYSTEM Emergency Action Level: Emergency Director judgment EAL Threshold:
LOSS: ..................................
Any condition in the opinion of the Emergency Director that indicates loss of the RCS barrier POTENTIAL LOSS: ..............
Any condition in the opinion of the Emergency Director that indicates potential loss of the RCS barrier Bases: LOSS or POTENTIAL LOSS -This EAL addresses any other factors that are to be used by the Emergency Director in determining whether the RCS barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be considered in this EAL as a factor in Emergency Director judgment that the barrier may be considered lost or potentially lost.
 
==References:==
 
Attachment 3 Page 66 of 122 FISSION PRODUCT BARRIER DEGRADATION PCI PRIMARY CONTAINMENT Emergency Action Level: Primary containment conditions EAL threshold:
LOSS: ..........................
1.Rapid unexplained loss of PC pressure following initial pressure rise OR 2. PC pressure response not consistent with LOCA conditions POTENTIAL LOSS: ..............
: 1. PC pressure > 15 psig and rising OR 2. a. PC hydrogen in the unsafe zone of HDOL curve OR b. DW hydrogen concentration
> 9%OR 3. RPV pressure and suppression pool temperature cannot be maintained below the HCTL Attachment 3 Page 67 of 122 FISSION PRODUCT BARRIER DEGRADATION PCI Bases: LOSS -Rapid unexplained loss of pressure (i.e., not attributable to condensation effects or restoration of containment or drywell unit coolers) following an initial pressure rise from a high energy line break indicates a loss of containment integrity.
Primary containment pressure should rise as a result of mass and energy released into containment from a LOCA. Thus, primary containment pressure not rising under these conditions indicates a loss of containment integrity.
This indicator relies on operator recognition of an unexpected response for the condition and therefore does not have a specific value associated with it. The unexpected response is important because it is the indicator for a containment bypass condition.
Control room indicators may include ERIS data points, P808 CMS indication, or back-panel CMS pressure indication.
POTENTIAL LOSS -The site specific pressure is based on the primary containment design pressure.
Primary Containment pressure greater than 15 psig and rising is based on the design pressure of thePrimary Containment.
If the Containment pressure is exceeded, this represents a condition outside the analyzed conditions.
This constitutes a potential loss of the Primary Containment barrier even if a failure to isolate has not occurred.The Emergency Procedure Guidelines and Severe Accident Guidelines identify that deflagration could occur if containment hydrogen concentration reaches the HDOL or drywell hydrogen concentration reaches 9%. The deflagration of Hydrogen represents a potential loss of the primary containment.
Indication of actual hydrogen concentration in the containment is affected by the environmental conditions (i.e., the presence of water vapor). The RBS hydrogen monitoring system removes water vapor from the sample before hydrogen concentration is measured and, thus, may provide readings that are higher than the actual hydrogen concentration.
The Heat Capacity Temperature Limit (HCTL) is the highest suppression pool temperature from which emergency RPV depressurization will not raise: suppression chamber temperature above the maximum temperature capability of the suppression chamber and equipment within the suppression chamber which may be required to operate when the RPV is pressurized, OR Suppression chamber pressure above PC pressure limit A, while the rate of energy transfer from the RPV to the containment is greater than the capacity of the containment vent.The HCTL is a function of RPV pressure and suppression pool water level. It is utilized to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant and therefore, the inability to maintain plant parameters below the limit constitutes a potential loss of containment.
 
==References:==
 
Attachment 3 Page 68 of 122 FISSION PRODUCT BARRIER DEGRADATION PC1 PRIMARY CONTAINMENT Emergency Action Level: Reactor vessel water level EAL Threshold:
LO SS : ..................................
NO N E POTENTIAL LOSS: ..............
Entry into PC flooding procedures SAP-1 and SAP-2 Bases: LOSS -NONE POTENTIAL LOSS -The potential loss requirement for Primary Containment Flooding indicates adequate core cooling cannot be established and maintained and that core melt is possible.
Entry into SAP-1 and SAP-2 is a logical escalation in response to the inability to maintain adequate core cooling.The condition in this potential loss threshold represents a potential core melt sequence which, if not corrected, could lead to vessel failure and higher potential for containment failure. In conjunction with Reactor Vessel water level "loss" thresholds in the fuel clad and RCS barrier columns, this threshold will result in the declaration of a General Emergency
-- loss of two barriers and the potential loss of a third.
 
==References:==
 
Attachment 3 Page 69 of 122 FISSION PRODUCT BARRIER DEGRADATION PC3 PRIMARY CONTAINMENT Emergency Action Level: Primary containment isolation failure or bypass EAL Threshold:
LOSS: ................
: 1. a. Failure of all valves in any one line to close AND b. Direct downstream pathway to the environment exists after PC isolation signal OR 2. Intentional PC venting per EOPs or SAPs OR 3. UNISOLABLE RCS leakage outside PC as indicated by exceeding either of the following:
: a. Max Safe Operating Temperature (Table F1)OR b. Max Safe Area Radiation (Table Fl)POTENTIAL LOSS: ..............
NONE TABLE F1 PC. 3 Loss of Primary Containment Parameter Area Temperature Area Radiation Level Max Safe Operating Value DRMS Grid 2 Max Safe Operating_
Value RHR A equipment 2000 F 1213 9.5E+03 mR/hr area RHR B equipment 2000 F 1214 9.5E+03 mR/hr area RHR C equipment N/A 1215 9.5E+03 mR/hr area RCIC room 2000 F 1219 9.5E+03 mR/hr MSL Tunnel 2000 F N/A RWCU pump room 2000 F N/A 1 (A) / 2 (B)Attachment 3 Page 70 of 122 FISSION PRODUCT BARRIER DEGRADATION PC3 Bases: These thresholds address incomplete containment isolation that allows direct release to the environment.
LOSS -Failure to isolate -Inability to isolate means the primary containment isolation valve(s) did not fully close after a VALID automatic or manual isolation signal and is not isolable from the Main Control Room, or an attempt for isolation from the Main Control Room has been made and was unsuccessful.
An attempt for isolation should be made upon identification and prior to the accident classification.
If isolated from the Main Control Room upon identification, this INITIATING CONDITION is not applicable.
Dispatch of Operators outside the Control Room for manual attempts to close the valve is not considered.
Primary Containment isolation valves are described in the Technical Specifications bases for Primary Containment, Primary Containment Airlock and Primary Containment Isolation Valves (T.S. 3.6.1.1).
The Containment airlock is not considered in this EAL since airlock failure would be a potential failure mode to cause the EAL PC1 threshold.
The use of the modifier "direct" in defining the release path discriminates against release paths through interfacing liquid systems. The existence of an in-line charcoal filter does not make a release path indirect since the filter is not effective at removing fission product noble gases. Typical filters have an efficiency of 95-99% removal of iodine.Given the magnitude of the core inventory of iodine, significant releases could still occur.In addition, since the fission product release would be driven by boiling in the reactor vessel, the high humidity in the release stream can be expected to render the filters ineffective in a short period.Containment Venting -Site specific EOPs and SAPs may direct containment isolation valve logic(s) to be intentionally bypassed, regardless of radioactivity release rates.Under these conditions with a valid containment isolation signal, the containment should also be considered lost if containment venting is actually performed.
Intentional venting of primary containment for primary containment pressure or combustible gas control per EOPs or SAPs to the secondary containment and/or the environment is considered a loss of containment.
Containment venting for pressure when not in an accident situation should not be considered.
Area temperature or radiation
-The presence of area radiation or temperature Max Safe Operating setpoints indicating unisolable primary system leakage outside the primary containment are addressed after a containment isolation.
The indicators should be confirmed to be caused by RCS leakage. Leakage into a closed system is to be considered a loss of primary containment only if the closed system is breached and thereby creates a path to the environment.
POTENTIAL LOSS -None
 
==References:==
 
Attachment 3 Page 71 of 122 FISSION PRODUCT BARRIER DEGRADATION PC4 PRIMARY CONTAINMENT Emergency Action Level: Primary containment radiation monitors EAL Threshold:
LO SS : ..................................
NO N E POTENTIAL LOSS: .............
Containment radiation monitor RMS-RE16 reading >10,000 R/hr BASIS LOSS -NONE POTENTIAL LOSS -The site specific reading is a value that indicates significant fuel damage well in excess of that required for loss of RCS and fuel clad.Regardless of whether containment is challenged, this amount of activity in containment, if released, could have such severe consequences that it is prudent to treat this as a potential loss of containment, such that a General Emergency declaration is warranted.
 
==References:==
 
............
Calculation G 13.18.9.4-045 Rev. 0 Attachment 3 Page 72 of 122 FISSION PRODUCT BARRIER DEGRADATION PC5 REACTOR COOLANT SYSTEM Emergency Action Level: Emergency Director judgment EAL Threshold:
LOSS: ..................................
Any condition in the opinion of the Emergency Director that indicates loss of the Primary Containment barrier POTENTIAL LOSS: ..............
Any condition in the opinion of the Emergency Director that indicates potential loss of the Primary Containment barrier Bases: LOSS or POTENTIAL LOSS -This EAL addresses any other factors that are to be used by the Emergency Director in determining whether the primary containment barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be considered in this EAL as a factor in Emergency Director judgment that the barrier may be considered lost or potentially lost.The primary containment barrier should not be declared lost or potentially lost based on exceeding Technical Specification action statement criteria, unless there is an event in progress requiring mitigation by the Primary Containment barrier. When no event is in progress (loss or potential loss of either fuel clad and/or RCS) the Primary Containment barrier status is addressed by Technical Specifications.
 
==References:==
 
Attachment 3 Page 73 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Attachment 3 Page 74 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU1 Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Confirmed SECURITY CONDITION or threat which indicates a potential degradation in the level of safety of the plant Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2 or 3)1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the RBS security shift supervision OR 2. A credible site specific security threat notification OR 3. A validated notification from NRC providing information of an aircraft threat Basis: NOTE: Timely and accurate communication between Security Shift Supervision and the Control Room is crucial for the implementation of effective Security EALs.Security events which do not represent a potential degradation in the level of safety of the plant are reported under 10 CFR 73.71 or in some cases under 10 CFR 50.72.Security events assessed as HOSTILE ACTIONS are classifiable under HA1, HS1 and HG1.A higher initial classification could be made based upon the nature and timing of the security threat and potential consequences.
Consideration shall be given to upgrading the emergency response status and emergency classification in accordance with the Safeguards Contingency Plan and Emergency Plan.EAL #1 The Security Shift Supervisor is the designated individual on-site qualified and trained to confirm that a security event is occurring or has occurred.
Training on security event classification confirmation is closely controlled due to the strict secrecy controls placed on the plant Safeguards Contingency Plan.This EAL is based on the Safeguards Contingency Plan .The Safeguards Contingency Plan is based on guidance provided in NEI 03-12.EAL #2 This EAL is included to ensure that appropriate notifications for the security threat are made in a timely manner. This includes information of a credible threat. Only the plant to which the specific threat is made need declare the Notification of Unusual Event.Attachment 3 Page 75 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HUI The determination of "credible" is made through use of information found in the Safeguards Contingency Plan.EAL #3 The intent of this EAL is to ensure that notifications for the aircraft threat are made in a timely manner and that Offsite Response Organizations and plant personnel are at a state of heightened awareness regarding the credible threat. It is not the intent of this EAL to replace existing non-hostile related EALs involving aircraft.This EAL is met when a plant receives information regarding an aircraft threat from NRC.Validation is performed by calling the NRC or by other approved methods of authentication.
Only the plant to which the specific threat is made need declare the Unusual Event.The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an airliner (airliner is meant to be a large aircraft with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC.Escalation to Alert via HA1 would be appropriate if the threat involves an airliner within 30 minutes of the plant.
 
==References:==
 
NEI 03-12 (Attachment 3 Page 76 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU2 Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Other conditions exist which in the judgment of the Emergency Director warrant declaration of a NOUE Operating Mode Applicability:
All Emergency Action Level(s): 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.
No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the NOUE emergency classification level.
 
==References:==
 
Attachment 3 Page 77 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA Operating Mode Applicability:
Emergency Action Level(s): All (1 or 2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the duration has exceeded, or will likely exceed, the applicable time.1. FIRE not extinguished within 15 minutes of Control Room notification or verification of a Control Room FIRE alarm in any Table H2 structure or area.OR 2. EXPLOSION within the PROTECTED AREA Standb Tower Auxiliary Building Diesel Generator Building Control Building Tunnels (B, D, E, F, G, T)Fuel Building Basis: This IC addresses the magnitude and extent of FIRES or EXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the FIRE EXPLOSION, and not the degradation in performance of affected systems that may result.As used here, detection is visual observation and report by plant personnel or sensor alarm indication.
EAL #1 The 15 minute time period begins with a credible notification that a FIRE is occurring, or indication of a fire detection system alarm/actuation.
Verification of a fire detection system alarm/actuation includes actions that can be taken within the control room or Attachment 3 Page 78 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 other nearby site specific location to ensure that it is not spurious.
An alarm is assumed to be an indication of a FIRE unless it is disproved within the 15 minute period by personnel dispatched to the scene. In other words, a personnel report from the scene may be used to disprove a sensor alarm if received within 15 minutes of the alarm, but shall not be required to verify the alarm.The intent of this 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket).EAL #2 This EAL addresses only those EXPLOSIONS of sufficient force to damage permanent structures or equipment within the PROTECTED AREA.No attempt is made to assess the actual magnitude of the damage. The occurrence of the EXPLOSION is sufficient for declaration.
The Emergency Director also needs to consider any security aspects of the EXPLOSION, if applicable.
Escalation of this emergency classification level, if appropriate, would be based on HA4.
 
==References:==
 
Attachment 3 Page 79 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU5 Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Release of toxic, corrosive, asphyxiant, or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2)1. Toxic, corrosive, asphyxiant or flammable gases in amounts that have or could adversely affect NORMAL PLANT OPERATIONS OR 2. Report by West Feliciana Parish for evacuation or sheltering of site personnel based on an off-site event Basis: This IC is based on the release of toxic, corrosive, asphyxiant or flammable gases of sufficient'quantity to affect NORMAL PLANT OPERATIONS.
The fact that SCBAs may be worn does not eliminate the need to declare the event.This IC is not intended to require significant assessment or quantification.
It assumes an uncontrolled process that has the potential to affect plant operations.
This would preclude small or incidental releases, or releases that do not impact structures needed for plant operation.
An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment.
This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.Escalation of this emergency classification level, if appropriate, would be based on HA5.
 
==References:==
 
Attachment 3 Page 80 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Natural or destructive phenomena affecting the PROTECTED AREA Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2 or 3 or 4 or 5)1. Seismic event identified by any 2 of the following:
* Seismic event confirmed by activated seismic switch as indicated by receipt of EITHER a OR b: a. Annunciator "Seismic Tape Recording SYS Start" (P680-02A-D06)
: b. Event Indicator on ERS-NBI-1 02 is white" Earthquake felt in plant" National Earthquake Center OR 2. Tornado striking within PROTECTED AREA boundary OR 3. Internal flooding that has the potential to affect safety related equipment required by Technical Specifications for the current operating mode in any Table H1 area OR 4. Turbine failure resulting in casing penetration or damage to turbine or generator seals OR 5. Severe weather or hurricane conditions with indication of SUSTAINED high winds> 74 mph within the PROTECTED AREA boundary Attachment 3 Page 81 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 MlltA,;t!U LU.;dUI1 I Parameter Aux Bldg Crescent Area 6 inches above floor 70' EL (must be verified locally)HPCS Room 70'EL 4 inches above floor (P870-51A-G4)
RHR A Room 70'EL 4 inches above floor (P870-51A-G4)
RHR B Room 70'EL 4 inches above floor (P870-51A-G4)
RHR C Room 70'EL 4 inches above floor (P870-51A-G4)
LPCS Room 70'EL 4 inches above floor (P870-51A-G4)
RCIC Room 70'EL 4 inches above floor (P870-51A-G4)
Basis: These EALs are categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators.
EAL #1 Damage may be caused to some portions of the site, but should not affect ability of safety functions to operate.As defined in the EPRI-sponsored Guidelines for Nuclear Plant Response to an Earthquake, dated October 1989, a "felt earthquake" is: An earthquake of sufficient intensity such that: (a) the vibratory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of control room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated.
The annunciators "Seismic Tape Recording SYS Start" and the "white" event indicator are listed in the Alarm Response Procedure as verification of an earthquake event.The National Earthquake Center can confirm if an earthquake has occurred in the area of the plant.Attachment 3 Page 82 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 EAL #2 This EAL is based on a tornado striking (touching down) within the.PROTECTED AREA.Escalation of this emergency classification level, if appropriate, would be based on VISIBLE DAMAGE, or by other in plant conditions, via HA6.EAL #3 This EAL addresses the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps.The EAL is only applicable to areas in Table H1 areas that contain systems required for safe shutdown of the plant and that are not designed to be partially or fully submerged.
The EAL is based on VALID indication that the area water level has reached the Maximum Safe Operating Values as identified in EOP-3. Exceeding the Maximum Safe Operating Value is interpreted as a potential degradation in the level of safety of the plant and is appropriately treated as an Unusual Event.Escalation of this emergency classification level, if appropriate, would be via HA6, or by other plant conditions.
EAL #4 This EAL addresses main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator.
Generator seal damage observed after generator purge does not meet the intent of this EAL because it did not impact normal operation of the plant.Of major concern is the potential for leakage of combustible fluids (lubricating oils) and gases (hydrogen cooling) to the plant environs.
Actual FIRES and flammable gas build up are appropriately classified via HU4 and HU5.This EAL is consistent with the definition of a NOUE while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment.
Escalation of this emergency classification level, if appropriate, would be to HA6 based on damage done by PROJECTILES generated by the failure or by the radiological releases.
These latter events would be classified by the radiological (A) ICs or Fission Product Barrier (F) ICs.EAL #5 This EAL is based on the assumption that high winds within the PROTECTED AREA may have potentially damaged plant structures, listed in Table H2, containing functions or systems required for safe shutdown of the plant. The high wind site specific value is based on the wind speed (74 mph) to classify severe weather conditions as a hurricane.
FSAR design basis is that all Seismic Category I structures at RBS are designed to withstand 100 mph fastest mile of sustained wind 30 ft above ground, based upon a 100-yr period of recurrence.
Methods to measure wind speed in the PROTECTED AREA are not available; therefore, a sustained indication of 74 mph on the Attachment 3 Page 83 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 Meteorological Tower lower elevation average wind speed indication will be used to determine that this EAL is met. The upper scale for the lower elevation average meter wind speed on the MET Tower is 100 mph If the MET Tower lower average wind speed sensors are not operable, other tower sensors or sources may be considered for estimating wind speed at RBS such as NOAA or Baton Rouge regional Airport.If damage is confirmed visually or by other in-plant indications, the event may be escalated to Alert.
 
==References:==
 
Attachment 3 Page 84 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 Initiating Condition
-ALERT HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2)1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the RBS security shift supervision
: 2. A validated notification from NRC of an airliner attack threat within 30 minutes of the site Basis: NOTE: Timely and accurate communication between Security Shift Supervision and the Control Room is crucial for the implementation of effective Security EALs.These EALs address the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. They are not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements.The fact that the site is under serious attack or is an identified attack target with minimal time available for further preparation or additional assistance to arrive requires a heightened state of readiness and implementation of protective measures that can be effective (such as on-site evacuation, dispersal or sheltering).
EAL #1 This EAL addresses the potential for a very rapid progression of events due to a HOSTILE ACTION. It is not intended to address incidents that are accidental events or acts of civil disobedience, such as small aircraft impact, hunters, or physical disputes between employees within the OWNER CONTROLLED AREA. Those events are adequately addressed by other EALs.Note that this EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes Independent Spent Fuel Storage Installations that may be outside the PROTECTED AREA but still in the OWNER CONTROLLED AREA.EAL #2 This EAL addresses the immediacy of an expected threat arrival or impact on the site within a relatively short time.The intent of this EAL is to ensure that notifications for the airliner attack threat are made in a timely manner and that Offsite Response Organizations and plant personnel are at a Attachment 3 Page 85 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 state of heightened awareness regarding the credible threat. Airliner is meant to be a large aircraft with the potential for causing significant damage to the plant.This EAL is met when a plant receives information regarding an airliner attack threat from NRC and the airliner is within 30 minutes of the plant. Only the plant to which the specific threat is made need declare the Alert.The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an airliner (airliner is meant to be a large aircraft with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC.
 
==References:==
 
NEI 03-12 Attachment 3 Page 86 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA2 Initiating Condition
-ALERT Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert Operating Mode Applicability:
All Emergency Action Level(s): 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the Alert emergency classification level.
 
==References:==
 
Attachment 3 Page 87 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA3 Initiating Condition
-ALERT Control room evacuation has been initiated Operating Mode Applicability:
All Emergency Action Level(s): 1. AOP-0031, Shutdown from Outside the Main Control Room requires Control Room evacuation Basis: With the Control Room evacuated, additional support, monitoring and direction through the Technical Support Center and/or other emergency response facilities may be necessary.
Inability to establish plant control from outside the Control Room will escalate this event to a Site Area Emergency.
 
==References:==
 
Attachment 3 Page 88 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA4 Initiating Condition
-ALERT FIRE or EXPLOSION affecting the operability of plant safety systems required to establish or maintain safe shutdown Operating Mode Applicability:
All Emergency Action Level(s): 1. FIRE or EXPLOSION resulting in VISIBLE DAMAGE to any of the structures or areas in Table H2 containing, safety systems or components or Control Room indication of degraded performance of those safety systemsuooiing Tower Auxiliary Building Diesel Generator Building Control Building Tunnels (B, D, E, F, G, T)Fuel Building Basis: VISIBLE DAMAGE is used to identify the magnitude of the FIRE or EXPLOSION and to discriminate against minor FIRES and EXPLOSIONS.
The reference to structures containing safety systems or components is included to discriminate against FIRES or EXPLOSIONS in areas having a low probability of affecting safe operation.
The significance here is not that a safety system was degraded but the fact that the FIRE or EXPLOSION was large enough to cause damage to these systems.The use of VISIBLE DAMAGE should not be interpreted as mandating a lengthy damage assessment prior to classification.
The declaration of an Alert and the activation of the Technical Support Center will provide the Emergency Director with the resources needed to perform detailed damage assessments.
The Emergency Director also needs to consider any security aspects of the EXPLOSION.
Escalation of this emergency classification level, if appropriate, will be based on System Malfunction (S), Fission Product Barrier Degradation (F) or Abnormal Radiation Levels /Radiological Effluent (A) ICs.
 
==References:==
 
Attachment 3 Page 89 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 Initiating Condition
-ALERT Access to a VITAL AREA is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of operable equipment required to maintain safe operations or safely shutdown the reactor Operating Mode Applicability:
All Emergency Action Level(s): Note: If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.1. Access to a VITAL AREA (Table H2) is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor Basis: Gases in a VITAL AREA can affect the ability to safely operate or safely shutdown the reactor.The, fact that SCBAs may be worn does not eliminate the need to declare the event.Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere poses an immediate threat to life and health or an immediate threat of severe exposure to gases. This could be based upon documented analysis, indication of personal ill effects from exposure, or operating experience with the hazards.If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment.
This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.An uncontrolled release of flammable gasses within a facility structure has the potential to affect safe operation of the plant by limiting either operator or equipment operations due to the potential for ignition and resulting equipment damage/personnel injury.Flammable gasses, such as hydrogen and acetylene, are routinely used to maintain plant systems (hydrogen) or to repair equipment/components (acetylene
-used in welding).
This EAL assumes concentrations of flammable gasses which can ignite/support combustion.
Attachment 3 Page 90 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 Escalation of this emergency classification level, if appropriate, will be based on System Malfunction (S), Fission Product Barrier Degradation (F) or Abnormal Radiation Levels /Radioactive Effluent (A) lCs.
 
==References:==
 
Attachment 3 Page 91 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA6 Initiating Condition
-ALERT Natural or destructive phenomena affecting VITAL AREAS Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2 or 3 or 4 or 5 or 6)1. a. Seismic event > Operating Basis Earthquake (OBE) as indicated by:.Annunciator "Seismic Tape Recording System Start" (P680-02A-D06)
AND Event Indicator on ERS-NBI-1 02 is white AND Receipt of EITHER 1 OR 2: 1. Annunciator "Seismic Event High" (P680-02A-C06)
: 2. Annunciator "Seismic Event High-High" (P680-02A-B06)
AND amber light(s) on panel NBI-101 AND b. Earthquake confirmed by any of the following:
* Earthquake felt in plant* National Earthquake Center* Control Room indication of degraded performance of systems required for the safe shutdown of the plant OR 2. Tornado striking resulting in VISIBLE DAMAGE to any of the Table H2 structures or areas containing safety systems or components or Control Room indication of degraded performance of those safety systems OR 3. Internal flooding in Auxiliary Building 70 ft elevation resulting in an electrical shock hazard that precludes access to operate or monitor safety equipment or Control Room indication of degraded performance of those safety systems OR 4. Turbine failure-generated PROJECTILES resulting in VISIBLE DAMAGE to or penetration of any of the Table H2 structures or areas containing safety systems or components or Control Room indication of degraded performance of those safety systems.OR 5. Vehicle crash resulting in VISIBLE DAMAGE to any of the Table H2 structures or areas containing safety systems or components or Control Room indication of degraded performance of those safety systems.OR Attachment 3 Page 92 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA6 6. Hurricane or high SUSTAINED wind conditions
-> 74 mph within the PROTECTED AREA boundary and resulting in VISIBLE DAMAGE to any of the Table H2 structures or areas containing safety systems or components or Control -Room indication of degraded performance of those safety systems Standby Cooling Tower Auxiliary Building Diesel Generator Building Control Building Tunnels (B, D, E, F, G, T)Fuel Building Basis: These EALs escalate from HU6 in that the occurrence of the event has resulted in VISIBLE DAMAGE to plant structures or areas containing equipment necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by Control Room indications of degraded system response or performance.
The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discriminate against lesser events. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification.
No attempt is made in these EALs to assess the actual magnitude of the damage. The significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause thisdegradation.
Escalation of this emergency classification level, if appropriate, would be based on System Malfunction (S) ICs.The Emergency Director may consider the Fuel Building as necessary to address the impact of the event on the loss of spent fuel cooling or spent fuel (e.g., freshly off-loaded reactor core in pool). At RBS, the term "freshly off-loaded reactor core" refers to fuel that has been discharged from the core and stored in the spent fuel pool for a period of LESS THAN one year.EAL #1 Seismic events of this magnitude can result in a VITAL AREA being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems.The National Earthquake Center can confirm if an earthquake has occurred in the area of the plant.Attachment 3 Page 93 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA6 EAL #2 This EAL is based on a tornado striking (touching down) that has caused VISIBLE DAMAGE to structures or areas containing functions or systems required for safe shutdown of the plant.EAL #3 This EAL addresses the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps. It is based on the degraded performance of systems, or has created industrial safety hazards (e.g., electrical shock) that preclude necessary access to operate or monitor safety equipment.
The inability to access, operate or monitor safety equipment represents an actual or substantial potential degradation of the level of safety of the plant.The areas of concern are the areas identifed in Table 4 of EOP 3 that contain systems required for safe shutdown of the plant that are not designed to be partially or fully submerged.
Indication may be by local verification, control room indication, or in degraded performance of systems affected by the flooding.Flooding as used in this EAL describes a condition where water is entering the room faster than installed equipment is capable of removal, resulting in a rise of water level within the room. Classification of this EAL should not be delayed while corrective actions are being taken to isolate the water source.EAL #4 This EAL addresses the threat to safety related equipment imposed by PROJECTILEs generated by main turbine rotating component failures.
Therefore, this EAL is consistent with the definition of an ALERT in that the potential exists for actual or substantial potential degradation of the level of safety of the plant. Some structures on the list may not be at risk for the turbine generated missile but are included for consistency in identifying structures or areas containing systems and functions required for safe shutdown of the plant. /EAL #5 This EAL addresses vehicle crashes within the PROTECTED AREA that result in VISIBLE DAMAGE to VITAL AREAS (as shown in Table H2) or indication of damage to safety structures, systems, or components containing functions and systems required for safe shutdown of the plant.EAL #6 This EAL is based on high winds within the PROTECTED AREA that have caused VISIBLE DAMAGE to structures or areas containing functions or systems required for safe shutdown of the plant. The high wind site specific value is based on the wind speed (74 mph) to classify severe weather conditions as a hurricane.
FSAR design basis is that all Seismic Category I structures at RBS are designed to withstand 100 mph fastest mile of sustained wind 30 ft above ground, based upon a 100-yr period of recurrence.
Methods to measure wind speed in the PROTECTED AREA are not Attachment 3 Page 94 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA6 available; therefore, a sustained indication of 74 mph on the Meteorological Tower lower elevation average wind speed indication will be used to determine that this EAL is met.The upper scale for the lower elevation average wind speed on the MET Tower is 100 mph. If the MET Tower lower average wind speed sensors are not operable, other tower sensors or sources may be considered for estimating wind speed at RBS such as NOAA or Baton Rouge regional Airport.
 
==References:==
 
Attachment 3 Page 95 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 Initiating Condition
-SITE AREA EMERGENCY HOSTILE ACTION within the PROTECTED AREA Operating Mode Applicability:
All Emergency Action Level(s): 1. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the RBS security shift supervision Basis: This condition represents an escalated threat to plant safety above that contained in the Alert in that a HOSTILE FORCE has progressed from the OWNER CONTROLLED AREA to the PROTECTED AREA.This EAL addresses the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. It is not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements.The fact that the site is under serious attack with minimal time available for further preparation or additional assistance to arrive requires Offsite Response Organization readiness and preparation for the implementation of protective measures.This EAL addresses the potential for a very rapid progression of events due to a HOSTILE ACTION. It is not intended to address incidents that are accidental events or acts of civil disobedience, such as small aircraft impact, hunters, or physical disputes between employees within the PROTECTED AREA. Those events are adequately addressed by other EALs.Escalation of this emergency classification level, if appropriate, would be based on actual plant status after impact or progression of attack.
 
==References:==
 
NEI 03-12 Attachment 3 Page 96 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 Initiating Condition
-SITE AREA EMERGENCY Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency Operating Mode Applicability:
All Emergency Action Level(s): 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for Site Area Emergency.
 
==References:==
 
Attachment 3 Page 97 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS3 Initiating Condition
-SITE AREA EMERGENCY Control Room evacuation has been initiated and plant control cannot be established Operating Mode Applicability:
All Emergency Action Level(s): 1. a. Control room evacuation has been initiated AND b. Control of the plant cannot be established in accordance with AOP-0031, Shutdown from Outside the Main Control Room, within 15 minutes Basis: The intent of this IC is to capture those events where control of the plant cannot be reestablished in a timely manner. In this case, expeditious transfer of control of safety systems has not occurred (although fission product barrier damage may not yet be indicated).
The intent of the EAL is to establish control of important plant equipment and knowledge of important plant parameters in a timely manner. Primary emphasis should be placed on those components and instruments that supply protection for and information about safety functions such as reactivity control (ability to shutdown the reactor and maintain it shutdown), reactor water level (ability to cool the core), and decay heat removal (ability to maintain a heat sink)..The determination of whether or not control is established at the remote shutdown panel is based on Emergency Director judgment.
The Emergency Director is expected to make a reasonable, informed judgment within 15 minutes that the plant staff has control-of the plant from the remote shutdown panel.Escalation of this emergency classification level, if appropriate, would be by Fission Product Barrier Degradation (F) or Abnormal Radiation Levels/Radiological Effluent (A)EALs.
 
==References:==
 
Attachment 3 Page 98 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG1 Initiating Condition
-GENERAL EMERGENCY HOSTILE ACTION resulting in loss of physical control of the facility Operating Mode Applicability:
All Emergency Action Level(s):
(1 or 2)1. A HOSTILE ACTION has occurred such that plant personnel are unable to operate equipment required to maintain safety functions OR 2. A HOSTILE ACTION has caused failure of Spent Fuel Cooling Systems and IMMINENT fuel damage is likely for a freshly off-loaded reactor core in pool Basis: EAL #1 This EAL encompasses conditions under which a HOSTILE ACTION has resulted in a loss of physical control of VITAL AREAS (containing vital equipment or controls of vital equipment) required to maintain safety functions and control of that equipment cannot be transferred to and operated from another location.
These safety functions are reactivity control (ability to shut down the reactor and keep it shutdown), reactor water level (ability to cool the core), and decay heat removal (ability to maintain a heat sink).Loss of physical control of the Control Room or remote shutdown panel capability alone may not prevent the ability to maintain safety functions per se. Design of the remote shutdown capability and the location of the transfer switches should be taken into account. Primary emphasis should be placed on those components and instruments that supply protection for and information about safety functions.
If control of the plant equipment necessary to maintain safety functions can be transferred to another location, then the threshold is not met.EAL #2 This EAL addresses failure of spent fuel cooling systems as a result of HOSTILE ACTION if IMMINENT fuel damage is likely, such as when a freshly off-loaded reactor core is in the spent fuel pool. At RBS, the term "freshly off-loaded reactor core" refers to fuel that has been discharged from the core and stored in the spent fuel pool for a period of LESS THAN one year.
 
==References:==
 
NEI 03-12 Attachment 3 Page 99 of 122 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG2 Initiating Condition
-GENERAL EMERGENCY Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency Operating Mode Applicability:
All Emergency Action Level(s): 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for General Emergency.
 
==References:==
 
Attachment 3 Page 100 of 122 SYSTEM MALFUNCTION Attachment 3 Page 101 of 122 SYSTEM MALFUNCTION Sul Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Loss of all offsite AC power to emergency busses for > 15 minutes Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. Loss of all offsite AC power to Div I & II ENS busses for > 15 minutes Basis: Preferred station transformers are: 1 RTX-XSR1 C, 1 RTX-XSR1 D, 1 RTX-XSR1 E and 1 RTX-XS R 1 F.Prolonged loss of offsite AC power reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete loss of AC power to emergency busses.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of off-site power.
 
==References:==
 
Attachment 3 Page 102 of 122 SYSTEM MALFUNCTION SU6 Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT UNPLANNED loss of safety system annunciation or indication in the Control Room for > 15 minutes Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. UNPLANNED Loss of > approximately 75% of the following for > 15 minutes: a. Control room safety system annunciation OR b. Control Room safety system indication Basis: This IC and its associated EAL are intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment.
Recognition of the availability of computer based indication equipment is considered e.g., SPDS, plant computer, etc.."Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.
Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected.
It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions.
It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies.
While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions.
The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.
The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the Attachment 3 Page 103 of 122 SYSTEM MALFUNCTION SU6 NOUE is based on SU1 1 "Inability to reach required operating mode within Technical Specification limits." Annunciators or indicators for this EAL include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures (EOPs and SAPs), and in other EALs (e.g., area process, and/or effluent rad monitors, etc.). Indicators associated with safety systems are those indicators for reactivity control, core cooling, RCS status and containment status. The panels to consider include: H13-P601, H13-P680, H13-P808 (CMS and DRMS), H13-P863 (DRMS), P870 and P877 safety related annunciators and indicators., Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.This NOUE will be escalated to an Alert based on a concurrent loss of compensatory indications or if a SIGNIFICANT TRANSIENT is in progress during the loss of annunciation or indication.
 
==References:==
 
Attachment 3 Page 104 of 122 SYSTEM MALFUNCTION SU7 Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT RCS leakage Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Emergency Action Level(s):
(1 or 2)1. Unidentified or pressure boundary leakage > 10 gpm OR 2. Identified leakage> 35 gpm Basis: This IC is included as a NOUE because it may be a precursor of more serious conditions and, as result, is considered to be a potential degradation of the level of safety of the plant. The 10 gpm value for the unidentified or pressure boundary leakage was selected as it is observable with normal Control Room indications.
Lesser values must generally be determined through time-consuming surveillance tests (e.g., mass balances).
Relief valve normaldoeration should be excluded from this IC. However, a relief valve that operates and fails to close per design should be considered applicable to this IC if the relief valve cannot be isolated.The EAL for identified leakage is set at a higher value due to the lesser significance of identified leakage in comparison to unidentified or pressure boundary leakage. In either case, escalation of this IC to the Alert level is via Fission Product Barrier Degradation (F)ICs.
 
==References:==
 
RBS Technical Specification
 
====3.4.5 Attachment====
 
3 Page 105 of 122 SYSTEM MALFUNCTION SU8 Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Loss of all onsite or offsite communications capabilities Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ..... Startup Mode 3 ...... Hot Shutdown Emergency Action Level(s):
(1 or 2)1. Loss of all of the following onsite communications methods affecting the ability to perform routine operations:
Plant radio system Plant paging system Sound powered phones In-plant telephones OR 2. Loss of all of the following offsite communications methods affecting the ability to perform offsite notifications:
All telephones NRC phones State of Louisiana Radio Offsite notification system and hotline Basis: The purpose of this IC and its associated EALs is to recognize a loss of communications capability that either defeats the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate issues with offsite authorities.
The availability of one method of ordinary offsite communications is sufficient to inform federal, state, and local authorities of plant problems.
This EAL is intended to be used only when extraordinary means (e.g., relaying of information from non-routine radio transmissions, individuals being sent to off-site locations, etc.) are being used to make communications possible.
 
==References:==
 
Attachment 3 Page 106 of 122 SYSTEM MALFUNCTION SU9 Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Fuel clad degradation Operating Mode Applicability:
Emergency Action Level(s): Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown (1 or 2)1. Offgas pre-treatment radiation monitor reading > the Table S1 Dose Rate Limit for the actual indicated offgas flow indicating fuel clad degradation
> T.S. allowable limits 7K Table S1 FLOW Dose Rate FLOW Dose Rate Limit (cfm) Limit (cfm) ~ .(mR/hr)(mR/hr)1 15 9579 70 1865 17.875 8064 80 1671 20 7219 90 1510 25 5788 100 1376 30 4829 110 1262 32.83 2849 120 1165 35 2810 130 1082 40 2680 140 1009 45 2529 150 945 50 2377 175 815 60 2098 200 716 OR 2. Reactor coolant sample allowable limits activity value indicating fuel clad degradation
> T.S.* >4.0 pCi/gm dose equivalent 1-131 OR* >0.2 pCi/gm dose equivalent 1-131 for > 48 hours Attachment 3 Page 107 of 122 SYSTEM MALFUNCTION SU9 Basis: This IC is included because it is a precursor of more serious conditions and, as result, is considered to be a potential degradation of the level of safety of the plant.EAL #1 This EAL addresses site-specific radiation monitor readings that provide indication of a degradation of fuel clad integrity.
The Technical Specification limit of 290 mCi/sec Offgas pre-treatment release is equivalent to 11,210 mR/hr (assumes flow of 17.875 cfm without adjustment for instrument accuracy).
The Table S1 values account for instrument inaccuracy and changing offgas flow rate. The dose rate in the table corresponds to the adjusted TS limit for that associated indicated flow. The table dose rate values may not reflect the H 13-P601/22A/F03 alarm setpoint.
To determine if EAL conditions are met when the pre-treatment high radiation alarm (H13-P601/22A/F03) is lit, the operator must read the actual indicated offgas flow rate and indicated pre-treatment mR/hr value on H 13-P600.Compare the indicated mR/hr value with the Table S1 dose rate mR/hr for the indicated flow value. If the indicated mR/hr is greater than the Table S1 value, the EAL condition is met.EAL #2 This EAL addresses coolant samples exceeding coolant technical specifications for transient iodine spiking limits and coolant samples exceeding coolant Technical Specifications for nominal operating iodine limits for the time period specified in the Technical Specifications.
Escalation of this IC to the Alert level is via the Fission Product Barriers (F).
 
==References:==
 
TS 3.4.8/B 3.4.8 TS 3.7.4 / B 3.7.4 G13.18.9.6.*012 Rev 0 G13.18.9.5-019-3B G13.18.9.5-019-3C USAR 15.7.1 Attachment 3 Page 108 of 122 SYSTEM MALFUNCTION SU10 Initiating Condition
-NOTIFICATION OF UNUSUAL EVENT Inadvertent criticality Operating Mode Applicability:
Mode 3 ...... Hot Shutdown Emergency Action Level(s): 1. UNPLANNED sustained positive period observed on nuclear instrumentation Basis: This IC addresses inadvertent criticality events. This IC indicates a potential degradation of the level of safety of the plant, warranting a NOUE classification.
This IC excludes inadvertent criticalities that occur during planned reactivity changes associated with reactor startups (e.g., criticality earlier than estimated).
This condition can be identified using period monitors.
The term "sustained" is used in order to allow exclusion of expected short term positive periods from planned fuel bundle or control rod movements during core alteration.
These short term positive periods are the result of the rise in neUtron population due to subcritical multiplication.
Escalation would be by the Fission Product Barrier Table (F), as appropriate to the operating mode at the time of the event.Attachment 3 Page 109 of 122 SYSTEM MALFUNCTION Sul1 Initiating Condition NOTIFICATION OF UNUSUAL EVENT Inability to reach required operating mode within Technical Specification limits Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Emergency Action Level(s): 1. Plant is not brought to required operating mode within Technical Specifications LCO Action Statement time Basis: Limiting Conditions of Operation (LCOs) require the plant to be brought to a required operating mode when the Technical Specification required configuration cannot be restored.
Depending on the circumstances, this may or may not be an emergency or precursor to a more severe condition.
In any case, the initiation of plant shutdown required by the site Technical Specifications requires a four hour report under 10 CFR 50.72 (b) Non-emergency events. The plant is within its safety envelope when being shut down within the allowable action statement time in the Technical Specifications.
An immediate NOUE is required when the plant is not brought to the required operating mode within the allowable action statement time in the Technical Specifications.
Declaration of a NOUE is based on the time at which the LCO-specified action statement time period elapses under the site Technical Specifications and is not related to how long a condition may have existed.
 
==References:==
 
Attachment 3 Page 110 of 122 SYSTEM MALFUNCTION SA1 Initiating Condition
-ALERT AC power capability to emergency busses reduced to a single power source for>15 minutes such that any additional single failure would result in station blackout Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. a. AC power capability to Div I and II ENS busses reduced to a single power source for > 15 minutes AND b. Any additional single power source failure will result in station blackout Basis: Preferred station transformers are: 1RTX-XSR1C, 1RTX-XSR1D, 1RTX-XSR1E and 1 RTX-XSR1 F.The condition indicated by this IC is the degradation of the offsite and onsite AC power systems such that any additional single failure would result in a station blackout.
This condition could occur due to a loss of offsite power with a concurrent failure of all but one emergency diesel generator to supply power to its emergency busses. Another related condition could be the loss of all offsite power and loss of onsite emergency diesels generators with only one train of emergency busses being backfed from the unit main generator, or the loss of onsite emergency diesel generators with only one train of emergency busses being fed from offsite power. The subsequent loss of this single power source would escalate the event to a Site Area Emergency in accordance with SS1.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.Div III D/G and bus E22-S004 are not discussed explicitly in this IC. The loss of Div I and Div II are considered a station blackout.
If Div III D/G or E22-S004 is available, entry into this IC is applicable.
 
==References:==
 
Attachment 3 Page 111 of 122 SYSTEM MALFUNCTION SA3 Initiating Condition
-ALERT Automatic scram fails to shutdown the reactor and the manual actions taken from the reactor control console are successful in shutting down the reactor Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Emergency Action Level(s): 1. a. An automatic scram failed to shutdown the reactor AND b. Manual actions taken at the reactor control console successfully shutdown the reactor as indicated by reactor power < 5%Basis: Manual scram actions taken at the reactor control console are any set of actions by the Reactor Operator(s) which causes or should cause control rods to be rapidly inserted into the core and shuts down the reactor.This condition indicates failure of the automatic protection system to scram the reactor.This condition is more than a potential degradation of a safety system in that a front line automatic protection system did not function in response to a plant transient.
Thus the plant safety has been compromised because design limits of the fuel may have been exceeded.
An Alert is indicated because conditions may exist that lead to potential loss of fuel clad or RCS and because of the failure of the Reactor Protection System to automatically shutdown the plant.If manual actions taken at the reactor control console fail to shutdown the reactor, the event would escalate to a Site Area Emergency.
 
==References:==
 
Attachment 3 Page 112 of 122 SYSTEM MALFUNCTION SA6 Initiating Condition
-ALERT UNPLANNED loss of safety system annunciation or indication in the Control Room with either (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable Operating Mode Applicability:
Mode 1 ..... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. a. UNPLANNED loss of > approximately 75% of the following for > 15 minutes: " Control room safety system annunciation OR* Control Room safety system indication AND b. Either of the following:
* A SIGNIFICANT TRANSIENT is in progress OR.0 Compensatory indications are unavailable Basis: This IC is intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a SIGNIFICANT TRANSIENT.
Recognition of the availability of computer based indication equipment is considered (e.g., SPDS, plant computer, etc.)."Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.
Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected.
It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions.
It is also not intended that Attachment 3 Page 113 of 122 SYSTEM MALFUNCTION SA6 the Shift Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation.
It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies.
While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions.
The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.
The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the NOUE is based on SU1 1 "Inability to reach required operating mode within Technical Specification limits." Annunciators or indicators for this EAL include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures (EOPs and SAPs), and in other EALs (e.g., area process, and/or effluent rad monitors, etc.). Indicators associated with safety systems are those indicators for reactivity control, core cooling, RCS status and containment status. The panels to consider include: H13-P601, H13-P680, H13-P808 (CMS and DRMS), H13-P863 (DRMS), P870 and P877 safety related annunciators and indicators."Compensatory indications" in this context includes computer based information such as SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits.
If both a major portion of the annunciation system and all computer monitoring are unavailable, the Alert is required.
Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor the transient in progress due to a concurrent loss of compensatory indications with a SIGNIFICANT TRANSIENT in progress during the loss of annunciation or indication.
 
==References:==
 
Attachment 3 Page 114 of 122 SYSTEM MALFUNCTION ss1 Initiating Condition
-SITE AREA EMERGENCY Loss of all offsite and all onsite AC power to emergency busses for> 15 minutes Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. Loss of all offsite and all onsite AC power to Div 1, 11 and III ENS busses for> 15 minutes Basis: Preferred station transformers are: 1RTX-XSR1C, 1RTX-XSR1D, 1RTX-XSR1E and 1 RTX-XSRI F.Loss of all AC power to emergency busses compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink. Prolonged loss of all AC power to emergency busses will lead to loss of Fuel Clad, RCS, and Containment, thus this event can escalate to a General Emergency.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power.Consideration should be given to operable loads necessary to remove decay heat or provide Reactor Vessel makeup capability when evaluating loss of AC power to emergency busses. Even though an emergency bus may be energized, if necessary loads (i.e., loads that if lost would inhibit decay heat removal capability or Reactor Vessel makeup capability) are not operable on the energized bus then the bus should not be considered operable.
If this bus was the only energized bus then aSAE per SS1 should be declared.Escalation to General Emergency is via Fission Product Barrier Degradation (F) or IC SG1, "Prolonged loss of all offsite and all onsite AC power to emergency busses."
 
==References:==
 
Attachment 3 Page 115 of 122 SYSTEM MALFUNCTION SS3 Initiating Condition
-SITE AREA EMERGENCY Automatic scram fails to shutdown the reactor and manual actions taken from the reactor control console are not successful in shutting down the reactor Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Emergency Action Level(s): 1. a. An automatic scram failed to shutdown the reactor AND b. Manual actions taken at the reactor control console do not shutdown the reactor as indicated by reactor power_> 5%Basis: Automatic and manual scrams are not considered successful if action away from the reactor control console was required to scram the reactor.Under these conditions, the reactor is producing more heat than the maximum decay heat load for which the safety systems are designed and efforts to bring the reactor subcritical are unsuccessful.
A Site Area Emergency is warranted because conditions exist that lead to IMMINENT loss or potential loss of both fuel clad and RCS.Manual scram actions taken at the reactor control console are any set of actions by the Reactor Operator(s) which causes or should cause control rods to be rapidly inserted into the core and shuts down the reactor.Manual scram actions are not considered successful if action away from the reactor control console is required to scram the reactor. This EAL is still applicable even if actions taken away from the reactor control console are successful in shutting the reactor down because the design limits of the fuel may have been exceeded or because of the gross failure of the Reactor Protection System to shutdown the plant.Escalation of this event to a General Emergency would be due to a prolonged condition leading to an extreme challenge to either core-cooling or heat removal.
 
==References:==
 
Attachment 3 Page 116 of 122 SYSTEM MALFUNCTION SS4 Initiating Condition
-SITE AREA EMERGENCY Loss of all vital DC power for > 15 minutes Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. < 105 VDC on all vital DC busses for > 15 minutes Basis: Loss of all DC power compromises ability to monitor and control plant safety functions.
Prolonged loss of all DC power will cause core uncovering and loss of containment integrity when there is significant decay heat and sensible heat in the reactor system.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation to a General Emergency would occur by Abnormal Radiation Levels/Radiological Effluent (A), Fission Product Barrier Degradation (F).
 
==References:==
 
Attachment 3 Page 117 of 122 SYSTEM MALFUNCTION SS6 Initiating Condition
-SITE AREA EMERGENCY Inability to monitor a SIGNIFICANT TRANSIENT in progress Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. a. Loss of > approximately 75% of the following for > 15 minutes:* Control Room safety system annunciation OR* Control Room safety system indication AND b. A SIGNIFICANT TRANSIENT is in progress AND c. Compensatory indications are unavailable Basis: This IC is intended to recognize the threat to plant safety associated with the complete loss of capability of the control room staff to monitor plant response to a SIGNIFICANT TRANSIENT."Planned" and "UNPLANNED" actions are not differentiated since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected.
It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions.
It is also not intended that the Shift Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation.
It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies.
While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the Attachment 3 Page 118 of 122 SYSTEM MALFUNCTION SS6 concern is included in this EAL due to difficulty associated with assessment of plant conditions.
The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.
The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the NOUE is based on SU 1 "Inability to reach required operating mode within Technical Specification limits." A Site Area Emergency is considered to exist if the Control Room staff cannot monitor safety functions needed for protection of the public while a significant transient is in progress.Site specific indications needed to monitor safety functions necessary for protection of the public must include Control Room indications, computer generated indications and dedicated annunciation capability.
Annunciators or indicators for this EAL include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures (EOPs and SAPs), and in other EALs (e.g., area process, and/or effluent rad monitors, etc.). Indicators associated with safety systems are those indicators for reactivity control, core cooling, RCS status and containment status. The panels to consider include: H13-P601, H13-P680, H13-P808 (CMS and DRMS), H13-P863 (DRMS), P870 and P877 safety related annunciators and indicators."Compensatory indications" in this context includes computer based information such as SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits.
Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.
 
==References:==
 
Attachment 3 Page 119 of 122 SYSTEM MALFUNCTION SG1 Initiating Condition
-GENERAL EMERGENCY Prolonged loss of all offsite and all onsite AC power to emergency busses Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Mode 3 ...... Hot Shutdown Emergency Action Level(s): 1. a. Loss of all offsite and all onsite AC power to Div 1, 11 and III ENS busses.AND b. Either of the following:
* Restoration of at least one emergency bus in < 4 hours is not likely OR* RPV level can not be maintained
> -162 inches Basis: Preferred station transformers are: 1RTX-XSR1C, 1RTX-XSR1 D, 1RTX-XSR1E and 1 RTX-XS R 1 F.Loss of all AC power to emergency busses compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink. Prolonged loss of all AC power to emergency busses will lead to loss of fuel clad, RCS, and containment, thus warranting declaration of a General Emergency.
This IC is specified to assure that in the unlikely event of a prolonged station blackout, timely recognition of the seriousness of the event occurs and that declaration of a General Emergency occurs as early as is appropriate, based on a reasonable assessment of the event trajectory.
The likelihood of restoring at least one emergency bus should be based on a realistic appraisal of the situation since a delay in an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions.In addition, under these conditions, fission product barrier monitoring capability may be degraded.Attachment 3 Page 120 of 122 SYSTEM MALFUNCTION SG1 Although it may be difficult to predict when power can be restored, it is necessary to give the Emergency Director a reasonable idea of how quickly (s)he may need to declare a General Emergency based on two major considerations:
: 1. Are there any present indications that core cooling is already degraded to the point that loss or potential loss of Fission Product Barriers is IMMINENT?2. If there are no present indications of such core cooling degradation, how likely is it that power can be restored in time to assure that a loss of two barriers with a potential loss of the third barrier can be prevented?
Thus, indication of continuing core cooling degradation must be based on Fission Product Barrier monitoring with particular emphasis on Emergency Director judgment as it relates to IMMINENT loss or potential loss of fission product barriers and degraded ability to monitor fission product barriers./Attachment 3 Page 121 of 122 SYSTEM MALFUNCTION SG3 Initiating Condition
-GENERAL EMERGENCY Automatic scram and all manual actions fail to shutdown the reactor and indication of an extreme challenge to the ability to cool the core exists Operating Mode Applicability:
Mode 1 ...... Power Operation Mode 2 ...... Startup Emergency Action Level(s): 1. a. An automatic scram failed to shutdown the reactor AND b. All manual actions do not shutdown the reactor as indicated by reactor power > 5%AND c. Either of the following exist or have occurred due to continued power generation:
* Core cooling is extremely challenged as indicated by RPV level can not be maintained
> -186 inches OR* Heat removal is extremely challenged as indicated by RPV pressure and Suppression Pool temperature cannot be maintained in the EOP Heat Capacity Temperature Limit (HCTL) Safe Zone Basis: Under these conditions, the reactor is producing more heat than the maximum decay heat load for which the safety systems are designed and efforts to bring the reactor subcritical are unsuccessful.
In the event either of these challenges exists at a time that the reactor has not been brought below the power associated with the safety system design a core melt sequence exists. In this situation, core degradation can occur rapidly. For this reason, the General Emergency declaration is intended to be anticipatory of the fission product barrier table declaration to permit maximum offsite intervention time.
 
==References:==
 
Attachment 3 Page 122 of 122 Attachment 4 To RBG-47165 Proposed EAL Matrix Chart and Review Table (For Information)
ATTACHMENT x PAGE x OF x ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENT I -&#xfd;&#xfd; &#xfd; I I=7III I -__M_____5v AGI lIIWD Offsite dose resulting from an actual or IMMINENT release of gaseous radioactivity
> 1000 mR TEDE or 5000 mR thyroid CDE for the actual or projected duration of the release using actual meteorology Emergency Action Level(s): (Q or 2 or 3)NOTE: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. If dose assessment results are available, the classification should be based on EAL #2 instead ofEAL#1L Do not delay declaration awaiting dose assessment results.t. VALID reading on any of the radiation monitors in Table RI > the GENERAL EMERGENCY reading for > 15 minutes OR 2. Dose assessment using actual meteorology indicates doses> 1000 rnR TEDE or 5000 mR thyroid CDE at or beyond the SITE BOUNDARY OR 3. Field survey results indicate closed window dose rates >1000 mP/hr expected to continue for > 60 minutes; or analyses of field survey samples indicate thyroid CDE >5000 mR for one hour of inhalation, at or beyond the SITE BOUNDARY ASI Offsite dose resulting from an actual or IMMINENT release of gaseous radioactivity
> 100 mR TEDE or 500 mR thyroid CDE for the actual or projected duration of the release Emergency Action Level(s) (I or 2 or 3)NOTE: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable tine. If dose assessment results are available, the classification should be based on EAL #2 instead of EAL #1. Do not delay declaration awaiting dose assessment results.1. VALID reading on any of the radiation monitors in Table RI> the SITE AREA EMERGENCY reading for> 15 minutes OR 2. Dose assessment using actual meteorology indicates doses> 100 mR TEDE or 500 mR thyroid CDE at or beyond the SITE BOUNDARY OR 3. Field survey results indicate closed window dose rates > 100 mR/hr expected to continue for > 60 minutes; or analyses of field survey samples indicate thyroid CDE > 500 mR for one hour of inhalation, at or beyond the SITE BOUNDARY AA1 A lI Any release of gaseous or liquid radioactivity to the environment
> 200 times the ODCM limit for> 15 minutes Emergency Action Level(s): (I or 2 or 3)NOTE: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown.1. VALID reading on any of the radiation monitors in Table RI> the ALERT reading for > 15 minutes OR 2. For RMS-REI07 effluent monutor: EITHER VALID reading > 200 times the alarm setpoint established by a current radioactivity discharge permit for > 15 minutes OR VALID reading> 1.27E-01 l 1 Ci/ml for> 15 minutes OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 200 times the ODCM limit for> 15 minutes AUI Any release of gaseous or liquid radioactivity to the environment
> 2 times the ODCM limit for> 60 minutes Emergency Action Level(s):
(1 or 2 or 3)NOTE: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time ifan ongoing release is detected and the release start time is unknown.1. VALID reading on any of the radiation monitors in Table RI > the NOUE reading for > 60 minutes OR 2. VALID reading on RMS-RE107 effluent monitor> 2 times the alarm setpoint established by a current radioactivity discharge permit for > 60 minutes OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates> 2 times the ODCM limit for > 60 minutes Table R1 EAL THRESHOLD SMetl .GENERAL EMERGENCY
.SITEAREA EMERGENCY , .ALERTI * : i(OUE DRMS Threshold iIS .lDRMS: Threshold .W>N;K>.. , .RIS4S Thresholds DRMS Thre"suid Main Plant Vent Primary 4GE125 4.70E+08uCi/sec 4GE125 4.70E+07l.tCi/sec 4GE125 3.06E+07 pCi/sec 4GE125 3.06E+05pCi/sec Secondary N/A N/A IGE126 2.82E-01 pCi/mI IGE126 5.26E-03pCi/ml Fuel Building Vent Primary 4GE005 6.70E+07.pCi/sec
.4GE005 6.70E+06p.Ci/sec 4GE005 2.19E+06 pCi/sec 4GE005 2.19E+04pCi/sec Secondary N/A N/A 5GE005 2.82E-01 pCi/mI 5GE005 4.65E-03 pCi/ml Radwaste Building Vent Primary N/A N/A 4GE006 2.58E+O6gCi/sec 4GE006 2.58E+O4pCi/sec Secondary 5GE006 6.84E-02 p.Ci/ml 5GE006 6.84E-04 gCi/ml Plant Modes (white boxes indicate applicable modes) t Power Operation 2 Startp 3 Hot Shutdown 4 Cold Shutdown 5 Refuel D Defueled ATTACHMENT 4 PAGE 1 OF 17 ATTACHMENT x PAGE x OF x ABNORMAL RADIATION LEVELS / RADIOLOGICAL EFFLUENT ml .I-m __AA11111 41 Damage to irradiated fuel or loss of water level that has resulted or will result in the uncovering of irradiated fuel outside the reactor vessel Emergency Action Level(s): (I or 2)i. A water level drop in the reactor refueling cavity, spent fuel pool or fuel transfer canal that will result in irradiated fuel becoming uncovered OR A VALID reading on any of the following radiation monitors due to damage to irradiated fuel or loss of water level: RMS-RE140 2000 mR/hr RMS-RE141 2000 mR/hr RMS-RE192 2000 mR/hr RMS-RE193 2000 mR/hr RMS-RE5A 1.64E+03 pCi/sec RMS-RE5B (GE) 5.29E-04 pCi/ml AU2 11211)UNPLANNED rise in plant radiation levels Emergency Action Level(s): (I or 2)1. a. UNPLANNED water level drop in a reactor refueling pathway as indicated by any of the following:
* Water level drop in the reactor refueling cavity, spent fuel pool, or fuel transfer canal indication on Control Room Panel 870* Personnel observation by visual or remote means.AND b UNPLANNED VALID area radiation monitor alarm on any of the following:
RMS-RE140 RMS-REI41 RMS-RE 192 RMS-RE193 OR 2. UNPLANNED VALID area radiation monitor readings or survey results indicate a rise by a factor of 1000 over normal* levels NOTE: For area radiation monitors with ranges incapable of measuring 1000 times normal* levels, classification shall be based on VALID full scale indications unless surveys conjirm that area radiation levels are below 1000 times normal* within 15 minutes of the area radiation monitor indications goingjfill scale.*Normal can be considered the highest reading in the*0 a.0'C AA3 11111D Rise in radiation levels within the facility that impedes operation of systems required to maintain plant safety functions Emergency Action Level(s): 1. Dose rate > 15 mR/hr in any of the following areas requiring continuous occupancy to maintain plant safety functions:
Main Control Room CAS Plant Modes (white boxes indicate applicable modes) t Power Operation 2 Staruup 3 Hot Shutdown 4 Cold Shutdown 5 Refoel D Defeioled ATTACHMENT 4 PAGE 2 OF 17 ATTACHMENT x PAGE x OF x COLD SHUTDOWN/REFUELING I I ,U CGI Loss of RCS/RPV inventory affecting fuel clad integrity with containment challenged Emergency Action Levells): (I or 2)1. a. RPV level <-162 inches (TAF) for> 30 minutes AND b. Any containment challenge indication in Table Cl OR 2. a. RCS level cannot be monitored with core uncovery indicated by any of the following for> 30 minutes: " RMS-RE16 reading> 100 R/hr* Erratic Source Range Monitor indication
* Unexplained rise in floor or equipment sump level, Suppression Pool level, vessel make-up rate or observation of leakage or inventory loss AND b. Any containment challenge indication in Table Cl CSI 4i+ CA1 11234501CU1 Nj~Loss of RCS/RPV inventory affecting core decay heat removal capability Emergency Action Level(s): (i or 2 or 3)NOTE: The Emergency Director should not wait until the applicable tine has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.I. With CONTAINMENT CLOSURE not established:
RPV level < -49, inches OR 2. With CONTAINMENT CLOSURE established, RPV level < -162 inches (TAF)OR 3. RCS level cannot be monitored for > 30 minutes with a loss of RCS inventory as indicated by any of the following: " RMS-RE16 reading > 100 Rlhr" Erratic Source Range Monitor indication
* Unexplained rise in floor or equipment sump level, Suppression Pool level, vessel make-up rate or observation of leakage or inventory loss Loss of RCS/RPV inventory Emnergency Action Level(s): (I or 2)NOTE: The Emergency Director should not wait until the applicable tine has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. UNPLANNED loss of RCS inventory as indicated by RPV level < -43 inches (Level 2)OR 2. RCS level cannot be monitored for > 15 minutes with a loss of RCS inventory as indicated by an unexplained rise in floor or equipment sump level, Suppression Pool level, vessel make-up rate or observation of leakage or inventory loss RCS leakage Emergency Action Level(s): NOTE: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. RCS leakage results in the inability to maintain or restore RPV level > +9.7 inches (Level 3) for > 15 minutes ifable(CI* CONTAINMENT CLOSURE not established
* Explosive mixture inside containment
* UNPLANNED rise in containment pressure* Secondary containmnent area radiation monitor above EOP Max Safe Operating Value below: Area DRMS Max Safe Grid 2 Operating Value RHR Equip 1213 9.5E+03 mRlhr Rm A RHR Equip 1214 9.5E+03 mR/hr Rmn B RHR Equip RmC 1215 9.5E+03 mR/hr Plant Modes (white boxes indicate applicable modes) I Power Operation 2 Suarstp 3 Hot Shutdown 4 Cold Shutdown 5 Refuel D Defueled ATTACHMENT 4 PAGE 3 OF 17 ATTACHMENT x PAGE x OF x COLD SHUTDOWN/REFUELING I __ , _I U cv2 UNPLANNED loss of RCS/RPV inventory Emergency Action Level(s) (I or 2)Note: The Emergency Director should not wait until the applicable tine has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. UNPLANNED RCS level drop as indicated by either of the following:
: a. RCS water level drop below the RPV flange for> 15 minutes when the RCS level band is established above the RPV flange OR b. RCS water level drop below the RPV level band for> 15 minutes when the RCS level band is established below the RPV flange OR 2. RCS level cannot be monitored with a loss of RCS inventory as indicated by an unexplained rise in floor or equipment sump level, Suppression Pool level, vessel make-up rate or observation of leakage or inventory loss Table C2 RCS Reheat Duration Thresholds RCS Containment Duratioa Closure Intact N/A 60 minutes*S-5 Inbility to maintain plant in cold shutdown "/Emereency Action Level(s): (I or 2)1. An UNPLANNED event results in RCS temperature
> 200 'F > the specified duration in Table C2 OR 2. An UNPLANNED event results in RCS pressure rise > 10 psig due to a loss of RCS cooling Not intact Established 20 minutes-Not Established 0 inmtes*lf an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.
CU3 UNPLANNED loss of decay heat removal capability with irradiated fuel in the RPV Emergency Action Level(s): (I or 2)Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.1. An UNPLANNED event results in RCS temperature exceeding 200&deg;P OR 2. Loss of all RCS temperature and RCS/RPV level indication for> 15 minutes Plant Modes (white boxes indicate applicable modes) I Power Operation 2 Startp 3 Hot Shutdown 4 Cold Shutdown 5 Refuel D Defutled ATTACHMENT 4 PAGE 4 OF 17 ATTACHMENT x PAGE x OF x COLD SHUTDOWN/REFUELING I,.V CA5 I Loss of all offsite and all onsite AC power to emergency usses for > 15 minutes Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable tine has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.CU5 AC power capability to emergency basses reuc toa single power source for > 15 minutes such that any additional single failure would result in station blackout Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.0.U-I 1. Loss of all offsite and all onsite AC power to Div I and Div 11 1. a. AC power capability to Div land Div I1ENS ENS busses for > 15 minutes busses reduced to a single power source for > 15 minutes AND b. Any additional single power source failure will result in station blackout CU6 aLoss of required DC power for > 15 minutes Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time 0 i. < 105 VDC on required Vital DC busses for > 15 minutes CU7 Inadvertent criticality Emergency Action Level(s): 1. UNPLANNED sustained positive period observed on nuclear instrumentation CUll Loss of all onsite or offsite cotmmunications LUILIU-capabilities Emergency Action Level(s): (I or 2)1. Loss of all of the following onsite communication omethods affecting the ability to perform routine! operations:
Plant radio system OPlant paging system Sound powered phones In-plant telephones OR 2. Loss of all of the following offsite communication 2methods affecting the ability to perform offsite notifications:
All telephones NRC phones State of Louisiana Radio Offsite notification system and hotline Plant Modesd (white boxes indicate applicable modes)l Power Operation 2 Stuamp 3 Hot Shutdown 4 Cold Shutdown, 5 Refutel D Deifueled ATTACHMENT 4 PAGE 5 OF 17 ATTACHMENT x PAGE xOF x ISFSI MALFUNCTION DamageUt a loaded cask CONFINEM-ENT BOUNDARY Emergency Action Levels(s):
____ _________________________________________________________
_____________Damage___to__aloadedDamceasoa loaed csk COFINEMNTUBONDAR Plant Modes (white boxes indicate applicable modes) I Power Operation 2 Startup 3 Hot Shutdown 4 Cold Shutdown 5 Refuel D Defiteled ATTACHMENT 4 PAGE 6 OF 17 ATTACHMENT x PAGE x OF x FISSION PRODUCT BARRIERS..
EMERG IG1 b2 u 1 FSI Loss of ANY two barriers AND loss or potential loss of the Loss or potential loss of ANY two barriers hd EmergencE Action Level(s): t Emergency Action Levelkh 1. Loss or potential loss of soy two barriers1. Loss ofany two barriersANDLoss or potential loss of the third barrier FAI bJ7GE1 = FUJI ANY loss or ANY potential loss of EITHER fuel clad or RCS ANY loss or ANY potential loss of containment Emergency Action Level(s):
Emergency Action Levelsi: .1. Any loss or any potential loss of fuel clad 1. Any loss or any potential loss of containment OR Any loss or any potential loss of RCS w1~I 1 .' -..... l.jjjjjjj tTL~ CA(FC) BarertjjJ2j:
j j jj REACTOR COOLANT SYSTEM (RC) nTjJ.jj&#xfd;iJ i PRIMARY CONTINMEN.T(PCCBrrerj Parameter
' .>Las- Potential Lrss Paeaneter
~KL-s~ Potential Loss Parantetr Los-. Potentitta Los FCI Primary coolant Coolant activity None RCI Drywellpressure Drywell pressure>
t.68 psid with None PCt Primary 1. Rapid unexplained loss of PC t. PC pressure > 15 psig and rising activity level > 300 /Ci/gm dose indications of reactor coolant leak in containment pressure following initial pressure OR equivalent 1-131 drywell conditions
! rise 2. a. PC hydrogen in the unsafe OR zone of HDOL curve 2. PC pressure response not consistent OR with LOCA conditions
: b. DW hydrogen concentration
> 9%OR 3. RPV pressure and suppression pool temperature cannot be maintained below the HCTL FC2 Reactor vessel RPV water level cannot be RPV water level cannot be RC2 Reactor vessel water RPV water level cannot be restored and None PC2 Reactor vessel None Entry into PC flooding procedures water level restored and maintained restored and maintained level maintained above -162 inches or cannot water level SAP- I and SAP-2 above -186 inches above -162 inches or be determined cannot be determined FC3 Primary Containment radiation None RC3 RCS Leak Rate 1. a. UNISOLABLE main steam line t. RCS leakage > 50 gpm inside PC3 Primary t.a. Failure of all valves in any one None containment moanitor RMS-RE16 break as indicated by the failure of the drywell containment line to close radiation reading > 3,000 R/hr both MSIVs in any one line to close OR isolation failure or AND monitors AND 2. UNISOLABLE RCS leakage bypass b. Direct downstream pathway to outside PC as indicated by the environment exists after PC High MSL flow annunciator exceeding either of the isolation signal (P601-19A-A2) following:
OfR AND a. Max Normat Operating
: 2. Intentional PC venting per EOPs or Main Steam Tunnel Temperature Temperature (Table P2) SAPs> 1441F [1731F NRC TS submittal OR OR change] b. Max Normal Area 3. UNISOLABLE RCS leakage outside OR Radiation (Table F2) PC as indicated by exceeding either b. Indication of an UNISOLABLE of the following:
HPCS, feedwater, RWCU or RCIC a. Max Safe Operating Temperature break (Table FI)OR OR 2. Emergency RPV depressurization is h. Max Safe Area Radiation (Table required FI)RC4 D~rywelt radiation Drywvell radiation monitor RMS-RE20 None PC4 Primary None Containment radiation monitor reading > 100 R/hr due to reactor coolant containment RMS-REI6 reading,>
10,OO R/hr leakage radiation monitors FC4 Emergency Any condition in the Any condition in the RC5 Emergency Director Any condition in the opinion of the Any condition in the opinion of PC5 Emergency Any condition in the opinion of the Any condition in the opinion of Directorjudgment opinion of the Emergency opinion of the Emergency judgment Emergency Director that indicates loss of the Emergency Director that Director judgment Emergency Director that indicates loss the Emergency Director that Director that indicates loss Director that indicates the RCS barrier indicates potential loss of the of the Primary Containment barrier indicates potential loss of the of the Fuel Clad barrier potential loss of the Fuel RCS barrier Primary Containment barrier Clad barrier ATTACHMENT 4 PAGE 7 OF 17 ATTACHMENT x PAGE x OF x FISSION PRODUCT BARRIERS TABLE F1 "_____________
_ : 3 Loss of Primary Containii ent , Parameter Area Temperature Area Radiation Level Max Safe Operating Value DRMS Grid 2 Max Safe Operating Value R HR A equipment area 200' F 1213 9.5EE+03 mR/hr RHR B equipment area 200' F 1214 9.5E+03 mR/hr RHR C equipment area N/A 1215 9.5E1+03 mR/hr RCIC room 200' F 1219 9.5E+03 mR/hr MSL Tunnel 200' F N/A RWCU pump room 1 2000 F N/A (A)/2 (B)- RC 3,Potential Loss of RCS Parameter Area Temperature Area Radiation Level (isolation temperature DRMS Grid 2 Max Normal Operating alarm) Value RHR A equipment area 117' F 1213 8.2E+01 mR/hr (P601-20A-B4)
RPHR B equipment area 1170 F 1214 8.2E+0l mR/hr (P601-20A-B4)
RHR C equipment area N/A 1215 8.2E+01 mR/hr RCIC room 182' F 1219 1.20E+02 mR/hr (P601-21A-B6)
MSL Tunnel 144&deg; F [173 0 F NRC TS N/A submittal change](P601-19A-A1/A3/BI/B3)
RWCU pump room I (A) / 2 (B) 165' F N/A (P680-I A-A2/B2)Plant Modes (white boxes indicate applicable modes) t Power Operation 2 Startup 3 Hot shutdown 4 Cold Shutdown 5 Refuel D Dcfueled ATTACHMENT 4 PAGE 8 OF 17 ATTACHMENT x PAGE x OF x HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY AM HGI HOSTILE ACTION resulting in loss of physical control of the facility Emergency Action Level(s): (I or 2)1. A HOSTILE ACTION has occurred such that plant personnel are unable to operate equipment required to maintain safety functions HSI ~ ~ EI HAl IiI HOSTILE ACTION within the PROTECTED AREA HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat Emergency Action Levelts): 1. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the RBS security shift supervision Emergency Action Level(s): (I or 2)I. A HOSTILE Action is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the RBS security shift supervision OR 2. A validated notification from NRC of an airliner attack threat within 30 minutes of the site HUt Confirmed SECURITY CONDITION or threat which indicates a potential degradation in the level of safety of the plant Emergency Action Level(s): (I or 2 or 3)1. A SECURITY CONDITION that does NOT involve a HOSTILE ACTION as reported by the RBS security shift supervision OR 2. A credible site specific security threat notification OR 3. A validated notification from NRC providing information of an aircraft threat OR 2. A HOSTILE ACTION has caused failure of Spent Fuel Cooling Systems and IMMINENT fuel damage is likely for a freshly off-loaded reactor core in pool t__ I -I- +t HG2 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency Emergency Action Level(s)I. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.
Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area HS2 1 1 1I HA2 Other conditions exist which in thejudgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY Emergency Action Level(s): i Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts: (1)toward site personnel or equipment that could lead to the likely failure of or: (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond die SITE BOUNDARY Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT Emefgency Action Level(s): i. Other conditions exist which in thejudgment of the Emergency Director indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels Other conditions exist which in the judgment of the Emergency Director warrant declaration of a NOUE Emergency Action Level(s): t. Other conditions exist which in thejudgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.
No releases of radioactive material requiring offsite response or monitoring are expected unless flxnter degradation of safety systems occurs IiI2I3I4II)
HU2 Plant Modes (while boxes indicate applicable modes) t Power Opiration 2 Starup 3 Hot Shutdown 4 Cold Shutdown 5 Refuel D Defueled ATTACHMENT 4 PAGE 9 OF 17 ATTACHMENT x PAGE x OF x HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY o 115S3 EIED HA3 Control room evacuation has been initiated and plant control Control room evacuation has been initiated cannot be established Emereencv Action Level(s): Emereency Action Level(s):
: i. AOP-0231, Shbutdwn fituOutdethstMain Control Rom turas E 1. a. Control room evacuation has been initiated CorttolRoom AND-b. Control of the platt cannot be established in Q accordance with AOP-003 1, Shutdown from Outside the Main Control Room, within 15 minutes 11A4 i235 HU4 KZE FIRE or EXPLOSION affecting the operability of plant safety FIRE within the PROTECTED AREA not extinguished systems required to establish or maintain safe shutdown within 15 minutes of detection or EXPLOSION within the PROTECTED AREA Emergency Action Level(s):
Emergency Action Level(s):
(0 or 2)1. FIRE or EXPLOSION resulting in VISIBLE DAMAGE Note: The Emergency Director should not wait until the to any of the structures or areas in Table H2 containing applicable time has elapsed, but should declare the event as safety systems or components or Control Room soon as it is determined that the duration has exceeded, or will indication of degraded performance of those safety likely exceed, the applicable time.systems 1. FIRE not extinguished within 15 minutes of Control Room notification or verification of a Control Room FIRE alarm in any Table H2 structure or area OR 2. EXPLOSION within the PROTECTED AREA HAS i2 45 US LE Access to a VITAL AREA is prohibited due to toxic, Release of toxic, corrosive, asphyxiant or flanmmable gases corrosive, asphyxiant or flammable gases which jeopardize deemed detrimental to NORMAL PLANT OPERATIONS operation of operable equipment required to maintain safe operations or safely shutdown the reactor Emereency Action Level(s): (I or 2)Emergency Action Level(s):
: 1. Toxic, corrosive, asphyxiant or flammable gases in a Note: If the equipment in the stated area was already amounts that have or could adversely affect NORMAL inoperable, or out of service, before the event occurred, then PLANT OPERATIONS this EAL should not be declared as it will have no adverse OR impact on the ability of the plant to safely operate or safely 2. Report by West Feliciana Parish for evacuation or shutdown beyond that already allowed by Technical sheltering of site personnel based on an offsite event Specifications at the time of the event.1. Access to a VITAL AREA (Table 112) is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor Plant Modes (white boxes indicate applicable modes) I Power Operation 2 Stamup 3 Hot Shutdown 4 Cold Shutdown 5 Refuel D Defaeied ATTACHMENT 4 PAGE 10 OF 17 ATTACHMENT x PAGE x OF x HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY WI WT I E 0~z w Un ,itrled FI ingTh-oOd Pv;reaWai Ketl-c Affected Location Max Safe Onerating Parameter Value / Indicator Aux Bldg Crescent 6 inches above floor Area 70' EL (must be verified locally)HPCS Room 70'EL 4 inches above floor (P870-5 IA-G4)RHR A Room 70'EL 4 inches above floor (P870-5 IA-G4)RHR B Room 70'EL 4 inches above floor (P870-51A-G4)
RHR C Room 70'EL 4 inches above floor (P870-5 IA-G4)LPCS Room 70'EL 4 inches above floor (P870-5 IA-G4)RCIC Room 70'EL 4 inches above floor (P870-5 IA-G4)Building Cooling Tower Auxiliary Diesel Building Generator Building Control Tunnels (B, D, Building E, F, G, T)Fuel Building HA6 111213 D Natural or destructive phenomena affecting VITAL AREAS Emernency Action Level(s): (I or 2 or 3 or 4 or 5 or 6)1. a. Seismic event > Operating Basis Earthquake (OBE) as indicated by: Annunciator "Seismic Tape Recording System Start" (P680-02A-D06)
AND Event Indicator on ERS-NBI-102 is white AND Receipt of EITHER I OR 2: 1. Annunciator "Seismic Event High" (P680-02A-C06)2. Annunciator "Seismic Event High-High" (P680-02A-B06)
AND amber light(s) on panel NBI-101 AND b. Earthquake confirmed by any of the following:
* Earthquake felt in plant* National Earthquake Center* Control Room indication of degraded performance of systems required for the safe shutdown of the plant OR 2. Tomado striking resulting in VISIBLE DAMAGE to any of the Table H2 structures or areas containing safety systems or components or Control Room indication of degraded performance of those safety systems OR 3. Internal flooding in Auxiliary Building 70 ft elevation resulting in an electrical shock hazard that precludes access to operate or monitor safety equipment or Control Room indication of degraded performance of those safety systems OR 4. Turbine failure-generated PROJECTILES resulting in VISIBLE DAMAGE to or penetration of any of the Table H2 structures or areas containing safety systems or components or Control Room indication of degraded performance of those safety systems OR 5. Vehicle crash resulting in VISIBLE DAMAGE to any of the Table H2 structures or areas containing safety systems or components or Control Room indication of degraded performance of those safety systems OR 6 Hurricane or high SUSTAINED wind conditions
> 74 mph within the PROTECTED AREA boundary and resulting in VISIBLE DAMAGE to any of the Table H2 structures or areas containing safety systems or components or Control Room indication of degraded nerrarroannee at these Cua0etv svstems n mnruvoecy u- eVtll~l 3 .1 ort 2 or 3 or 4 or 51 1. Seismic event identified by any 2 of the following:
Seismic event confirmed by activated seismic switch as indicated by receipt of EITHER a OR b: a. Annunciator "Seismic Tape Recording SYS Starn" (P680-02A-D06)
: b. Event Indicator on ERS-NBI-102 is white* Earthquake felt in plant* National Earthquake Center OR 2. Tomado striking within the PROTECTED AREA boundary OR 3. Internal flooding that has the potential to affect safety related equipment required by Technical Specifications for the current operating mode in any Table HI area OR 4. Turbine failure resulting in casing penetration or damage to turbine or generator seals OR 5. Severe weather or hurricane conditions with indication of SUSTAINED high winds > 74 mph within the PROTECTED AREA boundary HU6 11141D Natural or destructive phenomena affecting the PROTECTED AREA erformance_
aftoesfc tm Ptaut Mudes t rawer Operuauin 2 Surup 3 Hot Shutdows 4 Cold Shutdowu 5 Refuel D Defueled ATTACHMENT 4 PAGE 11 OF 17 ATTACHMENT x PAGE x OF x SYSTEM MALFUNCTION C 0.Id-4 SGIW111214IS[[
Prolonged loss of all offsite and all onsite AC power to emergency busses Emergency Action Level(s): 1. a. Loss of all offsite and all onsite AC power to Div 1, 11 and II ENS busses AND b. Either of the following:
* Restoration of at least one emergency bus in< 4 hours is not likely OR* RPV level cannot be maintained
> -162 inches SSI L1l1,1ZS6 Loss of all offsite and all onsite AC power to emergency busses for>15 minutes Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable tine has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.i. Loss of all offsitc and all onsite AC power to Div I, I1 and IIl ENS busses for> 15 minutes SAI AC power capability to emergency busses reduced to a single power source for > 15 minutes such that any additional single failure would result in station blackout Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. a. AC power capability to Div I and Div 11 ENS busses reduced to a single power source for > 15 minutes AND b. Any additional single failure will result in a station blackout 1 3-F Sul 1U213 Wd 1)Loss of all offsite AC power to emergency busses for > 15 minutes Emergency Action Level(s): Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.1. Loss of all offsite AC power to Div I and HENS busses for> 15 minutes 4 4 +a.t SG3 1L 11 [3 Automatic scram and all manual actions fail to shutdown the reactor and indication of an extreme challenge to the ability to cool the core exists Emergency Action Level(s): 1. a. An automatic scram failed to shutdown the reactor AND b. All manual actions do not shutdown the reactor as indicated by reactor power a 5%AND c. Either of the following exist or have occurred due to continued power generation:
* Core cooling is extremely challenged as indicated by RPV level can not be maintained
> -186 inches OR* Heat removal is extremely challenged as indicated by RPV pressure and Suppression Pool temperature cannot be maintained in the EOP Heat Capacity Temperature Limit (1iCTL) Safe Zone ss3 Automatic scram fails to shutdown the reactor and the manual actions taken from the reactor control console are not successful in shutting down the reactor Emergency Action Level(s): 1. a. An automatic scram failed to shutdown the reactor AND b. Manual actions taken at the reactor control console do not shutdown the reactor as indicated by reactor power > 5%SA3 I1U1 1 Automatic scram fails to shutdown the reactor and the manual actions taken from the reactor control console are successful in shutting down the reactor Emergency Action Level(s): 1. a. An automatic scram failed to shutdown the reactor AND b. Manual actions taken at the reactor control console successfully shutdown the reactor as indicated by reactor power < 5%Plant Modes (white boxes indicate applicable moodes) I Power Operation Stamup 3 Hot Shutdown 4 Cold Shutdown 5 Refuel D Defuoled I ATTACHMENT 4 PAGE 12 OF 17 ATTACHMENT x PAGE x OF x SYSTEM MALFUNCTION Loss of all vital DC power for> 15 minutes L Emergency Action Level(s): U Note. The Emergency Director should not wait until the applicable time ohas elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.I. < 105 VDC on all vital DC busses for> 15 minutes SS6 SA6 SU6 Inability to monitor a SIGNIFICANT TRANSIENT in progress UNPLANNED loss of safety system annunciation or indication UNPLANNED loss of safety system annunciation or in the control room with either (1) a SIGNIFICANT indication in the Control Room for> 15 minutes Emergency Action Level(s):
TRANSIENT in progress, or (2) compensatory non-alarming Note: The Emergency Director should not wait until the applicable tine indicators are not available Emergency Action Level(s): has elapsed, but should declare the event as soon as it is determined that Note: The Emergency Director should not wait until the the condition has exceeded, or will likely exceed, the applicable time. Emergency Action Level(s):
.applicable time has elapsed, but should declare the event as I. a. UNPLANNED loss of> approximately 75% of the following for Note: The Emergency Director should not wait until the soon as it is determined that the condition has exceeded, or> 15 minutes: applicable time has elapsed, but should declare the event as will likely exceed, the applicable time.soon as it is determined that the condition has exceeded, or 1. UNPLANNED loss of> approximately 75% of the* Control Room safety system annunciation will likely exceed, the applicable time. f for s 1 f minutes:= ~following for _> 15 minutes: OR 1. a. UNPLANNED loss of> approximately 75% of the following for > 15 minutes: a. Control Room safety system annunciation" Control Room safety system indication M Control Room safety system annunciation OR= AND A OR b. Control Room safety system indicationb. A SIGNIFICANT TRANSIENT is in progress AN Control Room safety system indication AND AND c. Compensatory indications are unavailable
: b. Either of the following:
.A SIGNIFICANT TRANSIENT is in progress OR* Compensatory indications are unavailable SU7 RCS leakage i Emergency Action Level(s): (I or 2)..n 1. Unidentified or pressure boundary leakage > 10 gpm UOR 2. Identified leakage > 35 gpm Plant Modes (white boxes indicate applicable modes)I Power Operation 2 Stamrop 3 Hot Shutdown 4 Cold Shutdown 5 Refuel D Defueled ATTACHMENT 4 PAGE 13 OF 17 ATTACHMENT x PAGE x OF x SYSTEM MALFUNCTION-a-p -I- SU2 HThIi1iL~i E ELoss of all onsite or offsite communications capabilities Emergency Action Level(s): (I or 2)1. Loss of all of the following onsite communications methods affecting the ability to perform routine operations:
Plant radio system Plant paging system Sound powered phones In-plant telephones OR 2. Loss of all of the following offsite communications methods affecting the ability to perform offsite notifications:
j All telephones NRC phones State of Louisiana Radio Offsite notification system and hotline SU9 Table Sl I Fuel clad degradation FLOW , Dose Rate F 1(O01, Dose Ratei Emergency Action Level(s): (I or 2)Sefm) U, Limit (cfils i, '1) Lmi t I .Offgas pre-treatment radiation monitor reading > the 0 0(mRlhkr):
7: : (riiR ) Table S I Dose Rate Limit for the actual indicated offgas 15 9579 70 1865 flow indicating fuel clad degradation
> T.S. allowable 17.875 8064 80 1671 limits 20 7219 90 1510 OR 25 5788 t00 1376 2. Reactor coolant sample activity value indicating fuel.30 4829 110 1262 clad degradation
> T.S. allowable limits a 32.83 2849 120 1165 35 2810 130 1082 .> 4.0 pCi/gm dose equivalent 1-131 40 2680 140 1009 OR 45 2529 150 945 * > 0.2 laCi/gma dose equivalent 1-131 for > 48 50 2377 175 815 hours 60 2098 200 716.SUI0*o -Inadvertent criticality Emergency Action Level(s):~1. UNPLANNED sustained positive period observed on nuclear instrumentation SUII U, Inability to reach required operating mode within Technical Specification limits 02 Emergency Action Level(s): 1. Plant is not brought to required operating mode within Technical Specifications LCO Action Statement time Plant Modes (white boxes indicate applicable modes) I Power Operatian 2 Stamup 3 Hot Shutdown 4 Cold Shutdown 5 Refuel D Defueled ATTACHMENT 4 PAGE 14 OF 17 CROSS REFERENCE MATRIX FROM NEI EAL NUMBER TO ENTERGY EAL NUMBER IRBS IC NEI 99-01 IC Diff. Doc. Page Clean Basis Page No AU1 AU1 4 11 AU2 AU2 7 14 AA1 AA1 10 16 AA2 AA2 13 19 AA3 AA3 15 21 AS1 ASI 17 22 AGI AGI 20 24-P.&#xfd;CU1 CU2 CU3 CU5 CU6 CU7 CU8 CAI CU1 CU2 CU4 CU3 CU7 CU8 CU6 CAI CA4 CA3 CS1 CG 1 23 25 27 29 31 33 35 37 39 41 43 45 27 28 30 31 32 33 34 35 36 38 39 41 CA3 CA5 CS1 CG 1 E-HU1 E-HU1 48 44 FU1 FU1 50 52 FA1 FA1 51 53 ATTACHMENT 4 Page 15 of 17 CROSS REFERENCE MATRIX FROM NEI EAL NUMBER TO ENTERGY EAL NUMBER"S IC NEI 99-01 IC Diff. Doc. Page Clean Basis Pa e No FS1 FS1 52 54 FG1 FG1 53 55 Fuel Clad EALs Fuel Clad EALs 54 56 RCS EALs RCS EALs 57 60 Containment EALs Containment EALs 61 67 HUl HU4 66 75 HI2 HI15 68 77 HU4 HU5 H1U6 HAI HA2 HA3 HA4 HA5 HA6 HS1 HS2-HS3 HU2 HU3 HUI HA4 HA6 HA5 HA2 HA3 HA1 HS4 HS3 RS2 70 72 74 78 80 82 84 86 88 93 95 97 78 80 81 85 87 88 89 90 92 96 97 99 HG1 HG2 Sul HG1 HG2 Sul 99 101 103 99 100 102 ATTACHMENT 4 Page 16 of 17 CROSS REFERENCE MATRIX FROM NEI EAL NUMBER TO ENTERGY EAL NUMBER IBS IC NEI 99-01 IC Diff. Doc. Page Clean Basis Pa e No]SU6 SU3 105 103 SU7 SU5 107 105 SU8 SU6 109 106 SU9 SU4 111 107 SU10 SU8 114 109 SUl1 SU2 116 110 SA1 SA5 118 111 SA3 SA2 120 112 SA6 SA4 122 113 SS1 SS1 125 115 SS3 SS2 127 116 SS4 SS3 129 117 SS6 SS6 131 118 SG1 SG1 133 120 SG3 SG2 135 122 ATTACHMENT 4 Page 17 of 17 Attachment 5 To RBG-47165 Supporting Referenced Document Pages NEI 99-01 Rev 5 EALs Bases for Values Main Plant Exhaust 4125 Primary Source document:
Calculations G13.18.9.6*012 RO (page 18) & PR-c-495 (page 3)1/3 TS = 5.1 1E4 uCi/Sec TS = 3 x 5.1 1E4 = 1.53E5 uCi/Sec AU1-1 2 x TS = 2 x 1.53E5 = 3.06E5 uCi/Sec AAI-1 200 x TS = 200 x 1.53E5 = 3.06E7 uCi/Sec 1126 Secondary Source document:
ESK-13RMS25
& Calculation G13.18.9.6-010 RO (pages 1, 8 & 9)1/3 TS = 8.77E-4 uCi/ml TS = 3 x 8.77E-4 = 2.63E-3 uCi/ml AU1-1 2 x TS = 2 x 2.63E-3 = 5.26E-3 uCi/ml*AAI-1 200 x TS = 200 x 2.63E-3 = 5.26E-1 = 2.82E-1 uCi/ml (max range)*Detector max range is 2.82E-1 for Kr-85 and 5.43E-1 for Xe-133 based on Calculation G13.18.9.6-010 RO. Limited to max conservative value of (Kr-85) 2.82E-1.Fuel Buildin2 Exhaust 4005 Primary Source documenit:
Calculation G13.18.9.6*012 RO (page 10)1/3 TS = 3.65E3 uCi/Sec TS = 3 x 3.65E3 = 1.095E4 uCi/Sec AUI-1 2 x TS = 2 x 1.095E4 = 2.19E4 uCi/Sec AAI-1 200 x TS = 200 x 1.095E4 = 2.19E6 uCi/Sec 5005 Secondary Source document:
Calculation G13.18.9.6*012 RO (page 10) & G13.18.9.6-010 RO (pages 1, 8 & 9)1/3 TS = 7.76E-4 uCi/ml TS = 3 x 7.76E-4 = 2.328E-3 uCi/ml AU1-1 2 x TS = 2 x 2.328E-3 = 4.65E-3 uCi/ml*AA1-1 200 x TS = 200 x 2.328E-3 -4.65E-1 = 2.82E-1 uCi/ml (max range)*Detector max range is 2.82E-1 for Kr-85 and 5.43E-1 for Xe-133 based on Calculation G13.18.9.6-010 RO. Limited to max conservative value of (Kr-85) 2.82E-1.Attachment 5 Page I of 5 NEI 99-01 Rev 5 EALs Bases for Values Radwaste Building Exhaust 4006 Primary Source document:
Calculation G 13.18.9.6*012 RO (page 11)1/3 TS = 4.3 1E3 uCi/Sec TS = 3 x 4.3 1E3 = 1.29E4 uCi/Sec AU1-1 2 x TS = 2 x 1.29E4 = 2.58E4 uCi/Sec AA1-1 200 x TS = 200 x 1.29E4 = 2.58E6 uCi/Sec 5006 Secondary Source document:
Calculation ESK-13RMS05 1/3 TS = 1.14E-4 uCi/ml TS = 3 x 1.14E-4 = 3.42E-4 uCi/ml AU1-1 2 x TS = 2 x 3.42E-4 = 6.84E-4 uCi/mi AAI-1 200 x TS = 200 x 3.42E-4 = 6.84E-2 uCi/ml Liquid Effluent 107 Source Document:
RSP-0008, CSP-01 10, Calculation G 13.18.9.6-010 RO (pages 1 & 7)The alarm setpoint is calculated for each discharge permit not to exceed TRM limit.AU1-2 >2 x alarm setpoint >60 minutes AAl-2 >200 x alarm setpoint OR 1.27E-l >15 minutes*Detector max range is 1.28E-1 based on Calculation G13.18.9.6-010 RO (pages 1 & 7).Reduced EAL value by 0.001 to allow a reading within detector range above EAL setpoint.AA2 RMS-RE140 2000 mr/hr *RMS-RE141 2000 mr/hr *RMS-RE192 2000 mr/hr *RMS-RE193 2000 mr/hr *RMS-RE5A 1.64E3 uCi/Sec (high alarm setpoint and ventilation shifts to filtered)RMS-RE5B (GE) 5.29E-04 uCi/ml (high alarm setpoint and ventilation shifts to filtered)*28 daily average readings were obtained from the 4 radiation monitors on 6/27/11. No refueling activities were being performed during this time period. During refueling activities the monitors may read higher due to work activities and higher pool water radioactivity concentrations.
The readings ranged from 0.32 to 1 mr/hr. If AU2-2 is applied to these monitors, NOUE entry requirements would range from 320 to 1000 mr/hr. To make the AA2 Alert values higher than the NOUE, the highest reading (1 mr/hr) was multiplied by 2000 to give a value of 2000 mr/hr or a factor of 2 higher than NOUE EAL value of 1000 times normal.Attachment 5 Page 2 of 5 NEI 99-01 Rev 5 EALs Bases for Values ASI Classification is based on effluent monitor reading which would meet or exceed 10% of an EPA Protective Action Guideline (100 mRem TEDE or 500 mRem CDE) at the Site Boundary.
The Effluent Monitor values were determined using CADAP (offsite dose calculation software) methodologies with the following assumptions:
* Wind Speed 4 mph 0 Stability Class D* Filtered Release* Pool Scrubbing (Fuel Building (FB) only) (required by software)* No Damage for MPE, Clad Damage for FB (required by software)* 1 hour Release Duration* Time after reactor shutdown = 1:00 hour 4125 4.7E7 uCi/Sec (Main Plant Exhaust)4005 6.7E6 uCi/Sec (Fuel Building Exhaust)AGI Classification is based on effluent monitor reading which would meet or exceed an EPA Protective Action Guideline (1 Rem TEDE or 5 Rem CDE) at the Site Boundary.
The Plant Vent and Fuel Building vent values was determined using CADAP (offsite dose calculation software) methodologies with the following assumptions:
* Wind Speed 4 mph 0 Stability Class D/0 Filtered Release* Pool Scrubbing (Fuel Building (FB) only) (required by software)* No Damage for MPE, Clad Damage for FB (required by software)* 1 hour Release Duration* Time after reactor shutdown = 1:00 hour 4125 4.7E8 uCi/Sec (Main Plant Exhaust)4005 6.7E7 uCi/Sec (Fuel Building Exhaust)Attachment 5 Page 3 of 5 NEI 99-01 Rev 5 EALs Bases for Values CS1 & CG1 RBS does not have a calculation for a specific setpoint to indicate that the core is uncovered.
As water level in the RPV lowers, the dose rate above the core will rise. The dose rate due to core shine should result in a rapid rise in the Containment high range monitor indication and possible alarm. COP-1050, the procedure used to estimate core damage in accident conditions, does have values for the containment PAMs during the 24 hour period following shutdown.
The COP-1050 values are from Calculation G13.18.9.4-047 which is based on the GE document NEDC-33045P.
The conditions are reactor shutdown and depressurized.
The 100% clad damage 24 hours after shutdown containment radiation level is 1.56E4 R/hr. The radiation level is assumed to be linear to the percent of clad damage.Indicated Radiation Level = 100% Clad Damage Radiation Level X % Clad Damage/100 Indicated Radiation Level = 1.56E4 R/hr X 1%/100 = 156 R/hr The 1% fuel cladding damage value shown above is rounded down to 100 R/hr to provide for a more conservative value. This value does not take into account any additional dose rates due to radiation shine from uncovered vessel internals and fuel due to low water level in an open RPV during refueling.
This value is not a calculated EAL measure since time of shutdown and available nuclide source may vary the magnitude of dose rate.Since fuel movement is allowed to start at 24 hours after shutdown, the assumption from COP-1050 is reasonable.
FC3 Containment radiation monitors reading in excess of 3000 R/hr after Reactor Shutdown are indicative of both the loss of the reactor coolant system and 5% clad failure with the instantaneous release and dispersal of the reactor coolant noble gas and Iodine inventory into the drywell and containment atmosphere.
Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations (including iodine spiking) allowed within Technical Specifications and are therefore indicative of fuel damage.Calculation G13.18.9.4-045 Rev. 0 (page 14) shows that 5% clad damage ranges from-7000 to -3000 R/hr during the first 3 hours.Attachment 5 Page 4 of 5 NEI 99-01 Rev 5 EALs Bases for Values RC4 The physical location of the River Bend drywell radiation monitor is exposed to shine from the reactor vessel and RCS piping. Calculation G13.18.9.4-051 (page 7) was performed to determine the expected radiation indication threshold in the drywell for a reactor coolant leak. The EAL threshold value of 100 R/hr is within the calculated value.The drywell post accident radiation monitor was selected in lieu of the containment post accident radiation monitor due to the physical layout of RCS piping and the location of the monitors.
The drywell contains the RPV with the majority of RCS piping and its respective containment isolation valves. The RCS piping continues through the enclosed containment steam tunnel (accessed via pull plugs) to the annulus and then to the auxiliary building steam tunnel. Therefore, the drywell radiation monitors are the most likely monitors to initially detect a RCS leak within the containment building.PC4 Calculation G13.18.9.4-045 Rev. 0 (page 15) shows that 20% clad damage ranges from-12,000 to -10,000 R/hr during the first 4 hours after shutdown and a failure of the reactor coolant system allowing the entire inventory to be disbursed inside the containment.
The threshold set point of 10,000 R/hr is used conservatively and is easily recognized.
The reading of 10,000 R/hr is a value which indicates significant fuel damage well in excess of that required for loss of RCS and fuel clad.Attachment 5 Page 5 of 5}}

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