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Cooper Nuclear Station, Emergency Plan Implementing Procedure 5.7.1, Emergency Classification, Rev. 58
	ML17206A084
Person / Time
Site:	Cooper
Issue date:	06/22/2017
From:	; Nebraska Public Power District (NPPD)
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML17206A075	List: ML17206A083; NLS2017061, Emergency Plan Implementing Procedure 5.7.1, Emergency Classification, Rev. 58;
References
	NLS2017061
	Download: ML17206A084 (337)
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NLS2017061 Attachment Page 1 of2 Attachment Report of Change and Summary of 50.54(q) Analysis Emergency Plan Implementing Procedure 5.7.1, Revision 58 Change Description Emergency Plan Implementing Procedure (EPIP) 5.7.1, Emergency Classification, contains the Nuclear Regulatory Commission approved Emergency Action Level (EAL) classification scheme used by Cooper Nuclear Station (CNS), which is based on Nuclear Energy Institute (NEI) 99-01 Revision 5. The EALs and the EAL Technical Basis are located within EPIP 5.7.1. Revision 58 to EPIP 5. 7.1 added a note containing examples of safety-related systems that can be assessed under EALs HUl.4, HAl.2, HAl.3, HAl.4, HAl.6, HA2.1, and HA3.1. Change Summary of Analysis (10 CFR 50.54(q) evaluation) Licensing Basis Affected by Change: CNS Emergency Plan (E-Plan), Section 4, discusses, in part, that CNS maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant Operators that an EAL has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. This section further references NEI 99-01, Revision 5, and the CNS Updated Safety Analysis Report, Chapter XIV, as documents utilized in development of the four emergency classifications and that EALs and corresponding classifications are included in EPIP 5.7.1. Subsequent tables in Section 4 provide a listing of the EALs for the four emergency classifications; EALs HUl.4, HAl.2, HAl.3, HAl.4, HAl.6, HA2.1, and HA3.1 are included in these tables. E-Plan, Section 5, provides a description of the normal on-shift operating organization, the emergency response organization, governmental agencies and other support available for dealing with emergency conditions. How Change Complies with Regulations and Previous Commitments: 10 CFR 50.47(b)(4), requires that a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures. 10 CFR 50, Appendix E, Section, IV.C.2, requires licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications that an EAL has been exceeded and shall promptly declare the NLS2017061 Attachment Page 2 of2 emergency condition as soon as possible following identification of the appropriate emergency classification level. The change to the EPIP continues to comply with the above regulatory requirements and does not impact CNS' ability to make accurate and timely classification. One regulatory commitment associated with development of a functional procedure for accident classification is relevant to this change. The change to EPIP 5. 7 .1 does not impact this commitment. Affected Emergency Planning Functions/Impact on Effectiveness of Emergency Planning Functions: 10 CFR 50.47(b)(4); Function -A standard scheme of emergency classification and action levels 1s muse. The change made to EPIP 5.7.l is in alignment with NEI 99-01, Revision 5, and does not negatively impact accuracy or timeliness of classification. The change meets the above planning standard and does not represent a reduction in the effectiveness of the CNS E-Plan. Other changes were also made to the EPIP to delete outdated or unnecessary references in the procedure. These changes did not impact a planning standard and did not require a full 10 CFR 50.54(q) evaluation.

NLS2017061 Enclosure Page 1 of 335 Enclosure Emergency Plan Implementing Procedure 5.7.1, Revision 58 COOPER NUCLEAR STATION Operations Manual Emergency Preparedness EMERGENCY PLAN IMPLEMENTING PROCEDURE 5.7.1 EPIP 5.7.1 EMERGENCY CLASSIFICATION Level of Use: MULTIPLE Quality: QAPD RELATED Effective Date: 6/22/17 Approval Authority: ITR-RDM Procedure Owner: EMERG PREP DRILL SCENARIO COORD REVISION 58 PAGE 1 OF 334 TABLE OF CONTENTS 1. ENTRY CONDITIONS (REFERENCE USE) ................................... ; ................ 3 2. INITIAL CLASSIFICATION AND DECLARATION (REFERENCE USE) ................. 3 3. RECLASSIFICATION (REFERENCE USE) ........................... , .............. , ............ 4 4. MISSED EAL CLASSIFICATION (REFERENCE USE) ....................................... 5 ATTACHMENT 1 EAL SCHEME EXPLANATION AND RATIONALE (INFORMATION USE) ....*. ,. ..... _,, *......*.. -................................ 6 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) ........... ,. ......... ......................... 18 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) .. ;,;; ... ; ....................................... 250 ATTACHMENT 4 EAL CLASSIFICATION MATRIX (INFORMATION USE) ..... 303 ATTACHMENT 5 EAL GROUPS, CATEGORIES, AND SUBCATEGORIES (INFORMATION USE) ................. , .................... , ........... 305 ATTACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) ................................................... .-........................ 316 ATTACHMENT 7 INFORMATION SHEET (INFORMATION USE) ............ uoooo 329 ATTACHMENT 8 MATRIX BASIS CROSS-REFERENCE (INFORMATION USE) ............... ...................................... _ ....................... 332 EPIP 5.7.1 REVISION 58 PAGE 2 OF 334

1. ENTRY CONDITIONS (REFERENCE USE) 1.1 An Emergency Operation Procedure has been initiated; or 1.2 An unusual occurrence has taken place at or near site. 2. INITIAL CLASSIFICATION AND DECLARATION (REFERENCE USE) 2.1 AFTER recognition of off-normal event, THEN SM shall: 2.1.1 COMPARE event to EALs on EAL Classification Matrix. 2.1.2 IF more than one EAL of different classification levels is reached (i.e., EAL for ALERT and EAL for SITE AREA EMERGENCY), THEN SELECT EAL for most severe emergency classification. 2.1.3 IF event appears to meet an EAL and time permits, THEN REFER to Attachment 2 or 3 for further explanation and guidance. 2.1.4 IF determined EAL is met, EPIP 5.7.1 THEN PERFORM following within 15 minutes: 2.1.4.1 ASSUME Emergency Director Responsibilities. 2.1.4.2 DECLARE emergency. 2.1.4.3 Enter EPIP 5.7.2. 2.1.4.4 As time permits, RECORD emergency class, time of declaration, and EAL number in CNS Operations Log. REVISION 58 PAGE 3 OF 334

3. RECLASSIFICATION (REFERENCE USE) j NOTE -Specific direction for upgrading or terminating an event is given via ! __ _ ----------------------------------------------------------------------------------------------------------3.1 AFTER SM has been relieved of Emergency Director duties, THEN SM shall bring changing emergency conditions to attention of Emergency Director. 3.2 COMPARE changing emergency conditions to EALs on EAL Classification Matrix. 3.3 IF more than one EAL of different classification levels is reached (i.e., EAL for ALERT and EAL for SITE AREA EMERGENCY), THEN SELECT EAL for most severe emergency classification. 3.4 IF emergency condition appears to meet an EAL and time permits, THEN REFER to Attachment 2 or 3 for further explanation and guidance as necessary. 3.5 IF GENERAL EMERGENCY has been declared, THEN consultation with state authorities and NRC should occur prior to reclassification or termination of event. 3 .6 IF determined new EAL is met, THEN: 3.6.1 DECLARE emergency. 3.6.2 ENTER appropriate section of EPIP 5.7.2. 3.6.3 RECORD emergency class, time of declaration, and EAL number in applicable Emergency Response Facility (ERF) Log. EPIP 5.7.1 REVISION 58 PAGE 4 OF 334

4. MISSED EAL CLASSIFICATION (REFERENCE USE) 4.1 IF determined condition existed which met an EAL but no emergency was declared and basis for Emergency Class no longer exists (e.g., condition occurred yesterday but was not caught at time or condition cleared before classification could be made and emergency response is no longer needed), THEN: 4.1.1 NOTIFY NRC within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of discovery of undeclared (or misclassified) event per Procedure 2.0.5. 4.1.2 INFORM Emergency Preparedness Manager of details. EPIPS.7.1 4.1.2.1 Emergency Preparedness Staff member CONTACT Responsible State and Local Governmental Agencies. a. PROVIDE details of undeclared event. REVISION 58 PAGE 5 OF 334 ATTACHMENT 1 EAL SCHEME EXPLANATION AND RATIONALE (INFORMATION USE) ATIACHMENT 1 EAL SCHEME EXPLANATION AND RATIONALE (INFORMATION USE) 1. PURPOSE 1.1 This attachment along with Attachments 2, 3, 5, 6, and 7 provide an explanation and rationale for each Emergency Action Level (EAL) included in the EAL Scheme for Cooper Nuclear Station (CNS). It should be used to facilitate review of the CNS EALs, provide historical documentation for future reference, and serve as a resource for training. Decision-makers responsible for implementation of the EAL Scheme may use these attachments as a technical reference in support of EAL interpretation. 1.2 The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present. Use of this document for assistance is not intended to delay the emergency classification. 1.3 This procedure, its attachments, and the EAL Classification Matrix are controlled pursuant to 10CFR50.54(q). 2. DISCUSSION 2.1 BACKGROUND 2.1.1 An EAL is a pre-determined, site specific, observable threshold for a plant Initiating Condition (IC) that places the plant in a given Emergency Classification Level (ECL). An EAL can be: an instrument reading; an equipment status indicator; a measurable parameter (on-site or off-site); a discrete, observable event; results of analyses; entry into specific emergency operating procedures; or another phenomenon which, if it occurs, indicates entry into a particular emergency classification level. EALs are utilized to classify emergency conditions defined in the CNS Emergency Plan. 2.1.2 In 1992, the NRC endorsed NUMARC/NESP-007, Methodology for Development of Emergency Action Levels, as an alternative to NUREG-0654 EAL guidance. EPIP 5.7.1 REVISION 58 PAGE 6 OF 334 ATTACHMENT 1 EAL SCHEME EXPLANATION AND RATIONALE (INFORMATION USE) 2.1.3 NEI 99-01 (NUMARC/NESP-007), Revision 5, was the most recently accepted methodology for development of Emergency Action Levels approved by the NRC when CNS upgraded this classification scheme. 2.1.4 Using NEI 99-01, Revision 5, CNS conducted an EAL implementation upgrade project that produced the EALs discussed in this procedure. CNS has matched plant features and safety system designs that are unique to CNS to the generic NEI 99-01, Revision 5, guidance. Should CNS implement any design differences not addressed in NEI 99-01, Revision 5, CNS will have to consider the applicable failure mechanisms involved when assessing the impact on the site specific EALs. 2.2 FISSION PRODUCT BARRIERS 2.2.1 Many of the EALs derived from the NEI methodology are fission product barrier based. That is, the conditions that define the EALs are based upon loss or potential loss of one or more of the three fission product barriers. "Loss" and "Potential Loss" signify the relative damage and threat of damage to the barrier. "Loss" means the barrier no longer assures containment of radioactive materials; "potential loss" infers an increased probability of barrier loss and decreased certainty of maintaining the barrier. 2.2.2 The primary fission product barriers are: EPIP 5.7.1 2.2.2.1 Fuel Clad (FC): The Fuel Clad barrier consists of the zircaloy fuel bundle tubes that contain the fuel pellets. 2.2.2.2 Reactor Coolant System (RCS): 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. 2.2.2.3 Containment (PC): The Primary Containment barrier includes the drywell, the wetwell (torus), their respective interconnecting paths, and other connections up to and including the outermost containment isolation valves. REVISION 58 PAGE 7 OF 334 ATTACHMENT 1 EAL SCHEME EXPLANATION AND RATIONALE (INFORMATION USE) 2.3 EMERGENCY CLASSIFICATION BASED ON FISSION PRODUCT BARRIER DEGRADATION 2.3.1 The following criteria are the bases for event classification related to fission product barrier loss or potential loss: 2.3.1.1 Unusual Event: Any loss or any potential loss of Primary Containment. 2.3.1.2 Alert: Any loss or any potential loss of either Fuel Clad or RCS. 2.3.1.3 Site Area Emergency: Loss or potential loss of any two barriers. 2.3.1.4 General Emergency: Loss of any two barriers and loss or potential loss of third barrier. 2.4 EAL RELATIONSHIP TO EOPS 2.4.1 Where possible, the EALs have been made consistent with and utilize the conditions defined in the CNS Emergency Operating Procedures (EOPs). While the symptoms that drive Operator actions specified in the EOPs are not indicative of all possible conditions which warrant emergency classification, they define the symptoms, independent of initiating events, for which reactor plant safety and/or fission product barrier integrity are threatened. When these symptoms are clearly representative of one of the NEI Initiating Conditions, they have been utilized as an EAL. This permits rapid classification of emergency situations based on plant conditions without the need for additional evaluation or event diagnosis. Although some of the EALs presented here are based on conditions defined in the EOPs, classification of emergencies using these EALs is not dependent upon EOP entry or execution. The EALs can be utilized independently or in conjunction with the EOPs. EPIP 5.7.1 REVISION 58 PAGE 8 OF 334 ATTACHMENT 1 EAL SCHEME EXPLANATION AND RATIONALE (INFORMATION USE) 2.5 SYMPTOM-BASED VS. EVENT-BASED APPROACH 2.5.1 To the extent possible,.the EALs are symptom-based. That is, the action level threshold is defined by values of key plant operating parameters that identify emergency or potential emergency conditions. This approach is appropriate because it allows the full scope of variations in the types of events to be classified as emergencies. However, a purely symptom-based approach is not sufficient to address all events for which emergency classification is appropriate. Particular events to which no pre-determined symptoms can be ascribed have also been utilized as EALs since they may be indicative of potentially more serious conditions not yet fully realized. 2.6 EAL ORGANIZATION 2.6.1 The CNS EAL scheme includes the following features: EPIP 5.7.1 2.6.1.1 Division of the EAL set into three broad groups . . a. GROUPS 1. EALs applicable under all plant operating modes -this group would be reviewed by the EAL-user any time emergency classification is considered. 2. EALs applicable only under Modes 1, 2, or 3 -this group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Startup, or Power Operation mode. 3. EALs applicable only under Modes 4, 5, or Defueled -this group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refueling, or Defueled Mode. REVISION 58 PAGE 9 OF 334 I ------

ATTACHMENT 1 EAL SCHEME EXPLANATION AND RATIONALE (INFORMATION USE) b. The purpose of the groups is to avoid review of EALs that cannot be applicable in the current operating mode of the plant. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden, and thereby, speeds identification of the EAL that applies to the emergency. 2.6.1.2 Within each of the above three groups, assignment of EALs to categories/subcategories. a. Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. Subcategories are used, as necessary, to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The CNS EAL categories/subcategories are contained in Attachment 5. 2.6.1.3 The primary tool for determining the emergency classification level is the EAL classification matrix. The user of the EAL classification matrix may (but is not required to) consult the EAL Technical Bases in order to obtain additional information concerning the EALs under classification consideration. The user should consult Sections 2. 7 and 2.8 of this attachment, and Attachments 2 and 3 for such information. 2. 7 TECHNICAL BASES INFORMATION 2. 7.1 EAL Technical Bases are provided in Attachment 2 for each EAL according to EAL group, EAL category (A, C, H, S, E, and F), and EAL subcategory. A summary explanation of each category and subcategory is given at the beginning of the technical bases discussions of the EA Ls included in the category. For each EAL, the following information is provided: 2.7.1.1 CATEGORY LETTER AND TITLE. 2.7.1.2 SUBCATEGORY NUMBER AND TITLE. 2.7.1.3 INITIATING CONDITION (IC). EPIP 5.7.1 REVISION 58 PAGE 10 OF 334 ATTACHMENT 1 EAL SCHEME EXPLANATION AND RATIONALE (INFORMATION USE) EPIP 5.7.1 2.7.1.4 SITE-SPECIFIC DESCRIPTION OF THE GENERIC IC GIVEN IN NEI 99-01. 2.7.1.5 EAL IDENTIFIER (ENCLOSED IN RECTANGLE) a. Each EAL is assigned a unique identifier to support accurate communication of the emergency classification to on-site and off-site personnel. Four characters define each EAL identifier: 1. First character (letter): Corresponds to the EAL category as described in Attachment 5 (A, C, H, S, E, or F). 2. Second character (letter): The emergency classification (G, S, A, or U). 3. Third character (number): Subcategory number within the given category. a) Subcategories are sequentially numbered beginning with the number one (1). If a category does not have a subcategory, this character is assigned the number one (1). 4. Fourth character (number): The numerical sequence of the EAL within the EAL subcategory. a) If the subcategory has only one EAL, it is given the number one (1). 2. 7 .1.6 CLASSIFICATION (ENCLOSED IN RECTANGLE) a. Unusual Event (U), Alert (A), Site Area Emergency (S), or General Emergency (G). 2.7.1.7 EAL (ENCLOSED IN RECTANGLE) a. Exact wording of the EAL as it appears in the EAL classification matrix. REVISION 58 PAGE 11 OF 334 ATIACHMENT 1 EAL SCHEME EXPLANATION AND RATIONALE (INFORMATION USE) 2.7.1.8 MODE APPLICABILITY a. One or more of the following plant operating conditions comprise the Mode to which each EAL is applicable: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown, 4 -Cold Shutdown, 5 -Refueling, D -Defueled (DEF), All or N/A -Not Applicable (see Section 2.8 for operating Mode definitions.) 2.7.1.9 NEI 99-01 BASIS a. Provides a description of the rationale for the EAL as provided in NEI 99-01. 2. 7 .1.10 CNS BASIS a. Provides CNS-relevant information concerning the EAL. 2.7.1.11 CNS BASIS REFERENCE(S) a. Site-specific source documentation from which the EAL is derived. 2.8 OPERATING MODE APPLICABILITY 2.8.1 MODES EPIP 5. 7.1 2.8.1.1 POWER OPERATION a. Reactor mode switch is in RUN. 2.8.1.2 STARTUP a. The mode switch is in either REFUEL (with all reactor vessel head closure bolts fully tensioned) or STARTUP/HOT STANDBY. 2.8.1.3 HOT SHUTDOWN a. The mode switch is in SHUTDOWN with all reactor vessel head closure bolts fully tensioned and reactor coolant temperature is > 212°F. REVISION 58 PAGE 12 OF 334 ATTACHMENT 1 EAL SCHEME EXPLANATION AND RATIONALE (INFORMATION USE) 2.8.1.4 COLD SHUTDOWN a. The mode switch is in SHUTDOWN with all reactor vessel head closure bolts fully tensioned and reactor coolant temperature 212°F. 2.8.1.5 REFUELING a. The mode switch is in either REFUEL or SHUTDOWN with one or more reactor vessel head closure bolts less than fully tensioned. 2.8.1.6 DEFUELED a. All reactor fuel removed from reactor pressure vessel (full core off load during refueling or extended outage). This mode is designated as DEF in the EAL Classification Matrix. 2.8.2 The plant operating mode that exists at the time that the event occurs (prior to any protective system or Operator action is initiated in response to the condition) should be compared to the mode applicability of the EALs. If a lower or higher plant operating mode is reached before the emergency classification is made, the declaration shall be based on the mode that existed at the time the event occurred. 2.8.3 For events that occur in Cold Shutdown or Refueling, escalation is via EALs that have Cold Shutdown or Refueling for mode applicability, even if Hot Shutdown (or a higher mode) is entered during any subsequent heat-up. In particular, the fission product barrier EALs are applicable only to events that initiate in Hot Shutdown or higher. 2.9 VALIDATION OF INDICATIONS, REPORTS, AND CONDITIONS 2.9.1 All classifications are to be based upon valid indications, reports, or conditions. Indications, reports, or conditions are considered valid when they are verified by (1) an instrument channel check, or (2) indications on related or redundant indications, or (3) by direct observation by plant personnel, such that doubt, related to the indication's operability, the condition's existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment. EPIP 5.7.1 REVISION 58 PAGE 13 OF 334 ATIACHMENT 1 EAL SCHEME EXPLANATION AND RATIONALE (INFORMATION USE) 2.10 PLANNED VS. UNPLANNED EVENTS 2.10.1 Planned evolutions involve preplanning to address the limitations imposed by the condition, the performance of required surveillance testing, and the implementation of specific controls prior to knowingly entering the in accordance with the specific requirements of the CNS Technical Specifications. Activities which cause operation beyond that allowed by Technical Specifications, planned or unplanned, may result in an EAL threshold being met or exceeded. Planned evolutions to test, manipulate, repair, perform maintenance, or modifications to systems and equipment that result in an EAL value being met or exceeded are not subject to classification and activation requirements as long as the evolution proceeds as planned and is within the operational limitations imposed by the operating license. However, these conditions may be subject to the reporting requirements of 10CFRSO. 72. 2.11 CLASSIFYING TRANSIENT EVENTS 2.11.1 For some events, the condition may be corrected before a declaration has been made. The key consideration in this situation is to determine whether or not further plant damage occurred while the corrective actions were being taken. In some situations, this can be readily determined; in other situations, further analyses (e.g., coolant radiochemistry sampling) may be necessary. Classify the event as indicated and terminate the emergency once assessment shows that there were no consequences from the event and other termination criteria are met. 2.11.2 Existing guidance for classifying transient events addresses the period of time of event recognition and classification (15 minutes). However, in cases when EAL declaration criteria may be met momentarily during the normal expected response of the plant, declaration requirements should not be considered to be met when the conditions are a part of the designed plant response or result from appropriate Operator actions. 2.11.3 There may be cases in which a plant condition that exceeded an EAL was not recognized at the time of occurrence but is identified well after the condition has occurred (e.g., as a result of routine log or record review) and the condition no longer exists. In these cases, an emergency should not be declared. EPIP 5.7.1 REVISION 58 PAGE 14 OF 334 ATTACHMENT 1 EAL SCHEME EXPLANATION AND RATIONALE (INFORMATION USE) 2.11.4 Reporting requirements of 10CFR50. 72 are applicable and the guidance of NUREG-1022, Event Reporting Guidelines 10CFR50.72 and 50.73, should be applied. 2.12 MULTIPLE SIMULTANEOUS EVENTS AND IMMINENT EAL THRESHOLDS 2.12.1 When multiple simultaneous events occur, the emergency classification level is based on the highest EAL reached. For example, two Alerts remain in the Alert category; or, an Alert and a Site Area Emergency is a Site Area Emergency. Further guidance is provided in RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications during Quickly Changing Events. 2.12.2 Although the majority of the EALs provide very specific thresholds, the Emergency Director must remain alert to events or conditions that lead to the conclusion that exceeding the EAL threshold 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. While this is particularly prudent at the higher emergency classification levels (the early classification may permit more effective implementation of protective measures), it is nonetheless applicable to all emergency classification levels. 2.13 EMERGENCY CLASSIFICATION LEVEL DOWNGRADING 2.13.1 Another important aspect of usable EAL guidance is the consideration of what to do when the risk posed by an emergency is clearly decreasing. A combination approach involving recovery from General Emergencies and some Site Area Emergencies and termination from Unusual Events, Alerts, and certain Site Area Emergencies causing no long term plant damage appears to be the best choice. Downgrading to lower emergency classification levels adds notifications but may have merit under certain circumstances. EPIP 5.7.1 REVISION 58 PAGE 15 OF 334 ATIACHMENT 1 EAL SCHEME EXPLANATION AND RATIONALE (INFORMATION USE) 2.14 CNS-TO-NEI 99-01 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of a CNS EAL within the NEI 99-01 IC/EAL identification scheme. CNS N EI 99-01, REV 5 CNS NEI 99-01, REV 5 EXAMPLE EXAMPLE EAL IC EAL EAL IC EAL AU1.1 AU1 1 AU1.2 AU1 2 AU1.3 AU1 3 AU2.1 AU2 1 AU2.2 AU2 2 AA1.1 AA1 1 AA1.2 AA1 2 AA1.3 AA1 3 AA2.1 AA2 2 AA2.2 AA2 1 AA3.1 AA3 1 ASl.1 ASl 1 AS1.2 AS1 2 ASl.3 ASl 4 AG1.1 AG1 1 AGl.2 AGl 2 AG1.3 AG1 4 CU1.1 CU3 1 CU2.1 CUl 1 CU2.2 CU2 1 CU2.3 CU2 2 CU3.1 CU4 1 CU3.2 CU4 2 CU4.1 CU6 1, 2 CUS.1 CU8 1 CU6.1 CU7 1 CA1.1 CA3 1 CA2.1 CA! 1, 2 CA3.1 CA4 1, 2 CS2.1 CS1 1 CS2.2 CS1 2 CS2.3 CS1 3 CG2.1 CG1 1 CG2.2 CG1 2 EU1.1 E-HU1 1 FU1.1 FU1 1 FA1.1 FA1 1 I FS1.1 FS1 1 EPIP 5.7.1 REVISION 58 PAGE 16 OF 334 ATTACHMENT 1 EAL SCHEME EXPLANATION AND RATIONALE (INFORMATION USE) CNS NEI 99-01, REV 5 CNS NEI 99-01, REV 5 EXAMPLE EXAMPLE EAL IC EAL EAL IC EAL HUL1 HU1 1 HUL2 HU1 2 HUL3 HU1 4 HUL4 HU1 3 HULS HU1 5 HU2.1 HU2 1 HU2.2 HU2 2 HU3.1 HU3 1 HU3.2 HU3 2 HU4.1 HU4 1, 2, 3 HU6.1 HUS 1 HA1.1 HA1 HAl.1 HAL2 HA1 2 HAL3 HA1 4 HA1.4 HA1 3 HALS HA1 6 HAL6 HA1 5 HA2.1 HA2 1 HA3.1 HA3 1 HA4.1 HA4 1, 2 HAS.1 HAS 1 HA6.1 HA6 1 HS4.1 HS4 1 HSS.1 HS2 1 HS6.1 HS3 1 HG4.1 HG1 1, 2 HG6.1 HG2 1 5UL1 SU1 1 SU2.1 SUS 1 5U3.1 SU2 1 5U4.1 SU3 1 SUS.1 SU4 1 SUS.2 SIJ4 2 SU6.1 SUS 1, 2 SA1.l SAS 1 SA2.1 SA2 1 SA4.1 SA4 1 551.1 SS1 1 552.1 552 1 SS4.1 SS6 1 SS7.1 553 1 SUS.1 SU6 1, 2 SGl.1 SG1 1 SG2.1 SG2 1 EPIP 5.7.1 REVISION 58 PAGE 17 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 1 -Off-Site Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than two times the ODAM limits for 60 minutes or longer EAL: AU1.1 Unusual Event Any valid gaseous monitor reading > Table A-1 column "UE" for;::: 60 min. (NOTE 2) ---------------------------------------------------------.. -----------------.-::-,-------------------.. --------. -----------------* NOTE 2 -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 on-going release is detected and the release start time is ' unknown. . ---":' -.. -":' ---------------------.. ------------------------------------------------------.. ------------------------------------------------.: .. * ' --------*-----. ; .--.:-.-'TableA.::1 *Effluent Monitor c1asslflcatlon*if11reshoids -----. -------------------------Monitor GE SAE ALERT UE for;<: 15 min. for;<: 15 min. 15 min. min. ERP 3.50E+08 µCi/sec 3.50E+07 µCi/sec 2.80E+06 µCi/sec 2.24E+05 µCi/sec Rx Bldg Vent 3.50E+07 µCi/sec 3.50E+06 µCi/sec 5.45E+05 µCi/sec B.48E+04 µCi/sec en ::> 0 w Turb Bldg Vent 3.50E+07 µCi/sec 3.50E+06 µCi/sec 5.62E+05 µCi/sec 9.02E+04 µCi/sec en <( (!) RW I ARW Bldg Vent 3.50E+07 µCi/sec 3.50E+06 µCi/sec 5.64E+05 µCi/sec 9.0BE+04 µCi/sec The lesser of*: The lesser of *: 0 200 x calculated 2 x calculated ::> Rad Waste Effluent ----alarm values alarm values 0 :::::i OR OR monitor upscale monitor upscale Service Water Effluent ------4.80E-04 µCi/cc 4.BOE-06 µCi/cc

with effluent discharge not isolated (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 18 OF 334 ATTACHMENT 2 Mode Applicability: All NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 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 EAL addresses a potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. Nuclear power plants incorporate 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 degradation in these features and/or controls. The ODAM multiples are specified in AU1.1 and AA1.1 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. This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in the EAL. 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. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 19 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis: The values listed for the Reactor Building vent, Turbine Building vent, and RW/ARW Building vent are based on a value of two times ODAM. The ERP UE value has been set to 1/5 the ODAM instantaneous release limit to provide for a reasonable progression between the UE, Alert, and SAE classifications. If the ERP UE value were placed at two times ODAM, the escalations between the UE, Alert, and SAE levels would have been significantly less than a decade apart. The ERP UE value allows approximately a 1 decade interval between the UE, Alert, and SAE classification points. Releases in excess of two times the site ODAM (Reference 3) instantaneous limits that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the Unusual Event emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that the release was not isolated within 60 minutes. CNS Basis Reference(s): 1. Instrument Operating Procedure 4.15, Elevated Release Point and Building Kaman Radiation Monitoring Systems. 2. COROOl-18-01, Radiation Monitoring. 3. Off-Site Dose Assessment Manual -ODAM -For Assessment of Gaseous and Liquid Effluents at COOPER NUCLEAR STATION. EPIP 5.7.1 REVISION 58 PAGE 20 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 1 -Off-Site Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than two times the ODAM limits for 60 minutes or longer EAL: AUl.2 Unusual Event Any valid liquid effluent monitor reading > Table A-1 column "UE" 60 min. (NOTE 2) _____ _ ! elapsed, but should declare the event as soon as it is determined that the release i duration has exceeded, or will likely exceed, the applicable time. In the absence i of data to the contrary, assume that the release duration has exceeded the i applicable time if an on-going release is detected and the release start time is i unknown. -----------------------------------.. -----------------------_" _______ ---------------------------------------------------------.------,, I Monitor GE SAE ALERT UE for;:;.: 15 min. for;:: 15 min. for;:: 15 min. for;:;.: 60 min. ERP 3.50E+08 µCi/sec 3.50E+07 µCi/sec 2.80E+06 µCi/sec 2.24E+05 µCi/sec Rx Bldg Vent 3.50E+07 µCi/sec 3.50E+06 µCi/sec 5.45E+05 µCi/sec 8.48E+04 µCi/sec en :::J 0 LU Turb Bldg Vent 3.50E+07 µCi/sec 3.50E+06 µCi/sec 5.62E+05 µCi/sec 9.02E+04 µCi/sec en ct: (!I RW I ARW Bldg Vent 3.50E+07 µCi/sec 3.50E+06 µCi/sec 5.64E+05 µCi/sec 9.08E+04 µCi/sec The lesser of ": The lesser of": c 200 x calculated 2 x calculated 5 Rad Waste Effluent -----alarm values alarm values 0 OR OR :i monitor upscale monitor upscale Service Water Effluent -----4.BOE-04 µCi/cc 4.BOE-06 µCi/cc

with effluent discharge not isolated (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 21 OF 334 ATTACHMENT 2 Mode Applicability: All NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 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 EAL addresses a potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. Nuclear power plants incorporate 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 degradation in these features and/or controls. The ODAM multiples are specified in AU1.2 and AAl.2 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. This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in the EAL. 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. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 22 OF 334 ATIACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Liquid releases in excess of two times the site ODAM (Reference 3) instantaneous limits that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The upper limit for the Radwaste Effluent monitor is currently 0.1 µCi/ml. Therefore, this monitor may not be able to read two times the calculated alarm value. If two times the calculated alarm value exceeds the range of the Radwaste Effluent monitor, the UE condition will be subsumed by the Alert EAL AAl.2. The final integrated dose (which is very low in the Unusual Event emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that the release was not isolated within 60 minutes. CNS Basis Reference(s): 1. Instrument Operating Procedure 4.15, Elevated Release Point and Building Kaman Radiation Monitoring Systems. 2. Chemistry Procedure 8.8.11, Liquid Radioactive Waste Discharge Authorization. 3. COROOl-18-01, Radiation Monitoring. 4. Off-Site Dose Assessment Manual -ODAM -For Assessment of Gaseous and Liquid Effluents at Cooper Nuclear Station. EPIP5.7.1 REVISION 58 PAGE 23 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 1 -Off-Site Rad Conditions Initiating Any release of gaseous or liquid radioactivity to the environment greater than two times the ODAM limits for 60 minutes or longer EAL: AU1.3 Unusual Event Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 x ODAM limits for;::: 60 min. (NOTE 2) i-...... -.... '"' ----.--.-------.----':' "." -----.--------" .... ------------------................... :. ...... * ... -----------------------------------*---.;; .. ..; ___ .: .. : .. * .. -,; .. ____ --"i i NOTE 2 -The Emergency Director should not wait until the applicable time has i elapsed, but should declare the event as soon as it is determined that the release i 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 i ! applicable time if an on-going release is detected and the release start time is ! !unknown. i ---... ----------------______ '""""' _________ ----.. -.... ------------,_----............... ---------------------------------------...... ' Mode Applicability: All NEI 99-01 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 EAL addresses a potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. Nuclear power plants incorporate 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 degradation in these features and/or controls. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 24 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The ODAM multiples are specified in AUl.3 and AAl.3 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. 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.). CNS Basis: Releases in excess of two times the site Off-Site Dose Assessment Manual (ODAM) (Reference 1) instantaneous limits that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the Unusual Event emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that the release was not isolated within 60 minutes. CNS Basis Reference(s): 1. Off-Site Dose Assessment Manual -ODAM -For Assessment of Gaseous and Liquid Effluents at Cooper Nuclear Station. EPIP 5.7.1 REVISION 58 PAGE 25 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 1 -Off-Site Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 200 times the ODAM limits for 15 minutes or longer EAL: AAl.1 Alert Any valid gaseous monitor reading > Table A-1 column "Alert" 15 min. (NOTE 2) 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 on-going release is detected and the release start time is unknown. -.. . *-'. :,eif1uenf . ----.:*..;*---::* ----. -** *--Monitor GE SAE ALERT UE for;::: 15 min. for;::: 15 min. for<: 15 min. for;:: 60 min. ERP 3.50E+08 µCi/sec 3.50E+07 µCi/sec 2.80E+06 µCi/sec 2.24E+05 µCi/sec Rx Bldg Vent 3.50E+07 µCi/sec 3.50E+06 µCi/sec 5.45E+05 µCi/sec 8.48E+04 µCi/sec (fJ ::> 0 w Turb Bldg Vent 3.50E+07 µCi/sec 3.50E+06 µCi/sec 5.62E+05 µCi/sec 9.02E+04 µCi/sec (!) RW I ARW Bldg Vent 3.50E+07 µCi/sec 3.50E+06 µCi/sec 5.64E+05 µCi/sec 9.08E+04 µCi/sec The lesser of *: The lesser of*: c 200 x calculated 2 x calculated 5 Rad Waste Effluent ---alarm values alarm values 0 OR OR ::i monitor upscale monitor upscale Service Water Effluent -------4.80E-04 µCi/cc 4.80E-06 µCi/cc

with effluent discharge not isolated (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 26 OF 334 ATTACHMENT 2 Mode Applicability: All NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 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 EAL addresses an actual or substantial potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. Nuclear power plants incorporate 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 degradation in these features and/or controls. The ODAM multiples are specified in AU1.1 and AA1.1 only to distinguish between non-emergency conditions and from each other. While these multiples obviously correspond to an off-site dose or dose rate1 the emphasis in classifying these events is the degradation in the level of safety of the plant1 not the magnitude of the associated dose or dose rate. This EAL includes any release for which a radioactivity discharge permit was not prepared. 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. This EAL directly correlates with the IC since annual average meteorology is required to be used in showing compliance with the ODAM and is used in calculating the Table A-1 setpoints. The underlying basis of this EAL involves the degradation in the level of safety of the plant implied by the uncontrolled release. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 27 OF 334 ATTACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) If the Alert thresholds were set at two-hundred times the ODAM limit, the resultant value would exceed the SAE threshold, which is based on 10% of the PAG limits. For this reason, the Alert gaseous thresholds have been set at the log-average of the UE threshold (two times ODAM limit for Turbine Building vent, Radwaste Building vent, and Reactor Building vent, 1/5 the ODAM limit for the ERP) and the SAE threshold (CNS-DOSE dose assessment calculation) (Reference 1). This provides a reasonable escalation in classification from the UE to the Alert and SAE thresholds. CNS Basis Reference(s): 1. EPIP 5.7.17, CNS-DOSE Assessment, and/or EPIP 5.7.17.1, Dose Assessment (Manual). 2. Instrument Operating Procedure 4.15, Elevated Release Point and Building Kaman Radiation Monitoring Systems. 3. COROOl-18-01, Radiation Monitoring. 4. Off-Site Dose Assessment Manual -ODAM -For Assessment of Gaseous and Liquid Effluents at Cooper Nuclear Station. EPIP 5.7.1 REVISION 58 PAGE 28 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 1 -Off-Site Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 200 times the ODAM limits for 15 minutes or longer EAL: AAl.2 Alert Any valid liquid effluent monitor reading >Table A-1 column "Alert" for;::: 15 min. (NOTE 2) ! NOTE 2 -The Emergency Director should not wait until the applicable time has i elapsed, but should declare the event as soon as it is determined that the release ' i 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 on-going release is detected and the release start time is 1 unknown. --Monitor GE SAE ALERT UE 15 min. 15 min. 15 min. 60 min. ERP 3. 50E+08 µCi/sec 3.50E+07 µCi/sec 2.80E+06 µCi/sec 2.24E+05 µCi/sec Rx Bldg Vent 3.50E+07 µCi/sec 3.50E+06 µCi/sec 5.45E+05 µCi/sec 8.48E+04 µCi/sec VJ ::::> 0 w Turb Bldg Vent 3.50E+07 µCi/sec 3.50E+06 µCi/sec 5.62E+05 µCi/sec 9.02E+04 µCi/sec VJ ci: (.!) RW I ARW Bldg Vent 3.50E+07 µCi/sec 3_50E+06 µCi/sec 5.64E+05 µCi/sec 9.08E+04 µCi/sec The lesser of*: The lesser of *: c 200 x calculated 2 x calculated 5 Rad Waste Effluent --alarm values alarm values 0 :i OR OR monitor upscale monitor upscale Service Water Effluent --------4.80E-04 µCi/cc 4.80E-06 µCi/cc

with effluent discharge not isolated (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 29 OF 334 ATTACHMENT 2 Mode Applicability: All NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 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 EAL addresses an actual or substantial potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. Nuclear power plants incorporate 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 degradation in these features and/or controls. The ODAM multiples are specified in AUl.2 and AAl.2 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. This EAL 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. This EAL addresses radioactivity releases, that for whatever reason, cause Radwaste Effluent radiation monitor readings to exceed the threshold identified in the IC established by the radioactivity discharge permit. The underlying basis of this EAL involves the degradation in the level of safety of the plant implied by the uncontrolled release. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 30 OF 334 ATIACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) This event escalates from the Unusual Event by escalating the magnitude of the release by a factor of 100. The Radwaste Effluent monitor may not be able to read two-hundred times the calculated alarm value because the top of its scale is 0.1 µCi/ml. Two-hundred times the calculated alarm value is to be assumed if the Radwaste Effluent monitor reading goes off scale high while discharges are in-progress via this path. CNS Basis Reference(s): 1. Instrument Operating Procedure 4.15, Elevated Release Point and Building Kaman Radiation Monitoring Systems. 2. Chemistry Procedure 8.8.11, Liquid Radioactive Waste Discharge Authorization. 3. COROOl-18-01, Radiation Monitoring. 4. Off-Site Dose Assessment Manual -ODAM -For Assessment of Gaseous and Liquid Effluents at Cooper Nuclear Station. EPIPS.7.1 REVISION 58 PAGE 31 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 1 -Off-Site Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 200 times the ODAM limits for 15 minutes or longer EAL: AAl.3 Alert Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 200 x ODAM limits 15 min. (NOTE 2) ______ i ! 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 on-going release is detected and the release start time is i unknown. Mode Applicability: All NEI 99-01 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 EAL addresses an actual or substantial potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. Nuclear power plants incorporate 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 degradation in these features and/or controls. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 32 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The ODAM multiples are specified in AU1.3 and AA1.3 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. This EAL 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. 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.). CNS Basis: None CNS Basis Reference(s): 1. Off-Site Dose Assessment Manual -ODAM -For Assessment of Gaseous and Liquid Effluents at Cooper Nuclear Station. EPIP 5.7.1 REVISION 58 PAGE 33 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 1 -Off-Site Rad Conditions Initiating Condition: Off-site dose resulting from an actual or imminent release of gaseous radioactivity greater than EAL: 0.1 Rem TEDE or 0.5 Rem thyroid CDE for the actual or projected duration of the release AS 1.1 Site Area Emergency Any valid gaseous monitor reading > Table A-1 column "SAE" 15 min. (NOTE 1) NOTE 1 -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 ! -y_ _ -J? J? ! ! -_ ---------------------------------------------------------If dose assessment results are available, declaration should be based on dose assessment instead of radiation monitor values (see EAL ASl.2). Do not delay declaration awaiting dose assessment results. 0 5 0 :J Monitor ERP Rx Bldg Vent RW I ARW Bldg Vent Rad Waste Effluent Service Water Effluent EPIP 5. 7 .1 GE 15 min. SAE 15 min. ALERT 15 min. UE 60 min. 3.50E+08 µCi/sec 3.50E+07 µCi/sec 2.80E+06 µCi/sec 2.24E+05 µCi/sec 3.50E+07 µCi/sec 3.50E+06 µCi/sec 5.45E+05 µCi/sec 8.48E+04 µCifsec 3.50E+07 µCifsec 3.50E+06 µCi/sec 5.64E+05 µCifsec 9.08E+04 µCifsec (continued on next page) The lesser of*: 200 x calculated alarm values OR monitor upscale The lesser of*: 2 x calculated alarm values OR monitor upscale 4.BOE-04 µCifcc 4.BOE-06 µCifcc

with effluent discharge not isolated REVISION 58 PAGE 34 OF 334 ATTACHMENT 2 Mode Applicability: All NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) This EAL 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. Since dose assessment is based on actual meteorology, whereas the monitor reading EAL is 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 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 EAL. CNS Basis: The Table A-1 Site Area Emergency thresholds have been determined using CNS-DOSE dose projection calculations (Reference 1). The Site Area Emergency effluent monitor readings are one decade less than the General Emergency values. For the purposes of this EAL, the Site Boundary for CNS is a 1 mile radius around the plant (Reference 1). CNS Basis Reference(s): 1. EPIP 5.7.17, CNS-DOSE Assessment, and/or EPIP 5.7.17.1, Dose Assessment (Manual). 2. CNS Drawing DWG.2.2 (P3-A-45). EPIP 5.7.1 REVISION 58 PAGE 35 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 1 -Off-Site Rad Conditions Initiating Condition: Off-site dose resulting from an actual or imminent release of gaseous radioactivity greater than 0.1 Rem TEDE or 0.5 Rem thyroid CDE for the actual or projected duration of the release EAL: ASl.2 Site Area Emergency Dose assessment using actual meteorology indicates doses > 0.1 Rem TEDE or > 0.5 Rem thyroid CDE at or beyond the site boundary Mode Applicability: All NEI 99-01 Basis: This EAL 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. Since dose assessment is based on actual meteorology, whereas the monitor reading EAL is 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 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 EAL. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 36 OF 334 ATIACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The dose rate EALs are based on a Site Boundary dose rate of 0.1 Rem/hr TEDE or 0.5 Rem/hr COE thyroid, whichever is more limiting. Actual meteorology is specifically identified since it gives the most accurate dose assessment. Actual meteorology (including forecasts) should be used whenever possible. For the purposes of this EAL, the Site Boundary for CNS is a 1 mile radius around the plant. CNS Basis Reference(s): 1. EPIP 5.7.17, CNS-DOSE Assessment, and/or EPIP 5.7.17.1, Dose Assessment (Manual). 2. CNS-DOSE. 3. CNS Drawing DWG.2.2 (P3-A-45). EPIP 5. 7.1 REVISION 58 PAGE 37 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 1 -Off-Site Rad Conditions Initiating Condition: Off-site dose resulting from an actual or imminent release of gaseous radioactivity greater than EAL: 0.1 Rem TEDE or 0.5 Rem thyroid CDE for the actual or projected duration of the release ASl.3 Site Area Emergency Field survey indicates closed window dose rates > 0.1 Rem/hr that is expected to continue 60 min. at or beyond the site boundary (NOTE 1) OR Field survey sample analysis indicates thyroid COE > 0.5 Rem for 1 hr of inhalation at or beyond the site boundary _______ ! i elapsed, but should declare the event as soon as it is determined that the i I ! condition will likely exceed the applicable time. . . . . . . . . l *----.-'": .. ... _ ... ----: "": ... ---------------.--.-----.-....................... -----------------------------*--..:-........ -------------------------------------------* If dose assessment results are available, declaration should be based on dose assessment instead of radiation monitor values (see EAL AS1.2). Do not delay declaration awaiting dose assessment results. Mode Applicability: All NEI 99-01 Basis: This EAL 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. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 38 OF 334 ATTACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The 0.5 Rem integrated CDE thyroid dose was established in consideration of the 1: 5 ratio of the EPA Protective Action Guidelines for TEDE and thyroid exposure. In establishing the field survey emergency action levels, a duration of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is assumed. Therefore, the dose rate EALs are based on a Site Boundary dose rate of 0.1 Rem/hr TEDE or 0.5 Rem for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of inhalation CDE thyroid, whichever is more limiting. For the purposes of this EAL, the Site Boundary for CNS is a 1 mile radius around the plant. CNS Basis Reference(s): 1. CNS Drawing DWG.2.2 (P3-A-45). EPIPS.7.1 REVISION 58 PAGE 39 OF 334

--ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 1 -Off-Site Rad Conditions Initiating Condition: Off-site dose resulting from an actual or imminent release of gaseous radioactivity greater than 1 Rem TEDE or 5 Rem thyroid CDE for the actual or projected duration of the release using actual meteorology EAL: AG1.1 General Emergency Any valid gaseous monitor reading >Table A-1 column 11GE11 15 min. (NOTE 1) j NOTE 1 -The Emergency Director should not wait until the applicable time has i elapsed, but should declare the event as soon as it is determined that the ! _ ! -y_ _ -_c:i J?J? ! --L _ ----------------------------------* --------------If dose assessment results are available, declaration should be based on dose assessment instead of radiation monitor values (see EAL AG1.2). Do not delay declaration awaiting dose assessment results. *--. -* -----,_ TableA;1 ; Efflueilt:Moriitor c1asslficatio)1.T:nresho1as. -------* --* -*---*------*-Monitor GE SAE ALERT UE for<: 15 min. for;:: 15 min. for;:: 15 min. for<: 60 min. ERP 3.50E+08 µCi/sec 3.50E+07 µCi/sec 2.80E+06 µCi/sec 2.24E+05 µCi/sec Rx Bldg Vent 3.50E+07 µCi/sec 3.50E+06 µCi/sec 5.45E+05 µCi/sec 8.48E+04 µCi/sec ll'J :::> 0 w Turb Bldg Vent 3.50E+07 µCi/sec 3.SOE+06 µCi/sec 5.62E+05 µCi/sec 9.02E+04 µCi/sec ll'J <( (!J RW I ARW Bldg Vent 3.50E+07 µCi/sec 3.50E+06 µCi/sec 5.64E+05 µCi/sec 9.08E+04 µCi/sec The lesser of*: The lesser of*: c 200 x calculated 2 x calculated :::> Rad Waste Effluent ------alarm values alarm values 0 :::i OR OR monitor upscale monitor upscale Service Water Effluent ------4.SOE-04 µCi/cc 4.BOE-06 µCi/cc

with effluent discharge not isolated (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 40 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Mode Applicability: All NEI 99-01 BASIS: This EAL 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. Since dose assessment is based on actual meteorology, whereas the monitor reading EAL is 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 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 EAL. CNS Basis: The Table A-1 General Emergency thresholds have been determined using CNS-DOSE dose projection calculations (Reference 1). The General Emergency effluent monitor readings are one decade greater than the Site Area Emergency values. For the purposes of thi$ EAL, the Site Boundary for CNS is a 1 mile radius around the plant (Reference 2). CNS Basis Reference(s): 1. EPIP 5.7.17, CNS-DOSE Assessment, and/or EPIP 5.7.17.1, Dose Assessment (Manual). 2. CNS Drawing DWG.2.2 (P3-A-45). 3. Computer Dose Projection (CNS DOSE). EPIP 5.7.1 REVISION 58 PAGE 41 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 1 -Off-Site Rad Conditions Initiating Condition: Off-site dose resulting from an actual or imminent release of gaseous radioactivity greater than 1 Rem TEDE or 5 Rem thyroid CDE for the actual or projected duration of the release using actual meteorology EAL: AG1.2 General Emergency Dose assessment using actual meteorology indicates doses > 1 Rem TEDE or > 5 Rem thyroid CDE at or beyond the site boundary Mode Applicability: All NEI 99-01 Basis: This EAL 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. Since dose assessment is based on actual meteorology, whereas the monitor reading EAL is 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 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 EAL. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 42 OF 334 ATTACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The General Emergency values are based on the boundary dose resulting from an actual or imminent release of gaseous radioactivity that exceeds 1 Rem TEDE or 5 Rem CDE thyroid for the actual or projected duration of the release. Actual meteorology is specifically identified since it gives the most accurate dose assessment. Actual meteorology (including forecasts) should be used whenever possible. For the purposes of this EAL, the Site Boundary for CNS is a 1 mile radius around the plant. CNS Basis Reference(s): 1. EPIP 5.7.17, CNS-DOSE Assessment, and/or EPIP 5.7.17.1, Dose Assessment (Manual). 2. CNS DOSE. 3. CNS Drawing DWG.2.2 (P3-A-45). EPIP 5.7.1 REVISION 58 PAGE 43 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 1 -Off-Site Rad Conditions Initiating Condition: Off-site dose resulting from an actual or imminent release of gaseous radioactivity greater than 1 Rem TEDE or 5 Rem thyroid CDE for the actual or projected duration of the release using actual meteorology EAL: AG1.3 General Emergency Field survey results indicate closed window dose rates > 1 Rem/hr expected to continue 60 min. at or beyond the site boundary (NOTE 1) OR Analyses of field survey samples indicate thyroid CDE > 5 Rem for 1 hr of inhalation at or beyond the site boundary -.. _ ... _ ...... ----------------------------.. -----..: ..: ..: .;.,;._ -_.,; .. -:_ .. ------------... -;., ----.--***-.-:-.-----:--'.--;*-------*-----:-_----------*--...-..;, NOTE 1 -The Emergency Director should not wait until the applicable time has l elapsed, but should declare the event as soon as it is determined that the i: 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 (see EAL AGl.2). Do not delay declaration awaiting dose assessment results. Mode Applicability: All NEI 99-01 Basis: This EAL 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. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 44 OF 334 ATIACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The 5 Rem integrated CDE thyroid dose was established in consideration of the 1: 5 ratio of the EPA Protective Action Guidelines for TEDE and thyroid exposure. In establishing the dose rate emergency action levels, a duration of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is assumed. Therefore, the dose rate EALs are based on a Site Boundary dose rate of 1 Rem/hr TEDE or 5 Rem for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of inhalation CDE thyroid, whichever is more limiting. For the purposes of this EAL, the Site Boundary for CNS is a 1 mile radius around the plant. CNS Basis Reference(s): 1. CNS Drawing DWG.2.2 (P3-A-45). EPIP 5.7.1 REVISION 58 PAGE 45 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 2 -On-Site Rad Conditions And Spent Fuel Pool Events Initiating Condition: Unplanned rise in plant radiation levels EAL: AU2.1 Unusual Event Unplanned water level drop in the reactor cavity or spent fuel pool as indicated by any of the following:

LI-86 (calibrated to 1001' elev.)

Spent fuel pool low level alarm

Visual observation AND Valid Area radiation monitor reading rise on RMA-RA-1 or RMA-RA-2 Mode Applicability: All NEI 99-01 Basis: This EAL addresses increased radiation levels as a result of water level decreases above irradiated fuel. These radiation increases represent a loss of control over radioactive material and represent a potential degradation in the level of safety of the plant. The refueling pathway is the combination of refueling cavity and spent fuel pool. While a radiation monitor could detect an increase 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 combined with another indicator (or personnel report) of water loss. (continued on next page) EPIP 5. 7.1 REVISION 58 PAGE 46 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) For refueling events where the water level drops below the RPV flange classification would be via CU2.1. This event escalates to an Alert per AA2.1 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 Table for events in operating Modes 1-3. CNS Basis: Loss of inventory from the reactor cavity or Spent Fuel Pool (SFP) may reduce water shielding above spent fuel and cause unexpected increases in plant radiation. Classification as an Unusual Event is warranted as a precursor to a more serious event. The major item of. concern on loss of inventory from the reactor cavity and SFP is to maintain adequate water level for personnel shielding and cooling of the irradiated fuel. Normal SFP water level is 37' 6 1/2" above the bottom. A low SFP level alarm can be determined by Annunciator 9 2/A-3, FUEL POOL COOLING TROUBLE, alarming due to Annunciator Panel 25-15, Fuel Pool Low Level at 4" below normal. Decreases in SFP water level can also be detected through visual observation. The Skimmer Surge Tank low level alarm (Annunciator 9 2/C-3 at 100 ft3 in the skimmer* surge tank, elevation 981' 3") alone may not be conclusive evidence of an uncontrolled loss of inventory from the SFP. SFP weir wall design should prevent inadvertent draining of the SFP through Fuel Pool Cooling and Demineralizer System connections. A Skimmer Surge Tank low level alarm needs to be confirmed by visual observation to determine the extent of inventory loss from the SFP (Reference 1, 3, 4). During refueling when the RPV head is removed, Shutdown Range RPV water level instrument NBl-Ll-86 is recalibrated to read vessel cavity level up to the 10011 elevation (Refuel Floor). With the reactor cavity in communication with the Spent Fuel Pool via the fuel transfer canal, uncontrolled inventory loss can be remotely monitored via this indicator. NBl-LI-86 can be used only if it has been set up to read to 1001' elevation as specified in Procedure 4.6.1, Reactor Vessel Water Level Indication (Reference 5). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 4 7 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Allowing level to decrease could result in spent fuel being uncovered, reducing spent fuel decay heat removal and creating an extremely hazardous radiation environment. Technical Specification Section LCO 3.7.6 (Reference 7) requires spent fuel storage pool water level be maintained at least 211 611 over the top of irradiated fuel assemblies seated in the spent fuel storage pool racks. Technical Specification LCO 3.9.6 (Reference 8) requires RPV water level to be maintained at least 21' above the top of the RPV flange. During refueling, this maintains sufficient water level in the refueling cavity and SFP to retain iodine fission product activity in the water in the event of a fuel handling accident. Area radiation monitors that may indicate a loss of shielding of spent fuel in the SFP or refueling cavity include (Reference 2, 6):

RMA-RA-1 (1448) RX BLDG FUEL POOL (HR) AREA.

RMA-RA-2 (1449) RX BLDG FUEL POOL (LR) AREA. Portable radiation monitors are routinely employed to conduct radiation surveys in the Reactor Building. This source of information should not be excluded when considering emergency classification under this EAL, particularly when RMA-RA-1 and RMS-RA-2 may be taken out of service for preventative or corrective maintenance. CNS Basis Reference(s): 1. System Operating Procedure 2.2.32, Fuel Pool Cooling and Demineralizer System. 2. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1. 3. Alarm Procedure 2.3_9 2, Panel 9 Annunciator 9 2, C-3. 4. Abnormal Procedure 2.4FPC, Fuel Pool Cooling Trouble. 5. Instrument Operating Procedure 4.6.1, Reactor Vessel Water Level Indication. 6. Emergency Procedure 5.lRAD, Building Radiation Trouble. 7. Technical Specification LCO 3.7.6. 8. Technical Specification LCO 3.9.6. EPIP 5.7.1 REVISION 58 PAGE 48 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 2 -On-Site Rad Conditions And Spent Fuel Pool Events Initiating Condition: Unplanned rise in plant radiation levels EAL: AU2.2 Unusual Event Unplanned Valid Area radiation monitor reading or survey results rise by a factor of 1,000 over normal levels*

Normal levels can be considered as the highest reading in the past 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months excluding the current peak value Mode Applicability: All NEI 99-01 Basis: This EAL addresses increased radiation levels as a result of water level decreases above irradiated fuel or events that have resulted, or may result, in UNPLANNED increases in radiation dose rates within plant buildings. These radiation increases represent a loss of control over radioactive material and represent a potential degradation in the level of safety of the plant. This EAL addresses increases 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 increases that result from planned activities such as use of radiographic sources and movement of radioactive 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. (continued on next page) EPIP 5. 7.1 REVISION 58 PAGE 49 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis: It is recognized that some plant area radiation monitors may not be able to detect or display a reading that is one-thousand times NORMAL LEVELS. The intent of this IC is to rely on currently installed plant monitors and not to require design changes/back fits. In cases where an installed area radiation monitor cannot detect or display values at or above 1,000 X NORMAL LEVELS value, then survey instrument results may be used. The ARMs monitor the gamma radiation levels in units of mR/hr at selected areas throughout the station. If radiation levels exceed a preset limit in any channel, the Control Room annunciator and local alarms will be energized to warn of abnormal or significantly changing radiological conditions. The alarm limit is normally set at approximately ten times normal background for each channel (Reference 1, 2). Routine and work specific surveys are conducted throughout the station at frequencies specified by RP Management. Routine surveys are scheduled per the RP Department surveillance schedule. Work specific surveys are conducted in accordance with the Radiation Work Permit (RWP) (Reference 3). CNS Basis Reference(s): 1. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1. 2. Emergency Procedure 5.1RAD, Building Radiation Trouble. 3. Rad Protection Procedure 9.ALARA.4, Radiation Work Permits. EPIP5.7.1 REVISION 58 PAGE 50 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 2 -On-Site Rad Conditions And Spent Fuel Pool Events Initiating Condition: Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the RPV EAL: AA2.1 Alert Damage to irradiated fuel OR loss of water level (uncovering irradiated fuel outside the RPV) that causes EITHER of the following: Valid RMA-RA-1 Fuel Pool Area Rad reading > 50 R/hr OR Valid RMP-RM-452 A-D Rx Bldg Vent Exhaust Plenum Hi-Hi alarm Mode Applicability: All NEI 99-01 Basis: This EAL addresses increases 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. This EAL addresses radiation monitor indications of fuel uncovery and/or fuel damage. Increased ventilation monitor readings may be indication of a radioactivity release from the fuel, confirming that damage has occurred. Increased background at the ventilation monitor due. to water level decrease may mask increased ventilation exhaust airborne activity and needs to be considered. While a radiation monitor could detect an increase 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. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 51 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Escalation of this emergency classification level, if appropriate, would be based on EALs in Subcategory A1. CNS Basis: When considering classification, information may come from:

Radiation monitor readings.

Sampling and surveys.

Dose projections/calculations.

Reports from the scene regarding the extent of damage (e.g., Refueling Crew, Radiation Protection Technicians). This EAL is defined by the specific areas where irradiated fuel is located, such as the refueling cavity or Spent Fuel Pool (SFP). The bases for the ventilation radiation Hi-Hi alarm is a spent fuel handling accident (Reference 2). Fuel Pool area radiation > 50 R/hr represents 100 times the high alarm setpoint (HR) and is unambiguously indicative of spent fuel damage or uncovery (Reference 1). CNS Basis Reference(s): 1. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1, Alarm A-10. 2. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1, Alarm E-4. EPIP 5.7.1 REVISION 58 PAGE 52 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 2 -On-Site Rad Conditions And Spent Fuel Pool Events Initiating Condition: Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the RPV EAL: AA2.2 Alert A water level drop in the reactor refueling cavity or spent fuel pool that will result in irradiated fuel becoming uncovered Mode Applicability: All NEI 99-01 Basis: This EAL addresses increases 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. Escalation of this emergency classification level, if appropriate, would be based on EALs in Subcategory Al. CNS Basis: When considering classification, information may come from:

Radiation monitor readings.

Sampling and surveys.

Dose projections/calculations.

Reports from the scene regarding the extent of damage (e.g., Refueling Crew, Radiation Protection Technicians). (continued on next page) EPIP 5. 7.1 REVISION 58 PAGE 53 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The major item of concern on loss of inventory from the Spent Fuel Pool and Refueling Cavity is to maintain adequate water level for personnel shielding and cooling of the irradiated fuel. Normal Spent Fuel Pool water level is 37' 6 1/2" above the bottom. A low pool level alarm occurs at 4" below the normal water level. Decreases in Spent Fuel Pool water level can also be detected only through visual observation and the existence of the Skimmer Surge Tank low level alarm (9 2/C-3) at 100 ft3 in the skimmer surge tank which is at elevation 9811 311 (Reference 1, 2, 3). During refueling when the RPV head is removed, Shutdown Range RPV water level instrument NBI-LI-86 is recalibrated to read vessel cavity level up to the 1001' elevation (Refuel Floor). With the reactor cavity in communication with the Spent Fuel Pool via the fuel transfer canal, uncontrolled inventory loss can be remotely monitored via this indicator. NBI-LI-86 can be used only if it has been set up to read to 1001' elevation as specified in Procedure 4.6.1, Reactor Vessel Water Level Indication (Reference 4). Allowing level to decrease could result in spent fuel being uncovered, reducing spent fuel decay heat removal and creating an extremely hazardous radiation environment. Technical Specification Section LCO 3. 7.6 (Reference 5) requires spent fuel storage pool water level be maintained at least 21' 6" over the top of irradiated fuel assemblies seated in the spent fuel storage pool racks. Technical Specification LCO 3.9.6 (Reference 6) requires RPV water level to be maintained at least 21' above the top of the RPV flange. During refueling, this maintains sufficient water level in the refueling cavity and SFP to retain iodine fission product activity in the water in the event of a fuel handling accident. CNS Basis Reference(s): 1. System Operating Procedure 2.2.32, Fuel Pool Cooling and Demineralizer System. 2. Annunciator Procedure 2.3_ 9 2, Panel 9 Annunciator 9 2. 3. Abnormal Procedure 2.4FPC, Fuel Pool Cooling Trouble. 4. Instrument Operating Procedure 4.6.1, Reactor Vessel Water Level Indication. 5. Technical Specification LCO 3.7.6. 6. Technical Specification LCO 3.9.6. EPIP 5.7.1 REVISION 58 PAGE 54 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: A -Abnormal Rad Release/Rad Effluent Subcategory: 2 -On-Site Rad Conditions And Spent Fuel Pool Events Initiating Condition: Rise in radiation levels within the facility that impedes EAL: AA3.1 Alert operation of systems required to maintain plant safety functions Dose rates > 15 mRem/hr in EITHER of the following areas requiring continuous occupancy to maintain plant safety functions: Main Control Room (RM-RA-20) OR CAS Mode Applicability: All NEI 99-01 Basis: ,-This EAL addresses increased 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 increase in radiation levels is not a concern of this EAL. The Emergency Director must consider the source or cause of the increased radiation levels and determine if any other EAL may be involved. The value of 15 mRem/hr is derived from the GDC 19 value of 5 Rem in 30 days with adjustment for expected occupancy times. Although Section III.D.3 of NUREG-0737, "Clarification of TMI Action Plan Requirements", provides that the 15 mRem/hr value can be averaged over the 30 days, the value is used here without averaging, as a 30 day duration implies an event potentially more significant than an Alert. Areas requiring continuous occupancy include the Main Control Room and the Central Alarm Station (CAS). (continued on next page) EPIP 5. 7.1 REVISION 58 PAGE 55 OF 334 ATTACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Areas that meet this threshold include the Main Control Room and the Central Alarm Station. The Central Alarm Station is included in this EAL because of its importance to permitting access to areas required to assure safe plant operations. There are no permanently installed CAS Area radiation monitors that may be used to assess this EAL threshold. Therefore, this portion of the EAL threshold must be assessed using local radiation survey (Reference 1, 2). CNS Basis Reference(s): 1. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1, B-10. 2. Emergency Procedure 5.1RAD, Building Radiation Trouble. EPIP 5.7.1 REVISION 58 PAGE 56 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 1 -Loss of Power Initiating Condition: AC power capability to critical buses reduced to a single power source for 15 minutes or longer such that any additional single failure would result in loss of all AC power to critical buses EAL: CU1.1 Unusual Event AC power capability to critical 4160V Buses 1F and 1G reduced to a single power source (Table C-4) 15 min. such that any additional single failure would result in loss of all AC power to critical buses (NOTE 3) NOTE 3 -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. -------------------------------------------------------------------------------------------.-----------------------------*----------------Ac Power Sources Offsite

Startup Station Service Transformer

Emergency Station Service Transformer

Backfeed 345 kv line through Main Power Transformer to the Normal Station Service Transformer (Note 8) On site

DG-1

DG-2 ________ _ ! specified time interval. If off-normal plant conditions have already established the !* backfeed, its power to the safety-related buses may be considered an off-site ____________________________________________________________________________________________________________ _ (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 57 OF 334 ATTACHMENT 2 Mode Applicability: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 4 -Cold Shutdown, 5 -Refueling NEI 99-01 Basis: The condition indicated by this EAL is the degradation of the off-site and on-site AC power systems such that any additional single failure would result in a loss of all AC power to critical buses. This condition could occur due to a loss of off-site power with a concurrent failure of all but one emergency generator to supply power to its emergency bus. The subsequent loss of this single power source would escalate the event to an Alert in accordance with CA1.1. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power. CNS Basis: The 4160V Critical Buses 1F (Div 1) and 1G (Div 2) are the plant essential, safety-related emergency buses. Each can be energized manually and separately by any of the following off-site sources of power: Figure C-1 illustrates the 4160V AC Distribution System (Reference 7, 8).

Startup Transformer -The Startup Transformer provides a source of off-site AC power to the entire Auxiliary Power Distribution System adequate for the startup operation or shutdown operation of the station. The Startup Transformer is the preferred source of off-site AC power to the station whenever the main generator is off-line. The Startup Transformer is energized from the 161 kV Switchyard. The transformer is normally left energized at all times to provide for quick automatic transfer of the 4160V auxiliaries to the Startup Transformer in the event that the station Normal Transformer fails or that the main generator trips off-line.

Emergency Transformer -The Emergency Transformer is the primary off-site AC power source to essential station loads. During normal station operation, the Emergency Transformer is energized by the 69 kV transmission line from OPPD. As such, it supplies 4160V Switchgear lF and/or 1G in the event that the Normal Transformer and Startup Transformer are not available for service. Use of the Emergency Transformer also allows portions of the 345 kV System to be removed from service for inspection, testing, and maintenance. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 58 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE)

Backfeeding power from the 345 kV line through the Main Power Transformer to the Normal Transformer. The Normal Transformer is the normal source of AC power to the station when the Main Generator is on-line above 20% (160 MWe) electrical power. The transformer is energized during Main Generator operation through the Isolated Phase Buses that feed the Main Power Transformers. As mentioned in NOTE 8, the time required to establish the backfeed is likely longer than the 15 minute interval. If off-normal plant conditions have already established the backfeed its power to the safety-related buses may be considered an off-site power source. On-site power sources are the emergency diesel generators (DG-1 and DG-2). If critical bus AC power is reduced to a single source for > 15 minutes, an Unusual Event is declared under this EAL. If a power supply should have picked up a critical bus but failed to do so, that power supply should be considered unavailable until it has been successfully tied onto the bus. If the power supply can be tied to the bus within 15 minutes, then the power supply is to be considered available. The Supplemental Diesel Generator (SDG) is not considered an on-site or an off-site emergency power supply and is not considered in classifications involving loss of power. The SBO Coping Time per Regulatory Guide 1.155 considers the impact of a SDG. This cold condition EAL is equivalent to the hot condition loss of AC power EAL SAl.1. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 59 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. System Operating Procedure 2.2.15, Startup Transformer. 2. System Operating Procedure 2.2.16, Normal Station Service Transformer. 3. System Operating Procedure 2.2.17, Emergency Station Service Transformer. 4. System Operating Procedure 2.2.18, 4160V Auxiliary Power Distribution System. 5. System Operating Procedure 2.2.20, Standby AC Power System (Diesel Generator). 6. Emergency Procedure 5.3SBO, Station Blackout. 7. BR 3001, One Line Diagram. 8. BR 3002, Sheet 1. 9. NC43456, One Line Switching Diagram 161kV Substation. 10. Enercon Services, Inc. Report No. NPPl-PR-01, Station Blackout Coping Assessment for Cooper Nuclear Station, Revision 2. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 60 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Figure C-1: 4160V AC Distribution System FROM MAIN GENERATOR y NORMAL STATION SERVICE TRANSfORMER Z! l<.V/4160V BKR ) 1CN i 4160VSWGR10 4160V SWGR 1A 4160V SWGR 1 P Bl<R ') 1FE BKR ) EG1 c5 BKR 1FA DIESEL GENERATOR #1 EPIP 5.7.1 BKR') 1FS I EMERGENCY SERI/ICE J

i ' '-TRANSFORMER FROM 345 KV/161 KV GRID STARTUP STATIO_N SERVICE TRANSFORMER )BKR )BKR 1DN 105 i ' 4160V SWGR 1D )BKR 1BN y \.AAA.I rvvY"I 16t'KVf4160V )BKR 185 ')BKR 1BE * * ')BKR 4160V SWGR 1B 180 ')Bl{R 1GS I SDG 4160V SWGR 1G ')BKR 1GE )BKR EG2 c5 DIESEL, GENERATOR #2 REVISION 58 PAGE 61 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 1 -Loss of Power Initiating Condition: Loss of all off-site and all on-site AC power to critical buses for 15 minutes or longer EAL: CAl.1 Alert Loss of all off-site and all on-site AC power (Table C-4) to critical 4160V Buses lF and lG for 2 15 min. (NOTE 3) NOTE 3 -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 __ _ lx _ ! _________________________________________________________ _ Table C-4 AC Power Sources I Offsite

startup Station Service Transformer

Emergency Station Service Transformer

Backfeed 345 kv line through Main Power Transformer ta the Normal station Service Transformer (Note 8) On site

DG-1

DG-2 NOTE 8 -The time required to establish the backfeed is likely longer than the specified time interval. If off-normal plant conditions have already established the backfeed, its power to the safety-related buses may be considered an off-site ------------------------------------------------_______ ,_ -----------------------------------------------------(continued on next page) EPIP5.7.1 REVISION 58 PAGE 62 OF 334 ATIACHMENT 2 Mode Applicability: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 4 -Cold Shutdown, 5 -Refueling, D -Defueled N EI 99-01 Basis: Loss of all AC power 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, increasing the time to restore one of the critical buses, relative to that specified for the Site Area Emergency EAL Escalating to Site Area Emergency, if appropriate, is by Abnormal Rad Levels/Radiological Effluent EALs. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. CNS Basis: The 4160V Critical Buses lF (Div 1) and lG (Div 2) are the plant essential, safety-related emergency buses. Each can be energized manually and separately by any of the following off-site sources of power: Figure C-1 illustrates the 4160V AC Distribution System (Reference 7, 8).

Startup Transformer -The Startup Transformer provides a source of off-site AC power to the entire Auxiliary Power Distribution System adequate for the startup operation or shutdown operation of the station. The Startup Transformer is the preferred source of off-site AC power to the station whenever the main generator is off-line ( < 160 MWe). The Startup Transformer is energized from the 161 kV Switchyard. The transformer is normally left energized at all times to provide for quick automatic transfer of the 4160V auxiliaries to the Startup Transformer in the event that the station Normal Transformer fails or that the main generator trips off-line. (continued on next page) EPIP5.7.1 REVISION 58 PAGE 63 OF 334 AITACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE)

Emergency Transformer -The Emergency Transformer is the primary off-site AC power source to essential station loads. During normal station operation, the Emergency Transformer is energized by the 69 kV transmission line from OPPD. As such, it supplies 4160V Switchgear 1F and/or 1G in the event that the Normal Transformer and Startup Transformer are not available for service. Use of the Emergency Transformer also allows portions of the 345 kV System to be removed from service for inspection, testing, and maintenance.

Backfeeding power from the 345 kV line through the Main Power Transformer to the Normal Transformer. The Normal Transformer is the normal source of AC power to the station when the Main Generator is on line above 20% (160 MWe) electrical power. The transformer is energized during Main Generator operation through the Isolated Phase Buses that feed the Main Power Transformers. As mentioned in NOTE 8, the time required to establish the backfeed is likely longer than the 15 minute interval. If off-normal plant conditions have already established the backfeed its power to the safety-related buses may be considered an off-site power source. On-site power sources are the emergency diesel generators (DG-1 and DG-2). If a power supply should have picked up a critical bus but failed to do so, that power supply should be considered unavailable until it has been successfully tied onto the bus. If the power supply can be tied to the bus within 15 minutes, then the power supply is to be considered available. The Supplemental Diesel Generator (SDG) is not considered an on-site or an off-site emergency power supply and is not considered in classifications involving loss of power. The SBO Coping Time per Regulatory Guide 1.155 considers the impact of a SDG. This EAL is the cold condition equivalent of the hot condition loss of all AC power EAL 551.1. When in Cold Shutdown, Refueling, or Defueled Mode, the event can be classified as an Alert because of the significantly reduced decay heat, lower temperature and pressure, increasing the time to restore one of the emergency buses, relative to that existing when in hot conditions. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 64 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. System Operating Procedure 2.2.15, Startup Transformer. 2. System Operating Procedure 2.2.16, Normal Station Service Transformer. 3. System Operating Procedure 2.2.17, Emergency Station Service Transformer. 4. System Operating Procedure 2.2.18, 4160V Auxiliary Power Distribution System. 5. System Operating Procedure 2.2.20, Standby AC Power System (Diesel Generator). 6. Emergency Procedure 5.3SBO, Station Blackout. 7. BR 3001, One Line Diagram. 8. BR 3002, Sheet 1. 9. NC43456, One Line Switching Diagram 161kV Substation. 10. Enercon Services, Inc. Report NPPl-PR-01, Station Blackout Coping Assessment for Cooper Nuclear Station, Revision 2. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 65 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Figure C-1: 4160V AC Distribution System FROM MAIN G.EN.ERATOR-y NORMAi. STATION SERVICE TRANSFORMER 1CN BKR ) 41'6\lV.SWGR 1C BKR I) 1AN 4160V SWGR 1A 4160V SWGR 1F 1FE BKR .) EG1 c5 BKR 1FA DIESEL GENERATOR #1 EPIPS.7.1 BKR ) 1AS BKR ) 1AE

4160V SWGR 1E Ol<R') 1FS I EMERGENCY SERVICE ""

i * "' TRANSFORMER FROM 345 KV/161 KV GRID STARTUP STATION SERVICE Tl'!ANSFORMER )BKR )BKR .mN ms i 4160V SWGR 10 i )BKR , 1BE lBG . ,-r; y v..AAI rVYV'\ 161 l<V/4160V 4160V SWGR 1G ')BKR *iGS I SOG ')BKR 1GE )BKR EG2 c5 DIESEL GENERATOR #2 REVISION 58 PAGE 66 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 2 -RPV Level Initiating Condition: Unplanned loss of RPV inventory EAL: CU2.1 Unusual Event RPV level cannot be restored and maintained > +3 in. 15 min. (NOTE 3) due to RCS leakage 1 NOTE 3 -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 !_ ! _ JY. _ _____________ -----------------------Mode Applicability: 4 -Cold Shutdown NEI 99-01 Basis: This EAL 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 EAL However, a relief valve that operates and fails to close per design should be considered applicable to this EAL if the relief valve cannot be isolated. Prolonged loss of RCS inventory may result in escalation to the Alert emergency classification level via either CA2.1 or CA3.1. The difference between CU2.1 and CU2.2 deals with the RCS conditions that exist between Cold Shutdown and Refueling Modes. In Cold Shutdown, the RPV will normally be intact and RPV level is typically controlled below the elevation of the RPV flange and above the low-end of the normal control band. In the Refueling Mode the RPV is not intact and any planned evolutions to lower RPV level below the elevation of the RPV flange must be carefully controlled. (continued on next page) EPIP 5. 7.1 REVISION 58 PAGE 67 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis: The condition of this EAL may be 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. When RPV level drops to +3 inches (low level scram setpoint), level is well below the normal control band and automatic RPS and PCIS actuations are required (Reference 3, 5). RPV level is normally monitored using the following instruments (Reference 1, 2):

Wide Range NBI-LI-85A, B & C (-155 to 60 inches).

Steam Nozzle Range NBI-Ll-92 (0 to 180 inches).

Fuel Zone Range NBI-LI-91A, B & C (-320 to 60 inches).

Narrow Range RFC-LI-94A, B & C (0 to 60 inches).

Shutdown Range NBI-LI-86 (0 to 400 inches). Procedure 2.4RXLVL provides guidance for erratic or unexplained RPV water level changes. EOP/SAG Caution #1 indicates when an instrument may be used for level indication in the EOPs/SAGs. This Cold Shutdown EAL represents the hot condition EAL SU6.1, in which RCS leakage is associated with Technical Specification limits. In Cold Shutdown, these limits are not applicable; hence, the use of RPV level as the parameter of concern in this EAL (Reference 4). CNS Basis Reference(s): 1. Abnormal Procedure 2.4RXLVL, RPV Water Level Control Trouble. 2. Instrument Operating Procedure 4.6.1, Reactor Vessel Water Level Indication. 3. EOP-1A RPV Control. 4. NEI/NRC EAL FAQ #2006-014. 5. Technical Specification Table 3.3.1.1-1. EPIP 5.7.1 REVISION 58 PAGE 68 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 2 -RPV Level Initiating Condition: Unplanned loss of RPV inventory EAL: CU2.2 Unusual Event Unplanned RPV level drop 15 min. (NOTE 3) below EITHER: RPV flange (Ll-86: 206 in. normal calibration, 113.75 in. elevated calibration) OR RPV level band when the RPV level band is established below the RPV flange NOTE 3 -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 C?_r:i_ !x _ _ J?J?!! ___________________________ ------------------------------Mode Applicability: 5 -Refueling NEI 99-01 Basis: This EAL 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 decrease RPV water level below the RPV flange are carefully planned and procedurally controlled. An unplanned event that results in water level decreasing below the RPV flange or below the planned RPV water level for the given evolution (if the planned RPV water level is already below the RPV flange) warrants declaration of an Unusual Event 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 refill that should be available. If level cannot be restored in this time frame, then it may indicate a more serious condition exists. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 69 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Continued loss of RCS inventory will result in escalation to the Alert emergency classification level via either CA2.1 or CA3.1. The difference between CU2.1 and CU2.2 deals with the RPV conditions that exist between Cold Shutdown and Refuel Modes. In Cold Shutdown, the RCS will normally be intact and standard RPV inventory and level monitoring means are available. In the Refuel Mode, the RCS is not intact and RPV level and inventory may be monitored by different means. This EAL involves a decrease in RPV level below the top of the RPV flange or a decrease below the RPV level band (when the RPV level band is established below the RPV flange) that continues for 15 minutes due to an unplanned event. This EAL is not applicable to decreases in flooded reactor cavity level, which is addressed by AU2.1, until such time as the level decreases to the level of the vessel flange. If RPV level continues to decrease and reaches the Low-Low ECCS actuation setpoint, then escalation to CA2.1 would be appropriate. CNS Basis: The RPV flange is 722.75 inches above the RPV bottom head. RPV water level at this elevation is normally indicated by the Shutdown Range instrument (LI-86 Shutdown, 0 -400 inches). When calibrated for normal plant operations, the Shutdown Range instrument reads 206 inches at the RPV flange. With the RPV head removed, the instrument is calibrated to indicate reactor cavity water levels as high as the refuel floor. When calibrated for elevated indication, the Shutdown Range instrument reads 113.75 inches at the RPV flange. Visual observation of water level in the reactor cavity and RPV is also used during refuel operations. CNS Basis Reference(s): 1. General Operating Procedure 2.1.20.3, RPV Refueling Preparation (Wet Lift or Dryer and Separator), Indicated RPV Level vs. RPV Height attachment. 2. Instrument Operating Procedure 4.6.1, Reactor Vessel Water Level Indication. 3. IAC Procedure 14.15.3, Reactor Vessel Open Head Level Monitor System. EPIP 5.7.1 REVISION 58 PAGE 70 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 2 -RPV Level Initiating Condition: Unplanned loss of RPV inventory EAL: CU2.3 Unusual Event RPV level cannot be monitored with any unexplained RPV leakage indication, Table C-1 . Table C-1 RPV Leakage Indications

Drywell equipment drain sump level rise

Drywell floor drain sump level rise

Reactor Building equipment drain sump level rise

Reactor Building floor drain sump level rise

Torus water level rise

RPV make-up rate rise

Observation of unisolable RCS leakage Mode Applicability: 5 -Refueling NEI 99-01 Basis: This EAL is a precursor of more serious conditions and considered to be a potential degradation of the level of safety of the plant. Continued loss of RCS Inventory will result in escalation to the Alert emergency classification level via either CA2.1 or CA3.1. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 71 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) This EAL addresses conditions in the Refueling Mode when normal means of core temperature indication and RPV 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 RPV inventory event, the Operators would need to determine that RPV inventory loss was occurring by observing sump level changes listed in Table C-1. Sump level increases 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 CA2.1 or CA3.1. CNS Basis: RPV level is normally monitored using the following instruments (Reference 3, 4):

Wide Range NBI-LI-85A, B & C (-155 to 60 inches).

Steam Nozzle Range NBI-LI-92 (0 to 180 inches).

Fuel Zone Range NBI-LI-91A, B & C (-320 to 60 inches).

Narrow Range RFC-LI-94A, B & C (0 to 60 inches).

Shutdown Range NBI-LI-86 (0 to 400 inches). Procedure 2.4RXLVL provides guidance for erratic or unexplained RPV water level changes. EOP/SAG Caution #1 indicates when an instrument may be used for level indication in the EOPs/SAGs. (continued on next page) EPIP5.7.1 REVISION 58 PAGE 72 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) In this EAL, all water level indication is unavailable and the RPV inventory loss should be detected by the leakage indications listed in Table C-1. Level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the drywell to ensure they are indicative of RPV leakage. Drywell equipment and floor drain sump level rise is the normal method of monitoring and calculating leakage from the RPV (Reference 1). A Reactor Building equipment or floor drain sump level rise may also be indicative of RCS inventory losses external to the Primary Containment from systems connected to the RPV. With RHR System operating in the Shutdown Cooling Mode, an unexplained rise in torus water level could be indicative of RHR valve misalignment or leakage (Reference 2). If the make-up rate to the RPV unexplainably rises above the pre-established rate, a loss of RPV inventory may be occurring even if the source of the leakage cannot be immediately identified. Visual observation of leakage from systems connected to the RCS in areas outside the Primary Containment that cannot be isolated could be indicative of a loss of RPV inventory. CNS Basis Reference(s): 1. System Operating Procedure 2.2.27, Equipment, Floor, and Chemical Drain System. 2. System Operating Procedure 2.2.69, Residual Heat Removal System. 3. Abnormal Procedure 2.4RXLVL, RPV Water Level Control Trouble. 4. Instrument Operating Procedure 4.6.1, Reactor Vessel Water Level Indication. EPIP 5.7.1 REVISION 58 PAGE 73 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 2 -RPV Level Initiating Condition: Loss of RPV inventory EAL: CA2.1 Alert RPV level < -42 in. OR RPV level cannot be monitored for;;::: 15 min. (NOTE 3) with any unexplained RPV leakage indication, Table C ---------.:. ------------------------------------------.;. ..:_-_______ ----------.. ------... -... -----------------NOTE 3 -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 <?_r:'_ ! ! _ !X _ ________ ._c _______________________________ . _________ _ RPV lndic_ations.

Drywell equipment drain sump level rise

Drywell floor drain sump level rise

Reactor Building equipment drain sump level rise

Reactor Building floor drain sump level rise

Suppression pool water level rise

RPV make-up rate rise

Observation of unisolable RCS leakage Mode Applicability: 4 -Cold Shutdown, 5 -Refueling (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 74 OF 334 _ _J

ATTACHMENT 2 NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) This EAL serves as precursor to a loss of heat removal. 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 decrease and potential core uncovery. This condition will result in a minimum classification of Alert. The low-low ECCS Actuation setpoint was chosen because it is a recognized setpoint. The inability to restore and maintain level after reaching this setpoint would therefore be indicative of a failure of the RCS barrier. In Cold Shutdown Mode, the RCS will normally be intact and standard RPV level monitoring means are available. In the Refueling Mode, the RCS is not intact and RPV level may be monitored by different means, including the ability to monitor level visually. In the Refueling Mode, normal means of RPV level indication may not be available. Redundant means of RPV level indication will be normally 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 RPV inventory event, the Operators would need to determine that RPV inventory loss was occurring by observing sump level changes listed in Table C-1. Sump level increases 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 15 minute duration for the loss of level indication was chosen because it is half of the CS2.1 Site Area Emergency EAL duration. The 15 minute duration allows CA2.1 to be an effective precursor to CS2.1. Significant fuel damage is not expected to occur until the core has been uncovered for > 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Therefore, this EAL meets the definition for an Alert. If RPV level continues to decrease, then escalation to Site Area Emergency will be via EAL CS2.1. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 75 OF 334

ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis: The threshold RPV level of -42 inches is the low-low ECCS actuation setpoint (Reference 5). RPV level is normally monitored using the following instruments (Reference 3, 4):

Wide Range NBI-LI-85A, B & C (-155 to 60 inches).

Steam Nozzle Range NBI-LI-92 (0 to 180 inches).

Fuel Zone Range NBI-LI-91A, B & C (-320 to 60 inches).

Narrow Range RFC-LI-94A, B & C (0 to 60 inches).

Shutdown Range NBI-LI-86 (0 to 400 inches). Procedure 2.4RXLVL provides guidance for erratic or unexplained RPV water level changes. EOP/SAG Caution #1 indicates when an instrument may be used for level indication in the EOPs/SAGs. Drywell equipment and floor drain sump level rise is the normal method of monitoring and calculating leakage from the RPV (Reference 1). A Reactor Building equipment or floor drain sump level rise may also be indicative of RCS inventory losses external to the Primary Containment from systems connected to the RPV. With RHR System operating in the Shutdown Cooling Mode, an unexplained rise in torus level could be indicative of RHR valve misalignment or leakage (Reference 2). If the make-up rate to the RPV unexplainably rises above the pre-established rate, a loss of RPV inventory may be occurring even if the source of the leakage cannot be immediately identified. Visual observation of leakage from systems connected to the RCS in areas outside the Primary Containment that cannot be isolated could be indicative of a loss of RPV inventory. CNS Basis Reference(s): 1. System Operating Procedure 2.2.27, Equipment, Floor, and Chemical Drain System. 2. System Operating Procedure 2.2.69, Residual Heat Removal System. 3. Abnormal Procedure 2.4RXLVL, RPV Water Level Control Trouble. 4. Instrument Operating Procedure 4.6.1, Reactor Vessel Water Level Indication. 5. Technical Specification Table 3.3.5.1-1. EPIP 5.7.1 REVISION 58 PAGE 76 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 2 -RPV Level Initiating Condition: Loss of RPV inventory affecting core decay heat removal capability EAL: CS2.1 Site Area Emergency With Containment Closure not established (NOTE 4), RPV level < -48 in. NOTE 4-Containment Closure is the action taken to secure primary or Secondary Containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. Containment Closure requirements are specified in Administrative _ !? _ ____________________ --_ ---------------------------------------Mode Applicability: 4 -Cold Shutdown, 5 -Refueling NEI 99-01 Basis: Under the conditions specified by this EAL, continued decrease in RPV level is indicative of a loss of inventory control. Inventory loss may be due to a 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 CG2.1 or AG1.1. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 77 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis: When RPV level decreases to -48 inches, water level is 6 inches below the low-low ECCS actuation setpoint: -42 inches -6 inches = -48 inches (Reference 4). RPV level is normally monitored using the following instruments (Reference 2, 3):

Wide Range NBI-LI-85A, B & C (-155 to 60 inches).

Steam Nozzle Range NBI-LI-92 (0 to 180 inches).

Fuel Zone Range NBI-LI-91A, B & C (-320 to 60 inches).

Narrow Range RFC-LI-94A, B & C (0 to 60 inches).

Shutdown Range NBI-LI-86 (0 to 400 inches). Procedure 2.4RXLVL provides guidance for erratic or unexplained RPV water level changes. EOP/SAG Caution #1 indicates when an instrument may be used for level indication in the EOPs/SAGs. 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 decrease and potential core uncovery. The inability to restore and maintain level after reaching this setpoint infers a failure of the RCS barrier and Potential Loss of the Fuel Clad barrier. Containment Closure is the action taken to secure Primary Containment or Secondary Containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. Containment Closure requirements are specified in Administrative Procedure 0.50.5, Outage Shutdown Safety (Reference 1). CNS Basis Reference(s): 1. Administrative Procedure 0.50.5, Outage Shutdown Safety. 2. Abnormal Procedure 2.4RXLVL, RPV Water Level Control Trouble. 3. Instrument Operating Procedure 4.6.1, ReactorVessel Water Level Indication. 4. Technical Specification Table 3.3.5.1-1. EPIP 5.7.1 REVISION 58 PAGE 78 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 2 -RPV Level Initiating Condition: Loss of RPV inventory affecting core decay heat removal capability EAL: CS2.2 Site Area Emergency With Containment Closure established (NOTE 4), RPV level < -158 in. NOTE 4 -Containment Closure is the action taken to secure primary or Secondary Containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. Containment Closure requirements are specified in Administrative _. _? 1 __ Q _ _____________________________________________________ ---------Mode Applicabmty: 4 -Cold Shutdown, 5 -Refueling NEI 99-01 Basis: Under the conditions specified by this EAL, continued decrease in RPV level is indicative of a loss of inventory control. Inventory loss may be due to a 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 CG2.1or AG1.1. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 79 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis: When RPV level drops to -158 inches, core uncovery is about to occur (Reference 4). RPV level is normally monitored using the following instruments (Reference 2, 3):

Wide Range NBI-LI-85A, B & C (-155 to 60 inches).

Steam Nozzle Range NBI-LI-92 (0 to 180 inches).

Fuel Zone Range NBI-LI-91A, B & C (-320 to 60 inches).

Narrow Range RFC-LI-94A, B & C (0 to 60 inches).

Shutdown Range NBI-LI-86 (0 to 400 inches). Procedure 2.4RXLVL provides guidance for erratic or unexplained RPV water level changes. EOP/SAG Caution #1 indicates when an instrument may be used for level indication in the EOPs/SAGs. 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 decrease and potential core uncovery. The inability to restore and maintain level after reaching this setpoint infers a failure of the RCS barrier and Potential Loss of the Fuel Clad barrier. Containment Closure is the action taken to secure Primary Containment or Secondary Containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. Containment Closure requirements are specified in Administrative Procedure 0.50.5, Outage Shutdown Safety (Reference 1). CNS Basis Reference(s): 1. Administrative Procedure 0.50.5, Outage Shutdown Safety. 2. Abnormal Procedure 2.4RXLVL, RPV Water Level Control Trouble. 3. Instrument Operating Procedure 4.6.1, Reactor Vessel Water Level Indication. 4. NEDC 97-089. EPIP 5.7.1 REVISION 58 PAGE 80 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 2 -RPV Level Initiating Condition: Loss of RPV inventory affecting core decay heat removal capability EAL: CS2.3 Site Area Emergency RPV level cannot be monitored 30 min. (NOTE 3) with a loss of inventory as indicated by EITHER: Unexplained RPV leakage indication, Table C-1 OR Erratic Source Range Monitor indication .-------------------------------. ------------------------------------.... -----------------------------------------*----------------------! NOTE 3 -The Emergency Director should not wait until the applicable time has i elapsed, but should declare the event as soon as it is determined that the 1 y_ _ ----------------------------------------------------------Table C-1 RPV Leakage Indications

Drywell equipment drain sump level rise

Drywell floor drain sump level rise

Reactor Building equipment drain sump level rise

Reactor Building floor drain sump level rise

Suppression pool water level rise

RPV make-up rate rise

Observation of unisolable RCS leakage (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 81 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Mode Applicabmty: 4 -Cold Shutdown, 5 -Refueling NEI 99-01 Basis: Under the conditions specified by this EAL, continued decrease in RPV level is indicative of a loss of inventory control. Inventory loss may be due to a 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 CG2.2 or AGl.1. In the Cold Shutdown Mode, normal 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 RPV inventory event, the Operators would need to determine that RPV inventory loss was occurring by observing sump level changes listed in Table C-1. Sump level increases 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. Post-TM! 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. CNS Basis: RPV level is normally monitored using the instruments in Figure C-3 (Reference 3, 5).

Wide Range NBI-LI-85A, B & C (-155 to 60 inches).

Steam Nozzle Range NBI-LI-92 (0 to 180 inches).

Fuel Zone Range NBI-LI-91A, B & C (-320 to 60 inches).

Narrow Range RFC-LI-94A, B & C (0 to 60 inches).

Shutdown Range NBI-LI-86 (0 to 400 inches). (continued on next page) EPIP5.7.1 REVISION 58 PAGE 82 OF 334

ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Procedure 2.4RXLVL provides guidance for erratic or unexplained RPV water level changes. EOP/SAG Caution # 1 indicates when an instrument may be used for level indication in the EOPs/SAGs. In this EAL, all water level indication is unavailable and the RPV inventory loss must be detected by the leakage indications listed in Table C-1 or erratic Source Range Monitor (SRM) indication:

Table C-1 level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the drywell to ensure they are indicative of RPV leakage. Drywell equipment and floor drain sump level rise is the normal method of monitoring and calculating leakage from the RPV (Reference 1). A Reactor Building equipment or floor drain sump level rise may also be indicative of RCS inventory losses external to the Primary Containment from systems connected to the RPV. With RHR System operating in the Shutdown Cooling Mode, an unexplained rise in torus water level could be indicative of RHR valve misalignment or leakage (Reference 2). If the make-up rate to the RPV unexplainably rises above the pre-established rate, a loss of RPV inventory may be occurring even if the source of the leakage cannot be immediately identified. Visual observation of leakage from systems connected to the RCS in areas outside the Primary Containment that cannot be isolated could be indicative of a loss of RPV inventory.

Source Range Monitor (SRM) indication is provided in the Main Control Room by NMS-l-43A-D, SRM A-D LOG COUNT RATE, NM-NR-45, SRM 2 PEN RECORDER, and SPDS (Reference 4 ). Erratic Source Range Monitor indication specified is caused by increased boiling in the vicinity of the SRMs as water level lowers and exposed fuel heats up. This instability will be greatly magnified when compared with normal source range monitor behavior. Additionally, once the water level falls below the SRM level, lack of thermalized neutron populations in the area will cause the SRMs to read abnormally low. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 83 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) At some plants, containment high range area radiation monitors are specified as an alternate means of detecting loss of water shielding above the core and possible core uncovery. The CNS Primary Containment radiation monitors are designated RA-RM-40A and B. The Containment High Range Monitoring System monitors gamma radiation levels of 1 R/hr to 107 R/hr in the reactor drywell area. The system consists of two ion chambers in the drywell and two readout modules in Panels 9-2 and 9-10. The detectors (RA-RE-40A and B) are located 180° from each other in the drywell above elevation 901' 611* The elevation of the bottom of the RPV bottom head is 917'. The elevation of the top of active fuel in the Primary Containment is approximately 947'. The detectors are approximately 45' 611 below the top of active fuel. RCS piping, components, and drywell structural members are positioned between the detectors and the reactor core. Due to the relative location of these detectors with respect to the top of active fuel, the CNS containment ,high range radiation monitors cannot be utilized for detection of loss of RPV inventory above the core. Additionally, no other installed Radiation Monitoring System exists that can be utilized for the function. CNS Basis Reference(s): 1. System Operating Procedure 2.2.27, Equipment, Floor, and Chemical Drain System. 2. System Operating Procedure 2.2.69, Residual Heat Removal System. 3. Abnormal Procedure 2.4RXLVL, RPV Water Level Control Trouble. 4. Instrument Operating Procedure 4.1.1, Source Range Monitoring System. 5. Instrument Operating Procedure 4.6.1, Reactor Vessel Water Level Indication. EPIP 5.7.1 REVISION 58 PAGE 84 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 2 -RPV Level Initiating Condition: Loss of RPV inventory affecting fuel clad integrity with containment challenged EAL: CG2.1 General Emergency RPV level < -158 in. for 2 30 min. (NOTE 3) AND Any Containment Challenge indication, Table C-5 elapsed, but should declare the event as soon as it is determined that the : !! Jx __ _______________ , _,, _. ___________ . ' * *ta:ble1 C-5 Containment

Containment Closure not established (Note 4)

Deflagration concentrations exist inside PC 2 6% H2 in drywell or torus AND ;::: 5% 02 in drywell or torus

Unplanned rise in PC pressure

Secondary Containment area radiation > 1000 mR/hr (EOP-5A Table 10) ---------... -... ----------------.-*--':----'"' _ __,__-_ .. -... *-----------.----*-'----------.-.-::-.-.... ---.. --.. -"" ....... * ... -.. "" ---.. ----------*-------.... *------, NOTE 4 -Containment Closure is the action taken to secure primary or Secondary i I Containment and its associated structures, systems, and components as a i functional barrier to fission product release under existing plant conditions. Containment Closure requirements are specified in Administrative Procedure 0.50.5, Outage Shutdown Safety. _ ! ------"'----.. ---,.. ___ --.. -----------------------... -*-... --------*---------___ ,. _____ .,., _ _. _____ ...... -.. -..... ,.. -......... --------------------(continued on next page) EPIP 5.7.1 REVISION 58 PAGE 85 OF 334 ATIACHMENT 2 Mode Applicability: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 4 -Cold Shutdown, 5 -Refueling NEI 99-01 Basis: This EAL 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. Analysis indicates that core damage may occur within an hour following continued core uncovery; therefore, conservatively, 30 minutes was chosen. The General Emergency is declared on the occurrence of the loss or imminent loss of function of all three barriers. Based on the above discussion, RCS barrier failure resulting in core uncovery for 30 minutes or more may cause fuel clad failure. With the Primary Containment and Secondary 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 General Emergency. Containment Closure is the action taken to secure containment (Primary or Secondary) and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. Containment Closure should not be confused with refueling containment integrity as defined in Technical Specifications. Site shutdown contingency plans typically provide for re-establishing Containment Closure following a loss of heat removal or RPV inventory functions. If the closure is re-established prior to exceeding the temperature or level thresholds of the RCS barrier and Fuel Clad barrier EALs, escalation to General Emergency would not occur. If Containment Closure is re-established prior to exceeding the 30 minute core uncovery time limit, then escalation to GE would not occur. The use of Secondary Containment radiation monitors should provide indication of increased release that may be indicative of a challenge to Secondary Containment. The radiation monitor values are based on the EOP 11maximum safe values" because these values are easily recognizable and have an emergency basis. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 86 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 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 Primary Containment. However, Primary 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. CNS Basis: When RPV level drops to -158 inches, core uncovery is about to occur (Reference 7). RPV level is normally monitored using the following instruments (Reference 3, 4):

Wide Range NBI-Ll-85A, B & C (-155 to 60 inches).

Steam Nozzle Range NBI-LI-92 (0 to 180 inches).

Fuel Zone Range NBI-LI-91A, B & C (-320 to 60 inches).

Narrow Range RFC-Ll-94A, B & C (0 to 60 inches).

Shutdown Range NBI-LI-86 (0 to 400 inches). Procedure 2.4RXLVL provides guidance for erratic or unexplained RPV water level changes. EOP/SAG Caution #1 indicates when an instrument may be used for level indication in the EOPs/SAGs. Four conditions are associated with a challenge to Primary Containment (PC) integrity: 1. Containment Closure is the action taken to secure Primary Containment or Secondary Containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. Containment Closure requirements are specified in Administrative Procedure 0.50.5, Outage Shutdown Safety (Reference 1). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 87 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 2. Deflagration (explosive) mixtures in the Primary Containment are assumed to be elevated concentrations of hydrogen and oxygen. BWR industry evaluation of hydrogen generation for development of EOPs/SAMGs indicates that any hydrogen concentration above minimum detectable is not to be expected within the short term. Post-LOCA hydrogen generation primarily caused by radiolysis is a slowly evolving, long-term condition. Hydrogen concentrations that rapidly develop are most likely caused by metal-water reaction. A metal-water reaction is indicative of an accident more severe than accidents considered in the plant design basis and would be indicative, therefore, of a potential threat to Primary Containment integrity. The specified values for this threshold are the minimum global deflagration concentration limits (6% hydrogen and 5% oxygen) (Reference 5). 3. Any unplanned increase in PC pressure in the Cold Shutdown or Refueling Mode indicates a potential loss of Containment Closure capability. Unplanned Primary Containment pressure increases indicates Containment Closure cannot be assured and the Primary Containment cannot be relied upon as a barrier to fission product release. 4. 1,000 mR/hr is the Secondary Containment Maximum Safe Operating radiation value. Exceeding this value is indicative of problems in the Secondary Containment that are spreading. The locations into which the primary system discharge is of concern correspond to the areas addressed in EOP-SA, Secondary Containment Control, Table 10. As indicated by NOTE 5 in EOP-5A, Table 10, RP Surveys and ARM Teledosimetry System may be used for these indications (Reference 6). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 88 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) EOP-SA Table 10 -Secondary Containment Radiation Levels FUD.. P00-1\REA f"U.!1. PQCI_ AREA 10J. 106 .Qt

100 $.;:rl'e Oper-..i:ri9 V.:ti.J<! t001' El 1000 1001* El --*--** ... **-*-*** RWCtJ PRcCO;\T ARCA RMA*RA-4 RWCU S..UOGE J\"{[} DE: CANT PUMP AREA RMA*RA..S CRD HYORAUUC EQUIP AREA fSOUTH} P.MA*RA<l CRD HYOR;\l..IUC r;'OUlP ARt:A t'ORTi1) RMA*RA*9 ttPCI PUMP ROOM RHR PU'MP ROOM. (SOUTltWESfl TORUS HW MU:ll {SOUTHWEST) RliR PUMP ROOM, (NORTft\VEST> RMA*RA-27 RMA*RA*12 0.1

ll'.lOO a t , 1oro .01. 100 .01

100 .01

100 t .0. 10000 .01. 100 9511' EL 931' 8'. 1000 9C3'0. *-. -HPCI Room S\NOJ!rl 1000 NWQwd 1000 .... ru'.:K:,CORE SPRAY PUMP ROOM, (NORHIEAST} .at, 100 NE Q.Ja.1 1 OOC CORE SPRAY PUMP ROOM, \$01.JTH!:AST} .01

too SEQwd 1000 EPIPS.7.1 NOTE5 Area radiation levels can be monitored by RP surveys or ARM teledosimetry system (continued on next page) REVISION 58 -" .... ,. ' ' -* --PAGE 89 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. Administrative Procedure 0.50.5, Outage Shutdown Safety. 2. System Operating Procedure 2.2.60.1, Containment H2/02 Monitoring System. 3. Abnormal Procedure 2.4RXLVL, RPV Water Level Control Trouble. 4. Instrument Operating Procedure 4.6.1, Reactor Vessel Water Level Indication. 5. AMP-TBDOO, Step PC/H. 6. EOP-5A, Secondary Containment Control, Table 10. 7. NEDC 97-089. EPIP 5.7.1 REVISION 58 PAGE 90 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 2 -RPV Level Initiating Condition: Loss of RPV inventory affecting fuel clad integrity with containment challenged EAL: CG2.2 General Emergency RPV level cannot be monitored 30 min. (NOTE 3) with core uncovery indicated by EITHER: AND Unexplained RPV leakage indication, Table C-1 OR Erratic Source Range Monitor indication Any Containment Challenge indication, Table C-5 *----------------------------------------------------------------------------... --.. ------------------.. ------------... ---------... ..: ...... .; ----** -: i NOTE 3 -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 i condition will likely exceed the applicable time. : *---=---------*-----------.--., ...... --------------------------------------------------------------------------------------------------------Table. C-1 RPV Leakage Indications

Drywell equipment drain sump level rise

Drywell floor drain sump level rise

Reactor Building equipment drain sump level rise

Reactor Building floor drain sump level rise

Suppression pool water level rise

RPV make-up rate rise

Observation of unisolable RCS leakage (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 91 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Table C-5 Containment Challenge Indications

Containment Closure not established (Note 4)

Deflagration concentrations exist inside PC 6% H2 in drywell or torus AND 5% 02 in drywell or torus

Unplanned rise in PC pressure

Secondary Containment area radiation > 1000 mR/hr (EOP-5A Table 10) ___ i j Containment and its associated structures, systems, and components as a : functional barrier to fission product release under existing plant conditions. Containment Closure requirements are specified in Administrative , Procedure 0.50.5, Outage Shutdown Safety. . ! *.-:-:-------------------------------------.. ---------------------------------------------------------------* -------------------------------* Mode Applicability: 4 -Cold Shutdown, 5 -Refueling NEI 99-01 Basis: In the Cold Shutdown Mode, normal RPV level and RPV Level Instrumentation Systems will normally be available. However, if all level indication were to be lost during a loss of RPV inventory event, the Operators would need to determine that RPV inventory loss was occurring by observing sump level changes. Sump level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the Primary Containment to ensure they are indicative of RCS leakage. In the Refueling Mode, normal means of RPV level indication may not be available. Redundant means of RPV level indication will be normally 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 RPV inventory event, the Operators would need to determine that RPV inventory loss was occurring by observing sump level changes listed in Table C-1. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 92 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) For both Cold Shutdown and Refueling Modes, sump level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the Primary Containment to ensure they are indicative of RCS leakage. A number of variables, such as initial RPV level or shutdown heat removal system design, can have a significant impact on heat removal capability challenging the fuel clad barrier. Analysis in the above references indicates that significant core damage may occur within an hour following continued core uncovery; therefore, conservatively, 30 minutes was chosen. Post-TM! 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. The General Emergency is declared on the occurrence of the loss or imminent loss of function of all three barriers. Based on the above discussion, RCS barrier failure resulting in core uncovery for 30 minutes or more may cause fuel clad failure. With the Primary Containment and Secondary 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 General Emergency. Containment Closure is the action taken to secure either Primary Containment or Secondary Containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. Containment Closure should not be confused with refueling containment integrity as defined in Technical Specifications. Site shutdown contingency plans provide for re-establishing Containment Closure following a loss of heat removal or RPV inventory functions. If the closure is re-established prior to exceeding the temperature or level thresholds of the RCS Barrier and Fuel Clad Barrier EALs, escalation to General Emergency would not occur. If Containment Closure is re-established prior to exceeding the 30 minute core uncovery time limit, then escalation to GE would not occur. The use of Secondary Containment radiation monitors should provide indication of increased release that may be indicative of a challenge to Secondary Containment. The radiation monitor values are based on the EOP "maximum safe values" because these values are easily recognizable and have an emergency basis. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 93 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 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 Primary Containment. However, Primary 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. CNS Basis: RPV level is normally monitored using the following instruments (Reference 5, 7):

Wide Range NBI-LI-85A, B & C (-155 to 60 inches).

Steam Nozzle Range NBI-LI-92 (0 to 180 inches).

Fuel Zone Range NBI-LI-91A, B & C (-320 to 60 inches).

Narrow Range RFC-LI-94A, B & C (0 to 60 inches).

Shutdown Range NBI-LI-86 (0 to 400 inches). Procedure 2.4RXLVL provides guidance for erratic or unexplained RPV water level changes. EOP/SAG Caution #1 indicates when an instrument may be used for level indication in the EOPs/SAGs. In this EAL, all water level indication is unavailable and the RPV inventory loss must be detected by the leakage indications listed in Table C-1 or erratic Source Range Monitor (SRM) indication:

Level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the drywell to ensure they are indicative of RPV leakage. Drywell equipment and floor drain sump level rise is the normal method of monitoring and calculating leakage from the RPV (Reference 2). A Reactor Building equipment or floor drain sump level rise may also be indicative of RCS inventory losses external to the Primary Containment from systems connected to the RPV. With RHR System operating in the Shutdown Cooling Mode, an unexplained rise in torus water level could be indicative of RHR valve misalignment or leakage (Reference 4). If the make-up rate to the RPV unexplainably rises above the pre-established rate, a loss of RPV inventory may be occurring even if the source of the leakage cannot be immediately identified. Visual observation of leakage from systems connected to the RCS in areas outside the Primary Containment that cannot be isolated could be indicative of a lo.ss of RPV inventory. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 94 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE)

Source Range Monitor (SRM) indication is provided in the Main Control Room by NMS-I-43A-D, SRM A-D LOG COUNT RATE, NM-NR-45, SRM 2 PEN RECORDER, and SPDS (Reference 6). Erratic Source Range Monitor indication specified is caused by increased boiling in the vicinity of the SRMs as water level lowers and exposed fuel heats up. This instability will be greatly magnified when compared with normal source range monitor behavior. Additionally, once the water level falls below the SRM level, lack of thermalized neutron populations in the area will cause the SRMs to read abnormally low. At some plants, containment high range area radiation monitors are specified as an alternate means of detecting loss of water shielding above the core and possible core uncovery. The CNS Primary Containment radiation monitors are designated RA-RM-40A and RA-RM-40B. The Containment High Range Monitoring System monitors gamma radiation levels of 1 R/hr to 107 R/hr in the reactor drywell area. The system consists of two ion chambers in the drywell and two readout modules in Panels 9-2 and 9-10. The detectors (RA-RE-40A and RA-RE-40B) are located 180° from each other in the drywell above elevation 901' 6". The elevation of the bottom of the RPV bottom head is 917'. The elevation of the top of active fuel in the Primary Containment is approximately 947'. The detectors are approximately 45' 6" below the top of active fuel. RCS piping, components, and drywell structural members are positioned between the detectors and the reactor core. Due to the relative location of these detectors, with respect to the top of active fuel, the CNS containment high range radiation monitors cannot be utilized for detection of loss of RPV inventory above the core. Additionally, no other installed Radiation Monitoring System exists that can be utilized for the function. Four conditions are associated with a challenge to Primary Containment (PC) integrity: 1. Containment Closure is the action taken to secure Primary Containment or Secondary Containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. Containment Closure requirements are specified in Administrative Procedure 0.50.5, Outage Shutdown Safety (Reference 1). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 95 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 2. Deflagration (explosive) mixtures in the Primary Containment are assumed to be elevated concentrations of hydrogen and oxygen. BWR industry evaluation of hydrogen generation for development of EOPs/SAMGs indicates that any hydrogen concentration above minimum detectable is not to be expected within the short term. Post-LOCA hydrogen generation primarily caused by radiolysis is a slowly evolving, long-term condition. Hydrogen concentrations that rapidly develop are most likely caused by metal-water reaction. A metal-water reaction is indicative of an accident more severe than accidents considered in the plant design basis and would be indicative, therefore, of a potential threat to Primary Containment integrity. The specified values for this threshold are the minimum global deflagration concentration limits (6°/o hydrogen and 5°/o oxygen) (Reference 8). 3. Any unplanned increase in PC pressure in the Cold Shutdown or Refueling Mode indicates a potential loss of Containment Closure capability. Unplanned Primary Containment pressure increases indicates Containment Closure cannot be assured and the Primary Containment cannot be relied upon as a barrier to fission product release. 4. 1,000 mR/hr is the Secondary Containment Maximum Safe Operating radiation value. Exceeding this value is indicative of problems in the Secondary Containment that are spreading. The locations into which the primary system discharge is of concern correspond to the areas addressed in EOP-5A, Secondary Containment Control, Table 10. As indicated by NOTE 5 in EOP-5A, Table 10, RP Surveys and ARM Teledosimetry System may be used for these indications (Reference 9). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 96 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) EOP-SA Table 10 -Secondary Containment Radiation Levels 10 SECONDARY CONTAINMENT RADIATION LEVELS I";"\. SPDS15 \:::..} Maximum Normal Operating Value Any ARM Alarmed FUEL POOL AREA FUEL POOL AREA RMA-RA-1 RMA-RA-2 RWCU PRECOAT AREA RMA-RA-4 RWCU SLUDGE AND DECANT PUMP AREA RMA-RA-5 CRD HYDRAULIC EQUIP AREA (SOUTH) RMA-RA-8 CRD HYDRAULIC EQUIP AREA (NORTH) RMA-RA-9 HPCI PUMP ROOM RHR PUMP ROOM, (SOUTHWEST) TORUS HPV AREA (SOUTHWEST) RHR PUMP ROOM, (NORTHWEST) RCIC/CORE SPRAY PUMP ROOM, (NORTHEAST) RMA-RA-10 RMA-RA-27 RMA-RA-12 RMA-RA-13 Range (roRD1rl 100 -106 .01 -100 0.1 -1000 0.1 -1000 .01 -100 .01 -100 .01 -100 .01 -100 1.0 -10000 .01 -100 .01 -100 Maximum Safe Operating Value Area Value (mR/hr) Actual Value 1001'EI. 1001' El. 958'EI. 931' El. 903'EI. HPGIRoom 1000 1000 SW Quad 1000 SW Torus NW Quad 1000 NE Quad 1000 **-*----------_______ ., .. ___ ---.. ***-------*----*-* ...... --.. --CORE SPRAY PUMP ROOM, (SOUTHEAST) RMA-RA-14 .01 -100 SE Quad 1000 EPIP 5.7.1 NOTES Area radiation levels can be monitored by RP surveys or ARM teledosimetry system (continued on next page) REVISION 58 PAGE 97 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. Administrative Procedure 0.50.5, Outage Shutdown Safety. 2. System Operating Procedure 2.2.27, Equipment, Floor, and Chemical Drain System. 3. System Operating Procedure 2.2.60.1, Containment H2/02 Monitoring System. 4. System Operating Procedure 2.2.69, Residual Heat Removal System. 5. Abnormal Procedure 2.4RXLVL, RPV Water Level Control Trouble. 6. Instrument Operating Procedure 4.1.1, Source Range Monitoring System. 7. Instrument Operating Procedure 4.6.1, Reactor Vessel Water Level Indication. 8. AMP-TBDOO, Step PC/H. 9. EOP-5A, Secondary Containment Control, Table 10. EPIP 5.7.1 REVISION 58 PAGE 98 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 3 -RCS Temperature Initiating Condition: Unplanned loss of decay heat removal capability with irradiated fuel in the RPV EAL: CU3.1 Unusual Event Any unplanned event results in RCS temperature > 212°F due to loss of decay heat removal capability Mode Applicability: 4 -Cold Shutdown, 5 -Refueling NEI 99-01 Basis: This EAL is an Unusual Event because it may be 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 RPV inventory. Since the RCS usually remains intact in the Cold Shutdown Mode, a large inventory of water is available to keep the core covered. In Cold Shutdown, the decay heat available to raise RCS temperature during a loss of inventory or heat removal event may be significantly greater than in the Refueling Mode. Entry into Cold Shutdown conditions may be attained within hours of operating at power. Entry into the Refueling Mode procedurally may not occur for many hours after the reactor has been shut down. 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). In addition, the Operators should be able to monitor RCS temperature and RPV level so that escalation to the Alert level via CA2.1 or CA3.1 will occur if required. (continued on next page) EPIP 5. 7.1 REVISION 58 PAGE 99 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) During refueling operations, the level in the RPV will normally be maintained above the vessel flange. Refueling evolutions that decrease water level below the vessel flange are carefully planned and procedurally controlled. Loss of forced decay heat removal at reduced inventory may result in more rapid increases in RCS temperatures depending on the time since shutdown. Normal means of core temperature indication and RPV 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. Escalation to the Alert level via CA3.1 may therefore be required should an unplanned event result in RCS temperature exceeding the Technical Specification Cold Shutdown temperature limit for an extended period of time. The allowed time varies and is dependent on the status of the Primary Containment and Secondary Containment barriers and the integrity of the RCS barrier. The Emergency Director must remain attentive to events or conditions that lead to the conclusion that exceeding the EAL threshold 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. CNS Basis: Several instruments are capable of providing indication of RPV temperature with respect to the Technical Specification cold shutdown temperature limit (2t2°F) (Reference 4). These include (Reference 1, 2):

NBI-TR-89, REACTOR VESSEL METAL TEMPERATURE RECORDER (Panel 9-21).

Vessel Drain, PMIS Point M180, or NBI-TR-89 -Point 06 if M180 is not available.

Vessel Bottom Head, PMIS Point M184, or NBI-TR-89 -Point 10 if M184 is not available.

Bottom Head Adjacent to Support Skirt, PMIS Point M183, or NBI-TR-89 -Point 09.

RR-TR-165, RR SUCTION & FEEDWATER TEMP (Panel 9-4). PMIS Points M174 through M185 can be used to monitor RPV temperatures. Thermocouples associated with computer Points M180, M183, and M185 do not respond as quickly nor register as high a temperature as other thermocouples due to their locations. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 100 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Inservice leak testing, hydrostatic testing, and control rod scram time testing in which RCS temperature is intentionally raised above 212°F per Technical Specification LCO 3.10.1 are not applicable to this EAL (Reference 3). CNS Basis Reference(s): 1. General Operating Procedure 2.1.1, Startup Procedure. 2. System Operating Procedure 2.2.69.2, RHR System Shutdown Operations. 3. Technical Specifications LCO 3.10.1. 4. Technical Specifications Table 1.1-1. EPIP 5.7.1 REVISION 58 PAGE 101 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 3 -RCS Temperature Initiating Condition: Unplanned loss of decay heat removal capability with irradiated fuel in the RPV EAL: CU3.2 Unusual Event Loss of all RCS temperature and RPV level indication 15 min. (NOTE 3) iN-ciiE-a:-=rti-e-Emer9encv--6ii-ectai--5tiau1d--no1:--waii-Lint:i1 ______ T ! elapsed, but should declare the event as soon as it is determined that the ! l concjition will likely exceed the applicable time. ! ---------------------------------------.--'"'--.-----------------.. -.. ---------.... ----....... -........ --*-.. --*--------------------Mode Applicability: 4 -Cold Shutdown, 5 -Refueling NEI 99-01 Basis: This EAL is included as an Unusual Event because it may be 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 RPV inventory. Since the RCS usually remains intact in the Cold Shutdown Mode, a large inventory of water is available to keep the core covered. In Cold Shutdown, the decay heat available to raise RCS temperature during a loss of inventory or heat removal event may be significantly greater than in the Refueling Mode. Entry into Cold Shutdown conditions may be attained within hours of operating at power. Entry into the Refueling Mode procedurally may not occur for many hours after the reactor has been shut down. 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 outage. In addition, the Operators should be able to monitor RCS temperature and RPV level so that escalation to the Alert level via CA2.1 or CA3.1 will occur if required. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 102 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) During refueling operations, the level in the RPV will normally be maintained above the vessel flange. Refueling operations that lower water level below the vessel flange are carefully planned and procedurally controlled. Loss of forced decay heat removal at reduced inventory may result in more rapid increases in RCS temperatures depending on the time since shutdown. Escalation to the Alert level via CA3.1 may therefore be required should an unplanned event result in RCS temperature exceeding the Technical Specification Cold Shutdown temperature limit for an extended period of time. The allowed time varies and is dependent on the status of the Primary Containment and Secondary Containment barriers and the integrity of the RCS barrier. Unlike the Cold Shutdown Mode, 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 or Refueling Modes, this EAL would result in declaration of an Unusual Event if either temperature or level indication cannot be restored within 15 minutes from the loss of both means of indication. Escalation to Alert would be under CA2.1 based on an inventory loss or CA3.1 based on exceeding its temperature criteria (212°F, Reference 3). The Emergency Director must remain attentive to events or conditions that lead to the conclusion that exceeding the EAL threshold 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. CNS Basis: RPV level is normally monitored using the following instruments (Reference 3, 4):

Wide Range NBI-LI-85A, B & C (-155 to 60 inches).

Steam Nozzle Range NBI-LI-92 (0 to 180 inches).

Fuel Zone Range NBI-LI-91A, B & C (-320 to 60 inches).

Narrow Range RFC-LI-94A, B & C (0 to 60 inches).

Shutdown Range NBI-Ll-86 (0 to 400 inches). RPV level monitoring also includes the ability to monitor level visually in Refueling Mode consistent with escalation EAL CA2.1. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 103 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Procedure 2.4RXLVL provides guidance for erratic or unexplained RPV water level changes. EOP/SAG Caution #1 indicates when an instrument may be used for level indication in the EOPs/SAGs. Several instruments are capable of providing indication of RPV temperature with respect to the Technical Specification cold shutdown temperature limit (212°F). These include (Reference 1, 2):

NBI-TR-89, REACTOR VESSEL METAL TEMPERATURE RECORDER (Panel 9-21).

Vessel Drain, PMIS Point M180, or NBI-TR-89 -Point 06 if M180 is not available.

Vessel Bottom Head, PMIS Point M184, or NBI-TR-89 -Point 10 if M184 is not available.

Bottom Head Adjacent to Support Skirt, PMIS Point M183, or NBI-TR-89 -Point 09.

RR-TR-165, RR SUCTION & FEEDWATER TEMP (Panel 9-4). PMIS Points M174 through M185 can be used to monitor RPV temperatures. Thermocouples associated with computer Points M180, M1831 and M185 do not respond as quickly nor register as high a temperature as other thermocouples due to their locations. CNS Basis Reference(s): 1. General Operating Procedure 2.1.1, Startup Procedure. 2. System Operating Procedure 2.2.69.2, RHR System Shutdown Operations. 3. Abnormal Procedure 2.4RXLVL, RPV Water Level Control Trouble. 4. Instrument Operating Procedure 4.6.1, Reactor Vessel Water Level Indication. EPIP 5.7.1 REVISION 58 PAGE 104 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 3 -RCS Temperature Initiating Condition: Inability to maintain plant in cold shutdown EAL: -CA3.1 Alert Any unplanned event results in EITHER: RCS temperature> 212°F for> Table C-3 duration (NOTE 4) OR RPV pressure increase > 10 psig due to a loss of RCS cooling --------------------------------------------------------------------------------------------------------": ----------------------------1 NOTE 4 -Containment Closure is the action taken -t:o secure Primary or Secondary Containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. Containment Closure requirements are specified in Administrative Procedure 0.50.5, Outage Shutdown Safety. __ EPIP 5.7.1 Table RCS Reheat Duration Thresholds " If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable I 1. RCS intact (Containment Closure N/A) \ 60 min.* ------------------------------------------------------!-----------------2. Containment Closure established AND RCS not intact j I I 20 min.* I ' ----------------------------------------------------------------------- -----------------------3. Containment Closure not established I AND O min. RCS not intact I ! (continued on next page) REVISION 58 PAGE 105 OF 334 ATTACHMENT 2 Mode Applicability: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 4 -Cold Shutdown, 5 -Refueling NEI 99-01 Basis: The first condition of this EAL addresses events in which RCS temperature exceeds the CU3.1 EAL threshold of 212°F (Reference 6) for the durations identified in Table C-3. Table C-3, Duration #3, addresses complete loss of functions required for core cooling during Refueling and Cold Shutdown Modes when neither Containment Closure nor RCS integrity are established. RCS integrity is in place when the RCS pressure boundary is in its normal condition for the Cold Shutdown Mode of operation. No delay time is allowed for Duration #3 because the evaporated reactor coolant that may be released into the containment during this heatup condition could also be directly released to the environment. Table C-3, Duration #2, addresses the complete loss of functions required for core cooling for > 20 minutes during Refueling and Cold Shutdown Modes when Containment Closure is established but RCS integrity is not established. 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. The allowed 20 minute time frame was included to allow Operator action to restore the heat removal function, if possible. The allowed time frame is consistent with the guidance provided by Generic Letter 88-17, Loss of Decay Heat Removal, and is believed to be conservative given that a low pressure containment barrier to fission product release is established. The table note indicates that this duration is not applicable if actions are successful in restoring a RCS Heat Removal System to operation and RCS temperature is being reduced within the 20 minute time frame. Table C-3, Duration #1, addresses complete loss of functions required for core cooling for > 60 minutes during Refueling and Cold Shutdown Modes when RCS integrity is established. As in Durations #2 and #3, 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. The status of Containment Closure in this EAL is immaterial given that the RCS is providing a high pressure barrier to fission product release to the environment. The 60 minute time frame should allow sufficient time to restore cooling without there being a substantial degradation in plant safety. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 106 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The 10 psig pressure increase covers situations where, due to high decay heat loads, the time provided to restore temperature control should be < 60 minutes. The table note indicates that Duration #1 is not applicable if actions are successful in restoring a RCS Heat Removal System to operation and RCS temperature is being reduced within the 60 minute time frame assuming that the RCS pressure increase has remained < 10 psig. Escalation to Site Area would be via CS2.1 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 212°F when the heat removal function is available and either the RCS is intact or Containment Closure is established. The Emergency Director must remain alert to events or conditions that lead to the conclusion that exceeding the EAL threshold 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. CNS Basis: A 10 psig RPV pressure increase can be read on (Reference 3, 4):

RFC-PI-90A (Panel 9-5, 0 -1200 psig).

RFC-PI-908 (Panel 9-5, 0 -1200 psig).

RFC-PI-90C (Panel 9-5, 0 -1200 psig).

Reactor pressure on PMIS Point 8025. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 107 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Several instruments are capable of providing indication of RPV temperature with respect to the Technical Specification cold shutdown temperature limit (212°F). These include (Reference 1, 2):

NBI-TR-89, REACTOR VESSEL METAL TEMPERATURE RECORDER (Panel 9-21).

Vessel Drain, PMIS Point M180, or NBI-TR-89 -Point 06 if M180 is not available.

Vessel Bottom Head, PMIS Point M184, or NBI-TR-89 -Point 10 if M184 is not available.

Bottom Head Adjacent to Support Skirt, PMIS Point M183, or NBI-TR-89 -Point 09.

RR-TR-165, RR SUCTION & FEEDWATER TEMP (Panel 9-4). PMIS Points M174 through M185 can be used to monitor RPV temperatures. Thermocouples associated with computer Points M180, M183, and Ml85 do not respond as quickly nor register as high a temperature as other thermocouples due to their locations. Inservice leak testing, hydrostatic testing, and control rod scram time testing in which RCS temperature is intentionally raised above 212°F per Technical Specification LCO 3.10.1 are not applicable to this EAL (Reference 5). CNS Basis Reference(s): 1. General Operating Procedure 2.1.1, Startup Procedure. 2. System Operating Procedure 2.2.69.2, RHR System Shutdown Operations. 3. Instrument Operating Procedure 4.6.2, Reactor Vessel Pressure Indication. 4. Emergency Procedure 5.9SAMG, Severe Accident Management Guidance, Technical Support Guidelines attachment (CPA TSG). 5. Technical Specifications LCO 3.10.1. 6. Technical Specifications Table 1.1-1. EPIP 5.7.1 REVISION 58 PAGE 108 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 4 -Communications Initiating Condition: Loss of all on-site or off-site communications capabilities EAL: CU4.1 Unusual Event Loss of an Table C-2 on-site (internal) communication methods affecting the ability to perform routine operations OR Loss of all Table C-2 off-site (external) communication methods affecting the ability to perform off-site notifications Table C-2 Communications Systems System I Onsite j Offsite I (internal) 1(external) Station Intercom System "Gaitronics" Site UHF Radio Consoles I x I II x i l Radio Paging System I f x I Alternate Intercom Sound Power System 1 CNS On-Site Cell Phone System ! I Telephone system (PBX) ; Federal Telecommunications System (FTS 2001) 1 .. Local Telephones (C.O. Lines) CNS State Notification Telephones Satellite Telephones x i x x x Mode Applicability: 4 -Cold Shutdown, 5 -Refueling, D -Defueled (continued on next page) EPIP 5.7.1 REVISION 58 x x x x x x PAGE 109 OF 334 ATTACHMENT 2 NEI 99-01 Basis: ----------------EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The purpose of this EAL 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 problems with off-site authorities. The loss of off-site communications ability is expected to be significantly more comprehensive than the condition addressed by lOCFRSO. 72. The availability of one method of ordinary off-site communications is sufficient to inform state and local authorities of plant problems. This EAL is intended to be used only when extraordinary means (e.g., relaying of information from radio transmissions, individuals being sent to off-site locations, etc.) are being utilized to make communications possible. The Table C-2 list for on-site communications loss encompasses the loss of all means of routine communications (e.g., commercial telephones, sound powered phone systems, page party system, and radios/walkie talkies). The Table C-2 list for off-site communications loss encompasses the loss of all means of communications with federal off-site authorities. This should include the ENS, commercial telephone lines, telecopy transmissions, and dedicated phone systems. CNS Basis: -.----------.-.--.--.--------.... --------------:-----------------------------------........... ------------... --------------------NOTE -EPIP 5. ?COMMUN has more detail on each of the communications systems _____________________________________________________________________________________________________ _ On-site/off-site communications include one or more of the systems listed in Table C-2 (Reference 1).

Station Intercom System "Gaitronics": Permits communication between the different parts of the plant and it also incorporates a public address system for plant wide announcements.

Site UHF Radio Consoles: The site UHF radio system uses four repeaters; Base 1 and Base 2 are used by Operations, Base 3 and Base 4 are used by Security. These repeaters operate on different frequencies. All remote control, portable, and mobile units are capable of selecting either repeater. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 110 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE)

Radio Paging System: CNS leases pagers and radio paging services from a telecommunications company. Pagers are issued to various Management and Emergency Response personnel at CNS and other NPPD locations. Pagers can be activated from any touch-tone phone, on-site or off-site.

Alternate Intercom: Provides an alternate in-plant communications network utilizing the back-up tone commander PBX System. This system is located in the ERP shack and has battery back-up.

Sound Powered System.

CNS On-Site Cell Phone System.

Telephone System (PBX): Provides voice communication between virtually all buildings, offices, and operation facilities within the station. The telephone system also provides communications between the plant and off-site facilities via the telephone switchboard network. The system allows Operating Crews to alert plant personnel in emergencies. The telephone company provides the normal and leased line services.

Federal Telecommunications System (FTS 2001): The Health Physics Network (HPN) and Emergency Notification System (ENS) provides communications between NRC and CNS during an emergency.

Local Telephones (C.O. Lines).

CNS State Notification Telephones: The CNS State Notification Telephone System is the primary means for the plant to make emergency notifications to state and local authorities. This system provides direct communication with the Nebraska State Patrol, the Missouri State Patrol, the Atchison County Sheriff's Department, and the Nemaha and Richardson County Sheriff's Departments.

Satellite Telephones. This EAL is the cold condition equivalent of the hot condition EAL SUS.1. CNS Basis Reference(s): 1. EPIP 5.7COMMUN, Communications, Emergency Response Facility Communication Equipment attachment. EPIP 5. 7.1 REVISION 58 PAGE 111OF334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 5 -Inadvertent Criticality Initiating Condition: Inadvertent criticality EAL: CUS.1 Unusual Event An unplanned sustained positive period observed on nuclear instrumentation Mode Applicability: 4 -Cold Shutdown, 5 -Refueling NEI 99-01 Basis: This EAL addresses criticality events that occur in Cold Shutdown or Refueling Modes (NUREG 1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States) such as fuel mis-loading events. This EAL indicates a potential degradation of the level of safety of the plant, warranting an Unusual Event classification. This EAL excludes inadvertent criticalities that occur during planned reactivity changes associated with reactor startups (e.g., criticality earlier than estimated) which are addressed in the companion EAL SU2.1. 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 increase in neutron population due to subcritical multiplication. Escalation to higher classification levels would be by the judgment EALs in Category H (EAL HA6.1, HS6.1, or HG6.1). CNS Basis: SRM A-D period Meters NMS-I-44A-D on Panel 9-5 identify this condition as well as Panel 9-5 amber light and SRM Period ( < 50 sec.) Annunciator 9 1/F-8 (Reference 1, 2). However, a SRM period alarm caused by SRM channel noise does not result in entry into this EAL (Reference 1). (continued on next page) EPIPS.7.1 REVISION 58 PAGE 112 OF 334 ------------------------------

ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference{s): 1. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1, F-8, SRM Period. 2. Instrument Operating Procedure 4.1.1, Source Range Monitoring System. EPIP 5.7.1 REVISION 58 PAGE 113 OF 334

ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: C -Cold Shutdown/Refueling System Malfunction Subcategory: 6 -Loss of DC Power Initiating Condition: Loss of required DC power for 15 minutes or longer EAL: CU6.1 Unusual Event < 105 VDC bus voltage indications on all Technical Specification required 125 VDC buses 15 min. (NOTE 3) _____ _ l elapsed, but should declare the event as soon as it is determined that the ! ! _ J y_ _ _ J? J?! ! : _________________________________________________________ _ Mode Applicability: 4 -Cold Shutdown, 5 -Refueling NEI 99-01 Basis: The purpose of this 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. This EAL is intended to be anticipatory in as much as the Operating Crew may not have necessary indication and control of equipment needed to respond to the loss. The plant will routinely perform maintenance on a train related basis during shutdown periods. The required buses are the minimum allowed by Technical Specifications for the mode of operation. 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 CA3.1. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 114 OF 334 ATIACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 105 VDC is the minimum design bus voltage (Reference 4). The 125 VDC System supplies DC power to conventional station emergency equipment and selected Safeguard System loads. 125 VDC Distribution Panels supply control and instrument power for annunciators control logic power and protective relaying. Figure C-2 illustrates the 125 VDC Power System (Reference 3). If 125 VDC Distribution Panel A is lost, the following major equipment is affected: RRMG A speed and breaker control, 4160V Bus lA, lE, and lF breaker control and undervoltage logics, 480V Bus lA and lF breaker control, the right light in all Control Room annunciators, annunciator panels for Water Treatment, RHR A Gland Water, Auxiliary Steam Boiler C, DG-1 starting and breaker control logics, CS A, RCIC, and RHR A control logics, TIP valve control monitors, main generator voltage regulation, RFPT A trip logic, and ARI solenoid valve power. If 125 VDC Distribution Panel B is lost, the following major equipment is affected: RRMG B speed and breaker control, 4160V Bus lB and lG breaker control and undervoltage logics, 480V Bus lB and lG breaker control, the left light in all Control Room annunciators, annunciator panels for ALRW, RHR B Gland Water, Auxiliary Steam Boiler D, DG-2 starting and breaker control logics, CS B, HPCI, and RHR B control logics, main generator trip logic, main generator and transformer protective relaying, bypass valves fail to control pressure after turbine trip, and RFPT B trip logic. Battery chargers receive their power from 460V critical motor control centers. Each 125 VDC bus receives power from either a 125 VDC battery or a 125 VDC battery charger. The battery chargers receive their power from 460V critical motor control centers. The 250 VDC System supplies DC power to conventional station emergency equipment and selected Safeguard System loads. Although 250 VDC Buses lA and lB provide vital DC emergency power, 250 VDC Safety System loads (such as motor operated valves) also require 125 VDC control power. Loss of 125 VDC buses alone, therefore, would render most Safeguard System loads inoperable (Reference 4, 5, 6). This EAL is the cold condition equivalent of the hot condition loss of DC power EAL 557.1. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 115 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference{s): 1. Emergency Procedure 5.3DC125, Loss of 125 VDC. 2. Surveillance Procedure 6.EE.607, 125V Station Battery Modified Performance Discharge Test. 3. BR 3058 DC One Line Diagram. 4. Technical Specifications B 3.8.4. 5. USAR Section Vlll-6.2. 6. USAR Section VIII-6.3. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 116 OF 334 ATIACHMENT 2 MC:c.LX [1B) EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Figure C-2: 125 VDC Power System MCC-LX MCC:-Tl< I LX TX I I I I I I I I MCC-TX I GND I L DET I LIGHTS: I (1Ell6 1----------, {I --------------, I A B I I I I I I l N e RCIG E Rx BLDG N !j OE DIST.PANELA HPCI EPIP 5.7.1 REVISION 58 126V DC SR "B-i, HPCI PANEL M0-16 PAGE 117 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 1 -Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the Protected Area EAL: HU1.1 Unusual Event Seismic event identified by any two of the following:

The Seismic Monitor System free field sensor actuated or Alarm B-3/B-1, SEISMIC EVENT

Earthquake felt in plant

National Earthquake Information Center Mode Applicability: All NEI 99-01 Basis: This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant Operators. 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 National Earthquake Information Center can confirm if an earthquake has occurred in the area of the plant. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 118 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis: The method of detection with respect to emergency classification relies on the agreement of the Shift Operators on-duty in the Control Room that the suspected ground motion is a 11felt earthquake" as well as the actuation of the CNS seismic instrumentation. Consensus of the Control Room Operators with respect to ground motion helps avoid unnecessary classification if the seismic switches inadvertently trip or detect vibrations not related to an earthquake. CNS seismic instrumentation actuates at 0.01 g. The free field seismic sensor, located in the metal enclosure north of the Intake Structure, provides a start signal to the Seismic Monitoring System when ground motion > 0.01 g is sensed. On receipt of this start signal, the Seismic Monitor System indicates or initiates:

An Event is in-progress.

An Event has been recorded.

Annunciator B-3/B-1, SEISMIC EVENT, alarms.

Recording of the seismic signals from sensors located north of the Intake Structure, in the Reactor Building NW Quad 859', and on the Reactor Building 1001' level. The National Earthquake Information Center can confirm if an earthquake has occurred in the area of the plant. Refer to the National Earthquake Information Center website: http ://earthquake.usgs.gov/eqcenter/ This event escalates to an Alert under EAL HA1.1 if the earthquake exceeds Operating Basis Earthquake (QBE) levels. In the absence of operable seismic switches, the Earthquake Magnitude Correlation below may be used to perform an assessment of the relative magnitude of an earthquake. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 119 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Modified Merical Ii Maximum Intensity Acceleration Scale Description of Effects* (g) I. Not felt except by a very few under especially favorable conditions. 0.001 to Felt only by a few persons at rest, especially on upper floors 0.002 II. of buildings. Felt quite noticeably by persons indoors, especially on upper floors of buildings. Many people do not recognize it as an III. earthquake. Standing motor cars may rock slightly. 0.003 to Vibrations similar to the passing of a truck. Duration 0.010 estimated. Felt indoors by many, outdoors by few during the day. At IV. night, some awakened. Dishes, windows, doors disturbed; walls make cracking sound. Sensation like heavy truck striking building. Standing motor cars rocked noticeably. 0.011 to Felt by nearly everyone; many awakened. Some dishes, 0.029 V. windows broken. Unstable objects overturned. Pendulum clocks may stop. VI. Felt by all, many frightened. Some heavy furniture moved; a 0.03 to 0.2 few instances of fallen plaster. Damage slight. (CNS Design Damage negligible in buildings of good design and Basis VII. construction; slight to moderate in well-built ordinary OBE = 0.1; structures; considerable damage in poorly built or badly CNS Design designed structures; some chimneys broken. Basis SSE= 0.2) Damage slight in specially designed structures; considerable damage in ordinary substantial buildings with partial collapse. VIII. Damage great in poorly built structures. Fall of chimneys, factory stacks, columns, monuments, walls. Heavy furniture 0.2 to 0.4 overturned. Damage considerable in specially designed structures; IX. well-designed frame structures thrown out of plumb. Damage great in substantial buildings, with partial collapse. Buildings shifted off foundations. 0.4 to 0.5 Some well-built wooden structures destroyed; most masonry x. and frame structures destroyed with foundations. Rails bent. XI. Few, if any (masonry), structures remain standing. Bridges destroyed. Rails bent greatly. > 0.5 XII. Damage total. Lines of sight and level are distorted. Objects thrown into the air. Richter Magnitude (Descriptor) 1.0 to 2.9 (Very Minor) 3.0 to 3.9 (Minor) 4.0 to 4.9 (Light) 5.0 to 5.9 (Moderate) 6.0 to 6.9 (Strong) 7.0 to 7.9 (Major) 8.0 and higher (Great) *The Richter magnitude and maximum acceleration (g) in the table above is provided for general comparison and description. Actual seismic intensity and effects will vary. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 120 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. Alarm Procedure 2.3_B-3, Panel B -Annunciator B-3/B-1. 2. Alarm Procedure 2.3_B-3, Panel B -Annunciator B-3/A-1. 3. Instrument Operating Procedure 4.12, Seismic Instrumentation. 4. Emergency Procedure 5. lQuake, Earthquake. 5. USAR Section II-5.2.4 and Table 11 1. EPIP 5.7.1 REVISION 58 PAGE 121 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 1 -Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the Protected Area EAL: HU1.2 Unusual Event Tornado striking within Protected Area boundary OR Sustained high winds;;:: 100 mph Mode AppUcability: All NEI 99-01 Basis: This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant Operators. This EAL is based on a tornado striking (touching down) or high winds 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 HA1.2. CNS Basis: A tornado striking (touching down) within the Protected Area warrants declaration of an Unusual Event regardless of the measured wind speed at the meteorological tower. A tornado is defined as a violently rotating column of air in contact with the ground and extending from the base of a thunderstorm. The design wind pressure for the station and structures is 30 lb/ft2 which is equivalent of sustained winds up to 100 mph (Reference 3). The Protected Area refers to the designated security area around the process buildings. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 122 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Sustained winds are of a prolonged duration and, therefore, do not include gusts. Sustained winds are not intermittent or of a transitory nature. Since the inauguration of the Automatic Surface Observation System (ASOS), the National Weather Service has adopted a 2 minute average standard for its sustained wind definition (Reference 1). CNS Basis Reference(s): 1. National Weather Service webpage "http://www.aoml.noaa.gov/hrd/tcfaq/D4.html". 2. USAR Section 11-3.2.2. EPIP 5.7.1 REVISION 58 PAGE 123 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 1 -Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the Protected Area EAL: HUl.3 Unusual Event Main turbine failure resulting in casing penetration or damage to turbine or generator seals Mode Applicability: All NEI 99-01 Basis: This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant Operators. 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 HU2.1 and HU3.1. This EAL is consistent with the definition of an Unusual Event 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 HAl.3 based on damage done by projectiles generated by the failure or by any radiological releases. These latter events would be classified by the Category A, Abnormal Rad Release/Rad Effluent EALs, or the Category F, Fission Product Barrier EALs. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 124 OF 334 ATIACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The main turbine generator stores large amounts of rotational kinetic energy in its rotor. In the unlikely event of a major mechanical failure, this energy may be transformed into both rotational and translational energy of rotor fragments. These fragments may impact the surrounding stationary parts. If the energy-absorbing capability of these stationary turbine generator parts is insufficient, external missiles will be released. These ejected missiles may impact various plant structures, including those housing safety-related equipment. In the event of missile ejection, the probability of a strike on a plant region is a function of the energy and direction of an ejected missile and of the orientation of the turbine with respect to the plant region. In addition to potential missile generation, the failure of the rotational elements will cause imbalances in these elements that may be of sufficient magnitude to damage turbine and generator seals resulting in the release of large quantities of lube oil and/or hydrogen. CNS Basis Reference(s): None EPIP 5.7.1 REVISION 58 PAGE 125 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 1 -Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the Protected Area EAL: HUl.4 Unusual Event Flooding in any Table H-1 area that has the potential to affect safety-related equipment required by Technical Specifications for the current operating mode Table H-1 Safe Shutdown Areas

Reactor Building

Control Building

Service Water Pump Room

Diesel Generator Building

Cable Expansion Room -------------------..... ---------...... -**-----------------------------*------------------------...... ---____ -NOTE -Examples of safety-related systems or components include: CRD (Control ' Rod Drive), CS (Core Spray), DG (Diesel Generator), and DG Support Systems, EE (Electrical Equipment, 4160 VAC, 480 VAC, 250 VDC, or 125 VDC), HPCI (High Pressure Coolant Injection), PC (Primary Containment), PCIS (Primary Containment Isolation System), REC (Reactor Equipment Cooling), RHR (Residual Heat Removal), RPS (Reactor Protection System), SGT (Standby Gas Treatment), SLC (Standby Liquid Control), SW (Service Water). : Mode Applicability: All (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 126 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) NEI 99-01 Basis: This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant Operators. This EAL addresses the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps. Escalation of this emergency classification level, if appropriate, would be based visible damage via HA1.4 or by other plant conditions. CNS Basis: The internal flooding areas of concern are listed in Table H-1 (Reference 1-5). 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. Flooding in these areas could have the potential to cause a reactor trip and could result in consequential failures to important systems. The potential for flooding in these areas was determined by an examination of piping systems in the area and also considered propagation of water from one area to another. The accumulation of water resulting in a rising water level in the area constitutes flooding. The Critical Switchgear Rooms are a part of the Reactor Building. CNS Basis Reference(s): 1. Site Services Procedure 1.1, Station Security. 2. CNS-FP-60, Fire Area Boundary Drawing Index. 3. Drawing CNS-EE-187, CNS Safe Shutdown Component Locations and Emergency Route Lighting -Site Plan. 4. Fire Safety Analysis Calculations. 5. USAR Section XII-2.1.2.1, Principal Class I Structures Required for Safe Shutdown. EPIP 5.7.1 REVISION 58 PAGE 127 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 1 -Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the Protected Area EAL: HULS Unusual Event High river/forebay water level > 899' MSL OR Low river level/forebay < 870' MSL Mode Applicability: All NEI 99-01 Basis: This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant Operators. This EAL addresses other site specific phenomena (such as flood) that can also be precursors of more serious events. CNS Basis: This EAL covers high river/forebay water level conditions that could be a precursor of more serious events as well as low river/forebay water level conditions which may threaten operability of plant cooling systems. Procedure 5. lFLOOD entry is based on any of the following:

River water level > 895' MSL.

Upstream dam failure.

Projected river water level 902' MSL within next 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 128 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 899' MSL is the level associated with the maximum flood of record (Reference 2). 870' MSL is the Minimum Probable river level (Reference 3). A further level drop may threaten availability of cooling systems and heat sink. The forebay refers to the area between the east Intake Structure wall and the guide wall (Reference 4). CNS Basis Reference(s): 1. Emergency Procedure 5.1FLOOD, Flood. 2. USAR Section II-4.2.2.2. 3. USAR Section II-4.2.3.1. EPIPS.7.1 REVISION 58 PAGE 129 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 1 -Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting Vital Areas EAL: HA1.1 Alert Seismic event > 0.1 g as indicated by the Seismic Monitor System free field sensor or Alarm B-3/A-1, EMERGENCY SEISMIC HIGH LEVEL AND Earthquake confirmed by any of the following:

Earthquake felt in plant

National Earthquake Information Center

Control Room indication of degraded performance of systems required for the safe shutdown of the plant Mode Applicability: All NEI 99-01 Basis: This EAL escalates from HU1.1 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 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 this EAL 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 this degradation. Escalation to higher classifications occur on the basis of other EALs (e.g., System Malfunction). 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. (continued on next page) EPIP5.7.1 REVISION 58 PAGE 130 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The National Earthquake Information Center can confirm if an earthquake has occurred in the area of the plant. CNS Basis: CNS seismic instrumentation actuates at 0.01 g. The free field seismic sensor, located in the metal enclosure north of the Intake Structure, provides a start signal to the Seismic Monitoring System when ground motion > 0.01 g is sensed. On receipt of this start signal, the Seismic Monitor System indicates or initiates:

An Event is in-progress.

An Event has been recorded.

Annunciator B-3/B-1, SEISMIC EVENT, alarms.

Recording of the seismic signals from sensors north of the Intake Structure, in the Reactor Building NW Quad 859', and on the Reactor Building 1001' level are recorded.

Alarm B-3/A-1, EMERGENCY SEISMIC HIGH LEVEL, is received if the seismic activity exceeds 0.1 g. The National Earthquake Information Center can confirm if an earthquake has occurred in the area of the plant. Refer to the National Earthquake Information Center website: http: //ea rthq ua ke. usgs.gov I eqcenter/ In the absence of operable seismic switches, the Earthquake Magnitude Correlation below may be used to perform an assessment of the relative magnitude of an earthquake. An earthquake in excess of the CNS Operating Basis Earthquake (OBE) levels should be classified under this EAL. (continued on next page) EPIP5.7.1 REVISION 58 PAGE 131 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Modified Merica Iii Maximum Intensity Acceleration Scale Description of Effects* (g) I. Not felt except by a very few under especially favorable conditions. 0.001 to Felt only by a few persons at rest, especially on upper floors 0.002 II. of buildings. Felt quite noticeably by persons indoors, especially on upper floors of buildings. Many people do not recognize it as an III. earthquake. Standing motor cars may rock slightly. 0.003 to Vibrations similar to the passing of a truck. Duration 0.010 estimated. Felt indoors by many, outdoors by few during the day. At IV. night, some awakened. Dishes, windows, doors disturbed; walls make cracking sound. Sensation like heavy truck striking building. Standing motor cars rocked noticeably. 0.011 to Felt by nearly everyone; many awakened. Some dishes, 0.029 v. windows broken. Unstable objects overturned. Pendulum clocks may stop. VI. Felt by all, many frightened. Some heavy furniture moved; a 0.03 to 0.2 few instances of fallen plaster. Damage slight. (CNS Design Damage negligible in buildings of good design and Basis VII. construction; slight to moderate in well-built ordinary OBE::::; 0.1; structures; considerable damage in poorly built or badly CNS Design designed structures; some chimneys broken. Basis SSE::::; 0.2) Damage slight in specially designed structures; considerable damage in ordinary substantial buildings with partial collapse. VIII. Damage great in poorly built structures. Fall of chimneys, factory stacks, columns, monuments, walls. Heavy furniture 0.2 to 0.4 overturned. Damage considerable in specially designed structures; IX. well-designed frame structures thrown out of plumb. Damage great in substantial buildings, with partial collapse. Buildings shifted off foundations. 0.4 to 0.5 Some well-built wooden structures destroyed; most masonry x. and frame structures destroyed with foundations. Rails bent. XI. Few, if any (masonry), structures remain standing. Bridges destroyed. Rails bent greatly. > 0.5 XII. Damage total. Lines of sight and level are distorted. Objects thrown into the air. Richter Magnitude (Descriptor) 1.0 to 2.9 (Very Minor) 3.0 to 3.9 (Minor) 4.0 to 4.9 (Light) 5.0 to 5.9 (Moderate) 6.0 to 6.9 (Strong) 7.0 to 7.9 (Major) 8.0 and higher {Great) *The Richter magnitude and maximum acceleration (g) in the table above is provided for general comparison and description. Actual seismic intensity and effects will vary. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 132 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. Alarm Procedure 2.3_B-3, Panel B -Annunciator B-3/A-1. 2. Alarm Procedure 2.3_B-3, Panel B -Annunciator B-3/B-1. 3. Instrument Operating Procedure 4.12, Seismic Instrumentation. 4. Emergency Procedure 5.1Quake, Earthquake. 5. USAR Section II-5.2.4 and Table 11 1. EPIP 5.7.1 REVISION 58 PAGE 133 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 1 -Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting Vital Areas EAL: HA1.2 Alert Tornado striking or high winds 100 mph resulting in EITHER: Visible damage to any Table H-1 area structure containing safety systems or components OR Control Room indication of degraded performance of safety systems Table H-1 Safe Shutdown Areas

Reactor Building

Control Building

Service Water Pump Room

Diesel Generator Building

Cable Expansion Room __ ERo_c_C:c;r1fr-a1--i i Rod Drive), CS (Core Spray), DG (Diesel Generator), and DG Support Systems, :* i EE (Electrical Equipment, 4160 VAC, 480 VAC, 250 VDC, or 125 VDC), HPCI (High i Pressure Coolant Injection), PC (Primary Containment), PCIS (Primary ! Containment Isolation System), REC (Reactor Equipment Cooling), RHR (Residual i Heat Removal), RPS (Reactor Protection System), SGT (Standby Gas Treatment), , i __ ! ) f_ _ _ Y'!_9_ 2 __________________________________________________ j Mode Applicability: All (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 134 OF 334 ATTACHMENT 2 NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) This EAL escalates from HUl.2 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 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 this EAL 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 this degradation. Escalation to higher classifications occur on the basis of other EALs (e.g., System Malfunction). This EAL is based on a tornado striking (touching down) or high winds that have caused visible damage to structures containing functions or systems required for safe shutdown of the plant. CNS Basis: This threshold addresses events that may have resulted in Safe Shutdown Areas being subjected to forces (tornado or high winds > 100 mph) (Reference 6) beyond design limits. Table H-1 safe shutdown areas house equipment the operation of which may be needed to ensure the reactor safely reaches and is maintained shutdown (Reference 1-4, 7). A tornado striking (touching down) within the Protected Area resulting in visible damage warrants declaration of an Alert regardless of the measured wind speed at the meteorological tower. A tornado is defined as a violently rotating column of air in contact with the ground and extending from the base of a thunderstorm. The design wind pressure for the station and structures is 30 lb/ft2 which is the equivalent of sustained winds up to 100 mph (Reference 6). The Protected Area refers to the designated security area around the process buildings. The Critical Switchgear Rooms are a part of the Reactor Building. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 135 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s}: 1. Site Services Procedure 1.1, Station Security. 2. CNS-FP-60, Fire Area Boundary Drawing Index. 3. Drawing CNS-EE-187, CNS Safe Shutdown Component Locations and Emergency Route Lighting -Site Plan. 4. Fire Safety Analysis Calculations. 5. USAR Section II-3.2.2. 6. USAR Section XII-2.1.2.1, Principal Class I Structures Required for Safe Shutdown. EPIPS.7.1 REVISION 58 PAGE 136 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 1 -Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting Vital Areas EAL: HAl.3 Alert Main turbine failure-generated projectiles result in EITHER: Visible damage to or penetration of any Table H-1 area structure containing safety systems or components OR Control Room indication of degraded performance of safety systems Table H-1 Safe Shutdown Areas

Reactor Building

Control Building

Service Water Pump Room

Diesel Generator Building

Cable Expansion Room NOTE -Examples of s*afety-related systems or components include: CRD (Control Rod Drive), CS (Core Spray), DG (Diesel Generator), and DG Support Systems, EE (Electrical Equipment, 4160 VAC, 480 VAC, 250 VDC, or 125 VDC), HPCI (High Pressure Coolant Injection), PC (Primary Containment), PCIS (Primary Containment Isolation System), REC (Reactor Equipment Cooling), RHR (Residual Heat Removal), RPS (Reactor Protection System), SGT (Standby Gas Treatment), SLC (Standby Liquid Control), SW (Service Water). ------------------------------------------------------_ .. ---------------...... _ ..... ----------.,. .,. -.,. --------Mode Applicability: All (continued on next page) EPIPS.7.1 REVISION 58 PAGE 137 OF 334 ATIACHMENT 2 NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The EAL escalates from HU1.3 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 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 this EAL 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 this degradation. Escalation to higher classifications occur on the basis of other EALs (e.g., System Malfunction). CNS Basis: The main turbine generator stores large amounts of rotational kinetic energy in its rotor. In the unlikely event of a major mechanical failure, this energy may be transformed into both rotational and translational energy of rotor fragments. These fragments may impact the surrounding stationary parts. If the energy-absorbing capability of these stationary turbine generator parts is insufficient, external missiles will be released. These ejected missiles may impact various plant structures, including those housing safety-related equipment. In the event of missile ejection, the probability of a strike on a plant region is a function of the energy and direction of an ejected missile and of the orientation of the turbine with respect to the plant region. The list of Table H-1 areas includes all areas containing safety-related equipment, their controls, and their power supplies (Reference 1-5). The Critical Switchgear Rooms are a part of the Reactor Building. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 138 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. Site Services Procedure 1.1, Station Security. 2. CNS-FP-60, Fire Area Boundary Drawing Index. 3. Drawing CNS-EE-187, CNS Safe Shutdown Component Locations and Emergency Route Lighting -Site Plan. 4. Fire Safety Analysis Calculations. 5. USAR Section XII-2.1.2.1, Principal Class I Structures Required for Safe Shutdown. EPIPS.7.1 REVISION 58 PAGE 139 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 1 -Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting Vital Areas EAL: HAl.4 Alert Flooding in any Table H-1 area resulting in EITHER: An electrical shock hazard that precludes access to operate or monitor safety equipment OR Control Room indication of degraded performance of safety systems Table H-1 Safe Shutdown Areas

Reactor Building

Control Building

Service Water Pump Room

Diesel Generator Building

Cable Expansion Room ------------------------------------------------------------------------------------------------------------------------------------' NOTE -Examples of safety-related systems or components include: CRD (Control

Rod Drive), CS (Core Spray), DG (Diesel Generator), and DG Support Systems, EE (Electrical Equipment, 4160 VAC, 480 VAC, 250 voe, or 125 VDC), HPCI (High ::* Pressure Coolant Injection), PC (Primary Containment), PCIS (Primary : Containment Isolation System), REC (Reactor Equipment Cooling), RHR (Residual : l Heat Removal), RPS (Reactor Protection System), SGT (Standby Gas Tr-eatment), . SLC (Standby Liquid Control), SW (Service Water). . ------------------------------------------------------------------------------------------------------------------------------------* Mode Applicability: All (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 140 OF 334 ATIACHMENT 2 NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The EAL escalates from HU1.4 in that the occurrence of the event has resulted in an electrical shock hazard precluding access 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 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 this EAL 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 this degradation. Escalation to higher classifications occur on the basis of other EALs (e.g., System Malfunction). 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. 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. CNS Basis: The internal flooding areas of concern are listed in Table H-1(Reference1-5). Flooding in these areas could have the potential to cause a reactor trip and could result in consequential failures to important systems. The potential for flooding in this area was determined by an examination of piping systems in the area and also considered propagation of water from one area to another. The accumulation of water resulting in a rising water level in the area constitutes flooding. The Critical Switchgear Rooms are a part of the Reactor Building. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 141 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. Site Services Procedure 1.1, Station Security. 2. CNS-FP-60, Fire Area Boundary Drawing Index. 3. Drawing CNS-EE-187, CNS Safe Shutdown Component Locations and Emergency Route Lighting -Site Plan. 4. Fire Safety Analysis Calculations. 5. USAR Section XIl-2.1.2.1, Principal Class I Structures Required for Safe Shutdown. EPIP 5.7.1 REVISION 58 PAGE 142 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 1 -Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting Vital Areas EAL: HAl.5 Alert High river/forebay water level > 902' MSL OR Low river/forebay level < 865' MSL Mode Applicability: All NEI 99-01 Basis: Escalation to higher classifications occurs on the basis of other EALs (e.g., System Malfunction). 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 components containing functions and systems required for safe shutdown of the plant (such as flood) that can also be precursors of more serious events. CNS Basis: HULS covers high river/forebay water level conditions that could pose a significant threat to plant safety as well as low river/forebay water level conditions which may threaten operability of vital emergency plant cooling systems. A river level of 902' requires reactor shutdown and represents the maximum possible (10,000 year) flood stage (Reference 3). A river level of 865' MSL corresponds to the Safe Shutdown low river level and threatens availability of cooling systems and heat sink (Reference 1, 4, 5). The forebay refers to the area between the east Intake Structure wall and the guide wall (Reference 2). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 143 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference{s}: 1. Emergency Procedure 5.1FLOOD, Flood. 2. USAR Section II-2.7.2. 3. USAR Section II-4.2.2.1. 4. USAR Section II-4.2.2.2. 5. USAR Section II-4.2.3.2. EPIP 5.7.1 REVISION 58 PAGE 144 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 1 -Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting Vital Areas EAL: HA1.6 Alert Vehicle crash resulting in EITHER: Visible damage to any Table H-1 area structure containing safety systems or components OR Control Room indication of degraded performance of safety systems Table H-1 Safe Shutdown Areas

Reactor Building

Control Building

Service Water Pump Room

Diesel Generator Building

Cable Expansion Room i Rod Drive), CS (Core Spray), DG (Diesel Generator), and DG Support Systems, ! i EE (Electrical Equipment, 4160 VAC, 480 VAC, 250 voe, or 125 VDC), HPCI (High I i Pressure Coolant Injection), PC (Primary Containment), PCIS (Primary ! Containment Isolation System), REC (Reactor Equipment Cooling), RHR (Residual j Heat Removal), RPS (Reactor Protection System), SGT (Standby Gas Treatment), i SLC (Standby Liquid Control), SW (Service Water). l_ ____________ ------.. ------------------------------------------------------------------------------------------------------------------Mode Applicability: All (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 145 OF 334 ATIACHMENT 2 NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) This EAL is based on the occurrence of a vehicle crash that 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 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 this EAL 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 this degradation. Escalation to higher classifications occur on the basis of other EALs (e.g., System Malfunction). This EAL addresses vehicle crashes within the PROTECTED AREA that results in VISIBLE DAMAGE to VITAL AREAS or indication of damage to safety structures, systems, or components containing functions and systems required for safe shutdown of the plant. CNS Basis: Table H-1 Safe Shutdown Areas house equipment the operation of which may be needed to ensure the reactor reaches and is maintained in shutdown (Reference 1-4, 6). The Protected Area refers to the designated security area around the process buildings. If the vehicle crash is determined to be hostile in nature, the event is classified under security based EALs. The Critical Switchgear Rooms are a part of the Reactor Building. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 146 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. Site Services Procedure 1.1, Station Security. 2. CNS-FP-60, Fire Area Boundary Drawing Index. 3. Drawing CNS-EE-187, CNS Safe Shutdown Component Locations and Emergency Route Lighting -Site Plan. 4. Fire Safety Analysis Calculations. 5. USAR Section XII-2.1.2.1, Principal Class I Structures Required for Safe Shutdown. EPIP 5.7.1 REVISION 58 PAGE 147 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 2 -Fire or Explosion Initiating Condition: Fire within the Protected Area not extinguished within EAL: HU2.1 Unusual Event 15 minutes of detection or explosion within the Protected Area Fire in any Table H-i area not extinguished within 15 min. of Control Room notification or receipt of a valid Control Room alarm due to fire (NOTE 3) i--------------*---..;, __ *..:,._-:_:_: __ -_:..,_ ----------*-----.; ---------........ _. __ '-:-.-.--.----------..:-------:-----_ ... *-'.------.--*---: -:------.... --_-_-_-..,..-----* ----------* : NOTE 3 -The Emergency Director should not wait until the applicable time has 1 elapsed, but should declare the event as soon as it is determined that the l condition will likely exceed the applicab_le time. _ ! . *----------------... -------------------.. -------------------------..... *----:-------.... -------.--*----__________ ,_,__-_._. ___________ -------------. -*-------* Table H-1 Safe Shutdown Areas

Reactor Building

Control Building

Service Water Pump Room

Diesel Generator Building

Cable Expansion Room Mode Applicability: All NEI 99-01 Basis: This EAL addresses the magnitude and extent of fires that may be potentially significant precursors of damage to safety systems. It addresses the fire 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. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 148 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 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 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). CNS Basis: Fire, as used in this EAL, means 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. The Critical Switchgear Rooms are a part of the Reactor Building. CNS Basis Reference(s): 1. Site Services Procedure 1.1, Station Security. 2. CNS-FP-60, Fire Area Boundary Drawing Index. 3. Drawing CNS-EE-187, CNS Safe Shutdown Component Locations and Emergency Route Lighting -Site Plan. 4. Fire Safety Analysis Calculations. 5. USAR Section XIl-2.1.2.1, Principal Class I Structures Required for Safe Shutdown. EPIP 5. 7.1 REVISION 58 PAGE 149 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 2 -Fire or Explosion Initiating Condition: Fire within the Protected Area not extinguished within EAL: HU2.2 Unusual Event 15 minutes of detection or explosion within the Protected Area Explosion within the Protected Area Mode Applicability: All NEI 99-01 Basis: This EAL addresses the magnitude and extent of explosions that m(;!y be potentially significant precursors of damage to safety systems. It addresses the 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. This EAL addresses only those explosions of sufficient force capable of causing damage to permanent structures or equipment within the Protected Area. No attempt is made to assess the actual magnitude of any 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 HA2.1. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 150 OF 334 AlTACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The Protected Area refers to the designated Security Area around the process buildings. As used here, an explosion is a rapid, violent, unconfined combustion or a catastrophic failure of pressurized equipment that potentially imparts significant energy to nearby structures and materials. A steam line break or steam explosion that damages surrounding permanent structures or equipment would be classified under this EAL. This does not mean the emergency is classified simply because the steam line break occurred. The method of damage is not as important as the degradation of plant structures or equipment. The need to classify the steam line break itself is considered in fission product barrier degradation monitoring (EAL Category F). If the explosion is determined to be hostile in nature, the event is classified under security based EALs. CNS Basis Reference(s): None EPIP 5.7.1 REVISION 58 PAGE 151 OF 334 ATTACHMENT 2 Category: Subcategory: Initiating Condition: EAL: HA2.1 Alert EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) H -Hazards And Other Conditions Affecting Plant Safety 2 -Fire or Explosion Fire or explosion affecting the operability of plant safety systems required to establish or maintain safe shutdown Fire or explosion resulting in EITHER: Visible dama.ge to any Table H-1 area containing safety systems or components OR Control Room indication of degraded performance of safety systems Table H-1 Safe Shutdown Areas

Reactor Building

Control Building

Service Water Pump Room

Diesel Generator Building

Cable Expansion Room ------------------------------------------------------------------------------------------------------------------------------------* NOTE -Examples of safety-related systems or components include: CRD (Control : Rod Drive), CS (Core Spray), DG (Diesel Generator), and DG Support Systems, EE (Electrical Equipment, 4160 VAC, 480 VAC, 250 VDC, or 125 VDC), HPCI (High Pressure Coolant Injection), PC (Primary Containment), PCIS (Primary Containment Isolation System), REC (Reactor Equipment Cooling), RHR (Residual Heat Removal), RPS (Reactor Protection System), SGT (Standby Gas Treatment), 1:?x _ g_ J. :_ ........... ----... ---. ----. -. ------. --. -----------Mode Applicability: All (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 152 OF 334 ATIACHMENT 2 NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 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 Malfunctions, Fission Product Barrier Degradation, or Abnormal Rad Levels/Radiological Effluent EALs. CNS Basis: Fire, as used in this EAL, means 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. An explosion is a rapid, violent, unconfined combustion or a catastrophic failure of pressurized equipment that potentially imparts significant energy to nearby structures and materials. A steam line break or steam explosion that damages permanent structures or equipment would be classified under this EAL. The method of damage is not as important as the degradation of plant structures or equipment. The need to classify the steam line break itself is considered in fission product barrier degradation monitoring (EAL Category F). The Critical Switchgear Rooms are a part of the Reactor Building. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 153 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference{s): 1. Site Services Procedure 1.1, Station Security. 2. CNS-FP-60, Fire Area Boundary Drawing Index. 3. Drawing CNS-EE-187, CNS Safe Shutdown Component Locations and Emergency Route Lighting -Site Plan. 4. Fire Safety Analysis Calculations. 5. USAR Section XII-2.1.2.1, Principal Class I Structures Required for Safe Shutdown. EPIP 5.7.1 REVISION 58 PAGE 154 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 3 -Hazardous Gas Initiating Condition: Release of toxic, corrosive, asphyxiant, or flammable gases deemed detrimental to normal plant operations EAL: HU3.1 Unusual Event Toxic, corrosive, asphyxiant, or flammable gases in amounts that have or could affect normal plant operations Mode Applicability: All NEI 99-01 Basis: This EAL is based on the release of toxic, corrosive, asphyxiant, or flammable gases of sufficient quantity to affect normal plant operations. The fact that SCBA may be worn does not eliminate the need to declare the event. This EAL 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 be!ow 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 HA3.1. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 155 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis: As used in this EAL, affecting normal plant operations means that activities at the plant site associated with routine testing, maintenance, or equipment operations, in accordance with normal operating or administrative procedures have been impacted. Entry into Abnormal or Emergency Operating Procedures, or deviation from normal security or radiological controls posture is a departure from normal plant operations, and thus, would be considered to have been affected. Administrative Procedure 0.36.6, Monitoring for Industrial Gases, may be used for help in assessing this EAL. Such review, however, does not constitute a departure from normal operations. The release may have originated within the Site Boundary or it may have originated off-site and subsequently drifted onto the Site Boundary. Off-site events (e.g., tanker truck accident releasing toxic gases, etc.) resulting in the plant being within the evacuation area should also be considered in this EAL because of the adverse affect on normal plant operations. At CNS there are various potential sources of atmospheric contamination. Some of these sources are:

Inert gas used for oxygen exclusion (nitrogen).

Combustion products.

Carbon dioxide from fire extinguishing.

Halon from fire extinguishing.

Welding gases (enclosed areas).

Vapors from painting (enclosed areas).

Vapors from petroleum products.

Hydrogen (OWC Hydrogen Gas Generation System, Generator Cooling System, batteries, and disassociation of water in the reactor).

Asphyxiants and irritants, found most often in confined areas (water and oil storage tanks, open manholes).

Methane from bacterial action (tanks and pits). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 156 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Some of the gases which could affect normal plant operations under this EAL are:

Carbon Monoxide -One of the most common asphyxiants encountered in industry. It is formed by the incomplete combustion of fuel containing carbon. It may be found in the vicinity of a fire or a leak in an exhaust system (flue gas or internal combustion engines).

Oxygen -Oxygen has two fundamentally important properties: it supports combustion and it supports life. Since oxygen is necessary for life, it must be present in sufficient quantity. Oxygen deficiency occurs in confined spaces where the level of oxygen has been reduced below the limit to support life. Oxygen content in the air can become fatally low in a brief period of time. Some of the more common causes of this problem are oxidation of metals, bacterial action, combustion, and displacement by other gases. An enriched oxygen atmosphere will accelerate combustion.

Hydrogen -Used in generator cooling. Hydrogen gas is also produced by the OWC Gas Generation System, located in the OWC Building, and subsequently injected into the Condensate System just upstream of the condensate booster pumps. Hydrogen is also produced by the disassociation of water from radiation in the reactor, which is seen in the off-gas. The presence of hydrogen will be especially significant in the Off-Gas and Augmented Off-Gas Systems. Hydrogen is also a by-product of battery charging. It is lighter than air so it will be found in pockets at the ceiling of enclosures.

Argon -Commonly used during the welding of certain metals. It is denser than air so it will settle in pockets below the welding area.

Carbon Dioxide -Used to fight fire. Being heavier than air, carbon dioxide will settle in pockets and displace oxygen.

Halon -Used to fight fire in the Service Water Pump Room, Computer Room, and in the Simulator. Discharge of a Halon System will result in exceeding IDLH limits in the area. Discharge of the Service Water Pump Room or Computer Room Halon System should be classified under EAL HA3.1.

Nitrogen -Used primarily to purge Primary Containment. Since it is approximately the same density as air, it can be dispersed by proper ventilation. Areas of poor ventilation may contain greater than expected concentrations of nitrogen and consequently may be deficient in oxygen.

Combustible Gases and Vapors -Includes naturally occurring gases (such as methane and hydrogen gas) and the vapors of a large group of liquids which are used as fuels and solvents. Monitoring shall be required in fuel tanks and other areas where explosive mixtures may be present. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 157 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE)

Hydrogen Sulfide -Classified as an irritant in low concentrations, but is even more toxic than carbon monoxide because it inflames the mucus membranes and results in the lungs filling with fluid. This colorless gas has a characteristic rotten egg odor, which renders the sense of smell ineffective. Hydrogen sulfide may be found in sewage treatment or wherever organic matter containing sulfur decomposes and shall be monitored constantly during work.

Methane -The chief constituent of natural gas and is extremely explosive. It is non-toxic, but may reduce the oxygen content of an atmosphere, causing asphyxiation. Methane is often found in the vicinity of sanitary landfills and has been detected in tanks where bacterial action is taking place (i.e., reactor water cleanup and condensate phase separator tanks). It is lighter than air and tends to accumulate in high spots or pockets. This can present a dangerous situation in storage tanks or sewers where access is normally gained at the top of the confined area. ** Ethyl Benzene -Used primarily as an additive to diesel fuel. Acute exposure results in a local irritant effect on the skin and mucous membranes. Chronic exposure can lead to nervous system disorders and upper respiratory tract inflammation. Monitoring is required when entering a diesel fuel tank.

Chlorine -Used in chemical treatment of Circulating Water and Service Water Systems. Chlorine gas can be recognized by its pungent, irritating odor, which

is like the odor of bleach. Chlorine is not flammable but can react explosively with other chemicals such as turpentine or ammonia. Chlorine gas stays close to the ground and spreads rapidly. When chlorine gas comes in contact with moist human tissues, such as the eyes throat and lungs, an acid is produced that can damage these tissues.

Chlorine Dioxide -This is a yellow to reddish-yellow manufactured gas which does not occur naturally in the environment. When added to water, chlorine dioxide forms chlorite ion, which is also a very reactive chemical. High levels of chlorine dioxide can be irritating to the nose, eyes, throat, and lungs.

Hydrogen Chloride -This is a colorless to slightly yellowish gas with a pungent odor. On exposure to air, the gas forms dense white vapors due to condensation with atmospheric moisture. The vapor is corrosive and air concentrations above 5 ppm can cause irritation. When mixed with water or atmospheric moisture, a highly corrosive atmosphere is formed. The most common source of Hydrogen Chloride gas is from Muriatic (Hydrochloric) Acid. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 158 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Should the release affect access to plant Safe Shutdown Areas, escalation to an Alert would be based on EAL HA3.1. Should an explosion or fire occur due to flammable gas within an affected plant area, an Alert may be appropriate based on EAL HA2.1. CNS Basis Reference(s): 1. Administrative Procedure 0.36.6, Monitoring for Industrial Gases. EPIP5.7.1 REVISION 58 PAGE 159 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 3 -Toxic, Corrosive, Asphyxiant, And Flammable Gas Initiating Condition: Release of toxic, corrosive, asphyxiant, or flammable gases deemed detrimental to normal plant operations EAL: HU3.2 Unusual Event Recommendation by local, county, or state officials to evacuate or shelter site personnel based on an off-site event Mode ApplicabiHty: All NEI 99-01 Basis: This EAL is based on the release of toxic, corrosive, asphyxiant, or flammable gases of sufficient quantity to affect normal plant operations. The fact that SCBA may be worn does not eliminate the need to declare the event. This EAL 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 HA3.1. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 160 OF 334 AITACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) This EAL is based on the existence of an uncontrolled release originating off-site and local, county, or state officials have reported the need for evacuation or sheltering of site personnel. Off-site events (e.g., tanker truck accident releasing toxic gases, etc.) are considered in this EAL because they may adversely affect normal plant operations. State officials may determine the evacuation area for off-site spills by using the Department of Transportation (DOT) Evacuation Tables for Selected Hazardous Materials in the DOT Emergency Response Guide for Hazardous Materials. If the evacuation area extends to any portion of the Owner Controlled Area, the EAL threshold is met. Should the release affect plant Safe Shutdown Areas, escalation to an Alert would be based on EAL HA3.1. Should an explosion or fire occur due to flammable gas within an affected plant area, an Alert may be appropriate based on EAL HA2.1. CNS Basis Reference(s): 1. Administrative Procedure 0.36.6, Monitoring for Industrial Gases. EPIP 5.7.1 REVISION 58 PAGE 161 OF 334 ATTACHMENT 2 Category: Subcategory: Initiating Condition: EAL: HA3.1 Alert EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) H -Hazards And Other Conditions Affecting Plant Safety 3 -Toxic, Corrosive, Asphyxiant, And Flammable Gas Access to a Vital Area is prohibited due to release of toxic, corrosive, asphyxiant, or flammable gases which jeopardizes operation of operable equipment required to maintain safe operations or safely shutdown the reactor Access to any Table H-1 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 (NOTE 7) NOTE 7 -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. Table H-1 Safe Shutdown Areas

Reactor Building

Control Building

Service Water Pump Room

Diesel Generator Building

Cable Expansion Room NOTE -Examples of safety-related systems or components include: CRD (Control Rod Drive), CS (Core Spray), DG (Diesel Generator), and DG Support Systems, EE (Electrical Equipment, 4160 VAC, 480 VAC, 250 VDC, or 125 VDC), HPCI (High Pressure Coolant Injection), PC (Primary Containment), PCIS (Primary Containment Isolation System), REC (Reactor Equipment Cooling), RHR (Residual Heat Removal), RPS (Reactor Protection System), SGT (Standby Gas Treatment), __ ( _ !) ! __ ?_'!!_ _ yy_ __________________________________________________ _ (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 162 OF 334 ATTACHMENT 2 Mode Applicability: All NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Gases in a Safe Shutdown Area can affect the ability to *safely operate or safely shutdown the reactor. The fact that SCBA may be worn does not eliminate the need to declare the event. Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere poses an immediate threat to life and health or an immediate threat of severe exposure to gases. This could be based upon documented analysis, indication of personal ill effects from exposure, or operating experience with the hazards. If 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. Escalation of this emergency classification level, if appropriate, will be based on System Malfunctions, Fission Product Barrier Degradation, or Abnormal Rad Levels/Radioactive Effluent EALs. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 163 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis: This EAL is based on gases that have entered a plant structure in concentrations that could be unsafe for plant personnel and, therefore, preclude access to equipment necessary for the safe operation of the plant. Table H-1 safe shutdown areas contain systems that are operated to,establish or maintain safe shutdown (Reference 2-6). The Critical Switchgear Rooms are a part of the Reactor Building. At CNS, there are various potential sources of atmospheric contamination. Some of these sources are:

Inert gas used for oxygen exclusion (nitrogen).

Combustion products.

Carbon dioxide from fire extinguishing.

Halon from fire extinguishing.

Welding gases (enclosed areas).

Vapors from painting (enclosed areas).

Vapors from petroleum products.

Hydrogen (OWC Hydrogen Gas Generation System, Generator Cooling System, batteries, and disassociation of water in the reactor).

Asphyxiants and irritants found most often in confined areas (water and oil storage tanks, open manholes).

Methane from bacterial action (tanks and pits). Some of the gases which could affect normal plant operations under this EAL are:

Carbon Monoxide -One of the most common asphyxiants encountered in industry. It is formed by the incomplete combustion of fuel containing carbon. It may be found in the vicinity of a fire or a leak in an exhaust system (flue gas or internal combustion engines).

Oxygen -Oxygen has two fundamentally important properties: it supports combustion and it supports life. Since oxygen is necessary for life, it must be present in sufficient quantity. Oxygen deficiency occurs in confined spaces where the level of oxygen has been reduced below the limit to support life. Oxygen content in the air can become fatally low in a brief period of time. Some of the more common causes of this problem are oxidation of metals, bacterial action, combustion, and displacement by other gases. An enriched oxygen atmosphere will accelerate combustion. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 164 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE)

Hydrogen -Used in generator cooling. Hydrogen gas is also produced by the OWC Gas Generation System, located in the OWC Building, and subsequently injected into the Condensate System just upstream of the condensate booster pumps. Hydrogen is also produced by the disassociation of water from radiation in the reactor, which is seen in the off-gas. The presence of hydrogen will be especially significant in the Off-Gas and Augmented Off-Gas Systems. Hydrogen is also a by-product of battery charging. It is lighter than air so it will be found in pockets at the ceiling of enclosures.

Argon -Commonly used during the welding of certain metals. It is denser than air so it will settle in pockets below the welding area.

Carbon Dioxide -Used to fight fire. Being heavier than air, carbon dioxide will settle in pockets and displace oxygen.

Halon -Used to fight fire in the Service Water Pump Room, Computer Room, and in the Simulator. Discharge of a Halon System will result in exceeding IDLH limits in the area. Discharge of the Service Water Pump Room or Computer Room Halon System should be classified under this EAL.

Nitrogen -Used primarily to purge Primary Containment. Since it is approximately the same density as air, it can be dispersed by proper ventilation. Areas of poor ventilation may contain greater than expected concentrations of nitrogen and consequently may be deficient in oxygen.

Combustible Gases and Vapors -Includes naturally occurring gases (such as methane and hydrogen gas) and the vapors of a large group of liquids which are used as fuels and solvents. Monitoring shall be required in fuel tanks and other areas where explosive mixtures may be present.

Hydrogen Sulfide -Classified as an irritant in low concentrations, but is even more toxic than carbon monoxide, because it inflames the mucus membranes and results in the lungs filling with fluid. This colorless gas has a characteristic rotten egg odor, which renders the sense of smell ineffective. Hydrogen sulfide may be found in sewage treatment or wherever organic matter containing sulfur decomposes and shall be monitored constantly during work.

Methane -The chief constituent of natural gas and is extremely explosive. It is non-toxic, but may reduce the oxygen content of an atmosphere, causing asphyxiation. Methane is often found in the vicinity of sanitary landfills and has been detected in tanks where bacterial action is taking place (i.e., reactor water cleanup and condensate phase separator tanks). It is lighter than air and tends to accumulate in high spots or pockets. This can present a dangerous situation in storage tanks or sewers where access is normally gained at the top of the confined area. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 165 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE)

Ethyl Benzene -Used primarily as an additive to diesel fuel. Acute exposure results in a local irritant effect on the skin and mucous membranes. Chronic exposure can lead to nervous system disorders and upper respiratory tract inflammation. Monitoring is required when entering a diesel fuel tank.

Chlorine -Used in chemical treatment of Circulate Water and Service Water Systems. Chlorine gas can be recognized by its pungent, irritating odor, which is like the odor of bleach. Chlorine is not flammable but can react explosively with other chemicals such as turpentine or ammonia. Chlorine gas stays close to the ground and spreads rapidly. When chlorine gas comes in contact with moist human tissues, such as the eyes throat and lungs, an acid is produced that can damage these tissues.

Chlorine Dioxide -This is a yellow to reddish-yellow manufactured gas which does not occur naturally in the environment. When added to water, chlorine dioxide forms chlorite ion, which is also a very reactive chemical. High levels of chlorine dioxide can be irritating to the nose, eyes, throat, and lungs.

Hydrogen Chloride -This is a colorless to slightly yellowish gas with a pungent odor. On exposure to air, the gas forms dense white vapors due to condensation with atmospheric moisture. The vapor is corrosive and air concentrations above 5 ppm can cause When mixed with water or atmospheric moisture, a highly corrosive atmosphere is formed. The most common source of Hydrogen Chloride gas is from Muriatic (Hydrochloric) Acid. This EAL does not apply to routine inerting of the Primary Containment. CNS Basis Reference(s): 1. Administrative Procedure 0.36.6, Monitoring for Industrial Gases. 2. Site Services Procedure 1.1, Station Security. 3. CNS-FP-60, Fire Area Boundary Drawing Index. 4. Drawing CNS-EE-187, CNS Safe Shutdown Component Locations and Emergency Route Lighting -Site Plan. 5. Fire Safety Analysis Calculations. 6. USAR Section XII-2.1.2.1, Principal Class I Structures Required for Safe Shutdown. EPIPS.7.1 REVISION 58 PAGE 166 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 4 -Security Initiating Condition: Confirmed security condition or threat which indicates a potential degradation in the level of safety of the plant EAL: HU4.1 Unusual Event A security condition that does not involve a hostile action as reported by the Security Shift Supervisor OR A credible site-specific security threat notification OR A validated notification from NRC providing information of an aircraft threat Mode Applicability: All NEI 99-01 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 10CFR73. 71 or in some cases under 10CFRSO. 72. Security events assessed as hostile actions are classifiable under HA4.1, HS4.1, and HG4.1. A higher initial classification could be made based upon the nature and timing of the security threat and potential consequences. Consideration should be given to upgrading the emergency response status and emergency classification level in accordance with the Physical Security Plan and Emergency Plan. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 167 OF 334 ATTACHMENT 2 1st Threshold EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Reference is made to the Security Shift Supervisor because these individuals are the designated personnel 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 Physical Security Plan. This threshold is based on the CNS Security and Safeguards Contingency Plan. Security Plans are based on guidance provided by NEI 03-12. 2nd Threshold The second threshold is 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 Unusual Event. The determination of "credible" is made through use of information found in the Physical Security Plan. 3rd Threshold The intent of this EAL threshold is to ensure that notifications for the aircraft threat are made in a timely manner and that off-site response organizations and plant personnel are at a state of heightened awareness regarding the credible threat. 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 emergency classification level via HA4.1 would be appropriate if the threat involves an airliner less than 30 minutes away from the plant. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 168 OF 334 ATTACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 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 CNS. 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). CNS Basis Reference(s}: 1. CNS Security and Safeguards Contingency Plan. EPIP 5.7.1 REVISION 58 PAGE 169 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 4 -Security Initiating Condition: Hostile action within the Owner Controlled Area or airborne attack threat©1 EAL: HA4.1 Alert A hostile action is occurring or has occurred within the Owner Controlled Area as reported by the Security Shift Supervisor OR A validated notification from NRC of an airliner attack threat within 30 min. of the site Mode Applicability: All NEI 99-01 Basis: NOTE -Timely and accurate communication between Security Shift Supervision __ These EAL thresholds 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). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 170 OF 334 ATTACHMENT 2 1st Threshold EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) This EAL threshold 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. Although nuclear plant Security Officers are well trained and prepared to protect against hostile action, it is appropriate for off-site response organizations 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. 2nd Threshold This EAL threshold addresses the immediacy of an expected threat arrival or impact on the site within a relatively short time. The intent of this EAL threshold is to ensure that notifications for the airliner attack threat are made in a timely manner and that off-site response organizations and plant personnel are at a 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 threshold is met when a plant receives information regarding an airliner attack threat from NRC and the airliner is within 30 minutes of the plant. 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 Alert. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an airliner. The status and size of the plane may be provided by NORAD through the NRC. 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. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 171 OF 334 ATTACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Reference is made to the Security Shift Supervisor because these individuals are the designated personnel on-site qualified and trained to confirm that a security event is occurring or has occurred. 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 CNS. 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). CNS Basis Reference(s): 1. CNS Security and Safeguards Contingency Plan. EPIP 5.7.1 REVISION 58 PAGE 172 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 4 -Security Initiating Condition: Hostile action within the Protected Area©1 EAL: HS4.1 Site Area Emergency A hostile action is occurring or has occurred within the Protected Area as reported by the Security Shift Supervisor Mode Applicability: All NEI 99-01 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 off-site response organizations 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. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 173 OF 334 I L __ _ ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Although nuclear plant Security Officers are well trained and prepared to protect against hostile action, it is appropriate for off-site response organizations to be notified and encouraged to begin preparations for public protective actions (if they do not normally) to be better prepared should it be necessary to consider further actions. If not previously notified by 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. Escalation of this emergency classification level, if appropriate, would be based on actual plant status after impact or progression of attack. CNS Basis: Timely and accurate communication between Security Shift Supervision and the Control Room is crucial for the implementation of effective Security EALs. Reference is made to the Security Shift Supervisor because this individual is the designated on-site person 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 CNS Security and Safeguards Contingency Plan (Reference 1). 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 CNS. 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). CNS Basis Reference(s): 1. CNS Security and Safeguards Contingency Plan. EPIP 5.7.1 REVISION 58 PAGE 174 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 4 -Security Initiating Condition: Hostile action resulting in loss of physical control of the facility©1 EAL: HG4.1 General Emergency A hostile action has occurred such that plant personnel are unable to operate equipment required to maintain safety functions OR 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 Mode Applicabilaty: All NEI 99-01 Basis: 1st Threshold This EAL threshold 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 shut down), 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 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. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 175 OF 334 ATIACHMENT 2 2nd Threshold EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) This EAL threshold 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. CNS Basis: A freshly off-loaded reactor core in pool consists of recently discharged fuel that has been out of the reactor for less than 1 year (Reference 1). CNS Basis Reference{s): 1. Nuclear Procedure 10.6, SFSP Fuel Storage Constraints (restricted access for B.S.b). 2. CNS Security and Safeguards Contingency Plan. EPIP 5.7.1 REVISION 58 PAGE 176 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 5 -Control Room Evacuation Initiating Condition: Control Room evacuation has been initiated EAL: HAS.1 Alert Procedure 5.lASD, Alternate Shutdown, or Procedure 5.4FIRE-S/D, Fire Induced Shutdown From Outside Control Room, requires Control Room evacuation Mode Applicability: All NEI 99-01 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. CNS Basis: Procedures 5. lASD, Alternate Shutdown (Reference 1), and 5.4FIRE-S/D, Fire Induced Shutdown From Outside Control Room (Reference 2), provide the instructions for scramming the unit and maintaining RCS inventory from outside the Control Room. The Shift Manager (SM) determines if the Control Room is inoperable and requires evacuation. Control Room inhabitability may be caused by fire, dense smoke, noxious fumes, bomb threat in or adjacent to the Control Room, or other life threatening conditions. CNS Basis Reference(s): 1. Emergency Procedure 5.lASD, Alternate Shutdown. 2. Emergency Procedure 5.4FIRE-S/D, Fire Induced Shutdown From Outside Control Room. EPIP 5. 7 .1 REVISION 58 PAGE 177 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 5 -Control Room Evacuation Initiating Condition: Control Room evacuation has been initiated and plant control cannot be established EAL: HS5.1 Site Area Emergency Control Room evacuation has been initiated AND Control of the plant cannot be established within 15 min. Mode Applicability: All NEI 99-01 Basis: The intent of this EAL is to capture those events where control of the plant cannot be re-established 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 15 minute time for transfer starts when the Control Room begins to be evacuated (not when Procedure 5.1ASD, Alternate Shutdown, is entered). The time interval is based on how quickly control must be re-established without core uncovery and/or core damage. 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. Typically, these safety functions are reactivity control (ability to shut down 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 from outside the Control Room is based on Emergency Director (ED) judgment. The Emergency Director is expected to make a reasonable, informed judgment that control of the plant from the Alternate Shutdown Panels cannot be established within the 15 minute interval. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 178 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Escalation of this emergency classification level, if appropriate, would be by Fission Product Barrier Degradation or Abnormal Rad Levels/Radiological Effluent EALs. CNS Basis: Procedures 5. lASD, Alternate Shutdown (Reference 1), and 5.4FIRE-S/D, Fire Induced Shutdown From Outside Control Room (Reference 2), provide the instructions for scramming the unit and maintaining RCS inventory from outside the Control Room. The Shift Manager determines if the Control Room is inoperable and requires evacuation. Control Room inhabitability may be caused by fire, dense smoke, noxious fumes, bomb threat in or adjacent to the Control Room, or other life threatening conditions. The 15 minute criterion applies from the time that the Control Room begins to be evacuated. CNS Basis Reference(s): 1. Emergency Procedure 5.1ASD, Alternate Shutdown. 2. Emergency Procedure 5.4FIRE-S/D, Fire Induced Shutdown From Outside Control Room. EPIP 5.7.1 REVISION 58 PAGE 179 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 6 -Judgment Initiating Condition: Other conditions exist which in the judgment of the Emergency Director warrant declaration of a UE EAL: HU6.1 Unusual Event Other conditions exist which in the judgment of the Emergency Director indicate that EITHER: Events are in-progress or have occurred which indicate a potential degradation of the level of safety of the plant OR 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 Mode Applicability: All NEI 99-01 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 Unusual Event emergency class. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 180 OF 334 ATTACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The Emergency Director is the designated on-site individual having the responsibility and authority for implementing the CNS Emergency Plan. The Shift Manager (SM) initially acts in the capacity of the Emergency Director and takes actions as outlined in the Emergency Plan implementing procedures. If required by the emergency classification or if deemed appropriate by the Emergency Director, emergency response personnel are notified and instructed to report to their emergency response locations. In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but Plant Management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency (Reference 1). CNS Basis Reference(s): 1. Emergency Plan for Cooper Nuclear Station, Section 5.0. EPIP5.7.1 REVISION 58 PAGE 181 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 6 -Judgment Initiating Condition: Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert EAL: HA6.1 Alert Other conditions exist which in the judgment of the Emergency Director indicate that events are in-progress or have occurred which involve EITHER: 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 beyond the site boundary Mode Applicability: All NEI 99-01 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 class. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 182 OF 334

ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (IN FORMATION USE) CNS Basis: The Emergency Director is the designated on-site individual having the responsibility and authority for implementing the CNS Emergency Plan. The Shift Manager (SM) initially acts in the capacity of the Emergency Director and takes actions as outlined in the Emergency Plan implementing procedures. If required by the emergency classification or if deemed appropriate by the Emergency Director, emergency response personnel are notified and instructed to report to their emergency response locations. In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but Plant Management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency (Reference 2). For the purposes of this EAL, the Site Boundary for CNS is a 1 mile radius around the plant. CNS Basis Reference(s): 1. CNS Drawing DWG.2.2 (P3-A-45). 2. Emergency Plan for Cooper Nuclear Station, Section 5.0. EPIP 5.7.1 REVISION 58 PAGE 183 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 6 -Judgment Initiating Condition: Other conditions exist which in the judgment of the Emergency Director warrant declaration of Site Area Emergency EAL: HS6. l Site Area Emergency Other conditions exist which in the judgment of the Emergency Director indicate that events are in-progress or have occurred which involve EITHER: An 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 (1 Rem TEDE and 5 Rem thyroid CDE) beyond the site boundary Mode Applicability: All NEI 99-01 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 class description for Site Area Emergency. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 184 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis: The Emergency Director is the designated on-site individual having the responsibility and authority for implementing the CNS Emergency Plan. The Shift Manager (SM) initially acts in the capacity of the Emergency Director and takes actions as outlined in the Emergency Plan implementing procedures. If required by the emergency classification or if deemed appropriate by the Emergency Director, emergency response personnel are notified and instructed to report to their emergency response locations. In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but Plant Management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency (Reference 2). For the purposes of this EAL, the Site Boundary for CNS is a 1 mile radius around the plant. CNS Basis Reference(s): 1. CNS Drawing DWG.2.2 (P3-A-45). 2. Emergency Plan for Cooper Nuclear Station, Section 5.0. EPIP 5.7.1 REVISION 58 PAGE 185 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: H -Hazards And Other Conditions Affecting Plant Safety Subcategory: 6 -Judgment Initiating Condition: Other conditions exist which in the judgment of the Emergency Director warrant declaration of General Emergency EAL: HG6.1 General Emergency Other conditions exist which in the judgment of the Emergency Director indicate that events are in-progress or have occurred which involve EITHER: 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 (1 Rem TEDE and 5 Rem thyroid CDE) beyond the site boundary Mode Applicability: All NEI 99-01 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 General Emergency class. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 186 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis: The Emergency Director is the designated on-site individual having the responsibility and authority for implementing the CNS Emergency Plan. The Shift Manager (SM) initially acts in the capacity of the Emergency Director and takes actions as outlined in the Emergency Plan implementing procedures. If required by the emergency classification or if deemed appropriate by the Emergency Director, emergency response personnel are notified and instructed to report to their emergency response locations. In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but Plant Management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency (Reference 2). Releases can reasonably be expected to exceed EPA PAG plume exposure levels outside the Site Boundary. For the purposes of this EAL, the Site Boundary for CNS is a 1 mile radius around the plant. CNS Basis Reference(s): 1. CNS Drawing DWG.2.2 (P3-A-45). 2. Emergency Plan for Cooper Nuclear Station, Section 5.0. EPIP 5.7.1 REVISION 58 PAGE 187 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: S -System Malfunction Subcategory: 1 -Loss of Power Initiating Condition: Loss of all off-site AC power to critical buses for 15 minutes or longer EAL: SU 1.1 Unusual Event Loss of all off-site AC power (Table S-3) to critical 4160V Buses 1F and 1G for 15 min. (NOTE 3) ---------------------------------------------------------------------*-------------------------------------------------* -__________ :;.. -NOTE 3 -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 9-?_ _ _ _ J? J?l ! _______________________________ _ -----Table S-3 AC Power Sources Offsite

Startup Station Service Transformer

Emergency Station Service Transformer

Backfeed 345 kv line through Main Power Transformer to the Normal Station Service Transformer (Note 8) Onsite

DG-1

DG-2

Main Generator ---------..... -------------------------*----------------------*-------------------------------------------------"':---------------------------NOTE 8 -The time required to establish the backfeed is likely longer than the specified time interval. If off-normal plant conditions have already established the backfeed, its power to the safety-rerated buses may be considered an off-site :._ ____ --------------*---------------------------------------------------------------------------------------------(continued on next page) EPIP 5.7.1 REVISION 58 PAGE 188 OF 334 ATTACHMENT 2 Mode Applicability: --------------EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown NEI 99-01 Basis: Prolonged loss of 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 (e.g., Station Blackout). Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. CNS Basis: The 4160V critical Buses 1F (Div. I) and 1G (Div. II) are the plant essential, safety-related emergency buses. Each can be energized manually and separately by any of the following off-site sources of power: Figure S-1 illustrates the 4160V AC Distribution System (Reference 7, 8).

Startup Transformer -The Startup Transformer provides a source of off-site AC power to the entire Auxiliary Power Distribution System adequate for the startup operation or shutdown operation of the station. The Startup Transformer is the preferred source of off-site AC power to the station whenever the main generator is off-line ( < 160 MWe). The Startup Transformer is energized from the 161 kV Switchyard. The transformer is normally left energized at all times to provide for quick automatic transfer of the 4160V auxiliaries to the Startup Transformer in the event that the station Normal Transformer fails or that the main generator trips off-line.

Emergency Transformer -The Emergency Transformer is the primary off-site AC power source to essential station loads. During normal station operation, the Emergency Transformer is energized by the 69 kV transmission line from OPPD. As such, it supplies 4160V Switchgear 1F and/or 1G in the event that the Normal Transformer and Startup Transformer are not available for service. Use of the Emergency Transformer also allows portions of the 345 kV System to be removed from service for inspection, testing, and maintenance. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 189 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE)

Backfeeding power from the 345 kV line through the Main Power Transformer to the Normal Transformer. The Normal Transformer is the normal source of AC power to the station when the Main Generator is on line above 20% (160 MWe) electrical power. The transformer is energized during Main Generator operation through the Isolated Phase Buses that feed the Main Power Transformers. As mentioned in NOTE 8, the time required to establish the backfeed is likely longer than the 15 minute interval. If off-normal plant conditions have already established the backfeed, its power to the safety-related buses may be considered an off-site power source. On-site power sources are the emergency diesel generators (DG-1 and DG-2) and the Main Generator. If a power supply should have picked up a critical bus but failed to do so, that power supply should be considered unavailable until it has been successfully tied onto the bus. If the power supply can be tied to the bus within 15 minutes, then the power supply is to be considered available. The Supplemental Diesel Generator (SDG) is not considered an on-site or an off-site emergency power supply and is not considered in classifications involving loss of power. The SBO Coping Time per Regulatory Guide 1.155 considers the impact of a SDG. The 15 minute interval was selected as a threshold to exclude transient or momentary power losses. If neither emergency bus is energized by an off-site source within 15 minutes, an Unusual Event is declared under this EAL. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 190 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE)

CNS Basis Reference(s): 1. System Operating Procedure 2.2.15, Startup Transformer. 2. System Operating Procedure 2.2.16, Normal Station Service Transformer. 3. System Operating Procedure 2.2.17, Emergency Station Service Transformer. 4. System Operating Procedure 2.2.18, 4160V Auxiliary Power Distribution System. 5. System Operating Procedure 2.2.20, Standby AC Power System (Diesel Generator). 6. Emergency Procedure 5.3SBO, Station Blackout. 7. BR 3001, One Line Diagram. 8. BR 3002, Sheet 1. 9. NC43456, One Line Switching Diagram 161kV Substation. 10. Enercon Services, Inc. Report No. NPPl-PR-01, Station Blackout Coping Assessment for Cooper Nuclear Station, Revision 2. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 191OF334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Figure S-1: 4160V AC Distribution System FROM MAIN Gl!NERATOR y NORMAL STATION SERVICE TRANSFORMER 22 KV/4160V 8KR ) 1CN 4160V SWGR 1C 4160VSWGR 1A 4160V SWGR 1F BKR IAN Bl<R ') 1FE BKR ) EG1 c5 ') BKR 1AF' BKR 1FA DIESEL GENERATOR #1 EPIP 5. 7 .1 BKR 1AS BKR') 1FS I EMERGENCY j:¢¢:¢:(srATION SERVICE I TRANSFORMER FROM 345 KV/161 KV GRID STARTUP STATION SERVICE TRANSFORMER ION 105 y VJJv f'YVV\ 161 KV/4160V )Bl<R )BKR l 41 GOV SWGR 1D )BKR 1BN )BKR 1BS * ')BKR 1BE * * ')BKR 4160V SWGR 1B 1BG SDG ! ')Bl<R lGS I 4160V SWGR 1G ')BKR IGE )BKR EG2 c5 DIESEL GENERATOR #2 REVISION 58 PAGE 192 OF 334

---ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: S -System Malfunction Subcategory: 1 -Loss of Power Initiating Condition: AC power capability to critical buses reduced to a single power source for 15 minutes or longer such that any additional single failure would result in loss of all AC power to critica I buses EAL: SA1.1 Alert AC power capability to critical 4160V Buses 1F and 1G reduced to a single power source (Table S-3) for 2:: 15 min. (NOTE 3) such that any additional single failure would result in loss of all AC power to emergency buses NOTE 3 -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 _J __ __ _________________________ . ______________________ _ Tab!e.*.s.,3. PQwer Sources I : Offsite

Startup Station Service Transformer

Emergency Station Service Transformer

Backfeed 345 kv line through Main Power Transformer to the Normal Station Service Transformer (Note 8) Onsite

DG-1

DG-2

Main Generator (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 193 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) ------------------------... .: --------------..:, ___ -----___ -..;-___ ._ ------........... ,._ -------------.. -------------------------------1 NOTE 8 -The time required to establish the backfeed is likely longer than the l specified time interval. If off-normal plant conditions have already established the 1* backfeed, its power to the safety-related buses may be considered an off-site l power: ! ;.. ............... ::.. .... * .... *------------------*-*---------* ----... ------------------...... -----------------.... --... ------------.. --------------------------.----* Mode Applicability: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown NEI 99-01 Basis: This EAL is intended to provide an escalation from IC SU1.1, "Loss of all off-site AC power to critical buses for 15 minutes or longer". The condition indicated by this EAL is the degradation of the off-site and on-site AC power systems such that any additional single failure would result in a loss of all AC power to the critical buses. This condition could occur due to a loss of off-site power with a concurrent failure of all but one emergency generator to supply power to its critical bus. Another related condition could be the loss of all off-site power and loss of on-site emergency generators with only one train of critical buses being backfed from the unit main generator or the loss of on-site emergency generators with only one train of critical buses being backfed from off-site power. The subsequent loss of this single power source would escalate the event to a Site Area Emergency in accordance with 551.1. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 194 OF 334 ATIACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The 4160V critical Buses 1F (Div. I) and 1G (Div. II) are the plant essential, safety-related emergency buses. Each can be energized manually and separately by any of the following off-site sources of power: Figure S-1 illustrates the 4160V AC Distribution System (Reference 7, 8).

Startup Transformer -The Startup Transformer provides a source of off-site AC power to the entire Auxiliary Power Distribution System adequate for the startup operation or shutdown operation of the station. The Startup Transformer is the preferred source of off-site AC power to the station whenever the main generator is off-line ( < 160 MWe). The Startup Transformer is energized from the 161 kV Switchyard. The transformer is normally left energized at all times to provide for quick automatic transfer of the 4160V auxiliaries to the Startup Transformer in the event that the station Normal Transformer fails or that the main generator trips off-line.

Emergency Transformer -The Emergency Transformer is the primary off-site AC power source to essential station loads. During normal station operation, the Emergency Transformer is energized by the 69 kV transmission line from OPPD. As such, it supplies 4160V Switchgear 1F and/or 1G in the event that the Normal Transformer and Startup Transformer are not available for service. Use of the Emergency Transformer also allows portions of the 345 kV System to be removed from service for inspection, testing, and maintenance.

Backfeeding power from the 345 kV line through the Main Power Transformer to the Normal Transformer. The Normal Transformer is the normal source of AC power to the station when the Main Generator is on line above 20% (160 MWe) electrical power. The transformer is energized during Main Generator operation through the Isolated Phase Buses that feed the Main Power Transformers. As mentioned in NOTE 8, the time required to establish the backfeed is likely longer than the 15 minute interval. If off-normal plant conditions have already established the backfeed, its power to the safety-related buses may be considered an off-site power source. On-site power sources are the emergency diesel generators (DG-1 and DG-2) and the Main Generator. If a power supply should have picked up a critical bus but failed to do so, that power supply should be considered unavailable until it has been successfully tied onto the bus. If the power supply can be tied to the bus within 15 minutes, then the power supply is to be considered available. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 195 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The Supplemental Diesel Generator (SDG) is not considered an on-site or an off-site emergency power supply and is not considered in classifications involving loss of power. The SBO Coping Time per Regulatory Guide 1.155 considers the impact of a SDG. The 15 minute interval was selected as a threshold to exclude transient or momentary power losses. If the capability of a second source of emergency bus power is not restored within 15 minutes, an Alert is declared under this EAL. CNS Basis Reference(s): 1. System Operating Procedure 2.2.15, Startup Transformer. 2. System Operating Procedure 2.2.16, Normal Station Service Transformer. 3. System Operating Procedure 2.2.17, Emergency Station Service Transformer. 4. System Operating Procedure 2.2.18, 4160V Auxiliary Power Distribution System. 5. System Operating Procedure 2.2.20, Standby AC Power System (Diesel Generator). 6. Emergency Procedure 5.3SBO, Station Blackout. 7. BR 3001, One Line Diagram. 8. BR 3002, Sheet 1. 9. NC43456, One Line Switching Diagram 161kV Substation. 10. Enercon Services, Inc. Report No. NPPl-PR-01, Station Blackout Coping Assessment for Cooper Nuclear Station, Revision 2. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 196 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Figure S-1: 4160V AC Distribution System FROM MAIN GENERATOR y NORMAL STATION SERVICE TRANSFORMER 22 KV141GOV 1CN BKR ) 4160V SWGR 1C 4160V SWGR 1A 4160V SWGR 1F BKR ') 1FE BKR ) EGl c5 BKR 1FA DIESEL GENERATOR.#1 EPIP 5.7.1 BKR') 1FS I EMERGENCY j¢¢¢( STATION SERVICE I TRANSFORMER FROM 345 KVti61 KV GRID STARTUP STATION* SERVICE TRANSFORMER )BKR )BKR 1DN *tOS 4160V SWGR fD )BKR 1BN y v...AJ...I rYV'V"'\ 161 KV/4160V )BKR 1BS * * ')BKR IBE * ')BKR. 4160V SWGR 1B IBG ! ')BKR 1GS I SDG 4160V SWGR 1G ')BKR 1GE )BKR EG2 c5 DIESEL GENERATOR #2 REVISION 58 PAGE 197 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: S -System Malfunction Subcategory: 1 -Loss of Power Initiating Condition: Loss of all off-site and all on-site AC power to critical buses for 15 minutes or longer EAL: SS1.1 Site Area Emergency Loss of alH off-site and all on-site AC power (Table S-3) to critical 4160V Buses 1F and 1G 15 min. (NOTE 3) -------------------------------.;.._;.,.._ _________ --------------------------------------------:-----""'----------------------------NOTE 3 -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. . . l ---------------------------__ ... ---------.., ____ ---------* ----------------... ------------------------------------------*------*-----*---... -----_, ,AC PgW¢r -. -----Offsite

Startup Station Service Transformer

Emergency Station Service Transformer

Backfeed 345 kv line through Main Power Transformer to the Normal Station Service Transformer (Note 8) Onsite

DG-1

DG-2

Main Generator specified time interval. If off-normal plant conditions have already established the : I backfeed, its power to the safety-related buses may be considered an off-site i I I _ -------------------------------------------------------------------*--"-" -------------------------------__ : (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 198 OF 334 ATTACHMENT 2 Mode Applicability: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown NEI 99-01 Basis: Loss of all AC power to critical buses 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 critical buses will lead to loss of Fuel Clad, RCS, and Primary 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. Escalation to General Emergency is via Fission Product Barrier Degradation or IC SG1, "Prolonged loss of all off-site power and prolonged loss of all on-site AC power". CNS Basis: The 4160V critical Buses 1F (Div. I) and 1G (Div. II) are the plant essential, safety-related emergency buses. Each can be energized manually and separately by any of the following off-site sources of power: Figure S-1 illustrates the 4160V AC Distribution System (Reference 7, 8).

Startup Transformer -The Startup Transformer provides a source of off-site AC power to the entire Auxiliary Power Distribution System adequate for the startup operation or shutdown operation of the station. The Startup Transformer is the preferred source of off-site AC power to the station whenever the main generator is off-line ( < 160 MWe). The Startup Transformer is energized from the 161 kV Switchyard. The transformer is normally left energized at all times to provide for quick automatic transfer of the 4160V auxiliaries to the Startup Transformer in the event that the station Normal Transformer fails or that the main generator trips off-line. (continued on next page) EPIP 5. 7.1 REVISION 58 PAGE 199 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE)

Emergency Transformer -The Emergency Transformer is the primary off-site AC power source to essential station loads. During normal station operation, the Emergency Transformer is energized by the 69 kV transmission line from OPPD. As such, it supplies 4160V Switchgear 1F and/or 1G in the event that the Normal Transformer and Startup Transformer are not available for service. Use of the Emergency Transformer also allows portions of the 345 kV System to be removed from service for inspection, testing, and maintenance.

Backfeeding power from the 345 kV line through the Main Power Transformer to the Normal Transformer. The Normal Transformer is the normal source of AC power to the station when the Main Generator is on line above 20% (160 MWe) electrical power. The transformer is energized during Main Generator operation through the Isolated Phase Buses that feed the Main Power Transformers. As mentioned in NOTE 8, the time required to establish the backfeed is likely longer than the 15 minute interval. If off-normal plant conditions have already established the backfeed, its power to the safety-related buses may be considered an off-site power source. On-site power sources are the emergency diesel generators (DG-1 and DG-2) and the Main Generator. If a power supply should have picked up a critical bus but failed to do so, that power supply should be considered unavailable until it has been successfully tied onto the bus. If the power supply can be tied to the bus within 15 minutes, then the power supply is to be considered available. The Supplemental Diesel Generator (SDG) is not considered an on-site or an off-site emergency power supply and is not considered in classifications involving loss of power. The SBO Coping Time per Regulatory Guide 1.155 considers the impact of a SDG. This EAL is the hot condition equivalent of the cold condition loss of all AC power EAL CA1.1. When in Cold Shutdown, Refueling, or Defueled Mode, the event can be classified as an Alert because of the significantly reduced decay heat, lower temperature and pressure, increasing the time to restore one of the critical buses, relative to that existing when in hot conditions. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 200 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. System Operating Procedure 2.2.15, Startup Transformer. 2. System Operating Procedure 2.2.16, Normal Station Service Transformer. 3. System Operating Procedure 2.2.17, Emergency Station Service Transformer. 4. System Operating Procedure 2.2.18, 4160V Auxiliary Power Distribution System. 5. System Operating Procedure 2.2.20, Standby AC Power System (Diesel Generator). 6. Emergency Procedure 5.3SBO, Station Blackout. 7. BR 3001, One Line Diagram. 8. BR 3002, Sheet 1. 9. NC43456, One Line Switching Diagram 161kV Substation. 10. Enercon Services, Inc. Report No. NPPl-PR-01, Station Blackout Coping Assessment for Cooper Nuclear Station, Revision 2. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 201 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Figure S-1: 4160V AC Distribution System FROM MAlN GENER'ATOR y >¢¢:¢< STATION SERVlCE TP.ANSFORMER 22KVi4160V BKR ) 1CN 4160V SWGR 1C 4160V SWGR 1A 4160V SWGR 1 F. BKR I) 1AN BKR 1FA BKR ') 1FE BKR 1AS BKR') 1FS I BKR ) 1AE

4160V SWGR 1E FROM 345 KV/161 KV GRID lDN STARTUP STATION SERVICE TRANSFORMER )BKR 4160V SWGR 10 )BKR 1BN y v...A.AJ fVVV' 161 KVf4160V )BKR 105 * ')BKR IBE * ')BKR 4160V SWGR 18 1BG t? i ')BKR 1GS I *l160V SWGR 1G ')BKR 1GE BKR ) EG1 "\..A.A..A.J". EMERGENCY . I ./YVV'\. STATION SERVICE )BKR EG:i c5 I '"""o"" l_J '"" c5 DIESEL GENERATOR.Ill DIESEL GENERATOR 112 EPIP5.7.1 REVISION 58 PAGE 202 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: S -System Malfunction Subcategory: 1 -Loss of Power Initiating Condition: Prolonged loss of an off-site and all on-site AC power to critical emergency buses EAL: SG1 .1 General Emergency Loss of all off-site and all on-site AC power (Table S-3) to critical 4160V Buses 1F and 1G, AND EITHER: Restoration of at least one emergency bus in < 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is not likely OR RPV level cannot be restored and maintained > -158 in. or cannot be determined TableS-3 AC Power Sources Off site

Startup Station Service Transformer

Emergency Station Service Transformer

Backfeed 345 kv line through Main Power Transformer to the Normal Station Service Transformer (Note 8) Onsite

DG-1

DG-2

Main Generator ! NOTE 8 -The time required to establish the backfeed is likely longer than the ! specified time interval. If off-normal plant conditions have already established the i backfeed, its power to the safety-related buses may be considered an off-site ! power source . .. -------------.; --.. ---------------.--.-----.. -----------------------------*--------------------,-------------.. -------------__________ ... ----.. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 203 OF 334 ATTACHMENT 2 Mode Applicability: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown NEI 99-01 Basis: Loss of all AC power to critical buses 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 critical buses will lead to loss of fuel clad, RCS, and containment, thus, warranting declaration of a General Emergency. This EAL is specified to assure that in the unlikely event of a prolonged loss of all critical bus AC power, 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 critical 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 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. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 204 OF 334 ATTACHMENT 2 CNS Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The 4160V Critical Buses 1F (Div. I) and 1G (Div. II) are the plant essential, safety-related emergency buses. Each can be energized manually and separately by any of the following off-site sources of power: Figure S-1 illustrates the 4160V AC Distribution System (Reference 7, 8).

Startup Transformer -The Startup Transformer provides a source of off-site AC power to the entire Auxiliary Power Distribution System adequate for the startup operation or shutdown operation of the station. The Startup Transformer is the preferred source of off-site AC power to the station whenever the main generator is off-line ( < 160 MWe). The Startup Transformer is energized from the 161 kV Switchyard. The transformer is normally left energized at all times to provide for quick automatic transfer of the 4160V auxiliaries to the Startup Transformer in the event that the station Normal Transformer fails or that the main generator trips off-line.

Emergency Transformer -The Emergency Transformer is the primary off-site AC power source to essential station loads. During normal station operation, the Emergency Transformer is energized by the 69 kV transmission line from OPPD. As such, it supplies 4160V Switchgear 1F and/or 1G in the event that the Normal Transformer and Startup Transformer are not available for service. Use of the Emergency Transformer also allows portions of the 345 kV System to be removed from service for inspection, testing, and maintenance.

Backfeeding power from the 345 kV line through the Main Power Transformer to the Normal Transformer. The Normal Transformer is the normal source of AC power to the station when the Main Generator is on line above 20°/o (160 MWe) electrical power. The transformer is energized during Main Generator operation through the Isolated Phase Buses that feed the Main Power Transformers. As mentioned in NOTE 8, the time required to establish the backfeed is likely longer than the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months interval. If off-normal plant conditions have already established the backfeed; however, its power to the safety-related buses may be considered an off-site power source. On-site power sources are the emergency diesel generators (DG-1 and DG-2) and the Main Generator. If a power supply should have picked up a critical bus but failed to do so, that power supply should be considered unavailable until it has been successfully tied onto the bus. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is the CNS Station Blackout Coping Analysis time (Reference 11, 13). (continued on next page) EPIP 5. 7.1 REVISION 58 PAGE 205 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The Supplemental Diesel Generator (SDG) is not considered an on-site or an off-site emergency power supply and is not considered in classifications involving loss of power. The SBO Coping Time per Regulatory Guide 1.155 considers the impact of a SDG. Indication of continuing core cooling degradation is manifested by a RPV level instrument reading of< -158 inches (RPV level is below the top of active fuel). When RPV level is at or above the top of active fuel, the core is completely submerged. Core submergence is the most desirable means of core cooling. When RPV level is below the top of active fuel, the uncovered portion of the core must be cooled by less reliable means (i.e., steam cooling or spray cooling). If core uncovery is threatened, the EOPs specify alternate, more extreme, RPV level control measures in order to restore and maintain adequate core cooling. Since core uncovery begins if RPV level drops to the top of active fuel, the level is indicative of a challenge to core cooling and the Fuel Clad barrier. When RPV level cannot be determined, EOPs require entry to EOP-2B, RPV Flooding, or EOP-7B, RPV Flooding (Failure-to-Scram). RPV water level indication provides the primary means of knowing if adequate core cooling is being maintained. When all means of determining RPV water level are unavailable, the fuel clad barrier is threatened and reliance on alternate means of assuring adequate core cooling must be attempted. The instructions in EOP-2B/7B specify these means, which include emergency depressurization of the RPV and injection into the RPV at a rate needed to flood to the elevation of the main steam lines or hold the Minimum Steam Cooling Pressures (in scram-failure events). If RPV water level cannot be determined with respect to the top of active fuel, a potential loss of the fuel clad barrier exists. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 206 OF 334

ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. System Operating Procedure 2.2.15, Startup Transformer. 2. System Operating Procedure 2.2.16, Normal Station Service Transformer. 3. System Operating Procedure 2.2.17, Emergency Station Service Transformer. 4. System Operating Procedure 2.2.18, 4160V Auxiliary Power Distribution System. 5. System Operating Procedure 2.2.20, Standby AC Power System (Diesel Generator). 6. Emergency Procedure 5.3SBO, Station Blackout. 7. BR 3001, One Line Diagram. 8. BR 3002, Sheet 1. 9. NC43456, One Line Switching Diagram 161kV Substation. 10. EOP-2B RPV Flooding. 11. EOP-7B RPV Flooding (Failure-to-Scram). 12. Enercon Services, Inc. Report No. NPPl-PR-01, Station Blackout Coping Assessment for Cooper Nuclear Station, Revision 2. 13. NEDC 97-089. 14. USAR Section VIIl-6.2. 7. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 207 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Figure S-1: 4160V AC Distribution System FROM MAIN GENERATOR y NORMAL STATION SERVICE TRANSFORMER 22 KV/4i60V BKR ) 1CN ! 4160V SWGR 1C 4160VSWGR 1A 4i60VSWGR 1F BKR 1AN BKR ') IEE BKR ) EG1 c5 BKR 1FA DIESEL GENERATOR 111 EPIP 5.7.1 BKR ) fAS BKR ) 1AE

4160VSWGR 1E BKR') 1FS I EMERGENCY )¢:¢¢(sTATIOM SERVICE I TRANSFORMER FROM 345 KV/161 KV GRID STARTUP STATION SERVICE TRANSFORMER 10N 1DS y v..A.A.I rYYV"\ 161 KV/4160V )BKR )BKR 4160V'SWGR 10 )BKR 1BN * ')BKR )BKR ,1BS ' . 1BE * ')BKR 1GS I MODS SDG 4'160V SWGR 1G ')BKR 1GE )BKR EG2 c5 DIESELGENERATOR tl2 REVISION 58 PAGE 208 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: S -System Malfunction Subcategory: 2 -ATWS/Criticality Initiating Condition: Inadvertent criticality EAL: SU2.1 Unusual Event An unplanned sustained positive period observed on nuclear instrumentation Mode Applicability: 3 -Hot Shutdown NEI 99-01 Basis: This EAL addresses inadvertent criticality events. This EAL indicates a potential degradation of the level of safety of the plant, warranting an Unusual Event classification. This EAL EXCLUDES inadvertent criticalities that occur during planned reactivity changes associated with reactor startups (e.g., criticality earlier than estimated). Escalation would be by the Fission Product Barrier Table, as appropriate, to the operating mode at the time of the event. CNS Basis: SRM A-D period Meters NMS-l-44A-D on Panel 9-5 identify this condition as well as Panel 9-5 amber light and SRM Period ( < 50 sec.) Annunciator 9 1/F-8 (Reference 1, 2). However, a SRM period alarm caused by SRM channel noise does not result in entry into this EAL (Reference 1). CNS Basis Reference(s): 1. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1, F-8, SRM Period. 2. Instrument Operating Procedure 4.1.1, Source Range Monitoring System. EPIP 5.7.1 REVISION 58 PAGE 209 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: S -System Malfunction Subcategory: 2 -ATWS/Criticality Initiating Condition: Automatic scram fails to shut down the reactor and the manual actions taken from the reactor control console are successful in shutting down the reactor EAL: SA2.1 Alert An automatic scram failed to shut down the reactor AND Manual actions taken at the reactor control console (NOTE 5) successfully shut down the reactor as indicated by reactor power < 3% !

Reactor Scram pushbuttons. ; i

Reactor Mode switch in SHUTDOWN. : !

Manual or auto actuation of ARI. 1 I.-----------------------------------------------*--------------.---'---'----------*-*-*-------* -........ ---..... --.. -------------= ':"-------.------* Mode Applicability: 1 -Power Operation, 2 -Startup NEI 99-01 Basis: Manual scram (trip) 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. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 210 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 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 shut down the plant. If manual actions taken at the reactor control console fail to shut down the reactor, the event would escalate to a Site Area Emergency. CNS Basis: The first condition of this EAL identifies the need to cease critical reactor operations by actuation of the automatic Reactor Protection System (RPS) scram function. A reactor scram is automatically initiated by the Reactor Protection System (RPS) when certain continuously monitored parameters exceed predetermined setpoints. A reactor scram may be the result of manual or automatic action in response to any of the following parameters (Reference 3):

APRM Fixed Neutron Flux -High.

APRM Fixed Neutron Flux -High (Setdown).

APRM Flow Biased -High.

IRM -High.

Reactor Steam Dome Pressure -High.

Reactor Vessel Water Level Low -Level-3.

Turbine Stop Valve Closure.

Turbine Control Valve Fast Closure.

MSIV Closure.

Scram Discharge Volume (SDV) Level -High.

Drywell Pressure -High. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 211OF334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Following a successful reactor scram, rapid insertion of the control rods occurs. Nuclear power promptly drops to a fraction of the original power level and then decays to a level several decades less with a negative period. The reactor power drop continues until reactor power reaches the point at which the influence of source neutrons on reactor power starts to be observable. A predictable post-scram response from an automatic reactor scram signal should therefore consist of a prompt drop in reactor power as sensed by the nuclear instrumentation and a lowering of power into the source range. A successful scram has therefore occurred when there is sufficient rod insertion to bring the reactor power below the APRM downscale setpoint of 3°/o (Reference 1, 2). The significance of the second condition of this EAL is that a potential degradation of a safety system exists because a front line automatic protection system did not function in response to a plant transient. Thus, plant safety has been compromised. Following any automatic RPS scram signal, Procedure 2.1.5 prescribe insertion of redundant manual scram signals to back up the automatic RPS scram function and ensure reactor shutdown is achieved (Reference 1). Even if the first subsequent manual scram signal inserts all control rods to the full-in position immediately after the initial failure of the automatic scram, the lowest level of classification that must be declared is an Alert. This EAL is not applicable if a manual scram is initiated and no RPS setpoints are exceeded. Taking the mode switch to shutdown is a manual scram action. When the mode switch is taken out of the Run position, however, the nuclear instrumentation scram setpoint is lowered. If reactor power remains above the lowered setpoint, an automatic scram is initiated. In the event that the Operator identifies a reactor scram is imminent and initiates a successful manual reactor scram before the automatic scram setpoint is reached, no declaration is required. Methods of inserting a manual scram are limited to those that can be taken rapidly at the reactor control console (Panel 9-5) and include:

Both manual Reactor Scram pushbuttons.

Reactor Mode switch in SHUTDOWN.

Manual or auto actuation of ARI. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 212 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Auto actuation of ARI is included in the list of methods because the Operator, by procedure, always ensures actuation of ARI has occurred if the ARI actuation setpoints are exceeded. This means action to depress the ARI pushbuttons is taken if the automatic ARI actuation setpoints are exceeded but failed to actuate. If ARI properly actuates automatically, the ARI pushbuttons are not depressed. Reactor shutdown achieved by use of the alternate rod insertion methods listed in Procedure 5.8.3 do not constitute a successful manual scram (Reference 2). The successful manual scram of the reactor before it reaches its automatic scram setpoint or reactor scram signals caused by instrumentation channel failures do not lead to a potential fission product barrier loss. If manual reactor scram actions fail to reduce reactor power below 3% (Reference 1, 2), the event escalates to the Site Area Emergency under EAL SS2.1. If by procedure, Operator actions include the initiation of an immediate manual scram following receipt of an automatic scram signal and there are no clear indications that the automatic scram failed (such as a time delay following indications that a scram setpoint was exceeded), it may be difficult to determine if the reactor was shut down because of automatic scram or manual actions. If a subsequent review of the scram actuation indications reveals that the automatic scram did not cause the reactor to be shut down, then consideration should be given to evaluating the fuel for potential damage and the reporting requirements of 50. 72 should be considered for the transient event. CNS Basis Reference(s): 1. General Operating Procedure 2.1.5, Reactor Scram. 2. Emergency Procedure 5.8.3, Alternate Rod Insertion Methods. 3. AMP-TBDOO, Appendix B, Step RC/Q-4. 4. USAR Table VII 2. EPIP 5.7.1 REVISION 58 PAGE 213 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: Subcategory: S -System Malfunction 2 -ATWS/Criticality Initiating Condition: Automatic scram fails to shut down the reactor and manual actions taken from the reactor control console are not successful in shutting down the reactor EAL: SS2.1 Site Area Emergency An automatic scram failed to shut down the reactor AND Manual actions taken at the reactor control console (NOTE 5) do not shut down the reactor as indicated by reactor power;::: 3°/o !

Reactor Scram pushbuttons. !

Reactor Mode switch in SHUTDOWN. i

Manual or auto actuation of ARI. . L----*---------------.., ___ --.. ** -. -------------------"-..: -------------.. ---------------------*----::--------------------------------------1 Mode Applicability: 1 -Power Operation, 2 -Startup NEI 99-01 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. 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) at which causes or should cause control rods to be rapidly inserted into the core and shuts down the reactor. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 214 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 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 shut down 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. CNS Basis: This EAL addresses any automatic reactor scram signal followed by a manual scram that fails to shut down the reactor to an extent the reactor is producing energy in excess of the heat load for which the safety systems were designed. Methods of inserting a manual scram are limited to those that can be taken rapidly at the reactor control console (Panel 9-5) and include (Reference 1):

Both manual Reactor Scram pushbuttons.

Reactor Mode switch in SHUTDOWN.

Manual or auto actuation of ARI. Auto actuation of ARI is included in the list of methods because the Operator, by procedure, always ensures actuation of ARI has occurred if the ARI actuation setpoints are exceeded. This means action to depress the ARI pushbuttons is taken if the automatic ARI actuation setpoints are exceeded but failed to actuate. If ARI properly actuates automatically, the ARI pushbuttons are not depressed. Reactor shutdown achieved by use of the alternate rod insertion methods listed in Emergency Procedure 5.8.3 do not constitute a successful manual scram (Reference 2). The APRM downscale trip setpoint (3o/o) is a minimum reading on the power range scale that indicates power production. It also approximates the decay heat which the shutdown systems were designed to remove and is indicative of a condition requiring immediate response to prevent subsequent core damage. Below the APRM downscale trip setpoint, plant response will be similar to that observed during a normal shutdown. Nuclear instrumentation (APRM) indications or other reactor parameters (steam flow, RPV pressure, torus temperature trend) can be used to determine if reactor power is greater than 3°/o power (Reference 1, 3). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 215 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Escalation of this event to a General Emergency would be under EAL SG2.1 or Emergency Director judgment. CNS Basis Reference(s): 1. General Operating Procedure 2.1.5, Reactor Scram. 2. Emergency Procedure 5.8.3, Alternate Rod Insertion Methods. 3. AMP-TBDOO, Appendix B, Step RC/Q-4. EPIPS.7.1 REVISION 58 PAGE 216 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: S -System Malfunction Subcategory: 2 -ATWS/Criticality Initiating Condition: Automatic scram and all manual actions fail to shut down the reactor and indication of an extreme challenge to the ability to cool the core exists EAL: SG2.1 General Emergency Automatic and aH manual scrams were not successful AND Reactor power ;:;:.: 3°/o AND EITHER of the following exist or have occurred due to continued power generation: RPV level cannot be restored and maintained > -183 in. or cannot be determined OR Average torus water temperature and RPV pressure cannot be maintained within the Heat Capacity Temperature Limit (EOP/SAG Graph 7) Mode Applicability: 1 -Power Operation, 2 -Startup NEI 99-01 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. The extreme challenge to the ability to cool the core is intended to mean that the reactor vessel water level cannot be restored and maintained above Minimum Steam Cooling RPV Water Level as described in the EOP bases. Considerations include inability to remove heat via the main condenser or via the suppression pool or torus (e.g., due to high pool water temperature). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 217 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 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 off-site intervention time. CNS Basis: This EAL addresses the following:

Any automatic reactor scram signal followed by failure of the automatic scram and all subsequent manual scrams to shut down the reactor to an extent the reactor is producing energy in excess of the heat load for which the safety systems were designed (EAL 552.1); and

Indications that either core cooling is extremely challenged or heat removal is extremely challenged.

Reactor shutdown achieved by use of the alternate rod insertion methods listed in Procedure 5.8.3 are credited as a successful manual scram provided reactor power can be reduced below the APRM downscale trip setpoint before indications of an extreme challenge to either core cooling or heat removal exist (Reference 1). The APRM downscale trip setpoint is a minimum reading on the power range scale that indicates power production. It also approximates the decay heat which the shutdown systems were designed to remove and is indicative of a condition requiring immediate response to prevent subsequent core damage. Below the APRM downscale trip setpoint, plant response will be similar to that observed during a normal shutdown. Nuclear instrumentation (APRM) indications or other reactor parameters (steam flow, RPV pressure, torus temperature trend) can be used to determine if reactor power is > 3% power (Reference 1, 3). The combination of failure of both front line and backup protection systems to function in response to a plant transient, along with the continued production of heat, poses a direct threat to the Fuel Clad and RCS barriers. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 218 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Indication that core cooling is extremely challenged is manifested by inability to restore and maintain RPV water level above -183 inches (or cannot be determined). -183 inches is the Minimum Steam Cooling RPV Water Level (MSCRWL). The MSCRWL is the lowest RPV level at which the covered portion of the reactor core will generate sufficient steam to prevent any clad temperature in the uncovered part of the core from exceeding 1500°F (Reference 5). This water level is utilized in the EOPs to preclude fuel damage when RPV level is below the top of active fuel. RPV level below the MSCRWL for an extended period of time without satisfactory core spray cooling could be a precursor of a core melt sequence. A threshold prescribing declaration when a parameter value cannot be maintained above a specified limit does not require immediate action simply because the current value is below the limit (-183 inches), but does not permit extended operation below the limit. Because the systems used to restore water level have different volume and discharge pressure capabilities, and pressure control methods also have varying rates that RPV pressure can be modified to support injection, the threshold must be considered reached as soon as it is apparent that the limit cannot be attained within a reasonable amount of time. Determination of inability to restore and maintain RPV level is based on actions driven by EOPs to restore level. When RPV level cannot be determined, EOPs require entry to EOP-7B, RPV Flooding (Failure-to-Scram). RPV water level indication provides the primary means of knowing if adequate core cooling is being maintained. When all means of determining RPV water level are unavailable, the fuel clad barrier is threatened and reliance on alternate means of assuring adequate core cooling must be attempted. The instructions in EOP-7B specify these means, which include emergency depressurization of the RPV and injection into the RPV at a rate needed to flood to the elevation of the main steam lines or hold the Minimum Steam Cooling Pressures. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 219 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) The Heat Capacity Temperature Limit (HCTL) is the highest torus temperature from which Emergency RPV Depressurization will not raise torus pressure above the Primary Containment Pressure Limit (PCPL), 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 torus level. It is utilized to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant. This threshold is met when EOP-3A, Primary Containment Control, Step SP/T-5, is reached (Reference 4). This condition addresses loss of functions required for hot shutdown with the reactor at pressure and temperature. CNS Basis Reference(s): 1. General Operating Procedure 2.1.5, Reactor Scram. 2. Emergency Procedure 5.8.3, Alternate Rod Insertion Methods. 3. AMP-TBDOO Appendix B, Step RC/Q-4. 4. EOP-3A, Primary Containment Control. 5. NEDC 97-090J. EPIP 5. 7.1 REVISION 58 PAGE 220 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: S -System Malfunction Subcategory: 3 -Inability to Reach Shutdown Conditions Initiating Condition: Inability to reach required shutdown within Technical Specification limits EAL: SU3.1 Unusual Event Plant is not brought to required operating mode within Technical Specifications LCO action statement time Mode Applicability: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown NEI 99-01 Basis: Limiting Conditions of Operation (LCOs) require the plant to be brought to a required Shutdown 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 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months report under 10CFR50. 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 Unusual Event 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 an Unusual Event is based on the time at which the LCD-specified action statement time period elapses under the site Technical Specifications and is not related to how long a condition may have existed. Other required Technical Specification shutdowns that involve precursors to more serious events are addressed by other EALs. CNS Basis: None CNS Basis Reference(s): 1. Technical Specifications. EPIP 5.7.1 REVISION 58 PAGE 221 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: S -System Malfunction Subcategory: 4 -Instrumentation/Communications Initiating Condition: Unplanned loss of safety system annunciation or indication in the Control Room for 15 minutes or longer EAL: SU4.1 Unusual Event Unplanned loss of > approximately 75% of annunciators or indicators associated with safety systems on Control Room Panels 9-3, 9-4, 9-5, and c 15 min. (NOTE 3) -----.--------------------------------------------------------------------.--------;.------.-----------------------------------------------------------' NOTE 3 -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. : ---------.-.------------------*-----------------.------------.---.-.-------------*----.-------------------------.-:--------.--I Mode Applicability: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown NEI 99-01 Basis: This EAL is intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment. Recognition of the availability of computer based indication equipment is considered. "PLANNED" loss of annunciators or indicators includes scheduled maintenance and testing activities. Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 222 OF 334 AlTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) 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 10CFRSO. 72. If the shutdown is not in compliance with the Technical Specification action, the UE is based on SU3.1, Inability to Reach Required Shutdown Within Technical Specification Limits. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. This UE will be escalated to an Alert based on a concurrent loss of compensatory indications or if a SIGNIFICANT TRANSIENT is in-progress during the loss of annunciation or indication. CNS Basis: The availability of computer-based monitoring capability (i.e., PMIS, SPDS) is not a factor at the Unusual Event emergency classification level. Safety system annunciation and indication considered in this EAL is found on Control Room Panels 9-3, 9-4, 9-5, and C. The other annunciators and indicators are important to plant operation but are not important to safety (Reference 1-14). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 223 OF 334 '

I i I_ ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. System Operating Procedure 2.2.64, Annunciator System. 2. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1. 3. Alarm Procedure 2.3_9 2, Panel 9 Annunciator 9 2. 4. Alarm Procedure 2.3_9 3, Panel 9 Annunciator 9 3. 5. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1. 6. Alarm Procedure 2.3_9 2, Panel 9 Annunciator 9 2. 7. Alarm Procedure 2.3_9 3, Panel 9 Annunciator 9 3. 8. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1. 9. Alarm Procedure 2.3_9 2, Panel 9 Annunciator 9 2. 10. Alarm Procedure 2.3_C-1, Panel C -Annunciator C-1. 11. Alarm Procedure 2.3_C-2, Panel C -Annunciator C-2. 12. Alarm Procedure 2.3_C-3, Panel C -Annunciator C-3. 13. Alarm Procedure 2.3_C-4, Panel C -Annunciator C-4. 14. Abnormal Procedure 2.4ANN, Annunciator Failure. EPIP 5.7.1 REVISION 58 PAGE 224 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: S -System Malfunction Subcategory: 4 -Instrumentation Initiating Condition: Unplanned loss of safety system annunciation or indication in the Control Room with EITHER (1) a significant transient in-progress, or (2) compensatory indicators unavailable EAL: SA4.1 Alert Unplanned loss of > approximately 75% of annunciators or indicators associated with safety systems on Control Room Panels 9-3, 9-4, 9-5, and C (NOTE 3) for 15 min. (NOTE 3) AND EITHER: Any significant transient is in-progress, Table S-1 OR Compensatory indications are unavailable ---------------------------------------------------------------------------------------------------------------------*----------------i NOTE 3 -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 l condition will likely exceed the applicable time. ! Table 5-1 Significant Transients Reactor scram Runback > 25% thermal power Electrical load rejection > 25% full electrical load ECCS injection Thermal power oscillations > 10% Mode Applicability: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown (continued on next page) EPIP5.7.1 REVISION 58 PAGE 225 OF 334 ATTACHMENT 2 NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) This EAL is intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a SIGNIFICANT TRANSIENT. 11PLANNED" loss of annunciators or indicators includes scheduled maintenance and testing activities. Quantification is arbitrary, 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 function 0.f 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 lOCFRSO. 72. If the shutdown is not in compliance with the Technical Specification action, the UE is based on EAL SU3.1, Inability to Reach Required Shutdown Within Technical Specification Limits. "Compensatory indications" in this context includes computer based information such as PMIS/SPDS. 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. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 226 OF 334 ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis: PMIS and SPDS serve as redundant compensatory indicators which may be utilized in lieu of normal Control Room indicators. Safety system annunciation and indication considered in this EAL is found on Control Room Panels 9-3, 9-4, 9-5, and C. The other annunciators and indicators are important to plant operation but are not important to safety (Reference 1-14). Significant transients are listed in Table S-1 and include response to automatic or manually initiated functions such as scrams, runbacks involving > 25% thermal power change, electrical load rejections of > 25% full electrical load, ECCS injections, or thermal power oscillations of 10°/o or greater. CNS Basis Reference(s}: 1. System Operating Procedure 2.2.64, Annunciator System. 2. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1. 3. Alarm Procedure 2.3_9 2, Panel 9 Annunciator 9 2. 4. Alarm Procedure 2.3_9 3, Panel 9 Annunciator 9 3. 5. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1. 6. Alarm Procedure 2.3_9 2, Panel 9 Annunciator 9 2. 7. Alarm Procedure 2.3_9 3, Panel 9 Annunciator 9 3. 8. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1. 9. Alarm Procedure 2.3_9-.5-21 Panel 9 Annunciator 9 2. 10. Alarm Procedure 2.3_C-1, Panel C -Annunciator C-1. 11. Alarm Procedure 2.3_C-2, Panel C -Annunciator C-2. 12. Alarm Procedure 2.3_C-3, Panel C -Annunciator C-3. 13. Alarm Procedure 2.3_C-4, Panel C -Annunciator C-4. 14. Abnormal Procedure 2.4ANN, Annunciator Failure. EPIP 5.7.1 REVISION 58 PAGE 227 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: S -System Malfunction Subcategory: 4 -Instrumentation Initiating Condition: Inability to monitor a significant transient in-progress EAL: SS4.1 Site Area Emergency Loss of > approximately 75% of the annunciators or indicators associated with safety systems on Control Room Panels 9-3, 9-4, 9-5, and C for 2'.: 15 min. (NOTE 3) AND Any significant transient is in-progress, Table S-1 AND Compensatory indications are unavailable ,...-------_..;; ---,;; ---------------------:------______ _.._ -------------------------*--.-------.. ----... -----------------------------------...... -" -------: NOTE 3 -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 l _ _________________________________________________________ _ Table S-1 Significant Transients Reactor scram Runback > 25% thermal power Electrical load rejection > 25% full electrical load ECCS injection Thermal power oscillations > 10% Mode Applicability: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown (continued on next page) EPIPS.7.1 REVISION 58 PAGE 228 OF 334 ATIACHMENT 2 NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) This EAL is intended to recognize the threat to plant safety associated with the complete loss of capability of the Control Room Staff to monitor plant response to a SIGNIFICANT TRANSIENT. "PLANNED" and "UNPLANNED" actions are not differentiated since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor. Quantification is arbitrary; however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Manager be tasked with making a judgment 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 10CFRSO. 72. If the shutdown is not in compliance with the Technical Specification action, the UE is based on SU3.1, Inability to Reach Required Shutdown 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. "Compensatory indications" in this context includes computer based information such as PMIS/SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 229 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. CNS Basis: The availability of computer-based monitoring capability (i.e., PMIS, SPDS) is a factor at the Site Area Emergency classification level because they are compensatory non-alarming indication. Safety system annunciation and indication considered in this EAL is found on Control Room Panels 9-3, 9-4, 9-5, and C. The other annunciators and indicators are important to plant operation but are not important to safety (Reference 1-14). Significant transients are listed in Table S-1 and include response to automatic or manually initiated functions such as trips, runbacks involving > 25o/o thermal power change, electrical load rejections of > 25% full electrical load, ECCS injections, or thermal power oscillations of> 10%. Due to the limited number of safety systems in operation during Cold Shutdown, Refueling and Defueled Modes, this EAL is not applicable during these modes of operation. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 230 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s}: 1. System Operating Procedure 2.2.64, Annunciator System. 2. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1. 3. Alarm Procedure 2.3_9 2, Panel 9 Annunciator 9 2. 4. Alarm Procedure 2.3_9 3, Panel 9 Annunciator 9 3. 5. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1. 6. Alarm Procedure 2.3_9 2, Panel 9 Annunciator 9 2. 7. Alarm Procedure 2.3_9 3, Panel 9 Annunciator 9 3. 8. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1. 9. Alarm Procedure 2.3_9 2, Panel 9 Annunciator 9 2. 10. Alarm Procedure 2.3_C-1, Panel C -Annunciator C-1. 11. Alarm Procedure 2.3_C-2, Panel C -Annunciator C-2. 12. Alarm Procedure 2.3_C-3, Panel C -Annunciator C-3. 13. Alarm Procedure 2.3_C-4, Panel C -Annunciator C-4. 14. Abnormal Procedure 2.4ANN, Annunciator Failure. EPIP 5.7.1 REVISION 58 PAGE 231 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: S -System Malfunction Subcategory: 5 -Fuel Clad Degradation Initiating Condition: Fuel clad degradation EAL: SU5.1 Unusual Event SJAE monitor > 1.58E+3 mR/hr Mode Applicability: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown NEI 99-01 Basis: This EAL 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. Escalation of this EAL to the Alert level is via the Fission Product Barriers. This threshold addresses site-specific radiation monitor readings that provide indication of a degradation of fuel clad integrity. CNS Basis: Steam Jet Air Ejectors (SJAEs) remove all non-condensable gases from the condensers including air in-leakage and disassociated products originating in the reactor and exhausts them to the off-gas holdup volume. A rise in off-gas activity could therefore indicate damage to the fuel cladding, a potential degradation in the level of safety of the plant, and a potential precursor of more serious problems. The Technical Specification allowable limit is s 1 Ci/sec. The SJAE monitor Hi-Hi radiation setpoint is set at 50°/o of the instantaneous release limit and represents approximately 0.1 % fuel cladding damage. The SJAE monitor Hi-Hi radiation setpoint has been selected because it is operationally significant and is readily recognizable by the Control Room Operating Staff (Reference 2-6). The Off-Gas System isolates after a 15 minute time delay (Reference 2, 3). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 232 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) In the Hot Modes, a steam source is available from which non-condensables can be separated for processing by the Off-Gas System. The Cold Shutdown, Refueling, and Defueled Modes do not afford a transfer mechanism from which the off-gas radiation monitors can draw a valid sample. The radiation monitors lose a valid sample source when the air ejectors are not in service (Reference 2, 4, 5). CNS Basis Reference(s): 1. System Operating Procedure 2.2.55, Main Condenser Gas Removal System. 2. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1, C-4, OFFGAS TIMER INITIATED. 3. Alarm Procedure 2.3_9 1, Panel 9 Annunciator 9 1, C-5, OFFGAS HIGH RAD. 4. Abnormal Procedure 2.40G, Off-Gas Abnormal. 5. Emergency Procedure 5.2FUEL, Fuel Failure. 6. NEDC 02-004, Estimation of the Steam Jet Air Ejector Radiation Monitor, RMP-RM-150A(B), Readings Following a 1°/o Fuel Clad Release (Degraded Core) in the Reactor Coolant System. 7. Technical Specification LCO 3. 7 .5, Air Ejector Off-Gas. EPIP 5.7.1 REVISION 58 PAGE 233 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: S -System Malfunction Subcategory: 5 -Fuel Clad Degradation Initiating Condition: Fuel clad degradation EAL: SUS.2 Unusual Event Coolant 4.0 µCi/gm dose equivalent I-131 Mode Applicability: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown NEI 99-01 Basis: This EAL 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. Escalation of this EAL to the Alert level is via the Fission Product Barriers. This threshold addresses coolant samples exceeding coolant Technical Specifications for transient iodine spiking limits. CNS Basis: Elevated reactor coolant activity represents a potential degradation in the level of safety of the plant and a potential precursor of more serious problems. This EAL addresses reactor coolant samples exceeding Technical Specification LCO 3.4.6, which is applicable in Hot Operating Modes (Reference 1). CNS Basis Reference(s): 1. Technical Specification LCO 3.4.6. EPIP 5.7.1 REVISION 58 PAGE 234 OF 334 ATIACHMENT 2 Category: Subcategory: Initiating Condition: EAL: SU6.1 Unusual Event EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) S -System Malfunction 6 -RCS Leakage RCS leakage Unidentified or pressure boundary leakage > 10 gpm OR Identified leakage > 30 gpm (NOTE 6) ------------------------------------------------------------------------------------------*-------------------------------------,.. ----. NOTE 6 -See Table F-1, Fission Product Barrier Matrix, for possible escalation i ' above the Unusual Event due to RCS Leakage. . : -----------------------------------------.-.-.-.-.--------------------------------------------------------------------------------------___ , Mode Applicability: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown NEI 99-01 Basis: This EAL is included as an Unusual Event 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 normal operation should be excluded from this EAL. However, a relief valve that operates and fails to close per design should be considered applicable to this EAL 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 EAL to the Alert level is via Fission Product Barrier Degradation EA Ls. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 235 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis:

Leakage is monitored by utilizing the following techniques (Reference 1):

Sensing excess flow in piping systems.

Sensing pressure and temperature changes in the Primary Containment.

Monitoring for high flow and temperature through selected drains.

Sampling airborne particulate and gaseous radioactivity.

Drywell floor and equipment drain sump leak rate alarm system. The 10 gpm value for the unidentified drywell leakage was selected because it is observable with normal Control Room measurement of sump pump out rates (e.g., Drywell Sump Pump Flow RW-FR-528, red/blue pen, etc.). Drywell equipment Sump G and drywell floor drain Sump F each have a FILL UP RATE HIGH annunciator on Panel 9 2. If either sump fills from the low-level switch reset point to the high-level pump start point before a preset timer has timed out, the annunciator will alarm indicating the sumps are filling at an excessive rate. Sumps F and G will overflow to each other through a trench system. Drywell equipment and floor drain sump pump isolation valves isolate on RPV low water level 3 inches) or high drywell pressure 1.84 psig). A SRV that opens but cannot be closed from the Control Room meets this criterion and the UE should be declared. CNS Basis Reference(s): 1. System Operating Procedure 2.2.27, Equipment, Floor, and Chemical Drain System. 2. Alarm Procedure 2.3_9 2, Panel 9 Annunciator 9 2, B-1, DRYWELL EQUIP SUMP G HIGH FILL-UP RATE. 3. Alarm Procedure 2.3_9 2, Panel 9 Annunciator 9 2, B-2, DRYWELL FLOOR ORN SUMP F HI FILL-UP RATE. 4. Surveillance Procedure 6.LOG.601, Daily Surveillance Log -Modes 1, 2, and 3. 5. Technical Specification LCO 3.4.4, RCS Operational Leakage. 6. Technical Specification LCO 3.4.5, RCS Leakage Detection Instrumentation. 7. USAR Section X-14.0, Equipment and Floor Drainage Systems. EPIP 5.7.1 REVISION 58 PAGE 236 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: S -System Malfunction Subcategory: 7 -Loss of DC Power Initiating Condition: Loss of all vital DC power for 15 minutes or longer EAL: SS7 .1 Site Area Emergency < 105 VDC bus voltage indications on all vital 125 VDC buses (lA and 1B) for ;::: 15 min. (NOTE 3) f-NoiE :.: ______ _ i elapsed, but should declare the event as soon as it is determined that the t £9_ _________________________ ________ _ Mode Applicability: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown NEI 99-01 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 Rad Levels/Radiological Effluent, Fission Product Barrier Degradation. CNS Basis: 105 VDC is the minimum design bus voltage (Reference 4). The 125 VDC System supplies DC power to conventional station emergency equipment and selected Safeguard System loads. 125 VDC Distribution Panels supply control and instrument power for annunciators control logic power, and protective relaying. Figure S-2 illustrates the 125 VDC Power System (Reference 3). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 237 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) If 125 VDC Distribution Panel A is lost, the following major equipment is affected: RRMG A speed and breaker control, 4160V Bus lA, 1E, and lF breaker control and undervoltage logics, 480V Bus 1A and 1F breaker control, the right light in all Control Room annunciators, annunciator panels for Water Treatment, RHR A Gland Water, Auxiliary Steam Boiler C, DG-1 starting and breaker control logics, CS A, RCIC, and RHR A control logics, TIP valve control monitors, main generator voltage regulation, RFPT A trip logic, and ARI solenoid valve power. If 125 VDC Distribution Panel B is lost, the following major equipment is affected: RRMG B speed and breaker control, 4160V Bus 1B and 1G breaker control and undervoltage logics, 480V Bus lB and 1G breaker control, the left light in all Control Room annunciators, annunciator panels for ALRW, RHR B Gland Water, Auxiliary Steam Boiler D, DG-2 starting and breaker control logics, CS B, HPCI, and RHR B control logics, main generator trip logic, main generator and transformer protective relaying, bypass valves fail to control pressure after turbine trip and RFPT B trip logic. Battery chargers receive their power from 460V critical motor control centers. Each 125 VDC bus receives power from either a 125 VDC battery or a 125 VDC battery charger. The battery chargers receive their power from 460V critical motor control centers. The 250 VDC System supplies DC power to conventional station emergency equipment and selected Safeguard System loads. Although 250 VDC Buses 1A and 1B provide vital DC emergency power, 250 VDC Safety System loads (such as motor operated valves) also require 125 VDC control . power. Loss of 125 VDC buses alone, therefore, would render most Safeguard System loads inoperable (Reference 4, 5, 6). This EAL is the hot condition equivalent of the cold condition loss of DC power EAL CU6.1. (continued on next page) EPIP5.7.1 REVISION 58 PAGE 238 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. Emergency Procedure 5.3DC125, Loss of 125 VDC. 2. Surveillance Procedure 6.EE.607, 125V Station Battery Modified Performance Discharge Test. 3. BR 3058 DC One Line Diagram. 4. Technical Specifications B 3.8.4. 5. USAR Section Vlll-6.2. 6. USAR Section VIII-6.3. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 239 OF 334 l ATTACHMENT 2 EPIP 5.7.1 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Figure 5-2: 125 VDC Power System MCC-LX (20J MCC-TX I LK TK I I I N RCIC (1' N RX BLOG N '!j OE OIST, PANELA N DIST. PANEL B HPCI I I I I I GNO I MCCl-TX L ClET '""'ir_ --------6 REVISION 58 ) 126VDC SR"B gf HPCI PANEL M0-16 PAGE 240 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) \ Category: S -System Malfunction Subcategory: 8 -Communications Initiating Condition: Loss of all on-site or off-site communications capabilities EAL: SU8.1 Unusual Event Loss of all Table S-2 on-site (internal) communications capability affecting the ability to perform routine operations OR Loss of au Table S-2 off-site (external) communications methods affecting the ability to perform off-site notifications Table S-2 Communications Systems I System I Onsite Offsite (internal} (external} Station Intercom System "Gaitronics" I x Site UHF Radio Consoles x Radio Paging System ' x I I Alternate Intercom r x r f r Sound Power System x CNS On-Site Cell Phone System x x Telephone system (PBX) x x Federal Telecommunications System (FTS 2001) x Local Telephones (C.O. Lines) x CNS State Notification Telephones x Satellite Telephones x Mode Applicability: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown (continued on next page) EPIPS.7.1 REVISION 58 PAGE 241 OF 334 ATIACHMENT 2 NEI 99-01 Basis: EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) This EAL addresses loss of communications capability that either prevents the plant operations staff ability to perform routine tasks necessary for plant operations or inhibits the ability to communicate problems externally to off-site authorities from the Control Room. The loss of off-site communications ability encompasses the loss of all means of communications with off-site authorities and is expected to be significantly more comprehensive than the condition addressed by 10CFRSO. 72. The availability of one method of ordinary off-site 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 radio transmissions, individuals being sent to off-site locations, etc.) are being utilized to make communications possible. CNS Basis: _! covered by this EAL. '---------.. --.. -------___ ___,_. ____ -------------*---:-.---------------: -"!'-----.... -------------------":"'"' -.-:-----------------------------* .. On-site/off-site communications include one or more of the systems listed in Table S-2 (Reference 1).

Station Intercom System "Gaitronics": Permits communication between the different parts of the plant and it also incorporates a public address system for plant wide announcements.

Site UHF Radio Consoles: The site UHF radio system uses four repeaters; Base 1 and Base 2 are used by Operations, Base 3 and Base 4 are used by Security. These repeaters operate on different frequencies. All remote control, portable, and mobile units are capable of selecting either repeater.

Radio Paging System: CNS leases pagers and radio paging services from a telecommunications company. Pagers are issued to various Management and Emergency Response personnel at CNS and other NPPD locations. Pagers can be activated from any touch-tone phone, on-site or off-site.

Alternate Intercom: Provides an alternate in-plant communications network utilizing the back-up tone commander PBX System. This system is located in the ERP shack and has battery back-up.

Sound Powered System.

CNS On-Site Cell Phone System. (continued on next page) EPIP 5. 7.1 REVISION 58 PAGE 242 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE)

Telephone System (PBX): Provides voice communication between virtually all buildings, offices, and operation facilities within the station. The telephone system also provides communications between the plant and off-site facilities via the telephone switchboard network. The system allows Operating Crews to alert plant personnel in emergencies. The telephone company provides the normal and leased line services.

Federal Telecommunications System (FTS 2001): The Health Physics Network (HPN) and Emergency Notification System (ENS) provide communications between NRC and CNS during an emergency.

Local Telephones (C.O. Lines).

CNS State Notification Telephones: The CNS State Notification Telephone System is the primary means for the plant to make emergency notifications to state and local authorities. This system provides direct communication with the Nebraska State Patrol, the Missouri State Patrol, the Atchison County Sheriff's Department, and the Nemaha and Richardson County Sheriff's Departments.

Satellite Telephones. This EAL is the hot condition equivalent of the cold condition EAL CU4.1. CNS Basis Reference(s): 1. EPIP 5. 7COMMUN, Communications, Emergency Response Facility Communication Equipment attachment. EPIP 5.7.1 REVISION 58 PAGE 243 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: E -ISFSI Subcategory: None Initiating Condition: Damage to a loaded cask confinement boundary EAL: EU1.1 Unusual Event Damage to a loaded cask confinement boundary Mode Applicability: N/A NEI 99-01 Basis: An Unusual Event in this EAL 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. CNS Basis: Minor surface damage that does not affect storage cask boundary is excluded from the scope of this EAL. CNS Basis Reference(s): 1. Certificate of Compliance Number 1004, April 17, 2007. EPIP 5.7.1 REVISION 58 PAGE 244 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: Fission Product Barrier Degradation Subcategory: N/ A Initiating Condition: Any loss or any potential loss of Primary Containment EAL: FUl.1 Unusual Event Any loss or any potential loss of Primary Containment (Table F-1) Mode Applicability: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown NEI 99-01 Basis: None CNS Basis: Fuel Clad, RCS, and Primary Containment comprise the fission product barriers. Table F-1 (Attachment 3) lists the fission product barrier thresholds, bases, and references. Fuel Clad and RCS barriers are weighted more heavily than the Primary Containment barrier. Unlike the Fuel Clad and RCS barriers, the loss of either of which results in an Alert (EAL FAl.1), loss of the Primary Containment barrier in and of itself does not result in the relocation of radioactive materials or the potential for degradation of core cooling capability. However, loss or potential loss of the Primary Containment barrier in combination with the loss or potential loss of either the Fuel Clad or RCS barrier results in declaration of a Site Area Emergency under EAL FSl.1. CNS Basis Referenc:e(s): None EPIP 5.7.1 REVISION 58 PAGE 245 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: Fission Product Barrier Degradation Subcategory: N/ A Initiating Condition: Any loss or any potential loss of either Fuel Clad or RCS EAL: FA1.1 Alert Any loss or any potential loss of either Fuel Clad or RCS (Table F-1) Mode Applicability: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown NEI 99-01 Basis: None CNS Basis: Fuel Clad, RCS, and Primary Containment comprise the fission product barriers. Table F-1 (Attachment 3) lists the fission product barrier thresholds, bases, and references.

At the Alert classification level, Fuel Clad and RCS barriers are weighted more heavily than the Primary Containment barrier. Unlike the Primary Containment barrier, loss or potential loss of either the Fuel Clad or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability. Note that the loss or potential loss of Primary Containment barrier in combination with loss or potential loss of either Fuel Clad or RCS barrier results in declaration of a Site Area Emergency under EAL FS1. CNS Basis Reference(s): None EPIPS.7.1 REVISION 58 PAGE 246 OF 334 -

ATIACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: Fission Product Barrier Degradation Subcategory: N/ A Initiating Condition: Loss or potential loss of any two barriers EAL: FSl.1 Site Area Emergency Loss or potential loss of any two barriers (Table F-1) Mode Applicability: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown NEI 99-01 Basis: None CNS Basis: Fuel Clad, RCS, and Primary Containment comprise the fission product barriers. Table F-1 (Attachment 3) lists the fission product barrier thresholds, bases, and references. At the Site Area Emergency classification level, each barrier is weighted equally. A Site Area Emergency is therefore appropriate for any combination of the following conditions:

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

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

One barrier potential loss and a second barrier potential loss (i.e., potential loss -potential loss). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 247 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) At the Site Area Emergency classification level, the ability to dynamically assess the proximity of present conditions with respect to the threshold for a General Emergency is important. For example, the existence of Fuel Clad and RCS Barrier loss thresholds in addition to off-site dose assessments would require continual assessments of radioactive inventory and Primary Containment integrity in anticipation of reaching a General Emergency classification. Alternatively, if both Fuel Clad and RCS potential loss thresholds existed, the Emergency Director would have greater assurance that escalation to a General Emergency is less imminent. CNS Basis Reference(s): None EPIP 5.7.1 REVISION 58 PAGE 248 OF 334 ATTACHMENT 2 EMERGENCY ACTION LEVEL TECHNICAL BASES (INFORMATION USE) Category: Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Loss of any two barriers and loss or potential loss of third barrier EAL: FG1.1 General Emergency Loss of any two barriers AND Loss or potential loss of third barrier (Table F-1) Mode Applicability: 1 -Power Operation, 2 -Startup, 3 -Hot Shutdown NEI 99-01 Basis: None CNS Basis: Fuel Clad, RCS, and Primary Containment comprise the fission product barriers. Table F-1 (Attachment 3) lists the fission product barrier thresholds, bases, and references. At the General Emergency classification level each barrier is weighted equally. A General Emergency is therefore appropriate for any combination of the following conditions:

Loss of Fuel Clad, RCS, and Primary Containment barriers.

Loss of Fuel Clad and RCS barriers with potential loss of Primary Containment barrier.

Loss of RCS and Primary Containment barriers with potential loss of Fuel Clad barrier.

Loss of Fuel Clad and Primary Containment barriers with potential loss of RCS barrier. CNS Basis Reference(s): None EPIP 5.7.1 REVISION 58 PAGE 249 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) AlTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Introduction Table F-1 lists the threshold conditions that define the Loss and Potential Loss of the three fission product barriers (Fuel Clad, Reactor Coolant System, and Primary Containment). The table is structured so that each of the three barriers occupies adjacent columns. Each fission product barrier column is further divided into two columns; one for Loss thresholds and one for Potential Loss thresholds. The first column of the table (to the left of the Fuel Clad Loss column) lists the categories (types) of fission product barrier thresholds. The fission product barrier categories are: A. RPV Level. B. PC Pressure/Temperature. c. Isolation. D. ERD. E. Rad. F. Judgment. Each category occupies a row in Table F-1, thus forming a matrix defined by the categories. The intersection of each row with each Loss/Potential Loss column forms a cell in which one or more fission product barrier thresholds appear. If NEI 99-01 does not define a threshold for a barrier Loss/Potential Loss, the word "None" is entered in the cell. Thresholds are assigned sequential numbers so that they can be easily identified. If a cell in Table F-1 contains more than one numbered threshold, each of the numbered thresholds, if exceeded, signifies a Loss or Potential Loss of the barrier. It is not necessary to exceed all of the thresholds in a category before declaring a barrier Loss/Potential Loss. Subdivision of Table F-1 by category facilitates association of plant conditions to the applicable fission product barrier Loss and Potential Loss thresholds. This structure promotes a systematic approach to assessing the classification status of the fission product barriers. (continued on next page) EPIP 5. 7.1 REVISION 58 PAGE 250 OF 334 ATIACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) When equipped with knowledge of plant conditions related to the fission product barriers, the EAL-user first scans down the category column of Table F-1, locates the likely category and then reads across the fission product barrier Loss and Potential Loss thresholds in that category to determine if a threshold has been exceeded. If a threshold has not been exceeded, the EAL-user proceeds to the next likely category and continues review of the thresholds in the new category. If the EAL-user determines that any threshold has been exceeded, by definition, the barrier is lost or potentially lost -even if multiple thresholds in the same barrier column are exceeded, only that one barrier is lost or potentially lost. The EAL-user must examine each of the three fission product barriers to determine if other barrier thresholds in the category are lost or potentially lost. For example, if containment radiation is sufficiently high, a Loss of the Fuel Clad and RCS barriers and a Potential Loss of the Primary Containment barrier can occur. Barrier Losses and Potential Losses are then applied to the algorithms given in EALs FG1.1, FS1.1, FA1.1, and FU1.1 to determine the appropriate emergency classification. In the remainder of this attachment, the Fuel Clad barrier threshold bases appear first, followed by the RCS barrier, and finally the Primary Containment barrier threshold bases. In each barrier, the bases are given according category Loss followed by category Potential Loss beginning with Category A, then B, then C, then D, then E, and then F. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 251 OF 334 ATIACHMENT 3 A.. RPV Level B. PC Pressure /Temperature C.lsola!lan 0. ERO E.Rad F. Judgment FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) . ' .. 'i::.-; \"e ** Fuel Clad Barrier Loss i Potential Loss 1. due lo any : ll

I *159 in O I determined ln,OI' o:: RPV water level cannot be restored and maintained c;: i , rutQj'ed me! 1' 4,750gpm 0 I 111. and care flaw cannot f i

Cere damage i& occurrlng due ta : loss of core cooling j 2. Orywel1 radiation monitor (RMA*RM-40AJ8) >250Ef.Q3Rerr.Jtir 3 Primarycoolantactivlty > 300 vcilgm dose e(luivalentl*131 4 Wain Steam Line Rod1abcn Mw1itor Readings;?. Hf-Hl Alarm seipolnt 5, 1 5E4 mrem/hr on SJAE monitor 6, Non-LOCA wittl DW Rad V,Qnitor reading > 11 S REM/hr I ! i I .. -* -7. Any condibon in the opinion of !he Emergency Oirectorthat loS'io Fud.0"'1 19 in ; EmergencyDirecicr t 1hatindic.ate$potential t 111e Fuel Clad Reactor Coolant System Barrier Loss "'-1SB in. orcaniiotbe determined 11. PC preuure:. ta4 psi51 due to RCS lee.k:ege ' i I I Potential Loss t2 p:ilrlwey e11'ii : 16.RCS leak.as a ::. 50 gpm inside ltle 01ootihio 1 dry-Nell Qilurc: lnenycf -"1kom:an : 'rn}: : '. l : fine !:, value (EOP-SA Tables 9 and 10)

Feedwaler 11 RPV ls required 14 DfyweU radiation monitor (RMA-RM-40AIB) :i-2 40E+02 Refl"'./tlr 15.Anyi:ondlticninthe opnioo of the ofthsRCSbarrier Primary Containment Barrier Loss 19'.PC preSS1Jre rise followed by a rapid drop in PC preswre 20 PC prHf>Ure response ncl with LOCA ccnditions 21.Faitur6 of all valve'i In an)" one line 10 dose ANO Direct downstream pathway lo lhe Ernvlronment after PC signal Zl..lntentional PC venting per C:OF's 23.. Unlsolable primary system discharge outside PC as indiected by exceeding any secondary <<in!Ginment Maximum Safe ()perming temperature or r&diation vaiu" (EOP-5A Tables !ii 1.1nd 1:>) 24 Any condition iri op;n1cn of tile Emergency Director that lr.dli:ates loss of !he PC barrier Potential Loss 2.5 SAG 1 ertry j 26.PC pn:swre:. 56 psig and rising I 27.Deflagration conccntriltiCtlS el(JSt inside PC I In dryweU or lorus I (or cannol be J 28 Average tonis water tempe1"11t!Jre and RPV : preu.ure cannot be cnalntalned within the Ht:at ; Capacity Temperature Limit {E0?1SAG Graph 7) "'" -129,0ryw-ell radiation monitor (RIJIA-RM-40A/8) ! ::> 5 OOE+04 Rem/hr i i ' j :30.An)" eoncf.fi*:m ii"I lh!! opinion of t?I& Emergency : Oirector that indicates potential los'i of the-PC : barrier ! EPIP 5.7.1 REVISION 58 PAGE 252 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Fuel Clad Category: A. RPV Level Degradation Threat: Loss Threshold: 1. SAG 1 entry is required due to any of the following:

Non-Failure-to-Scram: o RPV water level cannot be restored and maintained > -183 in., or o RPV water level cannot be restored and maintained 2 -209 in. and no core spray subsystem flow can be restored and maintained 2 4,750 gpm

Failure-to-Scram: o RPV water level cannot be restored and maintained > -183 in. and core steam flow cannot be restored and maintained > 800,000 lbm/hr

Core damage is occurring due to loss of core cooling. NEI 99-01 Basis: The "Loss" threshold 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. CNS Basis: EOP-1A, EOP-2B, EOP-7A, and EOP-7B specify entry into SAG 1 when it is determined that core damage is occurring due to loss of core cooling (Reference 1). SAG entry signifies the need to implement severe accident mitigation actions. These EOPs provide instructions to ensure adequate core cooling by maintaining RPV water level above prescribed limits or operating sufficient RPV injection sources when level cannot be determined. (continued on next page) EPIP 5. 7.1 REVISION 58 PAGE 253 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) SAG 1 entry is required during Non-Failure-to-Scram events when any of the following conditions exist (Reference 1):

RPV water level cannot be restored and maintained above -183 inches (MSCRWL, EOP-1A) (Reference 2, 6).

RPV water level cannot be restored and maintained at or above -209 inches (elevation of the jet pump suction) and no core spray subsystem flow can be restored and maintained equal to or;;::: 4,750 gpm (design core spray flow, EOP-1A) (Reference 2, 7). SAG 1 entry is required during Failure-to-Scram events when RPV water level cannot be restored and maintained > -183 inches and core steam flow cannot be restored and maintained > 800,000 lbm/hr (Reference 3, 6). *The specified steam flow is the Minimum Core Steam Flow (MCSF). The MCSF is the lowest core steam flow sufficient to preclude any clad temperature from exceeding 1500°F even if the reactor core is not completely covered (Reference 6). The MCSF is only applicable in failure-to-scram events because reactor power must be well above the decay heat generation rate for steam production to equal the MCSF. Whether or not RPV water level can be determined, SAG 1 entry is also required when core damage is occurring due to loss of core cooling (EOP-lA, EOP-2B, EOP-7A, or EOP-7B) (Reference 2, 3, 4, 5). If RPV water level cannot be determined, the absence of core damage indications may be the only means of determining if adequate core cooling is being maintained. If RPV water level can be determined, restoration of RPV water level to above -183 inches and restoration of core spray cooling requirements may not occur iri a timely manner. If indications of core damage occur while RPV injection is being restored, entry to SAG 1 is appropriate even if the required water levels and spray cooling flow are eventually achieved. Fuel Clad Losses 2 and 6 (drywell radiation), 3 (primary containment activity), 4 (MSL Hi-Hi Rad), and 5 (SJAE Monitor dose rate) are thresholds that would be indicative of core damage occurring due to loss of core cooling. The above EOP conditions represent a challenge to core cooling and are the minimum values to assure core cooling without further degradation of the clad. This threshold is also a Potential Loss of the Primary Containment barrier (PC P-Loss 25). Since the EOP requirement for SAG 1 entry is reached after core uncovery has occurred, a Loss of the RCS barrier exists (RCS Loss 10). SAG entry, therefore, represents a Loss of two barriers and a Potential Loss of a third, which requires a General Emergency classification. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 254 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) The EALs are aligned to the updated guidance of EPG/SAG Revision 3 such that the plant Operator can readily implement both when needed (Reference 8). CNS Basis Reference(s): 1. AMP-TBDOO PSTG/SATG Technical Bases, RC/L, Contingency #1, #4, #5. 2. EOP-1A, RPV Control. 3. EOP-7A, RPV ,Level (Failure-to-Scram). 4. EOP-2B, RPV Flooding. 5. EOP-7B, RPV Flooding (Failure-to-Scram). 6. NEDC 97-090J. 7. NEDC 97-089. 8. EPFAQ Number 2015-004. EPIP 5.7.1 REVISION 58 PAGE 255 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Fuel Clad Category: A. RPV Level Degradation Threat: Potential Loss Threshold: 8. RPV level cannot be restored and maintained > -158 in. or cannot be determined NEI 99-01 Basis: This threshold is the same as the RCS barrier "Loss" Threshold A.10 and corresponds to the 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 RCS barrier that appropriately escalates the emergency classification level to a Site Area Emergency. CNS Basis: The KEY consideration of this criterion is adequate core cooling. RPV conditions that result in inadequate core cooling shall result in determinations that the fuel clad barrier has been potentially lost and the RCS barrier has been lost. A RPV level instrument reading of -158 inches indicates RPV level is at the top of active fuel (TAF) (Reference 4). When RPV level is at or above TAF, the core is completely submerged. Core submergence is the most desirable means of core cooling. When RPV level is below TAF, the uncovered portion of the core must be cooled by less reliable means (i.e., steam cooling or spray cooling). To reach this level, RPV inventory loss would have previously required isolation of the RCS and Primary Containment barriers, and initiation of all ECCS. If after RPV pressure reduction (either manually, automatically, or by failure of the RCS barrier), RPV level cannot be restored and maintained above TAF, ECCS and other sources of RPV injection have been ineffective or incapable of reversing the decreasing level trend. If core uncovery is threatened, the EOPs specify alternate, more extreme, RPV level control measures in order to restore and maintain adequate core cooling. Since core uncovery begins if RPV level drops below TAF, the level is indicative of a challenge to core cooling and the Fuel Clad barrier. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 256 OF 334 ATIACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) EOPs allow the Operator a wide choice of RPV injection sources to consider when evaluating if RPV water level can be restored and maintained to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, an important consideration is the status of adequate core cooling during the pressure reduction process. A rapid depressurization which allows refilling the RPV with a high volume system will normally maintain adequate cooling with steam flow. Slow depressurizations, however, may challenge adequate core cooling due to both low water levels and low steam flows. A threshold prescribing declaration when a parameter value cannot be maintained above a specified limit does not require immediate action simply because the current value is below the limit (top of active fuel), but does not permit extended operation below the limit. Because the systems used to restore water level have different volume and discharge pressure capabilities, and pressure control methods also have varying rates that RPV pressure can be modified to support injection, the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained within a reasonable amount of time. Determination of inability to restore and maintain RPV level is based on actions driven by EOPs to restore level. In high-power ATWS/failure to scram events, EOPs may direct the Operator to deliberately lower RPV water level to the top of active fuel in order to reduce reactor power. RPV water level is then controlled between the top of active fuel and the Minimum Steam Cooling RPV Water Level (MSCRWL). Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority. For such events, ICs SA2, SS2, and SG2 will dictate an emergency classification. The fission product barrier criteria should continue to be evaluated independently to identify barrier conditions that would require escalation of the classification. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 257 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) When RPV level cannot be determined, EOPs require entry to EOP-28, RPV Flooding, or EOP-7B, RPV Flooding (Failure-to-Scram). RPV water level indication provides the primary means of knowing if adequate core cooling is being maintained. When all means of determining RPV water level are unavailable, the fuel clad barrier is threatened and reliance on alternate means of assuring adequate core cooling must be attempted. The instructions in EOP-2B/7B specify these means, which include emergency depressurization of the RPV and injection into the RPV at a rate needed to flood to the elevation of the main steam lines or hold the Minimum Steam Cooling Pressures (in scram-failure events). If RPV water level cannot be determined with respect to the top of active fuel, a potential loss of the fuel clad barrier exists (Reference 1, 3). CNS Basis Reference(s): 1. EOP-28, RPV Flooding. 2. EOP-7A, RPV Level (Failure-to-Scram). 3. EOP-78, RPV Flooding (Failure-to-Scram). 4. NEDC 97-089. EPIP 5.7.1 REVISION 58 PAGE 258 OF 334 ATIACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Category: Fuel Clad E. Rad Degradation Threat: Loss Threshold: j 2. Drywell radiation monitor (RMA-RM-40A/B) > 2.50E+03 Rem/hr NEI 99-01 Basis: 2. 50E+03 Rem/hr is a value which indicates the release of reactor coolant, with elevated activity indicative of fuel damage, into the drywell. The reading was calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with a concentration of approximately 300 µCi/gm dose equivalent I-131 (IV 1°/o clad damage) into the drywell 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. This value is higher than that specified for RCS barrier Loss Threshold 14. Thus, this threshold indicates a loss of both Fuel Clad barrier and RCS barrier that appropriately escalates the emergency classification level to a Site Area Emergency. CNS Basis: EPIP 5.7.17.1, Dose Assessment (Manual), Core Damage Estimation attachment provides a method of calculating percent fuel clad damage and fuel melt based on drywell radiation. Under LOCA conditions, a reading of 2.44E+6 Rem/hr corresponds to 100% core melt on drywell radiation Monitors RMA-RM-40A/B. A value of 2.44E+3 Rem/hr (rounded to 2.50E+03 Rem/hr) yields 1°/o fuel clad damage using this method. In order to reach this Fuel Clad barrier Potential* Loss threshold, a loss of the RCS barrier has already occurred (see RCS Loss 14 ). This threshold, therefore, represents at least a Site Area Emergency classification. CNS Basis Reference(s): 1. EPIP 5.7.17.1, Dose Assessment (Manual). EPIPS.7.1 REVISION 58 PAGE 259 OF 334

-, ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Fuel Clad Category: E. Rad Degradation Threat: Loss Threshold: 13. Primary coolant activity> 300 µCi/gm dose equivalent I-131 NEI 99-01 Basis: Coolant activity of 300 µCi/gm dose equivalent I-131 is well above that expected for iodine spikes and corresponds to about 1 % fuel clad damage. This amount of radioactivity indicates significant clad damage and thus, the Fuel Clad Barrier is considered lost. CNS Basis: None CNS Basis Reference(s): 1. EPIP 5.7.17, CNS-DOSE Assessment, and/or EPIP 5.7.17.1, Dose Assessment (Manual). 2. NEI 99-01, Revision 5. 3. NEDC 02-20, Estimation of Reactor Coolant System Dose Equivalent I-131 Concentration Following a 1 % Fuel Clad Failure (Degraded Core) Under Non-LOCA Conditions. EPIP 5.7.1 REVISION 58 PAGE 260 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Fuel Clad Category: E. Rad Degradation Threat: Loss Threshold: 4. Main Steam Line Radiation Monitor Readings Hi-Hi Alarm Setpoint NEI 99-01 Basis: None CNS Basis: The Hi-Hi alarm setpoint for the Main Steam Line Radiation Monitors is based on a Control Rod Drop Accident. This accident is most severe when initiated at < 10% rated thermal power. The setpoint is a multiple of the normal full power background reading on these monitors that was observed during the previous operating cycle. Clad damage resulting in the Hi-Hi Main Steam Line Radiation Monitor Alarms due to a Control Rod Drop Accident could exceed 2°/o of the core's fuel rods. USAR XIV-6.2 discusses the Control Rod Drop Accident. Specific Emergency Director evaluation is required to determine if the requisite plant conditions exist that would make this criteria valid.©3 CNS Basis Reference{s): 1. EPIP 5.7.17, CNS-DOSE Assessment, and/or EPIP 5.7.17.1, Dose Assessment (Manual).

2. USAR XIV-6.2, Control Rod Drop Accident. EPIP 5.7.1 REVISION 58 PAGE 261 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Fuel Clad Category: E. Rad Degradation Threat: Loss Threshold: Is. ;::: 1.5E4 mrem/hr on SJAE Monitor NEI 99-01 Basis: None CNS Basis: NEDC 02-004 assumes that cladding damage has resulted in 300 µCi/gm of I-131 in the reactor coolant, that non-LOCA conditions exist, and that normal sample flow through the monitor is maintained. Under these conditions, the SJAE monitors are expected to reach 15,000 mrem/hr. If sample flow is lost or the monitors are isolated and they reach this point, they are assumed to have failed. Specific Emergency Director evaluation is required to determine if the requisite plant conditions exist that would make this criteria valid.©3 CNS Basis Reference(s): 1. EPIP 5.7.17, CNS-DOSE Assessment, and/or EPIP 5.7.17.1, Dose Assessment (Manual). 2. NEDC 02-004, Estimation of the Steam Jet Air Ejector Radiation Monitor RMP-RM-150A(B), Readings Following a 1°/o Fuel Clad Release (Degraded Core) in the Reactor Coolant System. EPIP 5. 7.1 REVISION 58 PAGE 262 OF 334 ATIACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Fuel Clad Category: E. Rad Degradation Threat: Loss Threshold: 16. Non-LOCA with DW Rad Monitor reading > 115 REM/hr NEI 99-01 Basis: None CNS Basis: NEDC 02-009 assumes that cladding damage has resulted in 300 µCi/gm of I-131 in the reactor coolant and that non-LOCA conditions exist. The calculated value is based strictly on shine from the RR System piping, and as a result, is only valid if primary containment parameters do not indicate increased RCS leakage. With increased RCS leakage, any contaminants in the coolant could be in closer proximity to the detectors (as an aerosol or vapor) causing the monitors to read higher. If elevated RCS leakage is suspected, a drywell radiation monitor reading of 2500 R/hr, per Criteria 2, is the appropriate threshold for this parameter to determine Fuel Clad failure. Specific Emergency Director evaluation is required to determine if the requisite plant conditions exist that would make this criteria valid.©3 CNS Basis Reference(s): 1. EPIP 5.7.17, CNS-DOSE Assessment, and/or EPIP 5.7.17.1, Dose Assessment (Manual). 2. NEDC 02-009, Estimation of Primary Containment High Range Monitor RMA RM 40A(B), Readings Following 1 % Clad Failure in the RCS Under Non-LOCA Conditions. EPIP5.7.1 REVISION 58 PAGE 263 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Fuel Clad Category: F. Judgment Degradation Threat: Loss Threshold: 7. Any condition in the opinion of the Emergency Director that indicates loss of the Fuel Clad barrier N EI 99-01 Basis: This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad barrier is lost. In addition, the inability to monitor the barrier should also be considered as a factor in Emergency Director judgment that the barrier may be considered lost. CNS Basis: The Emergency Director judgment threshold addresses any other factors relevant to determining if the Fuel Clad barrier is lost. Such a determination should include imminent barrier degradation, barrier monitoring capability, and dominant accident sequences.

Imminent barrier degradation exists if the degradation will likely occur within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months based on a projection of current safety system performance. The term "imminent" refers to recognition of the inability to reach safety acceptance criteria before completion of all checks.

Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation, and consideration of off-site monitoring results.

Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Director should be mindful of the Loss of AC power (Station Blackout) and ATWS EALs to assure timely emergency classification declarations. CNS Basis Reference(s): None EPIP 5.7.1 REVISION 58 PAGE 264 OF 334 ATIACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Fuel Clad Category: F. Judgment Degradation Threat: Potential Loss* Threshold: 9. Any condition in the opinion of the Emergency Director that indicates potential loss of the Fuel Clad barrier NEI 99-01 Basis: This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad barrier is potentially lost. In addition, the inability to monitor the barrier should also be considered as a factor in Emergency Director judgment that the barrier may be considered potentially lost. CNS Basis: The Emergency Director judgment threshold addresses any other factors relevant to determining if the Fuel Clad barrier is potentially lost. Such a determination should include imminent barrier degradation, barrier monitoring capability, and dominant accident sequences.

Imminent barrier degradation exists if the degradation will likely occur within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months based on a projection of current safety system performance. The term "imminent" refers to recognition of the inability to reach safety acceptance criteria before completion of all checks.

Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation, and consideration of off-site monitoring results.

Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Director should be mindful of the Loss of AC power (Station Blackout) and ATWS EALs to assure timely emergency classification declarations. CNS Basis Reference{s): None EPIP 5.7.1 REVISION 58 PAGE 265 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Reactor Coolant System Category: A. RPV Level Degradation Threat: Loss Threshold: 10. RPV level cannot be restored and maintained > -158 in. or cannot be determined NEI 99-01 Basis: The Loss threshold for RPV water level corresponds to the level that is used in EOPs to indicate challenge of core cooling. This threshold is the same as Fuel Clad Barrier Potential Loss Threshold #8 and corresponds to a challenge to core cooling. Thus, this threshold indicates a Loss of RCS barrier and Potential Loss of Fuel Clad barrier that appropriately escalates the emergency classification level to a Site Area Emergency. There is no Potential Loss threshold associated with this item. CNS Basis: The KEY consideration of this criterion is the ability to maintain adequate core cooling. RPV conditions that result in inadequate core cooling shall result in determinations that the fuel clad barrier has been potentially lost and the RCS barrier has been lost. A RPV level instrument reading of -158 inches indicates RPV level is at the top of active fuel (TAF) (Reference 4). TAF is significantly lower than the normal operating RPV level control band. To reach this level, RPV inventory loss would have previously required isolation of the RCS and Primary Containment barriers, and initiation of all ECCS. If after RPV pressure reduction (either manually, automatically, or by failure of the RCS barrier), RPV level cannot be restored and maintained above TAF, ECCS, and other sources of RPV injection have been ineffective or incapable of reversing the decreasing level trend. The cause of the loss of RPV inventory is therefore assumed to be a LOCA. By definition, a LOCA event is a Loss of the RCS barrier. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 266 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) EOPs allow the Operator a wide choice of RPV injection sources to consider when evaluating if RPV water level can be restored and maintained to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, an important consideration is the status of adequate core cooling during the pressure reduction process. A rapid depressurization which allows refilling the RPV with a high volume system will normally maintain adequate cooling with steam flow. Slow depressurizations, however, may challenge adequate core cooling due to both low water levels and low steam flows. A threshold prescribing declaration when a parameters value cannot be maintained above a specified limit does not require immediate action simply because the current value is below the limit (top of active fuel), but does not permit extended operation below the limit. Because the systems used to restore water level have different volume and discharge pressure capabilities, and pressure control methods also have varying rates that RPV pressure can be modified to support injection, the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained within a reasonable amount of time. Determination of inability to restore and maintain RPV level is based on actions driven by EOPs to restore level. In high-power ATWS/failure to scram events, EOPs may direct the Operator to deliberately lower RPV water level to the top of active fuel in order to reduce reactor power. RPV water level is then controlled between the top of active fuel and the Minimum Steam Cooling RPV Water Level (MSCRWL). Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority. For such events, ICs SA2, 552, and SG2 will dictate an emergency classification. The fission product barrier criteria should continue to be evaluated independently to identify barrier conditions that would require escalation of the classification. When RPV level cannot be determined, EOPs require entry to EOP-2B, RPV Flooding, or EOP-78, RPV Flooding (Failure-to-Scram). The instructions in EOP-2B/78 specify emergency depressurization of the RPV, which is defined to be a Loss of the RCS barrier (RCS Loss 10) (Reference 1, 3). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 267 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. EOP-2B, RPV Flooding. 2. EOP-7A, RPV Level (Failure-to-Scram). 3. EOP-7B, RPV Flooding (Failure-to-Scram). 4. NEDC 97-089. EPIP 5.7.1 REVISION 58 PAGE 268 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Reactor Coolant System Category: B. PC Pressure/Temperature Degradation Threat: Loss Threshold: j 1 i. PC pressure > 1.84 psig due to RCS leakage NEI 99-01 Basis: The threshold pressure value is the Primary Containment high pressure scram setpoint and is indicative of a LOCA event that requires ECCS response. There is no Potential Loss threshold associated with this item. CNS Basis: The Primary Containment (PC) high pressure scram setpoint is an entry condition to EOP-1A, RPV Control, and EOP-3A, Primary Containment Control (Reference 1, 2). Normal Primary Containment pressure control functions (e.g., operation of drywell cooling, SBGT, etc.) are specified in EOP-3A in advance of less desirable but more effective functions (e.g., operation of drywell or torus sprays, etc.). In the CNS design basis, Primary Containment pressures above the high pressure scram setpoint are assumed to be the result of a high-energy release into the containment for which normal pressure control systems are inadequate or incapable of reversing the increasing pressure trend. Pressures of this magnitude, however, can be caused by non-LOCA events such as a loss of drywell cooling or inability to control Primary Containment vent/purge (Reference 3). The threshold phrase " ... due to RCS leakage" focuses the barrier failure on the RCS instead of the non-LOCA malfunctions that may adversely affect Primary Containment pressure. PC pressure > 1.84 psig with corollary indications (drywell temperature, humidity, etc.) should therefore be considered a Loss of the RCS barrier. Loss of drywell cooling that results in pressure > 1.84 psig should not be considered a RCS barrier Loss. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 269 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) CNS Basis Reference(s): 1. EOP-1A, RPV Control. 2. EOP-3A, Primary Containment Control. 3. USAR Section XIV-6.3. EPIP 5.7.1 REVISION 58 PAGE 270 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Reactor Coolant System Category: C. Isolation Degradation Threat: Loss Threshold: 12. Release pathway exists outside Primary Containment resulting from isolation failure in any of the following (excluding normal process system flowpaths from an unisolable system):

Main steam line.

HPCI steam line.

RCIC steam line.

RWCU.

Feedwater. NEI 99-01 Basis: An unisolable RCS break outside Primary Containment is a breach of the RCS barrier. Thus, this threshold is included for consistency with the Alert emergency classification level. Large high-energy line breaks such as HPCI, Feedwater, RWCU, or RCIC that are unisolable represent a significant loss of the RCS barrier and should be considered as MSL breaks for purposes of classification. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 271 OF 334 AITACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) CNS Basis: The conditions of this threshold include required containment isolation failures allowing a flow path to the environment. A release pathway outside Primary Containment exists when flow is not prevented by downstream isolations. In the case of a failure of both isolation valves to close but in which no downstream flowpath exists, emergency declaration under this threshold would not be required. Similarly, if the emergency response requires the normal process flow of a system outside Primary Containment (e.g., EOP requirement to bypass MSIV low RPV water level interlocks and maintain the main condenser as a heat sink using main turbine bypass valves), the threshold is not met. The combination of these threshold conditions represent the loss of both the RCS and Primary Containment (see PC Loss 21) barriers and justifies declaration of a Site Area Emergency (i.e., Loss or Potential Loss of any two barriers). Even though RWCU and Feedwater Systems do not contain steam, they are included in the list because an unisolable break could result in the high-pressure discharge of fluid that is flashed to steam from relatively large volume systems directly connected to the RCS. CNS Basis Reference(s): 1. System Operating Procedure 2.2.33, High Pressure Coolant Injection System. 2. System Operating Procedure 2.2.56, Main Steam System. 3. System Operating Procedure 2.2.66, Reactor Water Cleanup. 4. System Operating Procedure 2.2.67, Reactor Core Isolation Cooling System. 5. BR 2041, Reactor Building Main Steam System. 6. BR 2042. 7. BR 2043. 8. BR 2044, HPCI System. EPIP 5.7.1 REVISION 58 PAGE 272 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Reactor Coolant System Category: C. Isolation Degradation Threat: Potential Loss Threshold: I 16. RCS leakage > 50 gpm inside the drywell NEI 99-01 Basis: 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 50 gpm leak; however, break propagation leading to significantly larger loss of inventory is If primary system leak rate information is unavailable, other indicators of RCS leakage should be used. CNS Basis: RCS leakage inside the drywell is normally determined by monitoring drywell equipment and floor drain sump pump out rates. This method of monitoring leakage may be isolated as part of the drywell isolation, and thus, may be unavailable. If primary system leak rate information is unavailable, other indicators of RCS leakage should be used (Reference 1-6). Inventory loss events, such as a stuck open SRV, should not be considered when referring to "RCS leakage" because they are not indications of a break, which could propagate. CNS Basis Reference(s): 1. System Operating Procedure 2.2.27, Equipment, Floor, and Chemical Drain System. 2. Alarm Procedure 2.3_9 2, Panel 9 Annunciator 9 2, B-1/B-2. 3. Surveillance Procedure 6.LOG.601, Daily Surveillance Log -Modes 1, 2, and 3. 4. Technical Specifications LCO 3.4.4, RCS Operational Leakage. 5. Technical Specifications LCO 3.4.5, RCS Leakage Detection Instrumentation. 6. USAR Section X-14.0, Equipment and Floor Drainage Systems. EPIP 5.7.1 REVISION 58 PAGE 273 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Reactor Coolant System Category: C. Isolation Degradation Threat: Potential Loss Threshold: 17. Unisolable primary system discharge outside Primary Containment as indicated by exceeding any Secondary Containment Maximum Normal Operating temperature or radiation value (EOP-SA Tables 9 and 10) NEI 99-01 Basis: Potential loss of RCS based on primary system leakage outside the Primary Containment is determined from temperature or area radiation Maximum Normal Operating values (EOP-SA, Tables 9 and 10) in the areas of the main steam line tunnel, main turbine generator, RCIC, HPCI, etc., which indicate a direct path from the RCS to areas outside Primary Containment. The indicators reaching the threshold barriers and confirmed to be caused by RCS leakage warrant an Alert classification. An unisolable leak which is indicated by a high alarm setpoint escalates to a Site Area Emergency when combined with Containment Barrier Loss Threshold 20 (after a containment isolation) and a General Emergency when the Fuel Clad Barrier criteria is also exceeded. CNS Basis: The presence of elevated general area temperatures or radiation levels in the Secondary Containment may be indicative of unisolable primary system leakage outside the Primary Containment. The Maximum Normal Operating values define this RCS threshold because they signify the onset of abnormal system operation. When parameters reach this level, equipment failure or mis-operation may be occurring. Elevated parameters may also adversely affect the ability to gain access to or operate equipment within the affected area. The locations into which the primary system discharge is of concern correspond to the areas addressed in EOP-SA, Secondary Containment Control, Tables 9 and 10 (Reference 1) (see below). (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 274 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) In general, multiple indications should be used to determine if a primary system is discharging outside Primary Containment. For example, a high area radiation condition does not necessarily indicate that a primary system is discharging into the Secondary Containment since this may be caused by radiation shine from nearby steam lines or the movement of radioactive materials. Conversely, a high area radiation condition in conjunction with other indications (e.g., room flooding, high area temperatures, reports of steam in the Secondary Containment, an unexpected rise in feedwater flowrate, or unexpected main turbine control valve closure) may indicate that a primary system is discharging into the Secondary Containment. As indicated by Note 5 in EOP-5A, Table 10, RP surveys and ARM teledosimetry system may be used for these indications. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 275 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) EOP-SA Table 9 -Secondary Containment Temperatures 9 SECONDARY CONTAINMENT TEMPERATURES SPDS16 Maximum Normal Operating Value Maximum Safe Operating Value NE Quad SE Quad NW Quad SW Quad and HPCI Room 1001' El. 976' El. 958' El. 903' El. and 931' El. EPIP 5.7.1 Any Temp. Switch Alarmed RCIC-TS-77 A RCIC-TS-77C RWCU-TS-117F RHR-TS-99C RHR-TS-99G HPCl-TS-1058 . HPCl-TS-1050 RWCU-TS-117B RHR:.TS-99A RHR-TS-99E MS-TS-126A MS-TS*126C RWCU-TS-117E RWCU-TS-117A HPCl-TS-1058 NE Quad SE Quad NW Quad SW Quad and HPCIRoom 1001' El. 976'EI. 958' El. 903'EI. and 931' El. Value (F) 195 195 195 195 195 195 (continued on next page) REVISION 58 Actual Value PAGE 276 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) EOP-SA Table 10 -Secondary Containment Radiation Levels 10 SECONDARY CONTAINMENT RADIATION LEVELS SPDS 15 Maximum Normal Operating Value Maximum Safe Operating Value /\oy ARM Alarmed Range (mR/hr) FUEL POOL AREA FUEL POOL AREA RWCU PRECOAT AREA RWCU SLUDGE AND DECANT PUMP AREA CRD HYDRAULIC EQUIP AREA (SOUTH) CRD HYDRAULIC EQUIP AREA (NORTH) RMA*RA-1 RMA-RA-2 RMA-RA-4 RMA-RA-5 RMA-RA-8 RMA-RA-9 100 -106 .01 -100 0.1 -1000 0.1 -1000 .01 -100 .01 -100 Aw. Value (mR/hr) Actual Value 1001' El. 1001' El. 958'EI. 931' El. 903'EI. 1000 1000 ------------------------------.----*-*----*--*----*--*---* -.. --*----.. --------HPCI PUMP ROOM RHR PUMP ROOM, (SOUTHWEST) TORUS HPV AREA (SOUTHWEST) RHR PUMP ROOM, (NORTHWEST) RCIC/CORE SPRAY PUMP ROOM, (NORTHEAST) CORE SPRAY PUMP ROOM, RMA-RA-10 RMA-RA-11 RMA-RA-27 RMA-RA-12 RMA-RA-13 .01 -100 HPCI Room .01 -100 SW Quad 1000 1.0 -10000 SW Torus .01 -100 NW Quad 1000 .01-100 NE Quad 1000 (SOUTHEAST) RMA*RA-14 .01 -100 SE Quad 1000 CNS Basis Reference(s): NOTES Area radiation levels can be monitored by RP surveys or ARM teledosimetry system 1. EOP-SA, Secondary Containment Control. EPIPS.7.1 REVISION 58 PAGE 277 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Reactor Coolant System Category: D. ERD Degradation Threat: Loss Threshold: 13. Emergency RPV Depressurization is required NEI 99-01 Basis: Plant symptoms requiring Emergency RPV Depressurization are specified in the EOPs (Reference 1, 2, 4, 5, 8) and 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) (Reference 2, 7). 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. CNS Basis: Plant symptoms requiring Emergency RPV Depressurization per the 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). 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. Revision 3 of the BWROG EPG allows for limiting Reactor Pressure Vessel (RPV) depressurization by reclosing the Safety Relief Valves (SRVs) under certain conditions. This strategy is intended to prolong operation of steam-driven water injection sources required for adequate core cooling (e.g., RCIC System and/or HPCI) following an extended loss of AC power, and thus maintain the core cooling safety function. When the requirement to enact Emergency Depressurization occurs during such an event, Operators will determine if RPV depressurization will result in a loss of RCIC/HPCI, and, if so, terminate depressurization while maintaining RPV pressure as low as practicable. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 278 OF 334 ATIACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) There is no effect on the fission product barrier threshold intent. The relationship between the operationally significant action and the Reactor Coolant System (RCS) barrier status is unchanged, i.e., performing an Emergency RPV Depressurization per EOPs remains indicative of a loss of the RCS barrier, even though the SRVs may be reclosed. RCS mass has been lost to the wetwell and subsequent depressurizations may be required (i.e., the ability of the RCS pressure boundary to serve as an effective barrier to a release of fission products has been diminished). In conclusion, the threshold basis of this EAL remains in effect once the Emergency Depressurization starts, even though Operators may reclose the SRVs before the full depressurization is complete (Reference 1, 2, 3, 6, 9, and 10). CNS Basis Reference(s): 1. EOP-1A, RPV Control. 2. EOP-2A, Emergency RPV Depressurization/Steam Cooling. 3. EOP-2B, RPV Flooding. 4. EOP-3A, Primary Containment Control. 5. EOP-SA, Secondary Containment Control, Radioactivity Release Control. 6. EOP-6A, RPV Pressure (Failure to Scram). 7. EOP 6B, Emergency RPV Depressurization (Failure to Scram). 8. EOP-7A, RPV Control (Failure-to-Scram). 9. EOP 7B, RPV Flooding (Failure to Scram). 10. EPFAQ 2015-003. EPIP 5.7.1 REVISION 58 PAGE 279 OF 334 AlTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Reactor Coolant System Category: E. Rad Degradation Threat: Loss Threshold: j 14. Drywell radiation monitor (RMA-RM-40A/B) > 2.40E+02 Rem/hr -LOCA NEI 99-01 Basis: The 2.40E+02 Rem/hr value indicates the release of reactor coolant to the Primary Containment. The reading was calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with normal operating concentrations (i.e., within Technical Specifications) into the drywell atmosphere. This reading is less than that specified for Fuel Clad barrier Loss Threshold 2. 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 indicated. There is no Potential Loss threshold associated with this item. CNS Basis: EPIP 5. 7.17.1, Dose Assessment (Manual), Core Damage Estimation attachment provides a method of calculating percent fuel clad damage and fuel melt based on drywell radiation. Under LOCA conditions, a reading of 2.44E+6 Rem/hr corresponds to 100% core melt on RMA-RM-40A/B. A value of 2.44E+2 Rem/hr (rounded to 2.40E+02 Rem/hr) yields 0.1°/o fuel clad damage using this method. This amount of clad damage is approximately the equivalent of Technical Specification coolant activity discharged uniformly throughout the Primary Containment (Reference 1). CNS Basis Reference{s): 1. EPIP 5.7.17.1, Dose Assessment (Manual). EPIP 5.7.1 REVISION 58 PAGE 280 OF 334 ATIACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Reactor Coolant System Category: F. Judgment Degradation Threat: Loss Threshold: 15. Any condition in the opinion of the Emergency Director that indicates loss of the RCS barrier NEI 99-01 Basis: This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the RCS barrier is lost. In addition, the inability to monitor the barrier should also be considered in this threshold as a factor in Emergency Director judgment that the barrier may be considered lost. CNS Basis: The Emergency Director judgment threshold addresses any other factors relevant to determining if the RCS barrier is lost. Such a determination should include imminent barrier degradation, barrier monitoring capability, and dominant accident sequences.

Imminent barrier degradation exists if the degradation will likely occur within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months based on a projection of current safety system performance. The term "imminent" refers to the recognition of the inability to reach safety acceptance criteria before completion of all checks. e Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation, and consideration of off-site monitoring results.

Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Director should be mindful of the Loss of AC power (Station Blackout) and ATWS EALs to assure timely emergency classification declarations. CNS Basis Reference(s): None EPIP 5.7.1 REVISION 58 PAGE 281 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Reactor Coolant System Category: F. Judgment Degradation Threat: Potential Loss Threshold: 18. Any condition in the opinion of the Emergency Director that indicates potential loss of the RCS barrier NEI 99-01 Basis: This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the RCS barrier is potentially lost. In addition, the inability to monitor the barrier should also be considered in this threshold as a factor in Emergency Director judgment that the barrier may be considered potentially lost. CNS Basis: The Emergency Director judgment threshold addresses any other factors relevant to determining if the RCS barrier is potentially lost. Such a determination should include imminent barrier degradation, barrier monitoring capability, and dominant accident sequences.

Imminent barrier degradation exists if the degradation will likely occur within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months based on a projection of current safety system performance. The term "imminent" refers to recognition of the inability to reach safety acceptance criteria before completion of all checks.

Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation, and consideration of off-site monitoring results.

Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Director should be mindful of the Loss of AC power (Station Blackout) and ATWS EALs to assure timely emergency classification declarations. CNS Basis Reference(s): None EPIP 5.7.1 REVISION 58 PAGE 282 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Primary Containment Category: A. RPV Level Degradation Threat: Potential Loss Threshold: !2s. SAG 1 entry is required NEI 99-01 Basis: The potential loss requirement for SAG 1 indicates adequate core cooling cannot be established and maintained and that core melt is possible. Entry into the SAG 1 is a logical escalation in response to the inability to maintain adequate core cooling. EOPs direct SAG 1 entry when it is determined that core damage is occurring due to loss of core cooling (Reference 1): The condition in this potential loss threshold represents a potential core melt sequence which, if not corrected, could lead to vessel failure and increased 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. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 283 OF 334 ATTACHMENT 3 CNS Basis: FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) EOP-lA, EOP-2B, EOP-7A, and EOP-7B specify entry into SAG 1 when it is determined that core damage is occurring due to loss of core cooling (Reference 1). SAG entry signifies the need to implement severe accident mitigation actions. The EOPs provide instructions to ensure adequate core cooling by maintaining RPV water level above prescribed limits or operating sufficient RPV injection sources when level cannot be determined. SAG 1 entry is required during Non-Failure-to-Scram events when any of the following conditions exist (Reference 1):

RPV water level cannot be restored and maintained above -183 inches (MSCRWL, EOP-lA) (Reference 2, 6).

RPV water level cannot be restored and maintained at or above -209 inches (elevation of the jet pump suction) and no core spray subsystem flow can be restored and 4,750 gpm (design core spray flow, EOP-1A) (Reference 2, 7). SAG 1 entry is required during Failure-to-Scram events when RPV water level cannot be restored and maintained > -183 inches and core steam flow cannot be restored and maintained > 800,000 lbm/hr (Reference 3, 6). The specified steam flow is the Minimum Core Steam Flow (MCSF). The MCSF is the lowest core steam flow sufficient to preclude any clad temperature from exceeding 1500°F even if the reactor core is not completely covered (Reference 6). The MCSF is only applicable in failure-to-scram events because reactor power must be well above the decay heat generation rate for steam production to equal the MCSF. Whether or not RPV water level can be determined, SAG 1 entry is also required when core damage is occurring due to loss of core cooling (EOP-lA, EOP-2B, EOP-7A, or EOP-7B) (Reference 2, 3, 4, 5). If RPV water level cannot be determined, the absence of core damage indications may be the only means of determining if adequate core cooling is being maintained. If RPV water level can be determined, restoration of RPV water level to above -183 inches and restoration of core spray cooling requirements may not occur in a timely manner. If indications of core damage occur while RPV injection is being restored, entry to SAG 1 is appropriate even if the required water levels and spray cooling flow are eventually achieved. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 284 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) The above EOP conditions represent a potential core melt sequence which could lead to RPV failure and increased potential for containment failure. This threshold is also a Loss of the Fuel Clad barrier (FC Loss 1). Since SAG entry occurs after core uncovery has occurred, a Loss of the RCS barrier exists (RCS Loss 7). SAG entry, therefore, represents a Loss of two barriers and a Potential Loss of a third, which requires a General Emergency classification. The EALs are aligned to the updated guidance of EPG/SAG Revision 3 such that the plant Operator can readily implement both when needed (Reference 8). CNS Basis Reference(s): 1. AMP-TBDOO PSTG/SATG Technical Bases, RC/L, Contingency #1, #4, #5. 2. EOP-1A, RPV Control. 3. EOP-7A, RPV Level (Failure-to-Scram). 4. EOP-2B, RPV Flooding. 5. EOP-7B, RPV Flooding (Failure-to-Scram). 6. NEDC 97-090J. 7. NEDC 97-089. 8. EPFAQ 2015-004. EPIP 5.7.1 REVISION 58 PAGE 285 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Primary Containment Category: B. PC Pressure/Temperature Degradation Threat: Loss Threshold: 19. PC pressure rise followed by a rapid unexplained drop in PC pressure NEI 99-01 Basis: Rapid unexplained loss of pressure (i.e., not attributable to drywell spray or condensation effects) following an initial pressure increase from a high energy line break 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. CNS Basis: None CNS Basis Reference(s): None EPIPS.7.1 REVISION 58 PAGE 286 OF 334

--ATIACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Containment Category: B. PC Pressure/Temperature Degradation Threat: Loss Threshold: 20. PC pressure response not consistent with LOCA conditions NEI 99-01 Basis: Primary Containment pressure should increase initially as a result of mass and energy release into containment from a LOCA. Thus, Primary Containment pressure not initially increasing 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. CNS Basis: Analysis of the Primary Containment response to a postulated DBA LOCA event gives a peak drywell pressure of 54.4 psig and a peak drywell temperature of 301.4°F. These peak values were obtained for the power/flow point of 102%P/75%F (MELLL point). Due to conservatisms in LOCA analyses, actual pressure response is expected to be less than the analyzed response. For example, blowdown mass flowrate may be only 60% to 80% of the analyzed rate. The unexpected response is important because it is the indicator for a containment bypass condition (Reference 1). As stated in the NEI 99-01 basis, the anticipated response to a LOCA is that the Primary Containment pressure would increase. The failure of torus to drywell vacuum breaker(s) could cause peak Primary Containment pressure to be higher than the analyzed peak Primary Containment pressure, but this condition is addressed by the potential containment failure Criteria 26. As such, violation of the pressure suppression pressure curve (PSP) does not constitute a loss of the Primary Containment. CNS Basis Reference(s).: 1. USAR Section XIV-6.3.7. EPIP 5.7.1 REVISION 58 PAGE 287 OF 334 ATIACHMENT 3 Barrier: Category: Degradation Threat: Threshold: FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Primary Containment B. PC Pressure/Temperature Potential Loss j 26. PC pressure > 56 psig and rising NEI 99-01 Basis: The 56 psig for Potential Loss of containment is based on the Primary Containment design pressure.

CNS Basis: The Primary Containment internal design pressure is 56 psig (Reference 1). If this threshold is exceeded, a challenge to the Primary Containment structure has occurred because assumptions used in the accident analysis are no longer valid and an unanalyzed condition exists. This constitutes a Potential Loss of the Primary Containment barrier even if a containment breach has not occurred. CNS Basis Reference(s): 1. USAR Table V 1. EPIP 5.7.1 REVISION 58 PAGE 288 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Category: Degradation Threat: Threshold: Primary Containment B. PC Pressure/Temperature Potential Loss 27. Deflagration concentrations exist inside PC

z 6% H2 in drywell or torus (or cannot be determined) AND

z 5% 02 in drywell or torus or cannot be determined) NEI 99-01 Basis: BWRs specifically define the limits associated with explosive (deflagration) mixtures in terms of deflagration concentrations of hydrogen and oxygen. For Mk I/II containments, the deflagration limits are 116o/o hydrogen and 5% oxygen in the drywell or suppression chamber". CNS Basis: Deflagration (explosive) mixtures in the Primary Containment are assumed to be elevated concentrations of hydrogen and oxygen. BWR industry evaluation of hydrogen generation for development of EOPs/SAMGs indicates that any hydrogen concentration above minimum detectable is not to be expected within the short term. Post-LOCA hydrogen generation primarily caused by radiolysis is a slowly evolving, long-term condition. Hydrogen concentrations that rapidly develop are most likely caused by metal-water reaction. A metal-water reaction is indicative of an accident more severe than accidents considered in the plant design basis and would be indicative, therefore, of a potential threat to Primary Containment integrity. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 289 OF 334 ATIACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Except for brief periods during plant startup and shutdown, oxygen concentration in the Primary Containment is maintained at insignificant levels by nitrogen inertion. The specified values for this Potential Loss threshold are the minimum global deflagration concentration limits (6°/o hydrogen and 5°/o oxygen) and readily recognizable because 6% hydrogen is well above the EOP-3, Primary Containment Control, entry condition (Reference 2, 3). Since the EOPs/SAGs require deflagration concentration actions to be performed when hydrogen and oxygen concentrations cannot be determined, the phrase has been added to the meaning of explosive mixtures. The minimum global deflagration hydrogen/oxygen concentrations (6% and 5%, respectively) require intentional Primary Containment venting, which is defined to be a Loss of Containment (PC Loss 22). Drywell and suppression chamber atmosphere is monitored for H2 and 02 by a divisionally separated H2/02 Monitoring System. The system consists of two H2/02 analyzers (PC-AN-H2/02I and PC-AN-H2/021I), two remote process panels (PC-CS-H2/021 and PC-CS-H2/02II), two H2 recorders (PC-R-H21 and PC-R-H2II), two 02 recorders (PC-R-021 and PC-R-02II), an 02 digital indicator (PC-I-1), associated control switches and sample stream indicating lights. H2/02 analyzers are located in the Reactor Building at 976', remote process panels are located in the Cable Spreading Room, recorders are located on VBD-Pl and VBD-P2, the 02 digital indicator and sample stream lights are located on VBD-H. Div 2 is normally in service providing 02 concentration on VBD-H and H2 and 02 concentrations on PMIS (Reference 1). CNS Basis Reference(s): 1. System Operating Procedure 2.2.60.1, Containment H2/02 Monitoring System. 2. BWROG EPG/SAG Revision 2, Sections PC/G. 3. EOP-3A, Primary Containment Control. EPIP 5.7.1 REVISION 58 PAGE 290 OF 334 ATTACHMENT 3 Barrier: Category: Degradation Threat: Threshold: FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Primary Containment B. PC Pressure/Temperature Potential Loss 28. Average torus water temperature and RPV pressure cannot be maintained within the Heat Capacity Temperature Limit (EOP/SAG Graph 7) NEI 99-01 Basis: 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 Primary Containment 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. CNS Basis: This threshold is met when EOP-3, Primary Containment Control, Step SP/T-5 is reached (Reference 1). CNS Basis Reference(s): 1. EOP-3A, Primary Containment Control. EPIP 5. 7.1 REVISION 58 PAGE 291 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Primary Containment Category: C. Isolation Degradation Threat: Loss Threshold: 21. Failure of all valves in any one line to close AND Direct downstream pathway to the environment exists after PC isolation signal NEI 99-01 Basis: These thresholds address incomplete containment isolation that allows direct release to the environment. 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% to 99°/o 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. CNS Basis: This threshold addresses failure of open isolation devices which should close upon receipt of a manual or automatic containment isolation signal resulting in a significant radiological release pathway directly to the environment. The concern is the unisolable open pathway to the environment. A failure of the ability to isolate any one line indicates a breach of Primary Containment integrity. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 292 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Leakage into a closed system is to be considered only if the closed system is breached and thereby creates a significant pathway to the environment. Examples include unisolable Main steam line, HPCI steam line, or RCIC steam line breaks, unisolable RWCU System breaks, and unisolable containment atmosphere vent paths. If the main condenser is available with an unisolable main steam line, there may be releases through the steam jet air ejectors and gland seal exhausters. These pathways are monitored, however, and do not meet the intent of a non-isolable release path to the environment. These minor releases are assessed using the Category A, Abnormal Rad Release/Rad Effluent, EALs. The threshold is met if the breach is not isolable from the Control Room or an attempt for isolation from the Control Room has been made and was unsuccessful. An attempt for isolation from the Control Room should be made prior to the emergency classification. However, the expectation is that assessment, classification, and declaration of an emergency condition be made within 15 minutes after initial availability of the indication of a breach of Primary Containment integrity. If Operator actions from the Control Room are successful, this threshold is not applicable. Credit is not given for Operator actions taken in-plant (outside the Control Room) to isolate the breach. EOP-3A, Primary Containment Control, Step PC/P-6, may specify Primary Containment venting and intentional bypassing of the containment isolation valve logic, even if off-site radioactivity release rate limits are exceeded (Reference 1). Under these conditions with a valid containment isolation signal, the containment barrier should be considered lost under Criteria 22 for Intentional PC venting per EOPs. CNS Basis Reference(s): 1. EOP-3A, Primary Containment Control. EPIP 5.7.1 REVISION 58 PAGE 293 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Primary Containment Category: C. Isolation Degradation Threat: Loss Threshold: ! 22. Intentional PC venting per EOPs NEI 99-01 Basis: The EOPs 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 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. CNS Basis: EOP-3A, Primary Containment Control, Steps PC/P-3 and PC/P-8, may specify Primary Containment venting and intentional bypassing of the containment isolation valve logic, even if off-site radioactivity release rate limits are exceeded (Reference 1). The threshold is met when the Operator begins venting the Primary Containment in accordance with EOP-3A, not when actions are taken to bypass interlocks prior to opening the vent valves. Purge and vent actions specified in EOP-3A, Step PC/P-1, to control Primary Containment pressure below the Primary Containment high pressure scram setpoint does not meet this threshold because such action is only permitted if off-site radioactivity release rates will remain below ODAM limits. CNS Basis Reference(s): 1. EOP-3A, Primary Containment Control. EPIP 5.7.1 REVISION 58 PAGE 294 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Primary Containment Category: C. Isolation Degradation Threat: Loss Threshold: 23. Unisolable primary system discharge outside PC as indicated by exceeding any Secondary Containment Maximum Safe Operating temperature or radiation value (EOP-SA, Tables 9 and 10) NEI 99-01 Basis: The presence of area radiation levels or area temperatures above any Maximum Safe Operating value indicates 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. There is no Potential Loss threshold associated with this item. CNS Basis: The Maximum Safe Operating values define this Primary Containment barrier threshold because they are indicative of problems in the Secondary Containment that are spreading and pose a threat to achieving a safe plant shutdown. This threshold addresses problematic discharges outside Primary Containment that may not originate from a high-energy line break. The locations into which the primary system discharge is of concern correspond to the areas addressed in EOP-SA, Secondary Containment Control, Tables 9 and 10 (see below). In general, multiple indications should be used to determine if a primary system is discharging outside Primary Containment. For example, a high area radiation condition does not necessarily indicate that a primary system is discharging into the Secondary Containment since this may be caused by radiation shine from nearby steam lines or the movement of radioactive materials. Conversely, a high area radiation condition in conjunction with other indications (e.g., room flooding, high area temperatures, reports of steam in the Secondary Containment, an unexpected rise in feedwater flowrate, or unexpected main turbine control valve closure) may indicate that a primary system is discharging into the Secondary Containment. As indicated by NOTE 5 in EOP-SA, Table 10, RP surveys and ARM Teledosimetry System may be used for these indications. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 295 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) EOP-5A Table 9 -Secondary Containment Temperatures 9 SECONDARY CONTAINMENT TEMPERATURES SPDS16 Maximum Normal Operating Value Maximum Safe Operating Value NE Quad SE Quad NW Quad SW Quad and HPCI Room 100*1' El. 976' El. 958'EI. 903' El. and 931' El. EPIP5.7.1 Any Temp. Swjtch Alarmed RCIC-TS-77A RCIC-TS-77C RWCU-TS-117F RHR-TS-99C RHR-TS-99G HPCl-TS-1058 HPCl-TS-1050 RWCU-TS-1178 RHR-TS-99A RHR*TS-99E MS-TS*126A MS-TS-126C RWCU-TS*117E RWCU-TS-117A HPCl-TS-105A NE Quad SE Quad NW Quad SW Quad and HPCIRoom 1001' EL 976'EI. 958'EI. 903' El. and 931' El. Value (0E) 195 195 195 195 195 195 (continued on next page) REVISION 58 Actual Value PAGE 296 OF 334 ATTACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) EOP-SA Table 10 -Secondary Containment Radiation Levels 10 SECONDARY CONTAINMENT RADIATION LEVELS f0 SPDS 15 \:..I Maximum Normal Operating Value Maximum Safe Operating Value Any ARM Alarmed Range (mR/hr) Area Value (mR/hr) Acftia! Value FUEL POOL AREA FUEL POOL AREA RWCU PRECOAT AREA RWCU SLUDGE AND DECANT PUMP AREA CRD HYDRAULIC EQUIP AREA (SOUTH) CRD HYDRAULIC EQUIP AREA (NORTH} HPCI PUMP ROOM RHR PUMP ROOM, (SOUTHWEST) TORUS HPV AREA (SOUTHWEST) RHR PUMP ROOM, (NORTHWEST) RCIC/CORE SPRAY PUMP ROOM, (NORTHEAST) CORE SPRAY PUMP ROOM, RMA-RA-1 RMA-RA-2 RMA-RA-4 RMA-RA-5 RMA-RA-8 RMA-RA*9 RMA-RA-10 RMA-RA-11 RMA-RA-27 RMA-RA-12 RMA-RA-1.3 100 -106 .01 -100 0.1 -1000 0.1 -1000 . 01 -100 .01 -100 ,()1 -100 ,01 -100 1.0 -10000 .01 -100 .01 -100 1001' El. 1001' El. 958'EI. 1000 931'EI. 1000 903' El . HPCI Room SW Quad 1000 SW Torus NW Quad 1000 NE Quad 1000 (SOUTHEAST) RMA*RA-14 .01 -100 SE Quad 1000 CNS Basis Reference(s): NOTES Area radiation levels can be monitored by RP surveys or ARM teledosimetry system 1. EOP-SA, Secondary Containment Control. EPIPS.7.1 REVISION 58 PAGE 297 OF 334 ATIACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Primary Containment Category: E. Rad Degradation Threat: Potential Loss Threshold: 129. Drywell radiation monitor (RMA-RM-40A/B) > 5.00E+04 Rem/hr NEI 99-01 Basis: 50,000 Rem/hr is a value which indicates significant fuel damage well in excess of that required for loss of RCS and Fuel Clad. A major release of radioactivity requiring off-site protective actions from core damage is not possible unless a major failure of fuel cladding allows radioactive material to be released from the core into the reactor coolant. 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. 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 < 20°10. CNS Basis: EPIP 5.7.17.1, Dose Assessment (Manual), Core Damage Estimation attachment provides a method of calculating percent fuel clad damage and fuel melt based on drywell radiation. A reading of 2.44E+6 Rem/hr corresponds to 100°10 core melt on RMA-RM-40A/B. A value of 4.88E+4 Rem/hr (rounded to 5.00E+04 Rem/hr) yields 20°10 fuel clad damage using this method (Reference 1). CNS Basis Ref-erence(s): 1. EPIP 5.7.17.1, Dose Assessment (Manual). EPIP 5.7.1 REVISION 58 PAGE 298 OF 334 -----,

ATIACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) BarrHer: Primary Containment Category: F. Judgment Degradation Threat: Loss Threshold: 24. Any condition in the opinion of the Emergency Director that indicates loss of the PC barrier NEI 99-01 Basis: This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Primary Containment barrier is lost. In addition, the inability to monitor the barrier should also be considered as a factor in Emergency Director judgment that the barrier may be considered lost. The Containment barrier should not be declared 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. (continued on next page) EPIPS.7.1 REVISION 58 PAGE 299 OF 334 ATTACHMENT 3 CNS Basis: FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) The Emergency Director judgment threshold addresses any other factors relevant to determining if the Primary Containment barrier is lost. Such a determination should include imminent barrier degradation, barrier monitoring capability and dominant accident sequences.

Imminent barrier degradation exists if the degradation will likely occur within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months based on a projection of current safety system performance. The term "imminent" refers to recognition of the inability to reach safety acceptance criteria before completion of all checks.

Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation, and consideration of off-site monitoring results.

Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Director should be mindful of the Loss of AC power (Station Blackout) and ATWS EALs to assure timely emergency classification declarations. CNS Basis Reference(s): None EPIP 5.7.1 REVISION 58 PAGE 300 OF 334 ATIACHMENT 3 FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) Barrier: Primary Containment Degradation Threat: Potential Loss Category: F. Judgment Threshold: 30. Any condition in the opinion of the Emergency Director that indicates potential loss of the PC barrier NEI 99-01 Basis: This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Primary Containment barrier is potentially lost. In addition, the inability to monitor the barrier should also be considered as a factor in Emergency Director judgment that the barrier may be considered potentially lost. The Containment barrier should not be declared 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. (continued on next page) EPIP 5.7.1 REVISION 58 PAGE 301 OF 334 ATIACHMENT 3 CNS Basis: FISSION PRODUCT BARRIERS -INDICATIONS OF LOSS OR POTENTIAL LOSS TECHNICAL BASES (INFORMATION USE) The Emergency Director judgment threshold addresses any other factors relevant to determining if the Primary Containment barrier is potentially lost. Such a determination should include imminent barrier degradation, barrier monitoring capability, and dominant accident sequences.

Imminent barrier degradation exists if the degradation will likely occur within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months based on a projection of current safety system performance. The term "imminent" refers to recognition of the inability to reach safety acceptance criteria before completion of all checks.

Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation, and consideration of off-site monitoring results.

Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Director should be mindful of the Loss of AC power (Station Blackout) and ATWS EALs to assure timely emergency classification declarations. CNS Basis Reference(s): None EPIPS.7.1 REVISION 58 PAGE 302 OF 334 ATTACHMENT 4 EAL CLASSIFICATION MATRIX (INFORMATION USE) ATTACHMENT 4 EAL CLASSIFICATION MATRIX (INFORMATION USE} The following information defined in Attachment 1, EAL Scheme Explanation and Rationale, and contained in Attachment 2, Emergency Action Level Technical Bases, will be contained in the EAL Classification Matrix (Matrix or EAL Matrix):

EAL Identifier.

Mode Applicability.

EAL. The Matrix will also display the tables and notes from Attachments 2 and 3 applicable to the EALs. These items may be reformatted, arranged, and consolidated as required to facilitate use of the Matrix. The EALs will be arranged by Emergency Class left to right, greatest to least, then by Category and subcategory top to bottom, and finally by EAL identifier top to bottom where required. These Matrices will be controlled per this attachment. The information specified above will be word for word from Attachment 2 but may be formatted differently using different font sizes or color backgrounds to assist the visual presentation. Each Matrix will contain a Revision data box that will list the current matrix revision number based on the information below: EAL Classification Matrix Revision Data: Procedure EPIP 5.7.1, Attachment 4 EAL Classification Matrix Revision Number Revision 14 It is not necessary that the Matrix revision number be revised with each revision of this procedure. However, if the Matrix is revised or if the information specified above (EALs, Notes, or Tables) are revised in Attachment 2, then Attachment 4 and the matrix must be revised to reflect the revised information. Each controlled copy of the matrix will be labeled with the facility and copy number of the specific matrix card according to EPDG#2, Attachment F-5. Matrices that are not so labeled are uncontrolled and should be checked to verify the proper revision prior to use. Matrix distribution will be made to following locations in quantities specified in EPDG #2, Attachment F-5. EPIP 5.7.1 REVISION 58 PAGE 303 OF 334 ATTACHMENT 4 EAL CLASSIFICATION MATRIX (INFORMATION USE) EAL Classificatnon Matrix locations: 1. Control Room. 2. Simulator. 3. Emergency Operations Facility. 4. Technical Support Center. 5. Joint Information Center. 6. Emergency Preparedness Office. EPIP 5.7.1 REVISION 58 PAGE 304 OF 334 ATIACHMENT 5 EAL GROUPS, CATEGORIES, AND SUBCATEGORIES (INFORMATION USE) ATTACHMENT 5 EAL GROUPS, CATEGORIES, AND SUBCATEGORIES (INFORMATION USE) EAL Groups, Categories and Subcategories EAL Group/Category Any Operating Mode: A -Abnormal Rad Release/Rad Effluent H -Hazards And Other Conditions Affecting Plant Safety E -ISFSI MODES l, 2, or 3: S -System Malfunction F -Fission Product Barrier Degradation MODES 4, 5, or DEF: C -Cold Shutdown/Refuel System Malfunction EPIP 5. 7 .1 EAL Subcategory 1 -Off-Site Rad Conditions 2 -On-Site Rad Conditions and Spent Fuel Pool Events 1 -Natural or Destructive Phenomena 2 -Fire or Explosion 3 -Hazardous Gas 4 -Security 5 -Control Room Evacuation 6 -Judgment None 1 -Loss of AC Power 2 -ATWS/Criticality 3 -Inability to Reach Shutdown Conditions 4 -Instrumentation 5 -Fuel Clad Degradation 6 -RCS Leakage 7 -Loss of DC Power 8 -Communications None 1 -Loss of AC Power 2 -RPV Level 3 -RCS Temperature 4 -Communications 5 -Inadvertent Criticality 6 -Loss of DC Power REVISION 58 PAGE 305 OF 334 ATTACHMENT 5 EAL GROUPS, CATEGORIES, AND SUBCATEGORIES (INFORMATION USE) CATEGORY A -ABNORMAL RAD RELEASE/RAD EFFLUENT EAL Group: ANY (EALs in this category are applicable to any plant condition) Many EALS are based on actual or potential degradation of fission product barriers because of the elevated potential for off-site radioactivity release. Degradation of fission product barriers though is not always apparent via non-radiological symptoms. Therefore, direct indication of elevated radiological effluents or area radiation levels are appropriate symptoms for emergency classification. At lower levels, abnormal radioactivity releases may be indicative of a failure of Containment Systems or precursors to more significant releases. At higher release rates, off-site radiological conditions may result which require off-site protective actions. Elevated area radiation levels in plant may also be indicative of the failure of Containment Systems or preclude access to plant vital equipment necessary to ensure plant safety. Events of this category pertain to the following subcategories: 1. OFF-SITE RAD CONDITIONS Direct indication of effluent Radiation Monitoring Systems provides a rapid assessment mechanism to determine releases in excess of classifiable limits. Projected off-site doses, actual off-site field measurements or measured release rates via sampling indicate doses or dose rates above classifiable limits. 2. ON-SITE RAD CONDITIONS AND SPENT FUEL POOL EVENTS Sustained general area radiation levels in excess of those indicating loss of control of radioactive materials or those levels which may preclude access to vital plant areas also warrant emergency classification. EPIP 5.7.1 REVISION 58 PAGE 306 OF 334 ATTACHMENT 5 EAL GROUPS, CATEGORIES, AND SUBCATEGORIES (INFORMATION USE) CATEGORY H -HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY EAL GROUP: ANY (EALS in this category are applicable to any plant condition) Hazards are non-plant, system-related events that can directly or indirectly affect plant operation, reactor plant safety, or personnel safety. The events of this category pertain to the following subcategories: 1. NATURAL OR DESTRUCTIVE PHENOMENA Natural events include earthquakes, tornados, high winds, and high/low river levels that have potential to cause plant structure or equipment damage of sufficient magnitude to threaten personnel or plant safety. Non-naturally occurring events that can cause damage to plant facilities and include vehicle crashes, missile impacts, internal flooding, etc. 2. FIRE OR EXPLOSION Fires can pose significant hazards to personnel and reactor safety. Appropriate for classification are fires within the site Protected Area or which may affect operability of vital equipment. 3. HAZARDOUS GAS Non-naturally occurring events that can cause damage to plant facilities and include toxic, corrosive, asphyxiant, or flammable gas leaks. 4. SECURITY Unauthorized entry attempts into the Protected Area, bomb threats, sabotage attempts, and actual security compromises threatening loss of physical control of the plant. 5. CONTROL ROOM EVACUATION Events indicative of loss of Control Room habitability. If the Control Room must be evacuated, additional support for monitoring and controlling plant functions is necessary through the Emergency Response Facilities. EPIP 5.7.1 REVISION 58 PAGE 307 OF 334 ATTACHMENT 5 6. JUDGMENT EAL GROUPS, CATEGORIES, AND SUBCATEGORIES (INFORMATION USE) The EALs defined in other categories specify the pre-determined symptoms or events that are indicative of emergency or potential emergency conditions and thus, warrant classification. While these EALs have been developed to address the full spectrum of possible emergency conditions which may warrant classification and subsequent implementation of the Emergency Plan, a provision for classification of emergencies based on Operator/Management experience and judgment is still necessary. The EALs of this category provide the Emergency Director the latitude to classify emergency conditions consistent with the established classification criteria based upon Emergency Director judgment. EPIP 5.7.1 REVISION 58 PAGE 308 OF 334

ATTACHMENT 5 CATEGORY E -ISFSI EAL GROUPS, CATEGORIES, AND SUBCATEGORIES (INFORMATION USE) EAL GROUP: ANY (the EAL in this category is applicable to any plant condition) An Independent Spent Fuel Storage Installation (ISFSI) is a complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. A significant amount of the radioactive material contained within a cask must escape its packaging and enter the biosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel. Formal off-site planning is not required because the postulated worst-case accident involving an ISFSI has insignificant consequences to the public health and safety. An Unusual Event is declared on the basis of the occurrence of an event of sufficient magnitude that a loaded cask confinement boundary is damaged or violated. 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. A security event that leads to a potential loss of level of safety of the ISFSI is a classifiable event under Security Category EAL HU4.1. Minor surface damage that does not affect storage cask boundary is excluded from the scope of these EALs. EPIPS.7.1 REVISION 58 PAGE 309 OF 334 ATIACHMENT 5 EAL GROUPS, CATEGORIES, AND SUBCATEGORIES (INFORMATION USE) CATEGORY S -SYSTEM MALFUNCTION EAL GROUP: MODES 1, 2, OR 3 Numerous system-related equipment failure events that warrant emergency classification have been identified in this category. They may pose actual or potential threats to plant safety. The events of this category pertain to the following subcategories: 1. LOSS OF AC POWER Loss of emergency electrical power can compromise plant safety system operability including Decay Heat Removal and Emergency Core Cooling Systems which may be necessary to ensure fission product barrier integrity. 2. ATWS/CRITICALITY Events related to failure of the Reactor Protection System (RPS) to initiate and complete reactor scrams. In the plant licensing basis, postulated failures of the RPS to complete a reactor scram comprise a specific set of analyzed events referred to as Anticipated Transient Without Scram (ATWS) events. For EAL classification, however, ATWS is intended to mean any scram failure event that does not achieve reactor shutdown. If RPS actuation fails to assure reactor shutdown, positive control of reactivity is at risk and could cause a threat to Fuel Clad, RCS, and Containment integrity. Inadvertent criticalities pose potential personnel safety hazards as well being indicative of losses of reactivity control. 3. INABILITY TO REACH SHUTDOWN CONDITIONS One EAL falls into this subcategory. It is related to the failure of the plant to be brought to the required plant operating condition required by Technical Specifications if a limiting condition for operation (LCO) is not met. 4. INSTRUMENTATION Certain events that degrade plant Operator ability to effectively assess plant conditions within the plant warrant emergency classification. Loss of annunciators or indicators is in this subcategory. EPIP 5.7.1 REVISION 58 PAGE 310 OF 334 ATIACHMENT 5 EAL GROUPS, CATEGORIES, AND SUBCATEGORIES (INFORMATION USE) 5. FUEL CLAD DEGRADATION During normal operation, reactor coolant fission product activity is very low. Small concentrations of fission products in the coolant are primarily from the fission of tramp uranium in the fuel clad or minor perforations in the clad itself. Any significant increase from these base-line levels (1°/o clad failures) is indicative of fuel failures and is covered under the Fission Product Barrier Degradation category. However, lesser amounts of clad damage may result in coolant activity exceeding Technical Specification limits. These fission products will be circulated with the reactor coolant and can be detected by coolant sampling. 6. RCS LEAKAGE The Reactor Vessel provides a volume for the coolant that covers the reactor core. The Reactor Vessel and associated pressure piping (Reactor Coolant System) together provide a barrier to limit the release of radioactive material should the reactor fuel clad integrity fail. Excessive RCS leakage greater than Technical Specification limits are utilized to indicate potential pipe cracks that may propagate to an extent threatening fuel clad, RCS, and containment integrity. 7. LOSS OF DC POWER Loss of vital critical DC electrical power can compromise plant safety system operability including Decay Heat Removal and Emergency Core Cooling Systems which may be necessary to ensure fission product barrier integrity. This category includes loss of vital 125 VDC power sources. 8. COMMUNICATIONS Certain events that degrade plant Operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification. EPIP 5.7.1 REVISION 58 PAGE 311OF334 AlTACHMENT 5 EAL GROUPS, CATEGORIES, AND SUBCATEGORIES (INFORMATION USE) CATEGORY F -FISSION PRODUCT BARRIER DEGRADATION EAL GROUP: MODE 1, 2, OR 3 EALs in this category represent threats to the defense in depth design concept that precludes the release of highly radioactive fission products to the environment. This concept relies on multiple physical barriers any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment. The primary fission product barriers are: A. Fuel Clad (FC): The Fuel Clad barrier consists of the zircaloy fuel bundle tubes that contain the fuel pellets. B. Reactor Coolant System (RCS): 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. C. Primary Containment (PC): The Primary Containment barrier includes the drywell, the wetwell (torus), their respective interconnecting paths, and other connections up to and including the outermost containment isolation valves. The EALs in this category require evaluation of the loss and potential loss thresholds listed in the fission product barrier matrix of Table F-1 (Attachment 3). "Loss" and "Potential Loss" signify the relative damage and threat of damage to the barrier. "Loss" means the barrier no longer assures containment of radioactive materials. "Potential Loss" means integrity of the barrier is threatened and could be lost if conditions continue to degrade. The number of barriers that are lost or potentially lost and the following criteria determine the appropriate emergency classification level:

Unusual Event: Any loss or any potential loss of Primary Containment.

Alert: Any loss or any potential loss of either Fuel Clad or RCS. ** Site Area Emergency: Loss or potential loss of any two barriers.

General Emergency: Loss of any two barriers and loss or potential loss of third barrier. EPIP 5.7.1 REVISION 58 PAGE 312 OF 334 AlTACHMENT 5 EAL GROUPS, CATEGORIES, AND SUBCATEGORIES (INFORMATION USE) The logic used for emergency classification. based on fission product barrier monitoring should reflect the following considerations:

The Fuel Clad barrier and the RCS barrier are weighted more heavily than the Primary Containment barrier. UE EALs associated with RCS and Fuel Clad barriers are addressed under System Malfunction EALs.

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.

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.

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. Determine which combination of the three barriers are lost or have a potential loss and use FU 1.1, FA1.1, FS1.1, and FG1.1 to classify the event. Also, an event for multiple events could occur which result in the conclusion that exceeding the loss or potential loss thresholds is imminent. In this imminent loss situation, use judgment and classify as if the thresholds are exceeded. EPIP 5.7.1 REVISION 58 PAGE 313 OF 334 AlTACHMENT 5 EAL GROUPS, CATEGORIES, AND SUBCATEGORIES (INFORMATION USE) CATEGORY C -COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION EAL GROUP: MODES 4, 5, DEF Category C EALs are directly associated with cold shutdown or refueling system safety functions. Given the variability of plant configurations (e.g., systems out of service for maintenance, containment open, reduced AC power redundancy, time since shutdown) during these periods, the consequences of any given initiating event can vary greatly. For example, a loss of decay heat removal capability that occurs at the end of an extended outage has less significance than a similar loss occurring during the first week after shutdown. Compounding these events is the likelihood that instrumentation necessary for assessment may also be inoperable. The cold shutdown and refueling system malfunction EALs are based on performance capability to the extent possible with consideration given to RCS integrity, Containment Closure, and fuel clad integrity for the applicable operating modes (4 -Cold Shutdown, 5 -Refueling, D -Defueled). THE EVENTS OF THIS CATEGORY PERTAIN TO THE FOLLOWING SUBCATEGORIES: 1. LOSS OF AC POWER Loss of emergency plant electrical power can compromise plant safety system operability including Decay Heat Removal and Emergency Core Cooling Systems which may be necessary to ensure fission product barrier integrity. This category includes loss of on-site and off-site sources for 4160V emergency buses and loss of vital 125 VDC power sources. 2. RPV LEVEL RPV water level is a measure of inventory available to ensure adequate core cooling and, therefore, maintain fuel clad integrity. The RPV provides a volume for the coolant that covers the reactor core. The RPV and associated pressure piping (Reactor Coolant System) together provide a barrier to limit the release of radioactive material should the reactor fuel clad integrity fail. 3. RCS TEMPERATURE Uncontrolled or inadvertent temperature or pressure increases are indicative of a potential loss of safety functions. EPIP 5.7.1 REVISION 58 PAGE 314 OF 334 AlTACHMENT 5 4. COMMUNICATIONS EAL GROUPS, CATEGORIES, AND SUBCATEGORIES (INFORMATION USE) Certain events that degrade plant Operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification. 5. INADVERTENT CRITICALITY Inadvertent criticalities pose potential personnel safety hazards as well being indicative of losses of reactivity control. 6. LOSS OF DC POWER Loss of vital critical DC electrical power can compromise plant safety system operability including Decay Heat Removal and Emergency Core Cooling Systems which may be necessary to ensure fission product barrier integrity. This category includes loss of vital 125 VDC power sources. EPIP5.7.1 REVISION 58 PAGE 315 OF 334 ATTACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) ATTACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) DEFINITIONS 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 people violently protesting station operations or activities at the site. Confinement Boundary Is the barrier(s) between areas containing radioactive substances and the environment. Containment Closure Is the action taken to secure Primary or Secondary Containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. Containment Closure requirements are specified in Administrative Procedure 0.50.5, Outage Shutdown Safety. EPIP 5.7.1 REVISION 58 PAGE 316 OF 334 ATTACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) Emergency Action Level (EAL) A pre-determined, site specific, observable threshold for a plant IC that places the plant in a given emergency classification level. An EAL can be: an instrument reading; an equipment status indicator; a measurable parameter (on-site or off-site); a discrete, observable event; results of analyses; entry into specific emergency operating procedures; or another phenomenon which, if it occurs, indicates entry into a particular emergency classification level. Emergency Classification Level (ECL) One of a minimum set of names or titles established by the NRC for grouping off normal nuclear power plant conditions according to (1) their relative radiological seriousness, and (2) the time-sensitive on-site and off-site radiological emergency preparedness actions necessary to respond to such conditions. The existing radiological emergency classification levels, in ascending order of seriousness, are called:

Notification of Unusual Event (UE).

Alert.

Site Area Emergency (SAE).

General Emergency (GE). 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 Is 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. EPIP 5.7.1 REVISION 58 PAGE 317 OF 334 ATTACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) Flooding Flooding, as used within the EALs, describes a condition where water is entering a room faster than installed equipment is capable of removal, resulting in a rise of water level within the room. 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 off-site for more than the immediate site area. Hostage Person(s) held as leverage against the station to ensure that demands will be met by the station. Hostile Action An act toward CNS or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidates 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 CNS. Non-terrorism-based EALs should be used to address such activities (e.g., 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. EPIP 5.7.1 REVISION 58 PAGE 318 OF 334 ATTACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) Initiating Condition (IC) One of a pre-determined subset of nuclear power plant conditions where either the potential exists for a radiological emergency or such an emergency has occurred. Inoperable Not able to perform its intended function. Intruder Person(s) present in a specified area without authorization. Intrusion The act of entering without authorization. Discovery of a bomb in a specified area is indication of intrusion into that area by a hostile force. 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. 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 abnormal or emergency operating procedures, or deviation from normal security or radiological controls posture, is a departure from Normal Plant Operations. Operating Mode Applicability The plant mode existing at the start of an event under which a particular EAL is applicable. These modes are defined in Technical Specifications Table 1.1-1. The Defueled or DEF mode referred to in some EALs is the condition where all fuel has been removed from the reactor vessel. Note that the ISFSI EAL has no mode applicability. Projectile An object directed toward CNS that could cause concern for its continued operability, reliability, or personnel safety. EPIP 5.7.1 REVISION 58 PAGE 319 OF 334 ATTACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) Protected Area An area which normally 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 any of the following:

Runback > 25°/o thermal power.

Electrical load rejection > 25°/o full electrical load ..

Reactor scram.

ECCS injection.

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. EPIP 5.7.1 REVISION 58 PAGE 320 OF 334 ATTACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) Strike Action Work stoppage within the Protected Area by a body of workers to enforce compliance with demands made on CNS. The strike action must threaten to interrupt Normal Plant Operations. Sustained Wi_nd Sustained winds are of a prolonged duration and, therefore, do not include gusts. Sustained winds are not intermittent or of a transitory nature. Since the inauguration of the Automatic Surface Observation System (ASOS), the National Weather Service has adopted a 2 minute average standard for its sustained wind definition. 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. Unusual Event 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. Valid An indication, report, or condition is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment. EPIPS.7.1 REVISION 58 PAGE 321 OF 334 ATTACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) 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 affected safety structure, system, or component. Examples of 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. Acronyms AC ..................... Alternating Current ADS ................... Automatic De pressurization System APRM ................. Average Power Range Meter ATWS ................. Anticipated Transient Without Scram BIIT .. ; ................ Boron Injection Initiation Temperature BWR .................. Boiling Water Reactor CCW .......... , ....... Component Cooling Water CDE ................... Committed Dose Equivalent CFR ................ _ .... Code of Federal Regulations cps .................... Counts per Second CRD ...... ; ............ Control Rod Drive CS ..................... Core Spray . CST .................... Condensate Storage Tank CTMT/CNMT ........ Containment EPIP 5.7.1 REVISION 58 PAGE 322 OF 334 ATIACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) DBA ................... Design Basis Accident DC ..................... Direct Current Demin ................ Demineralizer DHRP ...... , .......... Decay Heat Removal Pressure DOT ................... Department of Transportation DW ......... ,, .. , .... ,. .. Drywell DWSIL. ............... Drywell Spray Initiation Limit EAL .................... Emergency Action Level ECCS ... , .............. Emergency Core Cooling System ECL .................... Emergency Classification Level ED ..................... Emergency Director El. ............ ........ Elevation EOF , ......... , ...... _ .. Emergency Operations Facility EOP ................... Emergency Operating Procedure EPA .................... Environmental Protection Agency EPG ................... Emergency Procedure Guideline EPIP ................... Emergency Plan Implementing Procedure EPRI .................. Electric Power Research Institute ERD ................... Emergency RPV Depressurization ESF .................... Engineered Safety Feature ESW ................... Emergency Service Water FAA ............. : ...... Federal Aviation Administration FBI .................... Federal Bureau of Investigation EPIP 5.7.1 REVISION 58 PAGE 323 OF 334 ATIACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) FEMA ................. Federal Emergency Management Agency FSAR ............ , ..... Final Safety Analysis Report ft ....................... Feet gal .......... .......... Gallon(s) GE ..................... General Emergency GPM ................... Gallons Per Minute HCTL .................. Heat Capacity Temperature Limit HCU ................... Hydraulic Control Unit HOO ................... Headquarters (NRC) Operations Officer HPCI .................. High Pressure Coolant Injection H2 ..................... Hydrogen hr ................... * ... Hour HX ..................... Heat Exchanger IC ...................... Initiating Condition in ...................... Inch(es) IPEEE ................. Individual Plant Examination of External Events (Generic Letter 88-20) ISFSI ................. Independent Spent Fuel Storage Installation Keff .................... Effective Neutron Multiplication Factor lb ........................ Pound(s) LCO ................... Limiting Condition of Operation LER .................... Licensee Event Report LOCA ................. Loss of Coolant Accident EPIPS.7.1 REVISION 58 PAGE 324 OF 334 ATTACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) LPCI. .................. Low Pressure Coolant Injection LWR ................... Light Water Reactor MDRIR ............... Minimum Debris Retention Injection Rate MDSL ................. Minimum Debris Submergence Level MELLL ................ Maximum Extended Load Line Limit min ..................... Minimum, minute mR ............ ....... milliRoentgen mRem , .. ........ , ... milliRem MSCP ................. Minimum Steam Cooling Pressure MSIV .................. Main Steam Isolation Valve MSL ................... Main Steam Line MW .................... Megawatt N/A .................... Not applicable NEI .................... Nuclear Energy Institute NESP .................. National Environmental Studies Project NORAD ............... North American Aerospace Defense Command NPP .................... Nuclear Power Plant NR ..................... Narrow Range NRC ................... Nuclear Regulatory Commission NSSS ................. Nuclear Steam Supply System NU MARC, ............ Nuclear Management and Resources Council 02 ...................... Oxygen OBE ................... Operating Basis Earthquake EPIP 5. 7.1 REVISION 58 PAGE 325 OF 334 AlTACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) OCA ................... Owner Controlled Area ODCM/ODAM ....... Off-site Dose Calculation (Assessment) Manual ORO ................... Off-site Response Organization PA ..................... Protected Area PAG ................... Protective Action Guideline PC ..................... Primary Containment PCPL .................. Primary Containment Pressure Limit PMIS .................. Plant Management Information System POAH ....... ; ......... Point of Adding Heat PRA/PSA ............. Probabilistic Risk Assessment/Probabilistic Safety Assessment PRM ....... -............ Process Radiation Monitor psig ................... Pounds per square inch (gauge) PSP .................... Pressure Suppression Pressure PSTG .................. Plant Specific Technical Guidelines R ........................ Roentgen RB ..................... Reactor Building RCC ................... Reactor Control Console RCIC ................... Reactor Core Isolation Cooling RCS ........ _ ........... Reactor Coolant System rem ................... Roentgen Equivalent Man RETS .................. Radiological Effluent Technical Specifications RHR ............. ; ..... Residual Heat Removal RPS .................... Reactor Protection System EPIPS.7.1 REVISION 58 PAGE 326 OF 334 ATTACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) RPV .................... Reactor Pressure Vessel RWCU ................ Reactor Water Cleanup SAG ................... Severe Accident Guideline SFP .................... Spent Fuel Pool SGT ................... Standby Gas Treatment SBO .. ro ............... Station Blackout SLC ..................... Standby Liquid Control SPDS ................. Safety Parameter Display System SRO ................... Senior Reactor Operator SRV ................... Safety Relief Valve SSE ................... Safe Shutdown Earthquake TAF .................. of Active Fuel TEDE ........ _ ........... Total Effective Dose Equivalent TSC ................... Technical Support Center UE ..................... Notification Of Unusual Event USAR ................. Updated Final Safety Analysis Report WR .................... Wide Range ' ......................... Feet 11 ........................ Inches 0/o ..*........*.........*.. *Percent & ............ _ ........... Ampersand (11and") °F ...................... Degrees Fahrenheit > ....................... Greater Than EPIP 5. 7 .1 REVISION 58 PAGE 327 OF 334 ATTACHMENT 6 EAL DEFINITIONS AND ACRONYMS (INFORMATION USE) < ....................... Less Than ;::: ................... , .... Greater Than or Equal To s-; ....................... Less Than or Equal To EPIP 5.7.1 REVISION 58 PAGE 328 OF 334 ATTACHMENT 7 INFORMATION SHEET (INFORMATION USE) ATIACHMENT 7 INFORMATION SHEET (INFORMATION USE) 1. PURPOSE 1.1 Procedure contains the instructions necessary for classification of emergencies consistent with the NRC approved EAL classification scheme. Also, included are the explanations and rational for the scheme, the detailed bases for the EALs, and controls required for the EAL Classification Matrix which is the primary tool used to determine when classification criteria are exceeded. 1.2 Procedure provides the formal set of threshold conditions necessary to classify an event at CNS into one of the four emergency classifications described in NUREG-0654, NEI 99-01, Revision 5, and the CNS Emergency Plan.©2 2. PRECAUTIONS AND LIMITATIONS 2.1 Assessment, classification, and declaration of an emergency condition shall be completed within 15 minutes after initial availability of indications to plant Operators that an EAL has been exceeded provided that: 2.1.1 Implementation of response actions required to protect public health and safety are not delayed; and1 2.1.2 Any delay in declaration does not deny State and Local authorities opportunity to implement measures necessary to protect public health and safety. 2.2 Classifying and declaration of an emergency is a non-delegable responsibility of Emergency Director. Although additional input in these decisions is encouraged, completion of timely and accurate performance of these activities rests solely with Emergency Director. 3. REFERENCES 3.1 CODES AND STANDARDS 3.1.1 10CFR50.48, Fire Protection. 3.1.2 10CFR50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors. 3.1.3 10CFR72.32, Emergency Plan. EPIP 5.7.1 REVISION 58 PAGE 329 OF 334 ATIACHMENT 7 INFORMATION SHEET (INFORMATION USE) 3.1.4 NEI 99-01, Revision 5, Methodology for the Development of Emergency Action Levels, February 2008 (ADAMS Accession Number ML080450149). 3.1.S NPPD Emergency Plan for CNS. 3.1.6 NUREG-0654, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. 3.1. 7 NUREG-1022, Event Reporting Guidelines 10CFR50. 72 and 50. 73, Revision 2. 3.2 PROCEDURES 3.2.1 Instrument Operating Procedure 4.12, Seismic Instrumentation. 3.2.2 Emergency Plan Implementing Procedure 5.7.2, Emergency Director EPIP. 3.2.3 Emergency Plan Implementing Procedure 5. 7 .16, Release Rate Determination. 3.2.4 Emergency Plan Implementing Procedure 5.7.17, CNS-DOSE Assessment. 3.2.5 Emergency Plan Implementing Procedure 5.7.17.1, Dose Assessment (Manual). 3.3 MISCELLANEOUS 3.3.1 ADAMS Accession No. ML100080231, Cooper Nuclear Station -Change to Emergency Action Level Scheme (TAC NO. ME0849). Document ID NRC2010008. 3.3.2 ADAMS Accession No. ML14055A023, Cooper Nuclear Station -Issuance of Amendment Regarding Transition to Risk-Informed, Performance-Based Fire Protection Program in Accordance With 10CFR50.48(c) (TAC No.ME8551). 3.3.3 ADAMS Accession No. ML15271A299, EPFAQ 2015-004, Fission Barrier Matrix Criteria, Date Accepted 01-Jul-15. 3.3.4 RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events. EPIP 5.7.1 REVISION 58 PAGE 330 OF 334 ATTACHMENT 7 INFORMATION SHEET (INFORMATION USE) 3.3.5 ©1 NRC Bulletin 2005-02 (Commitment Number NLS2005080-02), EALs reflect information provided in Attachment 2 of bulletin. Commitment affects EALs HA4.11 HS4.1, and HG4.1. 3.3.6 ©2 IR 81-013 (Commitment Number 811217-01-07), Develop Functional Procedure for Accident Classification. Commitment affects Attachment 7, Step 1.2. 3.3.7 ©3 IR 92-014 (Commitment Number 921110-02-03), Revise Guidance Documents for "Low Threshold" Core Damage Events. Commitment affects Attachment 3, Threshold 4, 5, and 6 CNS Basis. EPIP 5.7.1 REVISION 58 PAGE 331 OF 334 ATTACHMENT 8 MATRIX BASIS CROSS-REFERENCE (INFORMATION USE) ATTACHMENT 8 MATRIX BASIS CROSS-REFERENCE (INFORMATION USE) CAT SUB GE SAE ALERT UE -* : AG1.1 40 AS1.1 34 AA1.1 26 AU1.1 18 1 AG1.2 42 AS1.2 36 AA1.2 29 AU1.2 21 AG1.3 44 AS1.3 38 AA1.3 32 AU1.3 24 " A -AA2.1 51 AU2.1 46 '.'2' i ,--' AA2.2 53 AU2.2 49 -a; AA3.1 55 .. HA1.1 130 HU1.1 118 HA1.2 134 HUl.2 122 HA1.3 137 HU1.3 124 1 HA1.4 140 HU1.4 126 HA1.5 143 HUl.5 128 HA1.6 145 H HA2.1 152 HU2.1 148 2 HU2.2 150 HA3.1 162 HU3.1 155 3 HU3.2 160 4 HG4.1 175 HS4.1 173 HA4.1 170 HU4.1 167 5 HSS.l 178 HAS.l 177 6 HG6.l 186 HS6.1 184 HA6.1 182 HU6.l 180 E* ! d ' .. EU1.1 244 . --*--* -I . l ! 1 SG1.1 203 SSl.1 198 SA1.1 193 SU1.1 188 ' " .I 2 SG2.l 217 552.1 214 SA2.1 210 SU2.1 209 , -*-*-_:.... l ;' .:a: SU3.1 221 ; *, --** . , .. 4. 554.1 228 SA4.1 225 SU4.1 222 ;s ** SUS.1 232 '1'1 5 11 'i . SUS.2 234 " I i 6 SU6.l 235 7:* SS7.1 237 . ' . -' s SU8.1 241 EPIP5.7.l REVISION 58 PAGE 332 OF 334 ATTACHMENT 8 MATRIX BASIS CROSS-REFERENCE (INFORMATION USE) CAT SUB GE SAE ALERT UE ' 1 FG1.1 249 FS1.1 247 FA1.1 246 FU1.1 245 CA1.1 62 CUl.l 57 CG2.1 85 CS2.1 77 CA2.1 74 CU2.1 67 2 CG2.2 91 CS2.2 79 CU2.2 69 CS2.3 81 CU2.3 71 : .C CA3.1 105 CU3.1 99 3 CU3.2 102 4 CU4.1 109 *5 CUS.1 112 .. 5 CU6.1 114 EPIP5.7.1 REVISION 58 PAGE 333 OF 334 ATIACHMENT 8 MATRIX BASIS CROSS-REFERENCE (INFORMATION USE) -.. .. . -. -.. .. --* *fissient'.Product 1B:a*rfie*r :Matrix-. ., . *-. . "":....:_: .... ' ... '---::"'* ._ *,: .. *** -,*.:.. .. :,*-' . *-Reactor Coolant Sys Fuel Clad Barrier Barrier Primary Cont. Barrier Loss Pot. Loss Loss Pot. Loss Loss Pot. Loss A 1 253 8 256 10 266 25 283 11 269 19 286 26 288 B 20 287 27 289 28 291 12 271 16 273 21 292 c 17 274 22 294 23 295 D 13 278 2 259 E 3 260 14 280 29 298 4 261 5 262 6 263 F 7 264 9 265 15 281 18 282 24 299 30 301 EPIP 5.7.1 REVISION 58 PAGE 334 OF 334

ML17206A084: Difference between revisions

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ML17206A084: Difference between revisions

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