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{{#Wiki_filter:Dresden Nuclearfresden Annex ExeIon NuclearwRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSU76Initiating Condition:Loss of all On-site or Off-site communications capabilities.Operating Mode Applicability:1,2,3Emergency Acton Level (EAL):1. Loss of ALL Table M3 Onsite communications capability affecting the ability toperform routine operations.OR2. Loss of ALL Table M3 Offsite communication capability affecting the ability toperform offsite notifications.OR3. Loss of ALL Table M3 NRC communication capability affecting the ability toperform NRC notifications.Table M3 Communications CapabilitySystem Onsite Offsite NRCPlant Radio XPlant Paae XSound Powered Phones XAll telephone Lines (Commercial and microwave) X X XCellular Phones X XENS X XHPN X XSatellite Phones X XF i I I | |||
* mI f II w1. 6066 OT A66 of the followine onco communicav nion moetnoc:(cite-specifie Of communications method2 Less of ALL of the fallowinn ORQ Gemmuninations s) moetheds: -"" "3 ...............v wI ...........(c,*ite snocifi lirt ofcomnainsmtdsMonth 20XXDR 3-77EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS3. Lecs of ALL of the following NRC 1 OMMUniIatiens (cite specific list Of communications moethod&)Basis:This IC addresses a significant loss of on-site._-w-offsite, or NRC communicationscapabilities. While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs. and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 BasisaAddresses a total loss of the communications methods used in support of routine plantoperations.EAL #2 BasisaAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in procedure EP-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) Form. (see-Develope-Notes).EAL #3 BasisaAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, SU62. EP-MW-1 24-1001 Facilities Inventories and Equipment Tests3. UFSAR 9.5.24. DOA 0010-14 Loss of Off-Site Telephone Communication SystemsMonth 20XXDR 3-78EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCA12Initiating Condition:I Loss of all offsite and all onsite AC power to emergency bussesbuses for 15 minutes orlonger.Operating Mode Applicability:4,5, DEmergency Acton Level (EAL):Note:* The Emeraencv Director should declare the event nromntlv UDOn determinina thatthe applicable time has been exceeded, or will likely be exceeded.'=I'L A r%*- -A-- -t- .1-j 1--- AL- 61-ý -at. -J'A *-'-- A.L-A 4ýuC .TCUIL iuirtruiuu.~r i ~utuuiu. ur UUIIII1 ILýýn 1.-- ...!IE ~ -L.---mluit Has been ..ueeu.. , OFr Will 11...ly be ec..... .1. Loss of ALL offsite AC power to unit ECCS buses.AND2. Failure of DG 2(3). shared DG 2/3 and SBO DG 2(30 emeraencv dieselgenerators to supply power to unit EGGS buses.AND3. Failure to restore power to at least one unit EGGS bus in < 15 minutes from thetime of loss of both offsite and onsite AC power.Z AN I "-!. --ll Ak I 51 % M~I -- ----------- ... -L0C~ 01 ~LL OTTCI!0 ano :'.LL OflEliC :~L i-'owor 10 (SIlO SDOCITIC omoroancv DUCOCI IOU IDm:inuto or lnger.N r-1ý JBasis:SAFETY SYSTEM: A system reauired for safe plant operation, coolina down the plantand/or placing it in the cold shutdown condition, including the EGGS. These aretypically systems classified as safety-relatedThis IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergencycore cooling, containment heat removal/pressure control, spent fuel heat removal andthe ultimate heat sink.I When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas a Site Area Emergency because of the increased time available to restore anMonth 20XXDR 3-79EP-AA-1004 (Revision XX) | |||
NuelAarfrAetden Annex Exelnn NucleasrRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSemergency bus to service. Additional time is available due to the reduced core decayheat load, and the lower temperatures and pressures in various plant systems. Thus,when in these modes, this condition represents an actual or potential substantialdegradation of the level of safety of the plant.I Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via IC CS61- or RAS1.Basis Reference(s):1. NEI 99-01 Rev 6, CA22. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 KV System and 345 KV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-147. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-1 2 Partial or Complete Loss of AC PowerMonth 20XXDR 3-80EP-AA-1004 (Revision XX) | |||
AnnoyfrA-qd~fn Ann~x Exelnn Nucler~IRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCU12Initiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:4,5, DEmergency Acton Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.The Emoregcncy Director should declare the Unusual Event promptly upondeteminig that 15 mninutes has been exceeded, Or Will likely be exceeded.1. AC Power capability to unit ECCS buses reduced to only one of the following powersources for > 15 minutes." Reserve auxiliary Transformer TR-22 (TR-32)" Unit auxiliary transformer TR-21 (TR-31)* Unit Emergency Diesel Generator DG 2(3)" Shared Emergency Diesel Generator DG 2/3* Station Blackout Diesel Generator DG 2(3)" Unit crosstie breakersAND2. Any additional single power source failure will result in a loss of ALL AC power toSAFETY SYSTEMS.a. AC power capability to (sitespecific emer.gency buses) is reduced to a singlepower for 15 minutes or .ANDb. Any additional single pwer failure will result in loss of all A power t9SAFEII SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.Month 20XXDR 3-81EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSThis IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS. In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment.When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas an Alert because of the increased time available to restore another power source toservice. Additional time is available due to the reduced core decay heat load, and thelower temperatures and pressures in various plant systems. Thus, when in thesemodes, this condition is considered to be a potential degradation of the level of safety ofthe plant.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below.-A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).-A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator.-A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.The subsequent loss of the remaining single power source would escalate the event toan Alert in accordance with IC CA12.Basis Reference(s):1. NEI 99-01 Rev 6 CU22. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 KV System and 345 KV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout GeneratorTies to Plant Auxiliary Electric System7. UFSAR 9.5.9 Station Blackout System8. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-82EP-AA-1004 (Revision XX) | |||
Dresden Nuclearfr= d=n Ann nv Ex vlon NuclearvIRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSMonth 20XXDR 3-83EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCA26Initiating Condition:I Hazardous event affecting SAFETY SYSTEM needed-required for the current operatingmode.Operating Mode Applicability:4,5Emergency Acton Level (EAL):1. a,. The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)" Internal or external flooding event" High winds or tornado strike" FIRE" EXPLOSION" (site sepoific hazards)" Other events with similar hazard characteristics as determined by theShift ManagerAND2.b. EITHER of the following:a.__,. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM needed required byTechnical Specifications for the current operating mode.ORb._2L. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure needed-required by TechnicalSpecifications for the current operating mode.Basis:FIRE: Combustion characterized by heat and liqht. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization. A release of steam (from hiqhenerqy lines or components) or an electrical component failure (caused by short circuits,grounding, arcing, etc.) should not automatically be considered an explosion. Suchevents may require a post-event inspection to determine if the attributes of an explosionare present.Month 20XXDR 3-84EP-AA-1004 (Revision XX) | |||
AnnoyP:v-alnn im, rlarRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSSAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.VISIBLE DAMAGE: Damage to a component or structure that is readily observablewithout measurements, testing, or analysis. The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components, needed-required for the currentoperating mode, "required", i.e. required to be operable by Technical Specifications forthe current operating mode. This condition significantly reduces the margin to a loss orpotential loss of a fission product barrier, and therefore represents an actual or potentialsubstantial degradation of the level of safety of the plant. Manual or automatic electricalisolation of safety equipment due to flooding, in and of itself, does not constitutedegraded performance and is classified under HU6.EAL 41b7-#2.a Basis-aAddresses damage to a SAFETY SYSTEM train that is required to be operable byTechnical Specifications for the current operating mode, and is in SeF~4e perationsince indications for it will be readily available. The indications of degradedperformance should be significant enough to cause concern regarding the operability orreliability of the SAFETY SYSTEM train.EAL 4-42#2..b Basis-aAddresses damage to a SAFETY SYSTEM component that is required to be operableby Technical Specifications for the current operating mode, and is not inSeeive/operation or readily apparent through indications alone, or to a structurecontaining SAFETY SYSTEM components. Operators will make this determinationbased on the totality of available event and damage report information. This is intendedto be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC CS6-- or RAS1.If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):1. NEI 99-01 Rev 6, CA6Month 20XXDR 3-85EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCU34Initiating Condition:Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:4,5Emergency Acton Level (EAL):Note:= The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.The E.morgoncy Diroctor Should doc-laro the Unusual Event prom~ptly upondtrmnnthat 15 mninutos time has bcen exccoded, Or Will likely be oxceododVoltage is < 105 VDC on required 125 VDC battery buses #2 and #3for > 15 minutes.Indicated is loss than (site specific bus value) required \Vital DGbusos for 15 m inutes Or longor.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a loss of Vital DC power which compromises the ability to monitorand control operable SAFETY SYSTEMS when the plant is in the cold shutdown orrefueling mode. In these modes, the core decay heat load has been significantlyreduced, and coolant system temperatures and pressures are lower; these conditionsinefeaserise the time available to restore a vital DC bus to service. Thus, this conditionis considered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to supportoperation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.For example, if Train A is out-of-service (inoperable) for scheduled outage maintenancework and Train B is in-service (operable), then a loss of Vital DC power affecting Train Bwould require the declaration of an Unusual Event. A loss of Vital DC power to Train Awould not warrant an emergency classification.I Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Depending upon the event, escalation of the emergency classification level would be viaIC CA64- or CA53, or an IC in Recognition Category BA.Month 20XXDR 3-86EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSBasis Reference(s):1. NEI 99-01 Rev 6, CU42. UFSAR 8.3.2.2.1 Safety Related 125-V System3. DOA 6900-02(3) Failure of Unit 2(3) 125 VDC Power Supply4. Technical Specification Basis B.3.8.5, DC Power Sources -Shutdown5. Technical Specification Basis B.3.8.4, DC Power Sources -OperatingMonth 20XXDR 3-87EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCU4"Initiating Condition:Loss of all onsite or offsite communications capabilities.Operating Mode Applicability:4,5, DEmergency Acton Level (EAL):1. Loss of ALL Table C1 Onsite communications capabilitv affectinQ the abilitv toDerform routine oWerations.OR2. Loss of ALL Table Cl Offsite communication capability affecting the ability toperform offsite notifications.OR3. Loss of ALL Table C1 NRC communication capability affecting the ability toperform NRC notifications.TahkoIM (1 (nmmuini-atinne fon~ahilituSystem Onsite Offsite NRCPlant Radio XPlant Page XSound Powered Phones XAll telephone Lines (Commercial and microwave) X X XCellular Phones X XENS X XHPN X XSatellite Phones X X5 .~ ~. ~ %~. SB *~ S ~I5~*U*I B------- J[ I-- -- --I -- -(i-6te coec-Gific list Of communications mnethods)I l iI I I IVi 2. Loss of ALL Of the folloWing ORO communications methods:(cite-ssccfic list Of communications mnethods)Month 20XXDR 3-88EP-AA-1 004 (Revision XX) | |||
AnnexI=xolon fresden Annex Exellon Nuclea~rRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONS3. Lss- of ALL of the NRC ormmuni.ations methods(siteo Sp icl St Of cO',n'Rammu-nic'.0,-ations moI,' lthed)Basis:This IC addresses a significant loss of on-site_-er-offsite, or NRC communicationscapabilities. While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 BasisaAddresses a total loss of the communications methods used in support of routine plantoperations.EAL #2 BasisaAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in procedure EP-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) Formkseer. .. .,.Netes.EAL #3 BasisaAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, CU52. EP-MW-1 24-1001 Facilities Inventories and Equipment Tests3. UFSAR 9.5.24. DOA 0010-14 Loss of Off-Site Telephone Communication SystemsMonth 20XXDR 3-89EP-AA-1004 (Revision XX) | |||
Exelon NuclearDresden Annex Eeo ulaRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCA53Initiating Condition:Inability to maintain the plant in cold shutdown.Operating Mode Applicability:4,5Emergency Acton Level (EAL):Note:e The Emergency Director should declare the event promptly upon determining thatthe apolicable time has been exceeded. or will likely be exceeded.rL... I~.ii=- =I-z ýIIiui t Liu i 1Iu~ 1 ~ t 1i. :.:u.zu -: .............. ....the a,"li,,able imo has beon .....d.d, or will likely oX.eedod.UNPLANNED rise in RCS temperature > 212°F due to loss of decay heat removal for >Table C2 duration.Table C2 RCS Heat-up Duration ThresholdsRCS Containment Closure Heat-upStatus Status DurationIntact Not Applicable 60 minutes*Not Intact Established 20 minutes*Not Established 0 minutes* If an RCS heat removal system is in operation withinthis time frame and RCS temperature is beina reduced,then EAL #1 is not applicable.OR2. UNPLANNED RPV pressure rise > 10 psig as a result of temperature rise due toloss of decay heat removal.1. UNPLANNED ir- cre-e in RCS tmprater, to greater than Q ^^fifm.ýa~ tI%! ý- "p~, ko Arlptin~, *P~nrP pratIi UI if fP1 nnte fh n +6^duration specified in the fGollIin table.Lm m Lm ....... I "--" Month 20XXDR 3-90EP-AA-1004 (Revision XX) rmafltun AnnovFvtulnn ":,AaarfDlrne I tln II nnvp FA~rVI I. mIaVI~pRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSTable: RCS HMoat-Up Durtation Throohol,RCS Status Containment Clocure Heat-up DuratiOnStatusreduced inyentoy No i 6- Iil utNot intact (r Oat reduced Ebloh, 20, *iwente-fPi [R") Not E ;stabli Fhd | |||
* If an RCS heat removal 6ystemn is in operation within this time frameand RCS temperature is bein~g reduced, the EAL is not applicable..~J 1] LPd'.'r.~t~IJ iiii'- nro~uro incro~e aroa~nr man miTo ~nncmc orn~surn '.-~ -~w.v~.~plirrýi _15-t ý1- Al Ae ~~ i..rr a~~r'~alr~~w.w......... 0ý ...... ........[PKRJ)lBasis:UNPLANNED: A parameter chanae or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment (primary or secondary) and its associated structures, systems, andcomponents as a functional barrier to fission product release under shutdownconditions.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.a. no freeze seals, or steam line nozzle Dluas. etc.).This IC addresses conditions involving a loss of decay heat removal capability or anaddition of heat to the RCS in excess of that which can currently be removed. Eithercondition represents an actual or potential substantial degradation of the level of safetyof the plant.A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.The RCS Heat-up Duration Thresholds table addresses an iRe-easerise in RCStemperature when CONTAINMENT CLOSURE is established but the RCS is not intact._iOr RCS in'...ent,; (e.g., mid-loop operation in PWRs). The 20-minuteMonth 20XXDR 3-91EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONScriterion was included to allow time for operator action to address the temperatureiris___nse.The RCS Heat-up Duration Thresholds table also addresses an inr, eeaserise in RCStemperature with the RCS intact. The status of CONTAINMENT CLOSURE is notcrucial in this condition since the intact RCS is providing a high pressure barrier to afission product release. The 60-minute time frame should allow sufficient time toaddress the temperature i..reaserise without a substantial degradation in plant safety.Finally, in the case where there is an in RCS temperature, the RCS is notintact Or is at ..d..d inv.nt..y [P-VrI, and CONTAINMENT CLOSURE is notestablished, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) theevaporated reactor coolant may be released directly into the Containment atmosphereand subsequently to the environment, and 2) there is reduced reactor coolant inventoryabove the top of irradiated fuel.EAL #2 provides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS6 or RAS1.Basis Reference(s):1. NEI 99-01 Rev 6, CA32. Technical Specifications 3.6.1.13. Technical Specifications 3.6.4.14. OU-AA-103 Shutdown Safety Management Program5. DGP 02-01 Unit Shutdown6. DOA 0201-04 Loss of Vessel Flange, Shell, or Recirculation (Recirc) LoopTemperature Recorders During Heatup or Cooldown7. DGP 02-02 Reactor Vessel Slow Fill8. DIS 0263-19 Reactor Wide Range Pressure Transmitter Calibration Eq.Maintenance InspectionMonth 20XXDR 3-92EP-AA-1 004 (Revision XX) | |||
Nuclearflmsden Annex FvieInn Nucler!IRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSInitiating Condition:UNPLANNED ieeaee in RCS temperatureOperating Mode Applicability:4,5Emergency Acton Level (EAL):Note:CU53* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.The EmergncRy the Unusual Event promptly upon determiningthat 15 m*inutes has boon eXceeded, Or Will likely be exced.d.1. UNPLANNED rise in RCS temperature > 212°F due to loss of decay heatremoval.OR2. Loss of the following for > 15 minutes.* ALL RCS temperature indicationsAND* ALL RPV water level indications1. UNPLA.NNED increasorise in RCS temperatu to greater than (cite specificTechnical Spciiato cod hu-tdown%~f temper-ature limit).22. Losss of ALL RCS t9emperature and reactor vossoL'RCS level indic-atioen for 15mninutes or longer.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchanae or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment (primary or secondary) and its associated structures, systems, andcomponents as a functional barrier to fission product release under shutdownconditions.Month 20XXDR 3-93EP-AA-1004 (Revision XX) | |||
AnnoyI:xAIon frawign Anniax Exelnn NuleIasrRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSI This IC addresses an UNPLANNED ineFeaserise in RCS temperature above theTechnical Specification cold shutdown temperature limit, or the inability to determineRCS temperature and level, represents a potential degradation of the level of safety ofthe plant. If the RCS is not intact and CONTAINMENT CLOSURE is not establishedduring this event, the Emergency Director should also refer to IC CA53.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs. etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.EAL #1 involves a loss of decay heat removal capability, or an addition of heat to theRCS in excess of that which can currently be removed, such that reactor coolanttemperature cannot be maintained below the cold shutdown temperature limit specifiedin Technical Specifications. During this condition, there is no immediate threat of fueldamage because the core decay heat load has been reduced since the cessation ofpower operation.During an outage, the level in the reactor vessel will normally be maintained above thereactor vessel flange. Refueling evolutions that lower water level below the reactorvessel flange are carefully planned and controlled. A loss of forced decay heat removalat reduced inventory may result in a rapid iGireaserise in reactor coolant temperaturedepending on the time after shutdown.EAL #2 reflects a condition where there has been a significant loss of instrumentationcapability necessary to monitor RCS conditions and operators would be unable tomonitor key parameters necessary to assure core decay heat removal. During thiscondition, there is no immediate threat of fuel damage because the core decay heatload has been reduced since the cessation of power operation.I Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.I Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA53 basedon exceeding plant configuration-specific time criteria.Month 20XXDR 3-94EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSBasis Reference(s):1. NEI 99-01 Rev 6, CU32. Technical Specifications Table 1.1-13. DGP 02-01 UNIT SHUTDOWN4. DOA 0201-04, Loss of Vessel Flange, Shell, or Recirculation (Recirc) LoopTemperature Recorders During Heatup or Cooldown5. DGP 02-02 Reactor Vessel Slow Fill6. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines7. DEOP 100 RPV Control, Table A8. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level InstrumentationMonth 20XXDR 3-95EP-AA-1004 (Revision XX) | |||
Annoyflmsden Annex Exelon NucleI~arRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCG6-Initiating Condition:Loss of RPV inventory affecting fuel clad integrity with containment challenged.Operating Mode Applicability:4,5Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.The Emcrgoncy DircctOr should dcclare- tho Goncral EmorgoncY promnptly upondotrmiRRng that 30 miRutes has be,, or will likely be vcdod.,1. a. RPV water level < -143 inches (TAF) for > 30 minutes.ANDb. Any Containment Challenge Indication (Table 04)OR2. a. RPV water level unknown for > 30 minutes.ANDb. Core uncovery is indicated by any of the following:* Table C3 indications of a sufficient magnitude to indicate coreuncovery.OR" Refuel Floor Hi Range ARM >3000 mR/hr.ANDc. Any Containment Challenge Indication (Table 04)Table C3 Indications of RCS Leakaqe" UNPLANNED floor or equipment sump level rise*" UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise" Observation of leakage or inventory lossMonth 20XXDR 3-96EP-AA-1004 (Revision XX) | |||
Dresden AnnexI::xelon NuclearDresdn Annex iYlAorn NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONS*Rise in level is attributed to a loss in RPV inventory.Table C4 Containment Challen-ce Indications* Primary Containment Hydrogen Concentration > 6% and Oxvqen > 5%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established** Any Secondary Containment radiation monitor > DEOP 300-1 MaximumSafe operating level.* if CONTAINMENT CLOSURE is re-established prior to exceedina the 30-minutecore uncovery time limit, then escalation to a General Emergency is not required.1 .a. (Reactor uvossoVRCS level loss than (sito spocifi levol) for 30 minutes OFlonger.ANDb. ANY indiction fromn the Conta.nment Challenge Table (seo below).2. a. Reactnor ......oelnRCS level cannot be mon-,itoed for 30 minutes Or Ionger.IAN1b. Core uncovery is indicated by ANY of the following:-f oLLL Ojl.'kl ^ "ýta zttaf. flflfllrLJ1 ranaltSII b tial \O1L v 'L A | |||
* v AA- 4F.1 5 511 F* Effatte SOUrree Fafige MORHOF tBut6ittIORD f J .m .1 %e U.NPLANNEDhI inerease int (ste specitic sume anE.or- tank) levels of sut~icient(Other Site speeific indicationRs)Month~~~~~~D 3-9E7A- 04(eiso XMonth 20XXEP-AA-1004 (Revision XX) | |||
Dresden Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING MALFUNCTIONSAMDG. n ication fr o-m tho Colntaimeent t. Ch a lle e T abl1,e (s e .e ContainmInt Challng1 TabJlCONTAINMENT CLOSURE not establishedt(Explosive miAr'Ie) e1ists inside containmentUNPLANNED increase in eentainment pr-essufe*If CONTAINMVENT CLOSURE is ro cetablishod p~Or to eXceeding the 30 minute timeBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment (primary or secondary for BWR) and its associated structures,systems, and components as a functional barrier to fission product release undershutdown conditions.This IC addresses the inability to restore and maintain reactor vessel level above thetop of active fuel with containment challenged. This condition represents actual orIMMINENT substantial core degradation or melting with potential for loss of containmentintegrity. Releases can be reasonably expected to exceed EPA Protective ActionGuidelines (PAGI exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a directand unmonitored release of radioactivity to the environment. If CONTAINMENTCLOSURE is re-established prior to exceeding the 30-minute time limit, then declarationof a General Emergency is not required.The existence of an explosive mixture means, at a minimum, that the containmentatmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity. Ittherefore represents a challenge to Containment integrity.Month 20XXDR 3-98EP-AA-1 004 (Revision XX) | |||
Dresden AnnexExellon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSIn the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to acore uncovery could result in an explosive gas mixture in containment. If all installedhydrogen gas monitors are out-of-service during an event leading to fuel claddingdamage, it may not be possible to obtain a containment hydrogen gas concentrationreading as ambient conditions within the containment will preclude personnel access.During periods when installed containment hydrogen gas monitors are out-of-service,operators may use the other listed indications to assess whether or not containment ischallenged.bi:-EAL 2-b#1 Basis,-Ihe 30-minute criterion is tied to a readily recognizable event start time (i.e., the totalloss of ability to monitor level), and allows sufficient time to monitor, assess andcorrelate reactor and plant conditions to determine if core uncovery has actuallyoccurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor RPV-IeveIRPV water level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the RPV.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Basis Reference(s):1. NEI 99-01 Rev 6, CG12. DEOP 0100-00 RPV Control3. Technical Specifications 3.3.1.24. DOS 0700-01 SRM Functional Test5. DAN 902(3)-5 E-4 SRM Short Period6. DEOP 0200-01 Primary Containment Control7. DEOP 0200-02 Hydrogen Control8. DEOP 0300-01 Secondary Containment Control9. USAR Table 6.2-110. EP-EAL-0501Month 20XXDR 3-99EP-AA-1004 (Revision XX) | |||
Nuel@Arfres~den Annex ExAelon NucleanrRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSInitiating Condition:Loss of RPV inventory affecting core decay heat removal capability.Operating Mode Applicability:4,5Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.The Em;ergency D~irector should declare the Site Aroa EmergencGy promptly upondetWmining that 30 minutes has been esaieded, or will likely be e 6ecdesd.1. With CONTAINMENT CLOSURE not established, RPV water level < -60 inchesOR2. With CONTAINMENT CLOSURE established. RPV water level < -143 inches(TAF)* OR3. a. RPV water level unknown for > 30 minutesANDb. Core uncovery is indicated by any of the following:* Table C3 indications of a sufficient magnitude to indicate core uncovery.OR" Refueling Floor Hi Range ARM >3000 mR/hr.Table C3 Indications of RCS Leaka e" UNPLANNED floor or eguipment sump level rise** UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss in RPV inventory..a. CONTAINMENT CLOSURE not established.Month 20XXDR 3-100EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSm. (Rai r- Ve s E O L'rRCI fe~ I 1 or N P-1r.' ~ v i lovel0- ioAP mAA F An n o D0 icV --L ..... 3l ll l l;j. a. GGurT INP~ MENJ "LUO U11P esiaDi~sna.AANDLlit __ __ __JL _ _,IE-~,%f. rr~IiIrYI ~ I rFtArwI~ ,~, *. .U. I.!A..19. i-earior voesevmriu5 :I'e Jr or F --' Pd J IP5 level less than ske-eP e f G e ert __ lit __ __ __JL,, n r ,.. r wln ,ý % r 1 %6A ffA- iI I.. I.. .. L .. -1. .1 ..-^ ^vr-- z a =CV12 f-- a =- ý.. zf2z' 2minutes or longer.ANMI i IRID f IB fm Ab. 6 Q Fel-'AGoyew 16 'AG11Ga;eei PY A | |||
* OT tne T9110MAW!e (Site sneeifie r-adiatieft foeniter-) madine ffeater- than (site seeeifie v-V--+,- , ---rDIXIDIt J .1%* UNPLANNED iftervase ia ýsite sf amVer- tafwj ieveis of suffietentmagnitude to indieate eafe uneever-ye (Other- site speeifie indieations)ABasis:CONTAINMENT CLOSURE: The Procedurally defined conditions or actions taken tosecure containment (prima!y or seconda!y for BWR) and its associated structures,§ystems, and components as a functional barrier to fission product release undershutdown conditions.UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parametechange or event may be known or unknown.This lG addFesser, a signifiGant and pmlenged loss of RPV inventeFy Gentrel andFnakeUp Gapabolity leading to 1MMINENT fuel damage. The lost inventory may be due toa RCS component failure, a loss of configuration control or prolonged boiling of reactorcoolant. These conditions entail major failures of plant functions needed for protectionof the public and thus warrant a Site Area Emergency declaration.I Following an extended loss of core decay heat removal and inventory makeup, decayMonth 20XXDR 3-101EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.Outage/shutdown contingency plans typically provide for re-establishing or verifyingCONTAINMENT CLOSURE following a loss of heat removal or RCS inventory controlfunctions. The difference in the specified RCS/reactor vessel levels of EALs 1 .b and 2.breflect the fact that with CONTAINMENT CLOSURE established, there is a lowerprobability of a fission product release to the environment.In EAL #3.a, the 30-minute criterion is tied to a readily recognizable event start time(i.e., the total loss of ability to monitor level), and allows sufficient time to monitor,assess and correlate reactor and plant conditions to determine if core uncovery hasactually occurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor RPV-levelRPV water level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the RPV.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Escalation of the emergency classification level would be via IC CG1-6 or ARGI.Basis Reference(s):1. NEI 99-01 Rev 6, CS12. Technical Specifications Table 3.3.5.1 13. UFSAR 5.2.54. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines5. DEOP 0100-00 RPV Control6. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log7. DAN 902(3)-4 A-17 rywetlDrywell Equip Sump Lvl HI-HI8. DAN 902(3)-4 H-18 D Dywe~lrywell Floor Drn Sump Lvl HI-HI9. DOA 0040-01 Slow Leak10. DOP 2000-24 r..ywe. .rywel, Sump OperationMonth 20XXDR 3-102EP-AA-1004 (Revision XX) | |||
Exelon NuclearDresden Annex Eeo ulaRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONS11. Technical Specifications 3.3.1.212 DOS 0700-01 SRM Functional Test13. DAN 902(3)-5 E-4 SRM Short PeriodMonth 20XXDR 3-103EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCA64-Initiating Condition:Loss of RPV inventory.Operating Mode Applicability:4,5Emergency Acton Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.I E A B nThnneimenrrirFnr" nmrtnr itniu nnie the~ Alert nrnmm.' iinon Ennmimnine tha~t.4 Crvn inta+ kn knn 14,nnjr Ar H! Mes'n! ka a 1na4r -.-~, ~ .....a. Loss of RPV inventory as indicated by level < -54 inches.OR1. a. RPV water level unknown for > 15 minutes.ANDb. Loss of RPV inventory per Table C3 indications.Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise*" UNPLANNED Torus level rise*" UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss in RPV inventory.I4 ----A-. .i.ý re _ ..1_ 1__1 I --LL___ /-.'.L- __ _=level),drJ2. a. Reactor sVeVeVVVR level cannot be moFnitored 9fo 15 m nuto or longerANDL I IklIPJ'tl A !_=I av! -11 IA I I ý__D uL.W'IIIW inrn-AwI MINNT MDCI! Eum ==I~o awlK I6VCIEo~z OUZ0a-------- ----V -- --V beSS nO reacrtonr yosccvt9iV 6 inVeniorV.Month 20XXDR 3-104EP-AA-1004 (Revision XX) | |||
I::xAInn fresfd.en Annex Exelon Nucler~IRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.IC addresses conditions that are precursors to a loss of the ability toadequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier).This condition represents a potential substantial reduction in the level of plant safety.F-r-EAL #1 Basis--a lowering of water level below -54 inches (site cpo.ific le'.'el) indicates that operatoractions have not been successful in restoring and maintaining RPV water level. Theheat-up rate of the coolant will iPAeaserise as the available water inventory is reduced.A continuing deGiease rop in water level will lead to core uncovery.Although related, EAL #1 is concerned with the loss of RCS inventory and not thepotential concurrent effects on systems needed for decay heat removal (e.g., loss of aResidual Heat Removal suction point). AA ieieaeerise in RCS temperature caused bya loss of decay heat removal capability is evaluated under IC CA53.Fer-EAL #2 Basis,-tThe inability to monitor RPV-IeveIRPV water level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the RPV.The 15-minute duration for the loss of level indication was chosen because it is half ofthe EAL duration specified in IC CS64-If the RPV inentwy water level continues to lower, then escalation to Site AreaEmergency would be via IC CS6-1-.Basis Reference(s):1. NEI 99-01 Rev 6, CA12. USAR 5.2.5, Detection of Leakage through Reactor Coolant Pressure Boundary3. Technical Specification 3.3.5.1, Emergency Core Cooling System (ECCS)Instrumentation4. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines5. DEOP 100 RPV ControlMonth 20XXDR 3-105EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING MALFUNCTIONS6. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log7. DAN 902(3)-4 A-17 D~ywellDrywell Equip Sump Lvl HI-HI8. DAN 902(3)-4 H-18 Dyweg#Drywell Floor Drn Sump Lvl HI-HI9. DOA 0040-01 Slow Leak10. DOP 2000-24 Diywe#Drywell Sump OperationMonth 20XXDR 3-106EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCU61-Initiating Condition:UNPLANNED loss of RPV inventory for 15 minutes or longer.Operating Mode Applicability:4,5Emergency Acton Level (EAL):Note:9 The Emerqency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Trkmf Cmmvrt~ F-linn,4r~ ,ehidA AI, 1 *hk H 1r C' n+I r" r ~i,^1 % i r I I EV m*k.,, 4 mn..* ksr kna A.,nnr r *fH! !lu6k! knA A~ ~ ~ ~ t wwr ln wc v , Orl IyV V I7 VV llV V V V I!11Il VI =7w= ý .V 1. UNPLANNED loss of reactor coolant results in the inability to restore andmaintain RPV water level above the procedurally established lower limit for >15 minutes.OR2. a. RPV water level unknownANDb. Loss of RPV inventory per Table C3 indications.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss in RPV inventory.I lr'l k &1ýIP I-. .__ ....I ---__ IL .... J _ " ...... 1 I2 A -r %, ,;rr In.,,nr lran ; f r 1 iZ ,y% n fir Innrmn r0 D n.~n+nr ~,nt.enl IDt' Q mi In I ~ ri nn* ha mrir~i*r.rnAANDk I IKIDI AKIKIM r ;r^ ;n .msr" ^ntr4/ar *-AnIAIael~Month 20XX1row glDR 3-107vm EP-AA-1004 (Revision XX) | |||
Dregden Annexfresden Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the Parameterchange or event may be known or unknown.This IC addresses the inability to restore and maintain water level to a requiredminimum level (or the lower limit of a level band), or a loss of the ability to monitor RPVIeveIRPV water level concurrent with indications of coolant leakage. Either of theseconditions is considered to be a potential degradation of the level of safety of the plant.The procedurally established lower limit is not an operational band established abovethe procedural limit to allow for operator action prior to exceeding the procedural limit,but it is the procedurally established lower limit.Refueling evolutions that deGreaselower RCS water inventory are carefully planned andcontrolled. An UNPLANNED event that results in water level decreasing below aprocedurally required limit warrants the declaration of an Unusual Event due to thereduced water inventory that is available to keep the core covered.EAL #1 BasisiRecognizes that the minimum required RPV-leveIRPV water level can change severaltimes during the course of a refueling outage as different plant configurations andsystem lineups are implemented. This EAL is met if the minimum level, specified for thecurrent plant conditions, cannot be maintained for 15 minutes or longer. The minimumlevel is typically specified in the applicable operating procedure but may be specified inanother controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions torestore and maintain the expected water level. This criterion excludes transientconditions causing a brief lowering of water level.EAL #2 BasisaAddresses a condition where all means to determine RP-V-IeleIRPV water level havebeen lost. In this condition, operators may determine that an inventory loss is occurringby observing changes in sump and/or tank levels. Sump and/or tank level changesmust be evaluated against other potential sources of water flow to ensure they areindicative of leakage from the RPV.Continued loss of RCS inventory may result in escalation to the Alert emergencyclassification level via either IC CA6 or CA53.Month 20XXDR 3-108EP-AA-1004 (Revision XX)I Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSBasis Reference(s):1. NEI 99-01, Rev. 6 CUl2. USAR 5.2.5, Detection of Leakage through Reactor Coolant Pressure Boundary3. Technical Specifications 3.4.44. Technical Specifications 3.4.55. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log6. DAN 902(3)-4 A-17 DiyweUDrywell Equip Sump Lvi HI-HI7. DAN 902(3)-4 H-18 Dlywel4Drywell Floor Drn Sump Lvl HI-HI8. DOA 0040-01 Slow Leak9. DOP 2000-24 .Sump Operation10. DGP 02-02 Reactor Vessel Slow Fill11. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines12. DEOP 0100-00 RPV Control, Table A13. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level Instrumentation14. Technical Specifications Table 3.3.5.1 1Month 20XXDR 3-109EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1Initiating Condition:HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):1. A notification from the Security Force that a HOSTILE ACTION is occurring orhas occurred within the PROTECTED AREA.AND2. a. ANY Table H1 safety function cannot be controlled or maintained.ORb. Damage to spent fuel has occurred or is IMMINENTTable H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)A Unf 1CTII r ArTTIrnIM ;o r,, e ,mrnrr, err kn r~,^i irrrer4 t&,ifhki r kr DDn, TIT[=I-AREA as e,,povd by the (,it. \ p.,ifi hift ,up""' ii")...ANIDk C11ruc f +k f i! i k^A-%7 v %. .....rig..L I ,o r..... .I. L .... Jl.==ll--.J --=4. ANi of the roitowing safety; WRUnionc cannot Be GGnroIF onaRtaRed-7* Reactivity controel0 enar ennlinnWW UTRPV PP' ef level~ 03"1 WUP9 RCS heat removal-. -,OR, -*- IL AllI, ll"J r~96.amage te speRt fuel riaS 9cUrUUFFd OF IS 1MM1ivir=r1I.Month 20XXDR 3-110EP-AA-1004 (Revision XX) | |||
Oresden AnnexN.r-lAarDresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy eguipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.IMMINENT: The traiectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE FORCE: Any individuals who are engaaed in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.This IC addresses an event in which a HOSTILE FORCE has taken physical control ofthe facility to the extent that the plant staff can no longer operate equipment necessaryto maintain key safety functions. It also addresses a HOSTILE ACTION leading to aloss of physical control that results in actual or IMMINENT damage to spent fuel due to1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls,etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot bemaintained.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].EFm=eFrgny plans and implementing pro edures are public documents; EALss~hould no incorporat SecuiySenitiVe nomain This includos information thatmay be advantageu toaptntial adversary, such as the particulars concerning a-mu~~~~~~~~~~~ .~i .i .1: .~i .i .iu~ ..t i .i .t .r : .: .Iu .I .~u ..~ .~ ..1-Month 20XXDR 3-111EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYcontained on non public documen8t6 such as the Security Plan.Basis Reference(s):1. NEI 99-01, Rev. 6 HG15. Station Security Plan -Appendix CMonth 20XXDR 3-112EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS1Initiating Condition:HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.1. A HOSTILE ACTION ic occurring Or hac occrroF~d within tho PRO--GTECTEDAPREA acroportod by the (site-spccifiG cocrit hiftspcr:wisn).Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTEDAREA. This event will require rapid response and assistance due to the possibility fordamage to plant equipment.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Month 20XXDR 3-113EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYSecurity plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Site Area Emergency declaration will mobilize OROresources and have them available to develop and implement public protective actionsin the unlikely event that the attack is successful in impairing multiple safety functions.This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTEDAREA located outside the plant PROTECTED AREA; such an attack should beassessed using IC HA1. It also does not apply to incidents that are accidental events,acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by aHOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters,physical disputes between employees, etc. Reporting of these types of events isadequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR§ 50.72.Emorgoncy plans and implmerneting prOcodures arc public documents; theroforo, E=ALs-should not incorporae Security sencitivo nomain This inldsifrainthat_ay be advantageour, to a potenial adversaFy, such as the paticularS concerning aspecific throat Or throat location. Security-sensitive information should be contained inEscalation of the emergency classification level would be via IC HG1.Basis Reference(s):1. NEI 99-01 Rev 6, HS13. Station Security Plan -Appendix CMonth 20XXDR 3-114EP-AA-1004 (Revision XX) fl ma t4n Anniav=:vimlnn Kii,^lg--rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA1Initiating Condition:HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threatwithin 30 minutes.Operating Mode Applicability:1, 2,3,4,5, DEmergency Acton Level (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutes fromthe site.1. A HOST-ILE ACTION is cccufrring er has eccurred within the OWNEROR2. Notification by the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the OWNER CONTROLED AREA.A validatod rntificao-n ARfrom IRc , of an oircraft attack within 30 mnut ofthe steBasis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy eguipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An oboect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.OWNER CONTROLLED AREA (OCA): The property associated with the station andowned by the company. Access is normally limited to persons entering for officialbusiness.Month 20XXDR 3-115EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYPROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.This IC addresses the occurrence of a HOSTILE ACTION within the OWNERCONTROLLED AREA or notification of an aircraft attack threat. This event will requirerapid response and assistance due to the possibility of the attack progressing to thePROTECTED AREA, or the need to prepare the plant and staff for a potential aircraftimpact.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Alert declaration will also heighten the awareness ofOffsite Response Organizations, allowing them to be better prepared should it benecessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience,or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputesbetween employees, etc. Reporting of these types of events is adequately addressedby other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL 2 #1 BasisAaddresses the threat from the impact of an aircraft on the plant, and the anticipatedarrival time is within 30 minutes. The intent of this EAL is to ensure that threat-relatednotifications are made in a timely manner so that plant personnel and OROs are in aheightened state of readiness. This EAL is met when the threat-related information hasbeen validated in accordance with DOA 0010-18, Escalated Security Event/HostileForce Intrusio pr-edure)h.EAL #2 Basis4--4s applicable for any HOSTILE ACTION occurring, or that has occurred, in theOWNER CONTROLLED AREA. This includes any action directed against an ISFSI thatis located outside the plant PROTECTED AREA.Month 20XXDR 3-116EP-AA-1004 (Revision XX) | |||
Dresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYEAL #2 addresses the threat 4rom the impact of an aircraft on the plant, and theanticipated arrival tome is within 30 mninutoc. The intent of this EAL is to onsuro thathroat-rolatoed notfific-ations arc mnade in a timely manner SO that plant personnel andare in a heightened st.e, Of readiness. This E..L is. Uet whe n the has heen validated in %Ajfk,; fft- r^^,ft4,,infII | |||
* n mULISH nThe NRC Headquarters Operations Officer (HOO) will communicate to the licensee ifthe threat involves an aircraft. The status and size of the plane may be provided byNORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNERCONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected,although not certain, that notification by an appropriate Federal agency to the site wouldclarify this point. In this case, the appropriate federal agency is intended to be NORAD,FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs,should not be unduly delayed while awaiting notification by a Federal agency.plans and implementing proedures are pu .blic EAI.sshould- not incorpoate Security scncitive information. This includes information thatma" be advantageou toapoetial adversary, SUch as the particulars concrnig asp9cific throat Or threat locatýion. Security sensitiye information should be contained innon public documents such as the Security Plan.Escalation of the emergency classification level would be via IC HS1.Basis Reference(s):1. NEI 99-01 Rev 6, HA12. Station Security Plan -Appendix C3. DOA 0010-18, Escalated Security Event/Hostile Force IntrusionMonth 20XXDR 3-117EP-AA-1004 (Revision XX) | |||
Dresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU1Initiating Condition:Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):* Notification of a credible security threat directed at the site as determined perSY-AA-1 01-132, Security Assessment and Response to Unusual Activities.p A SECURITY CONDITION that does not inv..olve a H.STILE ACTION as r-eported bthe (site spenific security shift superCrisicn).OR" A validated notification from the NRC providing information of an aircraft threat." Notification of a credible security threat directed at the site.OR" Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.*A notific-ation fromn the NRG proViding infO.r.mAtion of an throat.Basis:SECURITY CONDITION: Any Security Event as listed in the approved securitycontingency plan that constitutes a threat/compromise to site security, threat/risk to sitepersonnel, or a potential degradation to the level of safely of the plant. A SECURITYCONDITION does not involve a HOSTILE ACTIONSAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.Month 20XXDR 3-118EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYPROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEMequipment, and thus represent a potential degradation in the level of plant safety.Security events which do not meet one of these EALs are adequately addressed by therequirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed asHOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Classification of these events will initiate appropriate threat-related notifications to plantpersonnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 BasisAddresses the receipt of a credible security threat. The credibility of the threat isassessed in accordance with SY-AA-101-132. -rfor.n.... ('ito ..p.eifi. c:u..ty chift,up,.-,e;.) bo.a-, o th.-o,- --r tho -I,-,-;_. tr-in; d to -onfirm that a' ,-,u, it;, o'.' 4 i.urinEAL #2 BasisaAddresses the threat from the impact of an aircraft on the plant. The NRCHeadquarters Operations Officer (HOO) will communicate to the licensee if the threatinvolves an aircraft. The status and size of the plane may also be provided by NORADthrouah the NRC. Validation of the threat is Derformed in accordance with DOA 0010-_ ....... I ..... \ -- --its tzscaiaiea ,:ecuriiy -venuriosiiie r-orce inirusiontsi'e spgf--adreses....... J1110 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~~i aOlTO ronnscsi'. noT In rafhITJO fDira E PCesseg in---------. -accodanc wit (cie e~eific roceedure).EAL #3 Basis"i I "tlf ererences Securiwy -orcmf',ds MG :ssurtey GR.- 6Upe"-f%"o -Decause tnese arethe individuals trained to confirm that a securitv event is occurring or has occurred.Training on security event confirmation and classification is controlled due to the natureof Safeguards and 10 CFR § 2.39 information.. th thr"ot from tho impa.t ofan irrarft on tho plant. Tho hNrC Hoadguartora Oporotinnc Officer (HOD) ''Ilcemmunipto to tho 4ioncoo- if tho throat nolocanaircrft. Th -ot -~tc and cizto of therilao ma.' aco b Dre.'idd hi: hnORA. throahci thci NC. 11alidation of the thr-oatiV.70p. ..ermod in a.crdnc ...... \c procedure)Month 20XXDR 3-119EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYEmergency plans and imlmnigprOceduroc arc pu blic documonts; therefore, EAI~sshould not increporate Security-sensitk'c information. T-hic inclu-doc- inforFmation thatmay be advantageous to a potential advcrsar,', such as the patiGiulaFGRG cocrin a.pecific threat or threat l.,atie,. Security sensitive info. ..ation should bo containedinnon public documentS such as the Security Plan.Escalation of the emergency classification level would be via IC HA1.Basis Reference(s):1. NEI 99-01 Rev 6, HU12. SY-AA-1 01-132, Security Assessment and Response to Unusual Activities3. Station Security Plan -Appendix C4. NRC Safeguards Advisory 10/6/015. Letter from Mr. B. A. Boger (NRC) to Ms. Lynette Hendricks (NEI) dated 2/4/026. DOA 0010-18, Escalated Security Event/Hostile Force IntrusionMonth 20XXDR 3-120EP-AA-1 004 (Revision XX) | |||
Dresden AnnexExalon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS26Initiating Condition:Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:1,2, 3, 4,5, DEmergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.The E.mergency Diroctor Ashould docnlaare the Site Area EmFergencyoVent prom~ptly Upondetemining that (site-specific number of minutes) has boon oXcoodod, Or willlikely be Xexededd.1. A Control Room eacuation has resulted in plant control being transferred from theControl Room to alternate locations per DSSP 0100-CR. Hot Shutdown Procedure-Control Room Evacuation.AND2. Control of ANY Table Hi key safety function is not reestablished in < 30 minutes.Table Hi Safety Functions" Reactivity Control (ability to shut down the reactor and keep it shutdown)" RPV Water Level (ability to cool the core)" RCS Heat Removal (ability to maintain heat sink)1. a. An ovcnt has resulted in plant control being transferred panels and localcontrol stations). fromn the Control Room to (site-specific remoete shutdownb. Control o-f ANY. of the floigkey safety functions is not Feestablishcdwithin (site-specific numbwer f minutess).* ReactiVity controa- Core cooling [PVVR] ý RPV water level [9144Ao RCS heat removalMonth 20XXDR 3-121EP-AA-1004 (Revision XX) nrimarign AnngavFva~lnn Na -harlrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:The time period to establish control of the plant starts when either:a. Control of the plant is no longer maintained in the Main Control RoomORb. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations, and the control of a key safety function cannot bereestablished in a timely manner. The failure to gain control of a key safety functionfollowing a transfer of plan control to alternate locations is a precursor to a challenge toono or morcany fission product barriers within a relatively short period of time.The determination of whether or not "control" is established at the remote safeshutdown location(s) is based on Emergency Director judgment. The EmergencyDirector is expected to make a reasonable, informed judgment within timefG 30 minutes whether or not the operating staff has control of key safetyfunctions from the remote safe shutdown location(s).Escalation of the emergency classification level would be via IC FG1 or CG6-1-.Basis Reference(s):1. NEI 99-01, Rev 6 HS62. DSSP 0100-CR Hot Shutdown Procedure -Control Room EvacuationMonth 20XXDR 3-122EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA26Initiating Condition:Control Room evacuation resulting in transfer of plant control to alternate locations.Operating Mode Applicability:1,2, 3, 4,5, DEmergency Acton Level (EAL):A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per DSSP 0100-CR, Hot Shutdown Procedure -Control Room Evacuation.An event has resulted in plant contrl being transferred from the GContel Room to (site-specific r~emte shutdown panels and local conrol1 stations).Basis:This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations outside the Control Room. The loss of the ability to controlthe plant from the Control Room is considered to be a potential substantial degradationin the level of plant safety.Following a Control Room evacuation, control of the plant will be transferred to alternateshutdown locations. The necessity to control a plant shutdown from outside the ControlRoom, in addition to responding to the event that required the evacuation of the ControlRoom, will present challenges to plant operators and other on-shift personnel.Activation of the ERO and emergency response facilities will assist in responding tothese challenges.Escalation of the emergency classification level would be via IC HS26.Basis Reference(s):1. NEI 99-01, Rev 6 HA62. DSSP 0100-CR, Hot Shutdown Procedure -Control Room EvacuationMonth 20XXDR 3-123EP-AA-1004 (Revision XX) nranlrin AnnovP~v--Inn k, ,,-IaorRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU34Initiating Condition:FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):Note:* The Emergency Director should declare the event Promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.The Emnergency Director should decl-are the Unusual Event promnptly Uponthat the applicable time has boon oXcoodd, OFr Wi11 likely be8XGeeded.1. A FIRE in any Table H2 area is not extinguished in < 15-minutes of ANY of thefollowing FIRE detection indications:" Report from the field (i.e., visual observation)" Receipt of multiple (more than 1) fire alarms or indications* Field verification of a single fire alarmTable H2 Vital Areas" Reactor Building (when inerted the Drywell is exempt)* Aux Electric Room* Control Room* Unit and Shared Emergency Diesel Generator Rooms* 4KV ECCS Switchgear Area (includes Bus 23, 24, 33 and 34 only)* CRD & CCSW Pump Rooms* Turbine Building Cable Tunnel" Turbine Building Safe Shutdown Areas as follows:* B- Train Control Room HVAC Room* Battery Rooms and DC Distribution Areas1) U2 Battery Room (includes DC switchgear, 125V, and 250V battery rooms)2) U3 Battery Room, Battery Cage area, and U3 Battery Charger Room (all on U3 TB 538)* Crib House-lORMonth 20XXDR 3-124EP-AA-1004 (Revision XX) | |||
AnnAxNuelAarfresd=n Anne NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY2. a. Receipt of a single fire alarm in any Table H2 area (i.e., no other indicationsof a FIRE).ANDb. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.OR3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes ofthe initial report, alarm or indication.OR4 A FIRE within the plant PROTECTED AREA that reguires firefighting support byan offsite fire response agency to extinguish.(1) a. A FIRE is NOT ,hinguishd within 15 _minutes of ANYI of tkhe followingFIRE d-etecntion indications:;"Report fromR the field (i.e., visual observation)" Receipt of multiple (mor~e than 1) fire alarms OrFniain" Field Yerification of a single fire alarmANDb. The FIRE ie located within ANY of the follow8 ng plant roomAs or a~reas:(cite-specific list of plant rooms Or areas)(2) a. Recoipt of a single fire alarm (i.e., no other indic-ations of a FIRE)-.ANDb. The FIRE is lcated within ANY of the follo g rlant room, or OrFas(site-specific list of plant rooms Or areas)ANDG. The of a FIRE is not ,,;rifi;d within 30 minutcs of alarm (3) A FIRE withiOn the plant or- ISF1S [fr plants with an ISF-S! outside the plnPrqtected Area] PROTECTED AREA Rot extiRgu-shed within 60 mninutes ofthI I I r+rs~lI4 St 'ru " *g flA at l 11 1 --1Month 20XXDR 3-125EP-AA-1004 (Revision XX) | |||
Dresden AnnexNuelAarfresden Annex Exelon NucilearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY(1) A FIRE within the plant or- ISFSI [for- plants with an ISFSI outside the planiP-ratected Afral PROTECTEFD AREA that roguirec firofighting cupport by anoffeite fire resepnco agency to e~inguishBasis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippinqdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of apotential degradation of the level of safety of the plant.EAL #1 BasisThe intent of the 15-minute duration is to size the FIRE and to discriminate againstsmall FIRES that are readily extinguished (e.g., smoldering waste paper basket). Inaddition to alarms, other indications of a FIRE could be a drop in fire main pressure,automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial firealarm, indication, or report. For EAL assessment purposes, the emergency declarationclock starts at the time that the initial alarm, indication, or report was received, and notthe time that a subsequent verification action was performed. Similarly, the fire durationclock also starts at the time of receipt of the initial alarms, indication or report.EAL #2 BasisThis EAL addresses receipt of a single fire alarm, and the existence of a FIRE is notverified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt,operators will take prompt actions to confirm the validity of a single fire alarm. For EALassessment purposes, the 30-minute clock starts at the time that the initial alarm wasreceived, and not the time that a subsequent verification action was performed.A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipmentfailure or a spurious activation, and not an actual FIRE. For this reason, additional timeis allowed to verify the validity of the alarm. The 30-minute period is a reasonableamount of time to determine if an actual FIRE exists; however, after that time, andabsent information to the contrary, it is assumed that an actual FIRE is in progress.Month 20XXDR 3-126EP-AA-1004 (Revision XX) nrgaadgn Anngav5:i:%1r~n Nhir-lgar* | |||
* S r5 SR S *5 S S *RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYIf an actual FIRE is verified by a report from the field, then EAL #1 is immediatelyapplicable, and the emergency must be declared if the FIRE is not extinguished within15-minutes of the report. If the alarm is verified to be due to anequipment failure or a spurious activation, and this verification occurs within 30-minutesof the receipt of the alarm, then this EAL is not applicable and no emergencydeclaration is warranted.EAL #3 BasisIn addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plantPROTECTED AREA not extinguished within 60-minutes may also potentially degradethe level of plant safety. This bais extends to a FIRE '. cur ..thin thsPROTECTED AREA of an ISFSI, the pl,,t POTECTED ARE.A.[Sentonco for plant-s wita.h aQn ISFSIoutsi the plant Protected Area]EAL #4 BasisIf a FIRE within the plant or ISFS1 [for-plants with an ISF,' "utskd; the plant Pro-tocd-AF-a]-PROTECTED AREA is of sufficient size to require a response by an offsitefirefighting agency (e.g., a local town Fire Department), then the level of plant safety ispotentially degraded. The dispatch of an offsite firefighting agency to the site requiresan emergency declaration only if it is needed to actively support firefighting effortsbecause the fire is beyond the capability of the Fire Brigade to extinguish. Declarationis not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix RAppendix R to 10 CFR 50, states in part:Criterion 3 of Appendix A to this part specifies that "Structures, systems, andcomponents important to safety shall be designed and located to minimize,consistent with other safety requirements, the probability and effect of fires andexplosions."When considering the effects of fire, those systems associated with achievingand maintaining safe shutdown conditions assume major importance to safetybecause damage to them can lead to core damage resulting from loss of coolantthrough boil-off.Because fire may affect safe shutdown systems and because the loss of functionof systems used to mitigate the consequences of design basis accidents underpost-fire conditions does not per se impact public safety, the need to limit firedamage to systems required to achieve and maintain safe shutdown conditions isMonth 20XXDR 3-127EP-AA-1004 (Revision XX) | |||
Dry.dAn AnnexDlresden Annex ExAeron Nuc~lerRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYgreater than the need to limit fire damage to those systems required to mitigatethe consequences of design basis accidents.In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of1-hour fire barriers for the enclosure of cable and equipment and associated non-safetycircuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify asingle alarm is well within this worst-case 1-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA26 or MA5SA9.Basis Reference(s):1. NEI 99-01, Rev 6 HU42. UFSAR 3.2, Classification of Structures, Components, and Systems3. UFSAR 3.5.34. General Arrangement Drawings M-3, M-4, M-4A, M-5 and M-10Month 20XXDR 3-128EP-AA-1004 (Revision XX) | |||
Dresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU42Initiating Condition:Seismic event greater than OBE levels.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):1. Control Room personnel feel an actual or potential seismic event.AND2. The occurrence of a seismic event is confirmed in a manner deemed appropriate bythe Shift Manager or Emergency Director.SeismniG event greater than Operating B3asis Earthquake (01BE) as, indicated by:.a. (cito spocific IndIIation that a seismic i5Int met Or exceeded OBE limits)Basis:This IC addresses a seismic event that results in accelerations at the plant site greaterthan those specified for an Operating Basis Earthquake (OBE)1.An earthquake greaterthan an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have nosignificant impact on safety-related systems, structures and components; however,some time may be required for the plant staff to ascertain the actual post-eventcondition of the plant (e.g., performs walk-downs and post-event inspections). Giventhe time necessary to perform walk-downs and inspections, and fully understand anyimpacts, this event represents a potential degradation of the level of safety of the plant.Event verification with external sources should not be necessary during or following anOBE. Earthquakes of this magnitude should be readily felt by on-site personnel andrecognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).Tho Shift Manager Or Emergency Director Ma" sook e~dernal Yorific-ation if doomo~dappropiate (e.g., a call to tho USGS, chock internet news sourcGes, etc.); however, thevorifiatination must not preclude a timecly emergency declaration.EAL #2 is included to ensure that a declaration does not result from felt vibrationscaused by a non-seismic source (e.g.. a dropped load). The Shift Manager orEmergency Director may seek external verification if deemed appropriate (e.g.. call toUSGS, check internet source. etc.) however, the verification action must not preclude atimely emergency declaration. This EAL wording recognizes that it may cause the site to1 An OBE is vibratory ground motion for which those features of a nuclear power plantnecessary for continued operation without undue risk to the health and safety of thepublic will remain functional.An SSE is vibratory ground motion for which certain (generally, safety-related)structures, systems, and components must be designed to remain functional.Mot 2OXX DR -12lEPAA- 00 (Revison XXMonth 20XXDR 3-129EP-AA-1004 (Revision XX) | |||
Exelan NuclearDresden Annex Eeo ulaRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYdeclare an Unusual Event while another site similarly affected but with readily availableOBE indications in the Control Room, may not.Depending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA26 or MA5SAG.Basis Reference(s):1. NEI 99-01, Rev 6 HU22. DOA 0010-03 EarthquakesMonth 20XXDR 3-130EP-AA-1 004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5Initiating Condition:Gaseous release impeding access to equipment necessary for normal plant operations,cooldown or shutdown.Operating Mode Applicability:1,2,3, 4,5, DEmergency Acton Level (EAL):Note:* If the equipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emeraencv classification iswarranted.1. Release of a toxic, corrosive, asphyxiant or flammable qas in a Table H3 area.Table H3Areas with Entry Related Mode ADplicabilityArea Entry Related ModeApplicabilityReactor Building* Modes 3, 4, and 5*Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impededNote: if the equipment in the listed roomA or arca was already inepcrable Or Out-of cor.ice beforo the event occUrrod, then no- eomogency classification ~waRranted7-(1) a. Reloase of a toxic, corrose, asphyxiant o.r flam.mabl. gar, int any of thefollowing plant roms oraeaqs:.(site-specific list of plant rooms Or areas with entry related moedeapp-licaiinidniid--ANDI P I I I IIl l19. t--ntr; into tne room or area is pronilimee or impeaaMonth 20XXDR 3-131EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:This IC addresses an event involving a release of a hazardous gas that precludes orimpedes access to equipment necessary to transition the plant from normal plantoperation to cooldown and shutdown as specified in normal plant proceduresmaintainno"mal plant .p.atin o .r....rod f!O a normal plant co,1,dwn and shutdown. Thiscondition represents an actual or potential substantial degradation of the level of safetyof the plant.Table H3 is a list of plant rooms or areas with entry-related mode applicability thatcontain equipment which require a manual/local action necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal operatingprocedures (establish shutdown cooling), where if this action is not completed the plantwould not be able to attain and maintain cold shutdown.This Table does not include rooms or areas for which entry is required solely to performactions of an administrative or record keeping nature (e.g., normal rounds or routineinspections).This Table does not include the Control Room since adequate enqineered safety/designfeatures are in place to preclude a Control Room evacuation due to the release of ahazardous gas.An Alert declaration is warranted if entry into the affected room/area is, or may be,procedurally required during the plant operating mode in effect and the gaseous releasepreclude the ability to place shutdown cooling in ser*iceat the time of the ga..ourelease. The emergency classification is not contingent upon whether entry is actuallynecessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires theEmergency Director's judgment that the gas concentration in the affected room/area issufficient to preclude or significantly impede procedurally required access. Thisjudgment may be based on a variety of factors including an existing job hazard analysis,report of ill effects on personnel, advice from a subject matter expert or operatingexperience with the same or similar hazards. Access should be considered as impededif extraordinary measures are necessary to facilitate entry of personnel into the affectedroom/area (e.g., requiring use of protective equipment, such as SCBAs, that is notroutinely employed).An emergency declaration is not warranted if any of the following conditions apply.* The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the timeof the gaseous release). For example, the plant is in Mode 1 when the gaseousrelease occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4.Month 20XXDR 3-132EP-AA-1004 (Revision XX) nrmQarn AnniavFvalnn hhu-ImarRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY" The gas release is a planned activity that includes compensatory measures whichaddress the temporary inaccessibility of a room or area (e.g., fire suppressionsystem testing)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerouslevels. Most commonly, asphyxiants work by merely displacing air in an enclosedenvironment. This reduces the concentration of oxygen below the normal level ofaround 19%, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that generate smoke, that automaticallyor manually activate a fire suppression system in an area, or to intentional inerting ofcontainment.I Escalation of the emergency classification level would be via Recognition Category RA,C or F ICs.Basis Reference(s):1. NEI 99-01, Rev 6 HA52. UFSAR 3.5.33. UFSAR 3.24. General Arrangement Drawings M-3, M-4, M-4A, M-5 and M-10Month 20XXDR 3-133EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU63Initiating Condition:Hazardous EventOperating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):Note:* EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, orvehicle breakdowns or accidents.1. Tornado strike within the PROTECTED AREA.OR2. Internal room or area flooding of a magnitude sufficient to require manual orautomatic electrical isolation of a SAFETY SYSTEM component reguired byTechnical Specifications for the current operating mode.OR3. Movement of Dersonnel within the PROTECTED AREA is impeded due to an offsiteevent involving hazardous materials (e.,q., an offsite chemical spill or toxic gasrelease).OR4. A hazardous event that results in on-site conditions sufficient to prohibit the plantstaff from accessing the site via personal vehicles.OR5. Abnormal River level, as indicated by EITHER:a. High river level > 509 ft.ORb. Low river level < 501 ft. 6 inches.aa PAL A2 daz nnt~ a *I~ tn~ muin traff~i. k, wh a'o' lrnr' antr1r, y-----------------------------------V -V"H4UM A &tr~tWVJ... W i ...~&L:... 4L.-0) 10FRu.GuO W~ine~ WKHLIRl Iul r-ri'.jvr -i-., ArI ;..(~ Intr~rn~d room or ~ro~i floodino of ~ mnnitjdo riiffiriont to rrwniirn m~niioI or'-IMl iniarnal rnnFn nF anna finnd4nn of amagnitude r,- dffr-iAnt ta nual ecurnt nt operating mXde.Month 2OXXDR 3-134EP-AA-1004 (Revision XX) | |||
Dresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY(3) Moveoment of porconnol within the PROTECTED AREA is impeded duo to an( f4) t. eye naadous .. atorials (e.g., an offito cGhemial spill Or toxi. -(1) A hazardous eVont that reSUltS in on site conditions sufficisent to prohibit the plantI ~SUR tFGFn aGGeS61AQ IR9 Site Via PeFSGAal VeHIGIes.II-~.. -/f-\An ane69o M louiii at. u n-atur-a or ionnio -ai z-Aru uvuniwT\ ..... rBasis:PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity Drotected area fence.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses hazardous events that are considered to represent a potentialdegradation of the level of safety of the plant.EAL #1 BasisaAddresses a tornado striking (touching down) within the Protected Area.EAL #2 BasisaAddresses flooding of a building room or area that results in operators isolating powerto a SAFETY SYSTEM component due to water level or other wetting concerns.Classification is also required if the water level or related wetting causes an automaticisolation of a SAFETY SYSTEM component from its power source (e.g., a breaker orrelay trip). To warrant classification, operability of the affected component must berequired by Technical Specifications for the current operating mode. Manual isolation ofpower to a SAFETY SYSTEM component as a result of leakage is an event of lesserimpact and would be expected to cause small and localized damage. The consequenceof this type of event is adequately assessed and addressed in accordance withTechnical Specifications.EAL #3 BasisaAddresses a hazardous materials event originating at an offsite location and ofsufficient magnitude to impede the movement of personnel within the PROTECTEDAREA.EAL #4 BasisaAddresses a hazardous event that causes an on-site impediment to vehicle movementand significant enough to prohibit the plant staff from accessing the site using personalMonth 20XXDR 3-135EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYvehicles. Examples of such an event include site flooding caused by a hurricane, heavyrains, up-river water releases, dam failure, etc., or an on-site train derailment blockingthe access road.This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehiclebreakdowns or accidents, but rather to more significant conditions such as theHurricane Andrew strike on Turkey Point in 1992, the flooding around the CooperStation during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in2011.EAL #5 Basis:The possible maximum flood (PMF) produces a peak flood to 528 ft el. This issignificantly above the grade elevation (517 ft) and the high river water level threshold,which is the lowest opening leading to safety-related eguipment (509 ft el.). When thislevel is reached, the reactors are shutdown, the drywells are deinerted, and the vesselsare flooded and cooled to cold shutdown conditions as guickly as possible. If the waterlevel reaches 513 ft el., reactor cooldown is transferred to the Isolation Condensers,which thereafter maintain a safe shutdown condition until the flood waters recede andplant startup can be initiated.Minimum river water levels to assure pump suction are:" Circulating Water Pumps: 490 ft el." Service Water Pumps: 494 ft el.* CCSW Pumps: 501 ft 6 in." Unit 2/3 Fire Pump: 498 ft 6 in.The low river water level threshold (501 ft. 6 in.) is based on the most limiting pumpsuction requirement (CCSW).EAL #6 addrccccc (site cpeoific deoVipt Escalation of the emergency classification level would be based on lCs in RecognitionCategories RA, F, MS, H or C.Basis Reference(s):1. NEI 99-01, Rev 6 HU32. DOA 0010-01 Dresden Lock and Dam Failure3. DOA 0010-04 Floods4. DOA 0010-02 Tornado Warning/Severe Winds5. DOA-0010-12, Toxic Gas/Chemical Release from Nearby Chemical FacilitiesMonth 20XXDR 3-136EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a GENERAL EMERGENCY.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):4( Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or IMMINENTsubstantial core degradation or melting with potential for loss of containment integrity orHOSTILE ACTION that results in an actual loss of physical control of the facility.Releases can be reasonably expected to exceed EPA Protective Action Guidelineexposure levels offsite for more than the immediate site area.Basis:IMMINENT: The traiectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy eguirpment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for aGeneral Emergency.Basis Reference(s):1. NEI 99-01, Rev 6 HG7Month 20XXDR 3-137EP-AA-1004 (Revision XX) | |||
I=yAInn flmttrien Annpx Exeinn NucleIarRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a SITE AREA EMERGENCY.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):(-14 Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or likely major failuresof plant functions needed for protection of the public or HOSTILE ACTION that results inintentional damage or malicious acts, (1) toward site personnel or equipment that couldlead to the likely failure of or, (2) that prevent effective access to equipment needed forthe protection of the public. Any releases are not expected to result in exposure levelswhich exceed EPA Protective Action Guideline exposure levels beyond the siteboundary.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy eguipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for a SiteArea Emergency.Basis Reference(s):1. NEI 99-01, Rev 6 HS7Month 20XXDR 3-138EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an ALERT Operating Mode Applicability:1,2,3, 4,5, DEmergency Acton Level (EAL):(-1-) Other conditions exist which, in the judgment of the Emergency Director, indicatethat events are in progress or have occurred which involve an actual or potentialsubstantial degradation of the level of safety of the plant or a security event thatinvolves probable life threatening risk to site personnel or damage to site equipmentbecause of HOSTILE ACTION. Any releases are expected to be limited to smallfractions of the EPA Protective Action Guideline exposure levels.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anAlert.Basis Reference(s):1. NEI 99-01, Rev 6 HA7Month 20XXDR 3-139EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an EVENT.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):(-1) Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which indicate a potential degradation ofthe level of safety of the plant or indicate a security threat to facility protection has beeninitiated. No releases of radioactive material requiring offsite response or monitoring areexpected unless further degradation of safety systems occurs.Basis:This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anNOUEUNUSUAL EVENT.Basis Reference(s):1. NEI 99-01, Rev 6 HU7Month 20XXDR 3-140EP-AA-1004 (Revision XX) | |||
Dr@sden AnnexDlresden Annex ExeIon NucilearRECOGNITION CATEGORYISFSI MALFUNCTIONSE-HU1Initiating ConditionDamage to a loaded cask CONFINEMENT BOUNDARY.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contactradiation reading:1. EAST HI-STAR:9 > 160 mrem/hr (neutron + gamma) on the top of the OvermackOR0 > 250 mrem/hr (neutron+ gamma) on the side of the OverpackOR2. EAST HI-STORM:* > 20 mrem/hr (neutron+ gamma) on the top of the OverpackOR* >100 mrem/hr (neutron+ gamma) on the side of the OverpackOR* > 45 mrem/hr (neutron+ gamma) at the inlet and outlet vent ducts of theOverpackOR3. WEST HI-STORM:* > 40 mrem/hr (neutron+ gamma) on the top of the OverpackOR* >100 mrem/hr (neutron+ gamma) on the side of the Overpack, excluding inletand outlet ducts-(1)----Damage to a loaded cask CONFINEMV=ENT BOUNDARY as indiatcd by an ont radiatioGnA ading greatc, than (2 ti;mes the site specific cask specific specification allowable radiation level) on the su~faco of tho spent fuel cask.Basis:CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) betweenareas containing radioactive substances and the environment.Month 20XX DR 3-141 EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYISFSI MALFUNCTIONSINDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)* A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.This IC addresses an event that results in damage to the CONFINEMENT BOUNDARYof a storage cask containing spent fuel. -It applies to irradiated fuel that is licensed fordry storage beginning at the point that the loaded storage cask is sealed. The wordcask, as used in this EAL, refers to the storage container in use at the site for drystorage of irradiated fuel. The issues of concern are the creation of a potential or actualrelease path to the environment, degradation of one Or moreany fuel assemblies due toenvironmental factors, and configuration changes which could cause challenges inremoving the cask or fuel from storage.The existence of "damage" is determined by radiological survey. The technicalspecification multiple of "2 times", which is also used in Recognition Category RA ICRAU1, is used here to distinguish between non-emergency and emergency conditions.The emphasis for this classification is the degradation in the level of safety of the spentfuel cask and not the magnitude of the associated dose or dose rate. It is recognizedthat in the case of extreme damage to a loaded cask, the fact that the "on-contact" doserate limit is exceeded may be determined based on measurement of a dose rate atsome distance from the cask.Security-related events for ISFSIs are covered under ICs HU1 and HAl.Basis Reference(s):1. NEI 99-01, Rev 6 E-HU12. Certificate of Compliance No. 1014 Appendix A, Section 5.7 (WEST HI-STORM)3. Certificate of Compliance No. 1014 Appendix A, Section 3.2.3 (EAST HI-STORM)4. Certificate of Compliance No. 1008 Appendix A, Amendment 2, Section 2.2.1(EAST HI-STAR)Month 20XXDR 3-142EP-AA-1004 (Revision XX) | |||
Dresden AnnexI:xelnn Dresden Annex FvaeInn N~uclarRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS* RG1Initiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRemTEDE or 5000 mRem thyroid CDE.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessmentusing actual meteorology are available.1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+09 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidORMonth 20XXDR 3-33EP-AA-1 004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRGI (cont)Emergency Action Level (EAL) (cont):3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for60 minutes of inhalation.Basis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to the EPA Protective Action Guides (PAGs). Itincludes both monitored and un-monitored releases. Releases of this magnitude willrequire implementation of protective actions for the public.Radiological effluent EALs are also included to provide a basis for classifying eventsand conditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at the EPA PAG of 1000 mRem while the 5000 mRem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Basis Reference(s):1. NE 199-01 Rev 6, AG12. EP-AA-1 12-500 Emergency Environmental Monitoring3. ODCM Section 12.4 Gaseous Effluents and Total Dose4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From theUnit 2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous EffluentEAL Threshold Values Dresden Station6. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-34EP-AA-1004 (Revision XX) nractin Annoyflr~Qrg~n An~w Fvinn NucleIarRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSRS1Initiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDEor 500 mRem thyroid CDE.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessmentusing actual meteorology are available.1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+08 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 100 mRem TEDEORb. > 500 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >100 mR/hr are expected to continuefor > 60 minutes.b. OR Analyses of field survey samples indicate > 500 mRem CDE Thyroidfor 60 minutes of inhalation.Month 20XXDR 3-35EP-AA-1004 (Revision XX) | |||
Dresden AnnexNuclearDlresden Annex Exellnn N~uclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRS1 (cont)Basis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).It includes both monitored and un-monitored releases. Releases of this magnitude areassociated with the failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying eventsand conditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at 10% of the EPA PAG of 1000 mRem while the 500 mRemthyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDEand thyroid CDE.Escalation of the emergency classification level would be via IC RG1.Basis Reference(s):1. NEI 99-01 Rev 6, AS12. EP-AA-1 12-500 Emergency Environmental Monitoring3. ODCM Section 12.4 Gaseous Effluents and Total Dose4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From theUnit 2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous EffluentEAL Threshold Values Dresden Station6. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-36EP-AA-1004 (Revision XX) nroau4an Annav=,v--Irhn Klorl--mr-.~ ~* * *-.. ...~,t ~fl~in t.* in | |||
* Uti -*t.t.inRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA1Initiating Condition:Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRemTEDE or 50 mRem thyroid CDE.Operating Mode Applicability:1,2,3, 4,5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessmentusing actual meteorology are available.1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+07 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 50 mRem CDE ThyroidORMonth 20XXDR 3-37EP-AA-1 004 (Revision XX) | |||
Dresden AnnexDresden Annex ExceInn Nmu~clarRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA1 (cont)Emergency Action Level (EAL) (cont):3. Analysis of a liquid effluent sample indicates a concentration or release rate thatwould result in doses greater than EITHER of the following at or beyond the siteboundarya. 10 mRem TEDE for 60 minutes of exposureORb. 50 mRem CDE Thyroid for 60 minutes of exposureOR4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mR/hr are expected tocontinue for a 60 minutes.ORb. Analyses of field survey samples indicate > 50 mRem CDEThyroid for 60 minutes of inhalation.Basis:This IC addresses a release of gaseous or liquid radioactivity that results in projected oractual offsite doses greater than or equal to 1% of the EPA Protective Action Guides(PAGs). It includes both monitored and un-monitored releases. Releases of thismagnitude represent an actual or potential substantial degradation of the level of safetyof the plant as indicated by a radiological release that significantly exceeds regulatorylimits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying eventsand conditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at 1% of the EPA PAG of 1000 mRem while the 50 mRem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Escalation of the emergency classification level would be via IC RS1.Month 20XXDR 3-38EP-AA-1004 (Revision XX) | |||
Dresden AnnexI:yelnn NuclearDlresden Annex FwAllnn Nuclea~rRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRAI (cont)Basis Reference(s):1. NEI 99-01 Rev 6, AA12. ODCM Section 12.3 Liquid Effluents3. ODCM Section 12.4 Gaseous Effluents4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From theUnit 2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. UNIT 2/3 DAN 2223-6 A-12 "2/3 RADWASTE DISCHARGE HIGH RADIATION"6. UNIT 2/3 DOP 2000-110, Radioactive Waste Discharge to River With the Off-Stream Liquid Effluent Monitor Operable7. UNIT 2/3 DOP 2000-109, Waste Surge Tank Batching for a Radwaste RiverDischarge8. Structural Drawing B-01A Composite Site Plan Dresden Station Units 1, 2 & 39. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous EffluentEAL Threshold Values Dresden Station10. DEOP 300-2, Radioactivity Release Control11. EP-EAL-0620 Revision 0, Dresden Criteria for Choosing Radiological LiquidEffluent EAL Threshold ValuesMonth 20XXDR 3-39EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU1Initiating Condition:Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60minutes or longer.Operating Mode Applicability:1,2, 3,4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 60 minutes.* Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.1. Reading on ANY of the following effluent monitors > 2 times alarm setpointestablished by a current radioactive release discharge permit for ?: 60 minutes." Radwaste Effluent Monitor 2/3-2001-948OR" Discharge Permit specified monitorOR2. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 9.02 E+05 uCi/sec for > 60 minutes (as determined by DOP 1700-10 orPPDS -Total Noble Gas Release Rate).OR3. Confirmed sample analyses for gaseous or liquid releases indicateconcentrations or release rates > 2 times ODCM Limit with a release duration of> 60 minutes.Month 20XXDR 3-40EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU1 (cont)Basis:This IC addresses a potential decrease in the level of safety of the plant as indicated bya low-level radiological release that exceeds regulatory commitments for an extendedperiod of time (e.g., an uncontrolled release). It includes any gaseous or liquidradiological release, monitored or un-monitored, including those for which a radioactivitydischarge permit is normally prepared.Nuclear power plants incorporate design features intended to control the release ofradioactive effluents to the environment. Further, there are administrative controlsestablished to prevent unintentional releases, and to control and monitor intentionalreleases. The occurrence of an extended, uncontrolled radioactive release to theenvironment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying eventsand conditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.Releases should not be prorated or averaged. For example, a release exceeding 4times release limits for 30 minutes does not meet the EAL.EAL #1 BasisThis EAL addresses radioactivity releases that cause effluent radiation monitor readingsto exceed 2 times the limit established by a radioactivity discharge permit. This EAL willtypically be associated with planned batch releases from non-continuous releasepathways (e.g., radwaste, waste gas).The effluent monitors listed are those normally used for planned discharges. If adischarge is performed using a different flowpath or effluent monitor other than thoselisted (e.g., a portable or temporary effluent monitor), then the declaration criteria will bebased on the monitor specified in the Discharge Permit.EAL #2 BasisThis EAL addresses normally occurring continuous radioactivity releases frommonitored gaseous effluent pathways.EAL #3 BasisThis EAL addresses uncontrolled gaseous or liquid releases that are detected bysample analyses or environmental surveys, particularly on unmonitored pathways (e.g.,spills of radioactive liquids into storm drains, heat exchanger leakage in river watersystems, etc.).Escalation of the emergency classification level would be via IC RAI.Month 20XXDR 3-41EP-AA-1004 (Revision XX) | |||
Dresden AnnexExalon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRUI (cont)Basis Reference(s):1. NEI 99-01 Rev 6, AU12. ODCM Section 12.3 Liquid Effluents3. ODCM Section 12.4 Gaseous Effluents4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From theUnit 2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. UNIT 2/3 DAN 2223-6 A-12 "2/3 RADWASTE DISCHARGE HIGH RADIATION"6. UNIT 2/3 DOP 2000-110, Radioactive Waste Discharge to River With the Off-Stream Liquid Effluent Monitor Operable7. UNIT 2/3 DOP 2000-109, Waste Surge Tank Batching for a Radwaste RiverDischarge8. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous EffluentEAL Threshold Values Dresden Station9. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-42EP-AA-1004 (Revision XX) | |||
N Hr.lp_;irDlresden Annex Exelon NuclerIArRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA2Initiating Condition:Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel asindicated by ANY Table R1 Radiation Monitor reading >1000 mRem/hr.Table RIFuel Handling Incident Radiation Monitors" Refuel Floor High Range ARM Station #2(4)* Fuel Pool Radiation MonitorBasis:REFUELING PATHWAY: all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) betweenareas containing radioactive substances and the environment.This IC addresses events that have caused IMMINENT or actual damage to anirradiated fuel assembly. These events present radiological safety challenges to plantpersonnel and are precursors to a release of radioactivity to the environment. As such,they represent an actual or potential substantial degradation of the level of safety of theplant.This IC applies to irradiated fuel that is licensed for dry storage up to the point that theloaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss ofthe CONFINEMENT BOUNDARY is classified in accordance with IC E-HUI.Month 20XXDR 3-43EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA2 (cont)Initiating Condition:EAL #1 BasisThis EAL escalates from RU2 in that the loss of level, in the affected portion of theREFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery ofirradiated fuel. Indications of irradiated fuel uncovery may include direct or indirectvisual observation (e.g., reports from personnel or camera images), as well assignificant changes in water and radiation levels, or other plant parameters.Computational aids may also be used (e.g., a boil-off curve). Classification of an eventusing this EAL should be based on the totality of available indications, reports andobservations.While an area radiation monitor could detect a rise in a dose rate due to a lowering ofwater level in some portion of the REFUELING PATHWAY, the reading may not be areliable indication of whether or not the fuel is actually uncovered. To the degreepossible, readings should be considered in combination with other available indicationsof inventory loss.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.EAL #2 BasisThis EAL addresses a release of radioactive material caused by mechanical damage toirradiated fuel. Damaging events may include the dropping, bumping or binding of anassembly, or dropping a heavy load onto an assembly. Spent fuel uncovery representsa major ALARA concern in that radiation levels could exceed 10,000 R/hr on the refuelbridge when fuel uncovery begins. The value of 1000 mR/hr was conservatively chosenfor classification purposes. A rise in readings on radiation monitors should beconsidered in conjunction with in-plant reports or observations of a potential fueldamaging event (e.g., a fuel handling accident).Escalation of the emergency would be based on either Recognition Category Ror C ICs.Basis Reference(s):1. NE 199-01 Rev 6, AA22. DAN 902(3)-3 C-1 6(E-16) Reactor Building Fuel Pool Hi Radiation3. DAN 902(3)-3 B-1 Refuel Floor Hi Radiation4. DAN 902(3)-3 A-3(F-14) Reactor building Vent Hi-Hi Radiation5. UFSAR 9.16. DAN 902(3)-4 D-24 Fuel Pool Skimmer Tank Level Lo7. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level Instrumentation8. DFP 0850-01 Water Level Loss in SFP or Cavity9. DOP 1900-03 Reactor Cavity, Dryer/Separator Storage Pit and Fuel Pool LevelControlMonth 20XXDR 3-44EP-AA-1004 (Revision XX) | |||
Dresden AnnexI=xelnn NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU2Initiating Condition:UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:1, 2,3,4,5, DEmergency Action Level (EAL):1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated byANY of the following:" Refueling Cavity water level < 466 in. (Refuel Outage Reactor Vesseland Cavity Level Instrument LI 2(3)-263-114)OR* Spent Fuel Pool water level < 19 ft. above the fuel (< 33 ft. 9 in.indicated level).OR* Indication or report of a drop in water level in the REFUELINGPATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable RI.Table RIFuel Handling Incident Radiation Monitors" Refuel Floor High Range ARM Station #2(4)" Fuel Pool Radiation MonitorMonth 20XXDR 3-45EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU2 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.REFUELING PATHWAY: all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.This IC addresses a loss in water level above irradiated fuel sufficient to cause elevatedradiation levels. This condition could be a precursor to a more serious event and is alsoindicative of a minor loss in the ability to control radiation levels within the plant. It istherefore a potential degradation in the level of safety of the plant.A water level loss will be primarily determined by indications from available levelinstrumentation. Other sources of level indications may include reports from plantpersonnel (e.g., from a refueling crew) or video camera observations (if available) orfrom any other temporarily installed monitoring instrumentation. A significant drop in thewater level may also cause a rise in the radiation levels of adjacent areas that can bedetected by monitors in those locations.The effects of planned evolutions should be considered. For example, a refuelingbridge area radiation monitor reading may rise due to planned evolutions such as liftingof the reactor vessel head or movement of a fuel assembly. Note that this EAL isapplicable only in cases where the elevated reading is due to an UNPLANNED loss ofwater level.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RA2.Month 20XXDR 3-46EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU2 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, AU22. RP-AA-203 Exposure Control and Authorization3. Technical Specifications 3.7.84. Technical Specifications 3.9.65. UFSAR 9.16. DAN 902(3)-4 D-24 Fuel Pool Skimmer Tank Level Lo7. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level Instrumentation8. DFP 0850-01 Water Level Loss in SFP or Cavity9. DOP 1900-03 Reactor Cavity, Dryer/Separator Storage Pit and Fuel Pool LevelControl10. DGP 02-02, Reactor Vessel Slow Fill11. DAN 902(3)-3 C-16(E-16) Reactor Building Fuel Pool Hi Radiation12. DAN 902(3)-3 B-1 Refuel Floor Hi Radiation13. DAN 902(3)-3 A-3(F-14) Reactor building Vent Hi-Hi RadiationMonth 20XXDR 3-47EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA3Initiating Condition:Radiation levels that impede access to equipment necessary for normal plantoperations, cooldown or shutdown.Operating Mode Applicability:1,2,3, 4,5, DEmergency Action Level (EAL):Note:* If the equipment in the room or area listed in Table R3 was already inoperable, orout of service, before the event occurred, then no emergency classification iswarranted.1. Dose rate > 15 mR/hr in ANY of the following Table R2 areas:Table R2Areas Requiring Continuous Occupancy" Main Control Room (Unit 2 ARM Station #22)* Central Alarm Station -(by survey)OR2. UNPLANNED event results in radiation levels that prohibit or significantly impedeaccess to ANY of the following Table R3 plant rooms or areas:Table R3Areas with Entry Related Mode ApplicabilityArea Entry Related Mode ApplicabilityReactor Building* Modes 3, 4, and 5*Areas required to establish shutdown coolingMonth 20XXDR 3-48EP-AA-1004 (Revision XX) | |||
Dresden AnnexDresden Annex Exelnn Nucler~IRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA3 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient topreclude or impede personnel from performing actions necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal plantprocedures. As such, it represents an actual or potential substantial degradation of thelevel of safety of the plant. The Emergency Director should consider the cause of theincreased radiation levels and determine if another IC may be applicable.Table R3 is a list of plant rooms or areas with entry-related mode applicability thatcontain equipment which require a manual/local action necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal operatingprocedures (establish shutdown cooling), where if this action is not completed the plantwould not be able to attain and maintain cold shutdown. This Table does not includerooms or areas for which entry is required solely to perform actions of an administrativeor record keeping nature (e.g., normal rounds or routine inspections).Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including theControl Room.For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, ormay be, procedurally required during the plant operating mode in effect and theelevated radiation levels preclude the ability to place shutdown cooling in service. Theemergency classification is not contingent upon whether entry is actually necessary atthe time of the increased radiation levels. Access should be considered as impeded ifextraordinary measures are necessary to facilitate entry of personnel into the affectedroom/area (e.g., installing temporary shielding beyond that required by procedure,requiring use of non-routine protective equipment, requesting an extension in doselimits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply.* The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the timeof the elevated radiation levels). For example, the plant is in Mode 1 when theradiation rise occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4.The increased radiation levels are a result of a planned activity that includescompensatory measures which address the temporary inaccessibility of a room or area(e.g., radiography, spent filter or resin transfer, etc.).Month 20XXDR 3-49EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA3 (cont)Basis (cont):" The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category R, Cor F ICs.Basis Reference(s):1. NEI 99-01 Rev 6, AA32. DOP 1800-01 Area Radiation Monitors3. FSAR Section 3.2 Classification of Structures, Components and Systems4. General Arrangement Drawings M-3, M-4, M-4A, M-5 and M-105. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-50EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU3Initiating Condition:Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):1. Offgas system radiation monitor HI-HI alarm.OR2. Specific coolant activity > 4.0 uCI/gm Dose equivalent 1-131.Basis:This IC addresses a reactor coolant activity value that exceeds an allowable limitspecified in Technical Specifications. This condition is a precursor to a more significantevent and represents a potential degradation of the level of safety of the plant.Conditions that cause the specified monitor to alarm that are not related to fuel claddegradation should not result in the declaration of an Unusual Event.This EAL addresses site-specific radiation monitor readings that provide indication of adegradation of fuel clad integrity.An Unusual Event is only warranted when actual fuel clad damage is the cause of theelevated coolant sample activity (as determined by laboratory confirmation). Fuel claddamage should be assumed to be the cause of elevated Reactor Coolant activity unlessanother cause is known.Escalation of the emergency classification level would be via ICs FA1 or theRecognition Category R ICs.Basis Reference(s):1. NEI 99-01 Rev 6, SU32. Technical Specifications 3.4.6, RCS Specific Activity3. DAN 902(3)-3 C-2(D-2) Off Gas Rad Monitor Hi-Hi4. Technical Specifications 3.7.6, Main Condenser Offgas5. DGA 16 Coolant High Activity/Fuel Element FailureMonth 20XXDR 3-51EP-AA-1004 (Revision XX) | |||
AnnexDlresden Annex FvA-Inn Nuci--r~IRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFG1Initiating Condition:Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-52EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFS1Initiating Condition:Loss or Potential Loss of ANY two barriers.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-53EP-AA-1004 (Revision XX) | |||
AnnexD .resden Annex Eineln NIuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFAIInitiating Condition:ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Alert classification level, Fuel Cladding and RCS barriers are weighted moreheavily than the Containment barrier. Unlike the Containment barrier, loss or potentialloss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactivematerials or degradation of core cooling capability. Note that the loss or potential loss ofContainment barrier in combination with loss or potential loss of either Fuel Cladding orRCS barrier results in declaration of a Site Area Emergency under EAL FSI.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-54EP-AA-1004 (Revision XX) nroadian AnnavI:::vg1ln n me.,rlarRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC1Initiating Condition:RCS ActivityOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSCoolant activity > 300 uCi/gm Dose Equivalent 1-131.Basis:This threshold indicates that RCS radioactivity concentration is greater than 300 PiCi/gmdose equivalent 1-131. Reactor coolant activity above this level is greater than thatexpected for iodine spikes and corresponds to an approximate range of 2% to 5% fuelclad damage. Since this condition indicates that a significant amount of fuel claddamage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highlyelevated activity levels could require several hours to complete. Nonetheless, asample-related threshold is included as a backup to other indications.There is no Potential Loss threshold associated with RCS Activity.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. DGA-16, Coolant High Activity / Fuel Element FailureMonth 20XXDR 3-55EP-AA-1004 (Revision XX) | |||
Dresden AnnexI=xelon NuclearDresden Annex Exelnn Nucla~rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC2Initiating Condition:RPV Water LevelOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. Plant conditions indicate Primary Containment flooding is required.POTENTIAL LOSS2. RPV water level cannot be restored and maintained > -143 inches (TAF)OR3. RPV water level cannot be determined.Basis:RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions. Compensated values may be used inaccordance with the Technical Support Guidelines.Loss Threshold #1 BasisThe Loss threshold represents the EOP requirement for primary containment flooding.This is identified in the BWROG EPGs/SAMGs when the phrase, "Primary ContainmentFlooding Is Required," appears. Since a site-specific RPV water level is not specifiedhere, the Loss threshold phrase, "Primary containment flooding required," alsoaccommodates the EOP need to flood the primary containment when RPV water levelcannot be determined and core damage due to inadequate core cooling is believed tobe occurring.Potential Loss Threshold #2 and #3 BasisThis water level corresponds to the top of the active fuel and is used in the EOPs toindicate a challenge to core cooling.The RPV water level threshold is the same as RCS Barrier RC2 Loss threshold. Thus,this threshold indicates a Potential Loss of the Fuel Clad barrier and a Loss of the RCSbarrier that appropriately escalates the emergency classification level to a Site AreaEmergency.This threshold is considered to be exceeded when, as specified in the site-specificEOPs, RPV water level cannot be restored and maintained above the specified levelfollowing depressurization of the RPV (either manually, automatically or by failure of theRCS barrier) or when procedural guidance or a lack of low pressure RPV injectionsources preclude Emergency RPV depressurization.Month 20XXDR 3-56EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC2 (cont)Basis (cont):EOPs allow the operator a wide choice of RPV injection sources to consider whenrestoring RPV water level to within prescribed limits. EOPs also specifydepressurization 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 leveluntil pressure drops below the shutoff heads of available injection sources. Therefore,this Fuel Clad barrier Potential Loss is met only after either: 1) the RPV has beendepressurized, or required emergency RPV depressurization has been attempted,giving the operator an opportunity to assess the capability of low-pressure injectionsources to restore RPV water level or 2) no low pressure RPV injection systems areavailable, precluding RPV depressurization in an attempt to minimize loss of RPVinventory.The term "cannot be restored and maintained above" means the value of RPV waterlevel is not able to be brought above the specified limit (top of active fuel). Thedetermination requires an evaluation of system performance and availability in relationto the RPV water level value and trend. A threshold prescribing declaration when athreshold value cannot be restored and maintained above a specified limit does notrequire immediate action simply because the current value is below the top of activefuel, but does not permit extended operation below the limit; the threshold must beconsidered reached as soon as it is apparent that the top of active fuel cannot beattained.Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator todeliberately lower RPV water level in order to reduce reactor power. Although suchaction is a challenge to core cooling and the Fuel Clad barrier, the immediate need toreduce reactor power is the higher priority. For such events, ICs MA3 or MS3 will dictatethe need for emergency classification.Since the loss of ability to determine if adequate core cooling is being provided presentsa significant challenge to the fuel clad barrier, a potential loss of the fuel clad barrier isspecified.Month 20XXDR 3-57EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC2 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. DEOP 100 RPV Control3. DEOP 400-5 Failure to Scram4. DEOP 400-1 RPV Flooding5. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines6. Technical Support GuidelinesMonth 20XXDR 3-58EP-AA-1 004 (Revision XX) n'ra*crian Annoy=,v'ft1rn Khir-IgmrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC5Initiating Condition:Primary Containment RadiationOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSDrywell radiation monitor reading > 6.70 E+02 R/hr (670 R/hr).Basis:The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that reactor coolant activityequals 300 p.Ci/gm dose equivalent 1-131. Reactor coolant activity above this level isgreater than that expected for iodine spikes and corresponds to an approximate rangeof 2% to 5% fuel clad damage. Since this condition indicates that a significant amountof fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.The radiation monitor reading in this threshold is higher than that specified for RCSBarrier RC5 Loss Threshold since it indicates a loss of both the Fuel Clad Barrier andthe RCS Barrier. Note that a combination of the two monitor readings appropriatelyescalates the emergency classification level to a Site Area Emergency.There is no Fuel Clad Barrier Potential Loss threshold associated with PrimaryContainment Radiation.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. Core Damage Assessment Methodology (CDAM)Month 20XXDR 3-59EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC7Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. Any condition in the opinion of the Emergency Director that indicates Loss of the FuelClad Barrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergency Director that indicates Potential Lossof the Fuel Clad Barrier.Basis:Loss Threshold #1 BasisThis threshold addresses any other factors that are to be used by the EmergencyDirector in determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold #2 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-60EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC2Initiating Condition:RPV Water LevelOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. RPV water level cannot be restored and maintained > -143 inches (TAF)OR2. RPV water level cannot be determined.Basis:RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions. Compensated values may be used inaccordance with the Technical Support Guidelines.This water level corresponds to the Top of Active Fuel (TAF) and is used in the EOPs toindicate challenge to core cooling.The RPV water level threshold is the same as Fuel Clad Barrier FC2 Potential Lossthreshold. Thus, this threshold indicates a Loss of the RCS barrier and Potential Loss ofthe Fuel Clad barrier and that appropriately escalates the emergency classification levelto a Site Area Emergency.This threshold is considered to be exceeded when, as specified in the site-specificEOPs, RPV water level cannot be restored and maintained above the specified levelfollowing depressurization of the RPV (either manually, automatically or by failure of theRCS barrier) or when procedural guidance or a lack of low pressure RPV injectionsources preclude Emergency RPV depressurization EOPs allow the operator a widechoice of RPV injection sources to consider when restoring RPV water level to withinprescribed limits. EOPs also specify depressurization of the RPV in order to facilitateRPV water level control with low-pressure injection sources. In some events, elevatedRPV pressure may prevent restoration of RPV water level until pressure drops belowthe shutoff heads of available injection sources. Therefore, this RCS barrier Loss is metonly after either: 1) the RPV has been depressurized, or required emergency RPVdepressurization has been attempted, giving the operator an opportunity to assess thecapability of low-pressure injection sources to restore RPV water level or 2) no lowpressure RPV injection systems are available, precluding RPV depressurization in anattempt to minimize loss of RPV inventory.Month 20XXDR 3-61EP-AA-1 004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC2 (cont)Basis (cont):The term, "cannot be restored and maintained above," means the value of RPV waterlevel is not able to be brought above the specified limit (top of active fuel). Thedetermination requires an evaluation of system performance and availability in relationto the RPV water level value and trend. A threshold prescribing declaration when athreshold value cannot be restored and maintained above a specified limit does notrequire immediate action simply because the current value is below the top of activefuel, but does not permit extended operation beyond the limit; the threshold must beconsidered reached as soon as it is apparent that the top of active fuel cannot beattained.Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator todeliberately lower RPV water level in order to reduce reactor power. Although suchaction is a challenge to core cooling and the Fuel Clad barrier, the immediate need toreduce reactor power is the higher priority. For such events, ICs MA3 or MS3 will dictatethe need for emergency classification.There is no RCS Potential Loss threshold associated with RPV Water Level.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. DEOP100 RPV Control3. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines4. Technical Support GuidelinesMonth 20XXDR 3-62EP-AA-1004 (Revision XX) | |||
Dry.dAn AnnexDlresden Annexr ExceInn NuclerIArRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC3Initiating Condition:Primary Containment PressureOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. Drywell pressure >2.0 psig.AND2. Drywell pressure rise is due to RCS leakage.Basis:The > 2.0 psig primary containment pressure is the Drywell high pressure setpointwhich indicates a LOCA by automatically initiating ECCS.The second threshold condition focuses the fission product barrier loss threshold on afailure of the RCS instead of the non-LOCA malfunctions that may adversely affectprimary containment pressure. Pressures of this magnitude can be caused by non-LOCA events such as a loss of Drywell cooling or inability to control primarycontainment vent/purge.The release of mass from the RCS due to the as-designed/expected operation of anyrelief valve does not warrant an emergency classification.A stuck-open Electromatic relief valve (ERV)/Target Rock SRV or ERV/ Target RockSRV leakage is not considered either identified or unidentified leakage by TechnicalSpecifications and, therefore, is not applicable to this EAL.There is no Potential Loss threshold associated with Primary Containment Pressure.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. Technical Specifications Table 3.3.5.1-13. DAN 902(3)-5 D-114. DEOP 100 RPV Control5. DEOP 200-1 Primary Containment ControlMonth 20XXDR 3-63EP-AA-1 004 (Revision XX) | |||
Dresden AnneaxI=xelnn NuclearD.......Ann.x mExelnn Nuici.earRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC4Initiating Condition:RCS Leak RateOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. UNISOLABLE Main Steam Line (MSL), Isolation Condenser, HPCI, Feedwater, orRWCU line break.OR2. Emergency RPV Depressurization is required.POTENTIAL LOSS3. UNISOLABLE primary system leakage that results in EITHER of the following:a. Secondary Containment area temperature > DEOP 300-1 Maximum Normaloperating levels.ORb. Secondary Containment area radiation level > DEOP 300-1 Maximum Normaloperating level.Basis:UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.Classification of a system break over system leakage is based on information availableto the Control Room from the event. Indications that should be considered are:* Reports describing magnitude of steam or water release.* Use of system high flow alarms / indications, if available," Significant changes in makeup requirements,* Abnormal reactor water level changes in response to the event.The use of the above indications provides the Control Room the bases to determine thatthe on going event is more significant than the indications that would be expected fromsystem leakage and therefore should be considered a system break.Month 20XXDR 3-64EP-AA-1004 (Revision XX) | |||
Dresden AnnexI=xelon N Dresden Annex Exelnn Nucler~IRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC4 (cont)Basis (cont):Loss Threshold #1 BasisLarge high-energy lines that rupture outside primary containment can dischargesignificant amounts of inventory and jeopardize the pressure-retaining capability of theRCS until they are isolated. If it is determined that the ruptured line cannot be promptlyisolated, the RCS barrier Loss threshold is met.Loss Threshold #2 BasisEmergency RPV Depressurization in accordance with the EOPs is indicative of a loss ofthe RCS barrier. If Emergency RPV Depressurization is performed, the plant operatorsare directed to open safety relief valves (SRVs) and keep them open. Even though theRCS is being vented into the Torus, a Loss of the RCS barrier exists due to thediminished effectiveness of the RCS to retain fission products within its boundary.Potential Loss Threshold #3 BasisPotential loss of RCS based on primary system leakage outside the primarycontainment is determined from EOP temperature or radiation Max Normal Operatingvalues in areas such as main steam line tunnel, HPCI, etc., which indicate a direct pathfrom the RCS to areas outside primary containment.A Max Normal Operating value is the highest value of the identified parameter expectedto occur during normal plant operating conditions with all directly associated supportand control systems functioning properly.The indicators reaching the threshold barriers and confirmed to be caused by RCSleakage from a primary system warrant an Alert classification. A primary system isdefined to be the pipes, valves, and other equipment which connect directly to the RPVsuch that a reduction in RPV pressure will effect a decrease in the steam or water beingdischarged through an unisolated break in the system.In general, multiple indications should be used to determine if a primary system isdischarging outside Primary Containment. For example, a high area radiation conditiondoes not necessarily indicate that a primary system is discharging into the ReactorBuilding since this may be caused by radiation shine from nearby steam lines or themovement of radioactive materials. Conversely, a high area radiation condition inconjunction with other indications (e.g. room flooding, high area temperatures, reports ofsteam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpectedMain Turbine Control Valve closure) may indicate that a primary system is discharginginto the Reactor Building.An UNISOLABLE leak which is indicated by Max Normal Operating values escalates toa Site Area Emergency when combined with Containment Barrier CT6 Loss Threshold#1 (after a containment isolation) and a General Emergency when the Fuel Clad Barriercriteria is also exceeded.Month 20XXDR 3-65EP-AA-1004 (Revision XX) | |||
Dresden AnnexFxplnn NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC4 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. M-12, M-345, Main steam piping3. Technical Specifications 3.4.4 RCS Operational LEAKAGE4. Technical Specifications Section 3.4.5, RCS Leakage Detection Instrumentation5. DAN 902(3)-4 A-17 DRYWELL EQUIP SUMP LVL HI-HI6. DAN 902(3)-4 H-18 DRYWELL FLOOR DRN SUMP LVL HI-HI7. DOA 0040-01 SLOW LEAK8. DOP 2000-24 DRYWELL SUMP OPERATION9. DEOP 300-1, Secondary Containment Control10. UFSAR Section 5.2.5Month 20XXDR 3-66EP-AA-1 004 (Revision XX) | |||
Annp.xNuclearDlresden Annex~ FYAlnn Nucler~IRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC5Initiating Condition:Primary Containment radiationOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. Drywell radiation monitor reading > 100 R/hr (>1.00 E+02 R/hr).Basis:The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that reactor coolant activityequals Technical Specification allowable limits. This value is lower than that specifiedfor Fuel Clad Barrier FC5 Loss Threshold since it indicates a loss of the RCS Barrieronly.There is no RCS Potential Loss threshold associated with Primary ContainmentRadiation.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. EP-EAL-061 1, Criteria for Choosing Containment Radiation Monitor ReadingIndicative of loss of the RCS Barrier.Month 20XXDR 3-67EP-AA-1 004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC7Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. Any condition in the opinion of the EmergencyBarrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergencyof the RCS Barrier.Basis:Loss Threshold #1 BasisDirector that indicates Loss of the RCSDirector that indicates Potential LossThis threshold addresses any other factors that are to be used by the EmergencyDirector in determining whether the RCS Barrier is lost.Potential Loss Threshold #2 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the RCS Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-68EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT2Initiating Condition:RPV Water LevelOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:POTENTIAL LOSSPlant conditions indicate Primary Containment flooding is required.Basis:The Potential Loss threshold is identical to the Fuel Clad Barrier RC2 Loss thresholdRPV Water Level. The Potential Loss requirement for Primary Containment Floodingindicates adequate core cooling cannot be restored and maintained and that coredamage is possible. BWR EPGs/SAMGs specify the conditions that require primarycontainment flooding. When primary containment flooding is required, the EPGs areexited and SAMGs are entered. Entry into SAMGs is a logical escalation in response tothe inability to restore and maintain adequate core cooling.PRA studies indicate that the condition of this Potential Loss threshold could be a coremelt sequence which, if not corrected, could lead to RPV failure and increased potentialfor primary containment failure. In conjunction with the RPV water level Loss thresholdsin the Fuel Clad and RCS barrier columns, this threshold results in the declaration of aGeneral Emergency.There is no Loss Threshold associated with this IC.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. Severe Accident Management Guidelines3. DEOP 0100, RPV Control4. DEOP 0400-01, RPV Flooding5. DEOP 0400-05, Failure to ScramMonth 20XXDR 3-69EP-AA-1004 (Revision XX) | |||
Dresden AnnexExallon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT3Initiating Condition:Primary Containment ConditionsOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. UNPLANNED rapid drop in Drywell pressure following Drywell pressure rise.OR2. Drywell pressure response not consistent with LOCA conditions.POTENTIAL LOSS3. Drywell pressure > 62 psig and rising.OR4. a. Drywell or torus hydrogen concentration > 6%.ANDb. Drywell or torus oxygen concentration > 5%.OR5. Heat Capacity Limit (DEOP 200-1, Fig.M) exceeded.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.Loss Threshold #1 and #2 BasisRapid UNPLANNED loss of primary containment pressure (i.e., not attributable toDrywell spray or condensation effects) following an initial pressure rise indicates a lossof primary containment integrity. Primary containment pressure should rise as a result ofmass and energy release into the primary containment from a LOCA. Thus, primarycontainment pressure not increasing under these conditions indicates a loss of primarycontainment integrity.These thresholds rely on operator recognition of an unexpected response for thecondition and therefore a specific value is not assigned. The unexpected(UNPLANNED) response is important because it is the indicator for a containmentbypass condition. A pressure suppression bypass path would not be an indication of acontainment breach.Month 20XXDR 3:70EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT3 (cont)Basis (cont):Potential Loss Threshold #3 BasisThe threshold pressure is the primary containment internal design pressure. Structuralacceptance testing demonstrates the capability of the primary containment to resistpressures greater than the internal design pressure. A pressure of this magnitude isgreater than those expected to result from any design basis accident and, thus,represent a Potential Loss of the Containment barrier.Potential Loss Threshold #4 BasisIf hydrogen concentration reaches or exceeds the lower flammability limit, as defined inplant EOPs, in an oxygen rich environment, a potentially explosive mixture exists. If thecombustible mixture ignites inside the primary containment, loss of the Containmentbarrier could occur.Potential Loss Threshold #5 BasisThe HCTL is a function of RPV pressure, Torus temperature and Torus water level. It isutilized to preclude failure of the containment and equipment in the containmentnecessary for the safe shutdown of the plant and therefore, the inability to maintainplant parameters below the limit constitutes a potential loss of containment.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. UFSAR 6.2.1.3.2.13. UFSAR Table 6.2-34. UFSAR 15.6.55. UFSAR 6.2.1.16. DEOP 200-1 Primary Containment Control7. DEOP 200-2 Hydrogen ControlMonth 20XXDR 3-71EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclaarRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT5Initiating Condition:Primary Containment RadiationOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:POTENTIAL LOSS1. Drywell radiation monitor reading > 1.60 E+03 R/hr (1600 R/hr).Basis:There is no Loss threshold associated with Primary Containment Radiation.The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that 20% of the fuel cladding hasfailed. This level of fuel clad failure is well above that used to determine the analogousFuel Clad Barrier Loss and RCS Barrier Loss thresholds.NUREG-1 228, Source Estimations During Incident Response to Severe Nuclear PowerPlant Accidents, indicates the fuel clad failure must be greater than approximately 20%in order for there to be a major release of radioactivity requiring offsite protectiveactions. For this condition to exist there must already have been a loss of the RCSBarrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as apotential loss of containment which would then escalate the emergency classificationlevel to a General Emergency.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. Core Damage Assessment Methodology (CDAM)Month 20XXDR 3-72EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT6Initiating Condition:Primary Containment Isolation FailureOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. UNISOLABLE direct downstream pathway to the environment exists after primarycontainment isolation signal.OR2. Intentional Primary Containment venting/purging per EOPs or SAMGs due toaccident conditions.OR3. UNISOLABLE primary system leakage that results in EITHER of the following:a. Secondary Containment area temperature > DEOP 300-1, Maximum Safeoperating levels.ORb. Secondary Containment area radiation level > DEOP 300-1, Maximum Safeoperating levels.Basis:UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.These thresholds address incomplete containment isolation that allows anUNISOLABLE direct release to the environment.Loss Threshold #1 BasisThe use of the modifier "direct" in defining the release path discriminates againstrelease paths through interfacing liquid systems or minor release pathways, such asinstrument lines, not protected by the Primary Containment Isolation System (PCIS).Leakage into a closed system is to be considered only if the closed system is breachedand thereby creates a significant pathway to the environment. Examples includeunisolable Main Steamline, HPCI steamline breaks, unisolable RWCU system breaks,and unisolable containment atmosphere vent paths.Examples of "downstream pathway to the environment" could be through theTurbine/Condenser, or direct release to the Turbine or Reactor Building.Month 20XXDR 3-73EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT6 (cont)Basis (cont):The existence of a filter is not considered in the threshold assessment. Filters do notremove fission product noble gases. In addition, a filter could become ineffective due toiodine and/or particulate loading beyond design limits (i.e., retention ability has beenexceeded) or water saturation from steam/high humidity in the release stream.Following the leakage of RCS mass into primary containment and a rise in primarycontainment pressure, there may be minor radiological releases associated withallowable primary containment leakage through various penetrations or systemcomponents. Minor releases may also occur if a primary containment isolation valve(s)fails to close but the primary containment atmosphere escapes to an enclosed system.These releases do not constitute a loss or potential loss of primary containment butshould be evaluated using the Recognition Category R ICs.Loss Threshold #2 BasisEOPs may direct primary containment isolation valve logic(s) to be intentionallybypassed, even if offsite radioactivity release rate limits will be exceeded. Under theseconditions with a valid primary containment isolation signal, the containment should alsobe considered lost if primary containment venting is actually performed.Intentional venting of primary containment for primary containment pressure orcombustible gas control to the secondary containment and/or the environment is a Lossof the Containment. Venting for primary containment pressure control when not in anaccident situation (e.g., to control pressure below the Drywell high pressure scramsetpoint) does not meet the threshold condition.Loss Threshold #3 BasisThe Max Safe Operating Temperature and the Max Safe Operating Radiation Level areeach the highest value of these parameters at which neither: (1) equipment necessaryfor the safe shutdown of the plant will fail, nor (2) personnel access necessary for thesafe shutdown of the plant will be precluded. EOPs utilize these temperatures andradiation levels to establish conditions under which RPV depressurization is required.The temperatures and radiation levels should be confirmed to be caused by RCSleakage from a primary system. A primary system is defined to be the pipes, valves, andother equipment which connect directly to the RPV such that a reduction in RPVpressure will effect a decrease in the steam or water being discharged through anunisolated break in the system.Month 20XXDR 3-74EP-AA-1004 (Revision XX) | |||
I=xelnn flreQrIn Annex FvAlnn NmuclIanrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT6 (cont)Basis (cont):In general, multiple indications should be used to determine if a primary system isdischarging outside Primary Containment. For example, a high area radiation conditiondoes not necessarily indicate that a primary system is discharging into the ReactorBuilding since this may be caused by radiation shine from nearby steam lines or themovement of radioactive materials. Conversely, a high area radiation condition inconjunction with other indications (e.g. room flooding, high area temperatures, reports ofsteam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpectedMain Turbine Control Valve closure) may indicate that a primary system is discharginginto the Reactor Building.In combination with RCS Barrier RC4 Potential Loss Threshold #3 this threshold wouldresult in a Site Area Emergency.There is no Potential Loss threshold associated with Primary Containment IsolationFailure.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. DEOP 200-1 Primary Containment Control3. DEOP 200-2 Hydrogen Control4. DEOP 500-4 Containment Venting5. DEOP 300-1 Secondary Containment ControlMonth 20XXDR 3-75EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT7Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. Any condition in the opinion of the EmergencyContainment Barrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergencyof the Containment Barrier.Basis:Loss Threshold #1 Basis:Director that indicates Loss of theDirector that indicates Potential LossThis threshold addresses any other factors that are to be used by the EmergencyDirector in determining whether the Containment Barrier is lost.Potential Loss Threshold #2 Basis:This threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is potentially lost. The EmergencyDirector should also consider whether or not to declare the barrier potentially lost in theevent that barrier status cannot be monitored.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-76EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG1Initiating Condition:Prolonged loss of all Off-site and all On-Site AC power to emergency buses.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1 Loss of ALL offsite AC power to unit ECCS buses.AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators tosupply power to unit ECCS buses.AND3. EITHER of the following:a. Restoration of at least one unit ECCS bus in < 4 hours is not likely.ORb. RPV water level cannot be restored and maintained > -164 inches.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a prolonged loss of all power sources to AC emergency buses. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiringelectric power including those necessary for emergency core cooling, containment heatremoval/pressure control, spent fuel heat removal and the ultimate heat sink. Aprolonged loss of these buses will lead to a loss of any fission product barriers. Inaddition, fission product barrier monitoring capabilities may be degraded under theseconditions.RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.The EAL should require declaration of a General Emergency prior to meeting thethresholds for IC FG1. This will allow additional time for implementation of offsiteprotective actions.Month 20XXDR 3-77EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG1 (cont)Basis (cont):Escalation of the emergency classification from Site Area Emergency will occur if it isprojected that power cannot be restored to at least one AC emergency bus by the endof the analyzed station blackout coping period. Beyond this time, plant responses andevent trajectory are subject to greater uncertainty, and there is an increased likelihoodof challenges to multiple fission product barriers.The estimate for restoring at least one emergency bus should be based on a realisticappraisal of the situation. Mitigation actions with a low probability of success should notbe used as a basis for delaying a classification upgrade. The goal is to maximize thetime available to prepare for, and implement, protective actions for the public.The EAL will also require a General Emergency declaration if the loss of AC powerresults in parameters that indicate an inability to adequately remove decay heat fromthe core.Basis Reference(s):1. NEI 99-01 Rev 6, SG12. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure5. DOA 6500-01 4-KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout GeneratorTies to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4-KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC Power10. DEOP100 RPV Control11. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Proceduresand Severe Accident Management GuidelinesMonth 20XXDR 3-78EP-AA-1004 (Revision XX) | |||
Dresden AnnawExelon NuclearDresde AnnexExelon NuclIearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS1Initiating Condition:Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:e The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC Power to unit ECCS buses.AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators tosupply power to unit ECCS buses.AND3. Failure to restore power to at least one ECCS bus in < 15 minutes from the time ofloss of both offsite and onsite AC power.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergencycore cooling, containment heat removal/pressure control, spent fuel heat removal andthe ultimate heat sink. In addition, fission product barrier monitoring capabilities may bedegraded under these conditions. This IC represents a condition that involves actual orlikely major failures of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RG1, FG1, MG1, orMG2.Month 20XXDR 3-79EP-AA-1004 (Revision XX) | |||
Dresden AnnexN rDresden Annex Exellon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS1 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, SS12. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout GeneratorTies to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-80EP-AA-1 004 (Revision XX) | |||
Dresden AnnexDlresden Annex Fvalnn Nucler~IRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA1Initiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. AC power capability to unit ECCS buses reduced to only one of the following powersources for > 15 minutes.* Reserve auxiliary Transformer TR-22 (TR-32)* Unit auxiliary transformer TR-21 (TR-31)* Unit Emergency Diesel Generator DG 2(3)* Shared Emergency Diesel Generator DG 2/3* Station Blackout Diesel Generator DG 2(3)* Unit crosstie breakersAND2. ANY additional single power source failure will result in a loss of ALL AC power toSAFETY SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS. In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment. This IC provides an escalation path from ICMUl.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below.* A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).Month 20XXDR 3-81EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA1 (cont)Basis (cont):" A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being fed from the unitmain generator." A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.Escalation of the emergency classification level would be via IC MS1.Basis Reference(s):1. NEI 99-01 Rev 6, SA12. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 KV System and 345 KV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout GeneratorTies to Plant Auxiliary Electric System7. UFSAR 9.5.9 Station Blackout System8. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-82EP-AA-1004 (Revision XX) rlr,-erl--n AnnovKlmmlnnrlrflra~rI~n A nnav I t~v~ LI. I l~ rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU1Initiating Condition:Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Loss of ALL offsite AC power capability to unit ECCS buses for > 15 minutes.Basis:This IC addresses a prolonged loss of offsite power. The loss of offsite power sourcesrenders the plant more vulnerable to a complete loss of power to AC emergency buses.This condition represents a potential reduction in the level of safety of the plant.For emergency classification purposes, "capability" means that an offsite AC powersource(s) is available to the emergency buses, whether or not the buses are poweredfrom it. (e.g. unit cross-tie breakers)Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof offsite power.Escalation of the emergency classification level would be via IC MAI.Basis Reference(s):1. NEI 99-01 Rev 6, SU12. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 kV System and 345 kV Alternate Supply Failure5. DOA 6500-01 4kV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout GeneratorTies to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4kV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-83EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG2Initiating Condition:Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to unit ECCS buses.AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generatorsto supply power to vital buses.AND3. Voltage is < 105 VDC on 125 VDC battery buses #2 and #3.AND4. ALL AC and Vital DC power sources have been lost for > 15 minutes.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiringelectric power including those necessary for emergency core cooling, containment heatremoval/pressure control, spent fuel heat removal and the ultimate heat sink. A loss ofVital DC power compromises the ability to monitor and control SAFETY SYSTEMS. Asustained loss of both AC and DC power will lead to multiple challenges to fissionproduct barriers.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses. The 15-minute emergency declaration clock begins at the point when all EALconditions are met.Month 20XXDR 3-84EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG2 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, SG82. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout GeneratorTies to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC Power10. UFSAR 8.3.211. DOA 6900-02(3) Failure of Unit 2(3) 125 VDC Power Supply12. Technical Specification B.3.8.4, DC Power Sources -OperatingMonth 20XXDR 3-85EP-AA-1004 (Revision XX) | |||
AnnoyDresden Annex Pvalnn Kiiii-borRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS2Initiating Condition:Loss of all vital DC power for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Voltage is < 105 VDC on 125 VDC battery buses #2 and #3 for > 15 minutes.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a loss of Vital DC power which compromises the ability to monitorand control SAFETY SYSTEMS. In modes above Cold Shutdown, this conditioninvolves a major failure of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RG1, FG1 or MG2.Basis Reference(s):1. NEI 99-01 Rev 6, SS82. UFSAR 8.3.23. DOA 6900-02(3) Failure of Unit 2(3) 125 VDC Power Supply4. Technical Specification B.3.8.4, DC Power Sources -OperatingMonth 20XXDR 3-86EP-AA-1004 (Revision XX) | |||
AnnoyDlresden Annex Fvplnn N"H~IanrRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS3Initiating Condition:Inability to shutdown the reactor causing a challenge to core cooling or RCS heatremoval.Operating Mode Applicability:1,2Emergency Action Level (EAL):1. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 6%.AND2, ALL manual / ARI actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 6%.AND3. EITHER of the following conditions exist:* RPV water level cannot be restored and maintained > -164 inchesOR* Heat Capacity Limit (DEOP 200-1, Fig. M) exceeded.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, all subsequent operator manualactions, both inside and outside the Control Room including driving in control rods andboron injection, are unsuccessful, and continued power generation is challenging thecapability to adequately remove heat from the core and/or the RCS. This condition willlead to fuel damage if additional mitigation actions are unsuccessful and thus warrantsthe declaration of a Site Area Emergency.In some instances, the emergency classification resulting from this IC/EAL may behigher than that resulting from an assessment of the plant responses and symptomsagainst the Recognition Category F ICs/EALs. This is appropriate in that theRecognition Category F ICs/EALs do not address the additional threat posed by afailure to shutdown the reactor. The inclusion of this IC and EAL ensures the timelydeclaration of a Site Area Emergency in response to prolonged failure to shutdown thereactor.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.Escalation of the emergency classification level would be via IC RG1 or FG1.Month 20XXDR 3-87EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS3 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, SS52. DEOP 100 RPV Control3. DEOP 400-5 Failure to Scram4. DEOP 200-1 Primary Containment Control5. Technical Support GuidelinesMonth 20XXDR 3-88EP-AA-1004 (Revision XX) | |||
Dresden AnnexDresden Annex Exelnn Nule a~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA3Initiating Condition:Automatic or manual scram fails to shutdown the reactor, and subsequent manualactions taken at the reactor control consoles are not successful in shutting down thereactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note:* A manual action is any operator action, or set of actions, which causes the controlrods to be rapidly inserted into the core, and does not include manually driving incontrol rods or implementation of boron injection strategies.1. Automatic or manual scram did not shutdown the reactor as indicated by ReactorPower > 6%.AND2. Manual / ARI actions taken at the reactor control consoles are not successful inshutting down the reactor as indicated by Reactor Power > 6%.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and subsequent operator manualactions taken at the reactor control consoles to shutdown the reactor are alsounsuccessful. This condition represents an actual or potential substantial degradationof the level of safety of the plant. An emergency declaration is required even if thereactor is subsequently shutdown by an action taken away from the reactor controlconsoles since this event entails a significant failure of the RPS.A manual action at the reactor control consoles is any operator action, or set of actions,which causes the control rods to be rapidly inserted into the core (e.g., initiating amanual reactor scram. This action does not include manually driving in control rods orimplementation of boron injection strategies. If this action(s) is unsuccessful, operatorswould immediately pursue additional manual actions at locations away from the reactorcontrol consoles (e.g., locally opening breakers). Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the reactor consoles".Taking the Reactor Mode Switch to Shutdown is considered to be a manual scramaction.Month 20XXDR 3-89EP-AA-1 004 (Revision XX) | |||
Dresden AnnexExelon NuclearDresden Annex Exellon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA3 (cont)Basis (cont):The plant response to the failure of an automatic or manual reactor scram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If the failure to shutdown the reactor is prolongedenough to cause a challenge to the RPV water level or RCS heat removal safetyfunctions, the emergency classification level will escalate to a Site Area Emergency viaIC MS3. Depending upon plant responses and symptoms, escalation is also possiblevia IC FS1. Absent the plant conditions needed to meet either IC MS3 or FS1, an Alertdeclaration is appropriate for this event.It is recognized that plant responses or symptoms may also require an Alert declarationin accordance with the Recognition Category F ICs; however, this IC and EAL areincluded to ensure a timely emergency declaration.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Basis Reference(s):1. NEI 99-01 Rev 6, SA52. DEOP 100 RPV Control3. DEOP 400-5 Failure to Scram4. DEOP 200-1 Primary Containment ControlMonth 20XXDR 3-90EP-AA-1004 (Revision XX) nrgmrtn AnngnyC-re%10%n K111AAMnrflr~av4~m, A mi ii~v I ~i Ma us r a ~ | |||
* s-s. ...~a ~ -I I I~ -~ IRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU3Initiating Condition:Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note:* A manual action is any operator action, or set of actions, which causes the controlrods to be rapidly inserted into the core, and does not include manually driving incontrol rods or implementation of boron injection strategies.1. a. Automatic scram did not shutdown the reactor as indicated by Reactor Power> 6%.ANDb. Subsequent manual / ARI action taken at the reactor control consoles issuccessful in shutting down the reactor.OR2. a. Manual scram did not shutdown the reactor as indicated by Reactor Power> 6%.ANDb. EITHER of the following:1. Subsequent manual / ARI action taken at the reactor control consoles issuccessful in shutting down the reactor.OR2. Subsequent automatic scram / ARI is successful in shutting down thereactor.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and either a subsequent operatormanual action taken at the reactor control consoles or an automatic scram is successfulin shutting down the reactor. This event is a precursor to a more significant conditionand thus represents a potential degradation of the level of safety of the plant.Month 20XXDR 3-91EP-AA-1004 (Revision XX) | |||
Dresden AnnexI::Yplnn Dresden Annex FYAlnn Nut-h-a~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU3 (cont)Basis (cont):EAL #1 BasisFollowing the failure on an automatic reactor scram, operators will promptly initiatemanual actions at the reactor control consoles to shutdown the reactor (e.g., initiate amanual reactor scram). If these manual actions are successful in shutting down thereactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.EAL #2 BasisIf an initial manual reactor trip is unsuccessful, operators will promptly take manualaction at another location(s) on the reactor control consoles to shutdown the reactor(e.g., initiate a manual reactor scram / ARI using a different switch). Depending uponseveral factors, the initial or subsequent effort to manually scram the reactor, or aconcurrent plant condition, may lead to the generation of an automatic reactor scramsignal. If a subsequent manual or automatic scram / ARI is successful in shutting downthe reactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.A manual action at the reactor control consoles is any operator action, or set of actions,which causes the control rods to be rapidly inserted into the core (e.g., initiating amanual reactor scram). This action does not include manually driving in control rods orimplementation of boron injection strategies. Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the reactor consoles".Taking the Reactor Mode Switch to Shutdown is considered to be a manual scramaction.The plant response to the failure of an automatic or manual reactor scram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If subsequent operator manual actions taken at thereactor control consoles are also unsuccessful in shutting down the reactor, then theemergency classification level will escalate to an Alert via IC MA3. Depending upon theplant response, escalation is also possible via IC FAI. Absent the plant conditionsneeded to meet either IC MA3 or FAI, an Unusual Event declaration is appropriate forthis event.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Month 20XXDR 3-92EP-AA-1004 (Revision XX) | |||
Dresden AnnexN Dresden Annex Fvalnn NucleIazrRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU3 (cont)Basis (cont):Should a reactor scram signal be generated as a result of plant work (e.g., RPS setpointtesting), the following classification guidance should be applied." If the signal generated as a result of plant work causes a plant transient that createsa real condition that should have included an automatic reactor scram and the RPSfails to automatically shutdown the reactor, then this IC and the EALs are applicable,and should be evaluated." If the signal generated as a result of plant work does not cause a plant transient butshould have generated an RPS scram signal and the scram failure is determinedthrough other means (e.g., assessment of test results), then this IC and the EALsare not applicable and no classification is warranted.Basis Reference(s):1. NEI 99-01 Rev 6, SU52. Technical Specifications Table 3.3.1.1-13. DEOP 100 RPV Control4. DEOP 400-5 Failure to ScramMonth 20XXDR 3-93EP-AA-1004 (Revision XX) rnnri=rl-" A snn--rfl rnal~vi A~ui~vFvainn NucleIa2rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA4Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED event results in the inability to monitor ANY Table M1 parameter fromwithin the Control Room for > 15 minutes.Table M1 Control Room Parameters* Reactor Power" RPV Water Level" RPV Pressure* Primary Containment Pressure* Torus Level* Torus TemperatureAND2. ANY Table M2 transient in progress.Table M2 Significant Transients* Turbine Trip" Reactor Scram* ECCS Activation" Recirc. Runback > 25% Reactor Power Change* Thermal Power oscillations > 10% Reactor Power ChangeMonth 20XXDR 3-94EP-AA-1004 (Revision XX) | |||
Exelon NuclearDresden Annex Exelon NuclIearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA4 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses the difficulty associated with monitoring rapidly changing plantconditions during a transient without the ability to obtain SAFETY SYSTEM parametersfrom within the Control Room. During this condition, the margin to a potential fissionproduct barrier challenge is reduced. It thus represents a potential substantialdegradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for any of the listedparameters cannot be determined from within the Control Room. This situation wouldrequire a loss of all of the Control Room sources for the given parameter(s). Forexample, the reactor power level cannot be determined from any analog, computerpoint, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)to determine if an NRC event report is required. The event would be reported if itsignificantly impaired the capability to perform emergency assessments. In particular,emergency assessments necessary to implement abnormal operating procedures,emergency operating procedures, and emergency plan implementing proceduresaddressing emergency classification, accident assessment, or protective actiondecision-making.This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity control, RPV water level and RCS heat removal. The lossof the ability to determine any of these parameters from within the Control Room isconsidered to be more significant than simply a reportable condition. In addition, if allindication sources for any of the listed parameters are lost, then the ability to determinethe values of other SAFETY SYSTEM parameters may be impacted as well. Forexample, if the value for RPV water level cannot be determined from the indications andrecorders on a main control board, the SPDS or the plant computer, the availability ofother parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation of the emergency classification level would be via ICs FS1 or IC RS1.Basis Reference(s):1. NEI 99-01 Rev 6, SA2Month 20XXDR 3-95EP-AA-1004 (Revision XX) | |||
AnnAyDlreden Annex Fwalnn Nur~clarRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU4Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.UNPLANNED event results in the inability to monitor ANY Table M1 parameter fromwithin the Control Room for > 15 minutes.Table M1 Control Room Parameters* Reactor Power" RPV Water Level* RPV Pressure" Primary Containment Pressure* Torus Level* Torus TemperatureBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses the difficulty associated with monitoring normal plant conditionswithout the ability to obtain SAFETY SYSTEM parameters from within the ControlRoom. This condition is a precursor to a more significant event and represents apotential degradation in the level of safety of the plant.Month 20XXDR 3-96EP-AA-1 004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU4 (cont)Basis (cont):As used in this EAL, an "inability to monitor" means that values for any of the listedparameters cannot be determined from within the Control Room. This situation wouldrequire a loss of all of the Control Room sources for the given parameter(s). Forexample, the reactor power level cannot be determined from any analog, digital andrecorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)to determine if an NRC event report is required. The event would be reported if itsignificantly impaired the capability to perform emergency assessments. In particular,emergency assessments necessary to implement abnormal operating procedures,emergency operating procedures, and emergency plan implementing proceduresaddressing emergency classification, accident assessment, or protective actiondecision-making.This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity control, core cooling and RCS heat removal. The loss ofthe ability to determine any of these parameters from within the Control Room isconsidered to be more significant than simply a reportable condition. In addition, if allindication sources for any of the listed parameters are lost, then the ability to determinethe values of other SAFETY SYSTEM parameters may be impacted as well. Forexample, if the value for reactor vessel level cannot be determined from the indicationsand recorders on a main control board, the SPDS or the plant computer, the availabilityof other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation of the emergency classification level would be via IC MA4.Basis Reference(s):1. NEI 99-01 Rev 6, SU2Month 20XXDR 3-97EP-AA-1004 (Revision XX) | |||
AnnexFxelon NuclearDpresden Annex Exe..n.Nu.l.a.RECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA5Initiating Condition:Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):1. The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)" Internal or external flooding event* High winds or tornado strike* FIRE" EXPLOSION" Other events with similar hazard characteristics as determined by theShift ManagerAND2. EITHER of the following:a. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM required by TechnicalSpecification for the current operating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure required by Technical Specification for thecurrent operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization. A release of steam (from highenergy lines or components) or an electrical component failure (caused by short circuits,grounding, arcing, etc.) should not automatically be considered an explosion. Suchevents may require a post-event inspection to determine if the attributes of an explosionare present.Month 20XXDR 3-98EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA5 (cont)Basis (cont):SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.VISIBLE DAMAGE: Damage to a component or structure that is readily observablewithout measurements, testing, or analysis. The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components, required for the current operatingmode, "required", i.e. required to be operable by Technical Specifications for the currentoperating mode. This condition significantly reduces the margin to a loss or potentialloss of a fission product barrier, and therefore represents an actual or potentialsubstantial degradation of the level of safety of the plant. Manual or automatic electricalisolation of safety equipment due to flooding, in and of itself, does not constitutedegraded performance and is classified under HU6.EAL #2.a BasisThis EAL addresses damage to a SAFETY SYSTEM train that is required to beoperable by Technical Specifications for the current operating mode, and is in operationsince indications for it will be readily available. The indications of degradedperformance should be significant enough to cause concern regarding the operability orreliability of the SAFETY SYSTEM train.EAL #2.b BasisThis EAL addresses damage to a SAFETY SYSTEM component that is required to beoperable by Technical Specifications for the current operating mode, and is not inoperation or readily apparent through indications alone, as well as damage to astructure containing SAFETY SYSTEM components. Operators will make thisdetermination based on the totality of available event and damage report information.This is intended to be a brief assessment not requiring lengthy analysis or quantificationof the damage.Escalation of the emergency classification level would be via IC FS1 or RS1.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):1. NEI 99-01, Rev 6 SA9Month 20XXDR 3-99EP-AA-1004 (Revision XX) | |||
Dresden Annexl:xelnn N rDresden Annex Fxelnn NucleIarRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU6Initiating Condition:RCS leakage for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage in the Drywell > 10 gpm for> 15 minutes.OR2. RCS identified leakage in the Drywell >25 gpm for > 15 minutes.OR3. Leakage from the RCS to a location outside the Drywell >25 gpm for > 15 minutes.Basis:UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.This IC addresses RCS leakage which may be a precursor to a more significant event.In this case, RCS leakage has been detected and operators, following applicableprocedures, have been unable to promptly isolate the leak. This condition is consideredto be a potential degradation of the level of safety of the plant.EAL #1 and EAL #2 BasisThese EALs are focused on a loss of mass from the RCS due to "unidentified leakage","pressure boundary leakage" or "identified leakage" (as these leakage types are definedin the plant Technical Specifications).EAL #3 BasisThis EAL addresses an RCS mass loss caused by an UNISOLABLE leak through aninterfacing system.These EALs thus apply to leakage into the containment, a secondary-side system or alocation outside of containment.Month 20XXDR 3-100EP-AA-1004 (Revision XX) | |||
Dresden AnnexNuclearDresden Annex FxeInn NuclerIsrRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU6 (cont)Basis (cont):The leak rate values for each EAL were selected because they are usually observablewith normal Control Room indications. Lesser values typically require time-consumingcalculations to determine (e.g., a mass balance calculation). EAL #1 uses a lower valuethat reflects the greater significance of unidentified or pressure boundary leakage.The release of mass from the RCS due to the as-designed/expected operation of anyrelief valve does not warrant an emergency classification.A stuck-open Electromatic relief valve (ERV)/Target Rock SRV or ERV/ Target RockSRV leakage is not considered either identified or unidentified leakage by TechnicalSpecifications and, therefore, is not applicable to this EAL.The 15-minute threshold duration allows sufficient time for prompt operator actions toisolate the leakage, if possible.Escalation of the emergency classification level would be via ICs of RecognitionCategory R or F.Basis Reference(s):1. NEI 99-01 Rev 6, SU42. Technical Specification 3.4.4, RCS Operational Leakage3. UFSAR 5.2.5, Detection of Leakage through Reactor Coolant Pressure Boundary4. Technical Specifications 3.4.55. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log6. DAN 902(3)-4 A-17 Drywell Equip Sump LvI HI-HI7. DAN 902(3)-4 H-18 Drywell Floor Drn Sump LvI HI-HI8. DOA 0040-01 Slow Leak9. DOP 2000-24 Drywell Sump Operation10. DGP 02-02 Reactor Vessel Slow FillMonth 20XXDR 3-101EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU7Initiating Condition:Loss of all On-site or Off-site communications capabilities.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):" Loss of ALL Table M3 Onsite communications capability affecting the ability toperform routine operations.OR" Loss of ALL Table M3 Offsite communication capability affecting the ability toperform offsite notifications.OR" Loss of ALL Table M3 NRC communication capability affecting the ability toperform NRC notifications.Table M3 Communications CapabilitySystem Onsite Offsite NRCPlant Radio XPlant Page XSound Powered Phones XAll telephone Lines (Commercial and microwave) X X XENS X XHPN X XSatellite Phones X XBasis:This IC addresses a significant loss of on-site, offsite, or NRC communicationscapabilities. While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).Month 20XXDR 3-102EP-AA-1004 (Revision XX) | |||
Dresden AnnexDresden Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU7 (cont)Basis (cont):EAL #1 BasisAddresses a total loss of the communications methods used in support of routine plantoperations.EAL #2 BasisAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in procedure EP-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) Form.EAL #3 BasisAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, SU62. EP-MW-124-1001 Facilities Inventories and Equipment Tests3. UFSAR 9.5.24. DOA 0010-14 Loss of Off-Site Telephone Communication SystemsMonth 20XXDR 3-103EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCAIInitiating Condition:Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:4,5, DEmergency Action Level (EAL):Note:" The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded." Loss of ALL offsite AC power to unit ECCS buses.AND" Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency dieselgenerators to supply power to unit ECCS buses.AND" Failure to restore power to at least one unit ECCS bus in < 15 minutes from thetime of loss of both offsite and onsite AC power.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-relatedThis IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergencycore cooling, containment heat removal/pressure control, spent fuel heat removal andthe ultimate heat sink.When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas a Site Area Emergency because of the increased time available to restore anemergency bus to service. Additional time is available due to the reduced core decayheat load, and the lower temperatures and pressures in various plant systems. Thus,when in these modes, this condition represents an actual or potential substantialdegradation of the level of safety of the plant.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via IC CS6 or RS1.Month 20XXDR 3-104EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA1 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CA22. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 KV System and 345 KV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-147. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-105EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSculInitiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:4,5, DEmergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. AC power capability to unit ECCS buses reduced to only one of the followingpower sources for > 15 minutes.* Reserve auxiliary Transformer TR-22 (TR-32)* Unit auxiliary transformer TR-21 (TR-31)* Unit Emergency Diesel Generator DG 2(3)* Shared Emergency Diesel Generator DG 2/3* Station Blackout Diesel Generator DG 2(3)* Unit crosstie breakersAND2. ANY additional single power source failure will result in a loss of ALL AC power toSAFETY SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS. In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment.Month 20XXDR 3-106EP-AA-1004 (Revision XX) | |||
Dresden rDlresden Annex FwAlnn Nui~clarRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCUI (cont)Basis (cont):When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas an Alert because of the increased time available to restore another power source toservice. Additional time is available due to the reduced core decay heat load, and thelower temperatures and pressures in various plant systems. Thus, when in thesemodes, this condition is considered to be a potential degradation of the level of safety ofthe plant.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below." A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator)." A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator." A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.The subsequent loss of the remaining single power source would escalate the event toan Alert in accordance with IC CAl.Basis Reference(s):1. NEI 99-01 Rev 6 CU22. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 KV System and 345 KV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout GeneratorTies to Plant Auxiliary Electric System7. UFSAR 9.5.9 Station Blackout System8. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-107EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA2Initiating Condition:Hazardous event affecting SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:4,5Emergency Action Level (EAL):1. The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)" Internal or external flooding event" High winds or tornado strike" FIRE" EXPLOSION" Other events with similar hazard characteristics as determined by theShift ManagerAND2. EITHER of the following:a. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM required by TechnicalSpecifications for the current operating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure required by Technical Specifications for thecurrent operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization. A release of steam (from highenergy lines or components) or an electrical component failure (caused by short circuits,grounding, arcing, etc.) should not automatically be considered an explosion. Suchevents may require a post-event inspection to determine if the attributes of an explosionare present.Month 20XXDR 3-108EP-AA-1004 (Revision XX) | |||
Dresden AnnexDresen AnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA2 (cont)Basis (cont):SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.VISIBLE DAMAGE: Damage to a component or structure that is readily observablewithout measurements, testing, or analysis. The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components, needed for the current operatingmode, "needed", i.e. required to be operable by Technical Specifications for the currentoperating mode. This condition significantly reduces the margin to a loss or potentialloss of a fission product barrier, and therefore represents an actual or potentialsubstantial degradation of the level of safety of the plant. Manual or automatic electricalisolation of safety equipment due to flooding, in and of itself, does not constitutedegraded performance and is classified under HU6.EAL #2.a BasisAddresses damage to a SAFETY SYSTEM train that is "needed", i.e. required to beoperable by Technical Specifications for the current operating mode, and is in operationsince indications for it will be readily available. The indications of degradedperformance should be significant enough to cause concern regarding the operability orreliability of the SAFETY SYSTEM train.EAL #2.b BasisAddresses damage to a SAFETY SYSTEM component that is "needed", i.e. required tobe operable by Technical Specifications for the current operating mode, and is not inoperation or readily apparent through indications alone, or to a structure containingSAFETY SYSTEM components. Operators will make this determination based on thetotality of available event and damage report information. This is intended to be a briefassessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC CS6 or RSI.If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):1. NEI 99-01 Rev 6, CA6Month 20XXDR 3-109EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU3Initiating Condition:Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.Voltage is < 105 VDC on required 125 VDC battery busses #2 and #3 for > 15 minutes.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a loss of Vital DC power which compromises the ability to monitorand control operable SAFETY SYSTEMS when the plant is in the cold shutdown orrefueling mode. In these modes, the core decay heat load has been significantlyreduced, and coolant system temperatures and pressures are lower; these conditionsrise the time available to restore a vital DC bus to service. Thus, this condition isconsidered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to supportoperation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.For example, if Train A is out-of-service (inoperable) for scheduled outage maintenancework and Train B is in-service (operable), then a loss of Vital DC power affecting Train Bwould require the declaration of an Unusual Event. A loss of Vital DC power to Train Awould not warrant an emergency classification.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Depending upon the event, escalation of the emergency classification level would be viaIC CA6 or CA5, or an IC in Recognition Category R.Month 20XXDR 3-110EP-AA-1004 (Revision XX) | |||
Annexflresrh-n Annex FvAlnn NucleIiarRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU3 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CU42. UFSAR 8.3.2.2.1 Safety Related 125-V System3. DOA 6900-02(3) Failure of Unit 2(3) 125 VDC Power Supply4. Technical Specification Basis B.3.8.5, DC Power Sources -Shutdown5. Technical Specification Basis B.3.8.4, DC Power Sources -OperatingMonth 20XXDR 3-111EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU4Initiating Condition:Loss of all onsite or offsite communications capabilities.Operating Mode Applicability:4,5, DEmergency Action Level (EAL):1. Loss of ALL Table C1 Onsite communications capability affecting the ability toperform routine operations.OR2. Loss of ALL Table C1 Offsite communication capability affecting the ability toperform offsite notifications.OR3. Loss of ALL Table C1 NRC communication capability affecting the ability toperform NRC notifications.Table C1 Communications CapabilitySystem Onsite Offsite NRCPlant Radio XPlant Page XSound Powered Phones XAll telephone Lines (Commercial and microwave) X X XENS X XHPN X XSatellite Phones X XBasis:This IC addresses a significant loss of on-site, offsite, or NRC communicationscapabilities. While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 BasisAddresses a total loss of the communications methods used in support of routine plantoperations.Month 20XXDR 3-112EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU4 (cont)Basis (cont):EAL #2 BasisAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in procedure EP-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) Form.EAL #3 BasisAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, CU52. EP-MW-124-1001 Facilities Inventories and Equipment Tests3. UFSAR 9.5.24. DOA 0010-14 Loss of Off-Site Telephone Communication SystemsMonth 20XXDR 3-113EP-AA-1004 (Revision XX) nradin AnnavPvtalnn k, ,-l,-nrRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA5Initiating Condition:Inability to maintain the plant in cold shutdown.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature > 212°F due to loss of decay heat removalfor > Table C2 duration.Table C2 RCS Heat-up Duration ThresholdsRCS Containment Closure Heat-upStatus Status DurationIntact Not Applicable 60 minutes*Not Intact Established 20 minutes*Not Established 0 minutes* If an RCS heat removal system is in operation withinthis time frame and RCS temperature is being reduced,then EAL #1 is not applicable.OR2. UNPLANNED RPV pressure rise > 10 psig as a result of temperature rise due toloss of decay heat removal.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment (primary or secondary) and its associated structures, systems, andcomponents as a functional barrier to fission product release under shutdownconditions.Month 20XXDR 3-114EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearD...s.en..Annex.Exelon Nulea.rRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA5 (cont)Basis (cont):RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs, etc.).This IC addresses conditions involving a loss of decay heat removal capability or anaddition of heat to the RCS in excess of that which can currently be removed. Eithercondition represents an actual or potential substantial degradation of the level of safetyof the plant.A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperaturewhen CONTAINMENT CLOSURE is established but the RCS is not intact. The 20-minute criterion was included to allow time for operator action to address thetemperature rise.The RCS Heat-up Duration Thresholds table also addresses a rise in RCS temperaturewith the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in thiscondition since the intact RCS is providing a high pressure barrier to a fission productrelease. The 60-minute time frame should allow sufficient time to address thetemperature rise without a substantial degradation in plant safety.Finally, in the case where there is a rise in RCS temperature, the RCS is not intact andCONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0minutes). This is because 1) the evaporated reactor coolant may be released directlyinto the Containment atmosphere and subsequently to the environment, and 2) there isreduced reactor coolant inventory above the top of irradiated fuel.EAL #2 provides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS6 or RSI.Month 20XXDR 3-115EP-AA-1004 (Revision XX) | |||
AnnexDresden Annex FvAlnn MNuir-larRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA5 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CA32. Technical Specifications 3.6.1.13. Technical Specifications 3.6.4.14. OU-AA-103 Shutdown Safety Management Program5. DGP 02-01 Unit Shutdown6. DOA 0201-04 Loss of Vessel Flange, Shell, or Recirculation (Recirc) LoopTemperature Recorders During Heatup or Cooldown7. DGP 02-02 Reactor Vessel Slow Fill8. DIS 0263-19 Reactor Wide Range Pressure Transmitter Calibration Eq.Maintenance InspectionMonth 20XXDR 3-116EP-AA-1004 (Revision XX) | |||
AnnexrDlresden Annex ExeInn NuclarIcrRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCU5Initiating Condition:UNPLANNED rise in RCS temperatureOperating Mode Applicability:4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature > 212°F due to loss of decay heat removal.OR2. Loss of the following for >15 minutes.* ALL RCS temperature indicationsAND" ALL RPV water level indicationsBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment (primary or secondary) and its associated structures, systems, andcomponents as a functional barrier to fission product release under shutdownconditions.This IC addresses an UNPLANNED rise in RCS temperature above the TechnicalSpecification cold shutdown temperature limit, or the inability to determine RCStemperature and level, represents a potential degradation of the level of safety of theplant. If the RCS is not intact and CONTAINMENT CLOSURE is not established duringthis event, the Emergency Director should also refer to IC CA5.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs, etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.Month 20XXDR 3-117EP-AA-1004 (Revision XX) | |||
Dresden AnnexNuclearDresden Annex FwceInn NucleiarRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU5 (cont)Basis (cont):EAL #1 involves a loss of decay heat removal capability, or an addition of heat to theRCS in excess of that which can currently be removed, such that reactor coolanttemperature cannot be maintained below the cold shutdown temperature limit specifiedin Technical Specifications. During this condition, there is no immediate threat of fueldamage because the core decay heat load has been reduced since the cessation ofpower operation.During an outage, the level in the reactor vessel will normally be maintained above thereactor vessel flange. Refueling evolutions that lower water level below the reactorvessel flange are carefully planned and controlled. A loss of forced decay heat removalat reduced inventory may result in a rapid rise in reactor coolant temperature dependingon the time after shutdown.EAL #2 reflects a condition where there has been a significant loss of instrumentationcapability necessary to monitor RCS conditions and operators would be unable tomonitor key parameters necessary to assure core decay heat removal. During thiscondition, there is no immediate threat of fuel damage because the core decay heatload has been reduced since the cessation of power operation.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA5 based onexceeding plant configuration-specific time criteria.Basis Reference(s):1. NEI 99-01 Rev 6, CU32. Technical Specifications Table 1.1-13. DGP 02-01 UNIT SHUTDOWN4. DOA 0201-04, Loss of Vessel Flange, Shell, or Recirculation (Recirc) LoopTemperature Recorders During Heatup or Cooldown5. DGP 02-02 Reactor Vessel Slow Fill6. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines7. DEOP 100 RPV Control, Table A8. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level InstrumentationMonth 20XXDR 3-118EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCG6Initiating Condition:Loss of RPV inventory affecting fuel clad integrity with containment challenged.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. a. RPV water level < -143 inches (TAF) for > 30 minutes.ANDb. Any Containment Challenge Indication (Table C4)OR2. a. RPV water level unknown for > 30 minutes.ANDb. Core uncovery is indicated by ANY of the following:" Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Refuel Floor Hi Range ARM >3000 mR/hr.ANDc. ANY Containment Challenge Indication (Table C4)Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise*" UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.Month 20XXDR 3-119EP-AA-1004 (Revision XX) nrgcu{an Annov=wn1rn Kbir-Lanr-.~a--. 5'* *~ 'en fl~ I I., I I U t -i*RECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCG6 (cont)Emergency Action Level (EAL) (cont):Table C4 Containment Challenge Indications* Primary Containment Hydrogen Concentration > 6% and Oxygen > 5%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established** ANY Secondary Containment radiation monitor > DEOP 300-1 MaximumSafe operating level.* if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minutecore uncovery time limit, then escalation to a General Emergency is not required.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment (primary or secondary for BWR) and its associated structures,systems, and components as a functional barrier to fission product release undershutdown conditions.This IC addresses the inability to restore and maintain reactor vessel level above thetop of active fuel with containment challenged. This condition represents actual orIMMINENT substantial core degradation or melting with potential for loss of containmentintegrity. Releases can be reasonably expected to exceed EPA Protective ActionGuidelines (PAG) exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a directand unmonitored release of radioactivity to the environment. If CONTAINMENTCLOSURE is re-established prior to exceeding the 30-minute time limit, then declarationof a General Emergency is not required.Month 20XXDR 3-120EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCG6 (cont)Basis (cont):The existence of an explosive mixture means, at a minimum, that the containmentatmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity. Ittherefore represents a challenge to Containment integrity.In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to acore uncovery could result in an explosive gas mixture in containment. If all installedhydrogen gas monitors are out-of-service during an event leading to fuel claddingdamage, it may not be possible to obtain a containment hydrogen gas concentrationreading as ambient conditions within the containment will preclude personnel access.During periods when installed containment hydrogen gas monitors are out-of-service,operators may use the other listed indications to assess whether or not containment ischallenged.EAL #1 BasisThe 30-minute criterion is tied to a readily recognizable event start time (i.e., the totalloss of ability to monitor level), and allows sufficient time to monitor, assess andcorrelate reactor and plant conditions to determine if core uncovery has actuallyoccurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor RPV water level may be caused by instrumentation and/orpower failures, or water level dropping below the range of available instrumentation. Ifwater level cannot be monitored, operators may determine that an inventory loss isoccurring by observing changes in sump and/or tank levels. Sump and/or tank levelchanges must be evaluated against other potential sources of water flow to ensure theyare indicative of leakage from the RPV.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Month 20XXDR 3-121EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCG6 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CG12. DEOP 0100-00 RPV Control3. Technical Specifications 3.3.1.24. DOS 0700-01 SRM Functional Test5. DAN 902(3)-5 E-4 SRM Short Period6. DEOP 0200-01 Primary Containment Control7. DEOP 0200-02 Hydrogen Control8. DEOP 0300-01 Secondary Containment Control9. USAR Table 6.2-110. EP-EAL-0501Month 20XXDR 3-122EP-AA-1 004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCS6Initiating Condition:Loss of RPV inventory affecting core decay heat removal capability.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. With CONTAINMENT CLOSURE not established, RPV water level< -60 inchesOR2. With CONTAINMENT CLOSURE established, RPV water level< -143 inches (TAF)OR3. a. RPV water level unknown for > 30 minutesANDb. Core uncovery is indicated by ANY of the following:* Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Refueling Floor Hi Range ARM >3000 mR/hr.Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise** UNPLANNED Torus level rise*" UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.Month 20XXDR 3-123EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCS6 (cont)Basis:CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment (primary or secondary for BWR) and its associated structures,systems, and components as a functional barrier to fission product release undershutdown conditions.UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.The lost inventory may be due to a RCS component failure, a loss of configurationcontrol or prolonged boiling of reactor coolant. These conditions entail major failures ofplant functions needed for protection of the public and thus warrant a Site AreaEmergency declaration.Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.Outage/shutdown contingency plans typically provide for re-establishing or verifyingCONTAINMENT CLOSURE following a loss of heat removal or RCS inventory controlfunctions. The difference in the specified RCS/reactor vessel levels of EALs 1 and 2reflect the fact that with CONTAINMENT CLOSURE established, there is a lowerprobability of a fission product release to the environment.In EAL #3.a, the 30-minute criterion is tied to a readily recognizable event start time(i.e., the total loss of ability to monitor level), and allows sufficient time to monitor,assess and correlate reactor and plant conditions to determine if core uncovery hasactually occurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor RPV water level may be caused by instrumentation and/orpower failures, or water level dropping below the range of available instrumentation. Ifwater level cannot be monitored, operators may determine that an inventory loss isoccurring by observing changes in sump and/or tank levels. Sump and/or tank levelchanges must be evaluated against other potential sources of water flow to ensure theyare indicative of leakage from the RPV.Month 20XXDR 3-124EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCS6 (cont)Basis (cont):These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Escalation of the emergency classification level would be via IC CG6 or RG1.Basis Reference(s):1. NEI 99-01 Rev 6, CS12. Technical Specifications Table 3.3.5.1 13. UFSAR 5.2.54. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines5. DEOP 0100-00 RPV Control6. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log7. DAN 902(3)-4 A-17 Drywell Equip Sump LvI HI-HI8. DAN 902(3)-4 H-18 Drywell Floor Drn Sump Lvl HI-HI9. DOA 0040-01 Slow Leak10. DOP 2000-24 Drywell Sump Operation11. Technical Specifications 3.3.1.212 DOS 0700-01 SRM Functional Test13. DAN 902(3)-5 E-4 SRM Short PeriodMonth 20XXDR 3-125EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA6Initiating Condition:Loss of RPV inventory.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. Loss of RPV inventory as indicated by level < -54 inches.OR2. a. RPV water level unknown for > 15 minutes.ANDb. Loss of RPV inventory per Table C3 indications.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus level rise*" UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses conditions that are precursors to a loss of the ability to adequatelycool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). Thiscondition represents a potential substantial reduction in the level of plant safety.Month 20XXDR 3-126EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA6 (cont)Basis (cont):EAL #1 BasisA lowering of water level below -54.15 inches indicates that operator actions have notbeen successful in restoring and maintaining RPV water level. The heat-up rate of thecoolant will rise as the available water inventory is reduced. A continuing drop in waterlevel will lead to core uncovery.Although related, EAL #1 is concerned with the loss of RCS inventory and not thepotential concurrent effects on systems needed for decay heat removal (e.g., loss of aResidual Heat Removal suction point). A rise in RCS temperature caused by a loss ofdecay heat removal capability is evaluated under IC CA5.EAL #2 BasisThe inability to monitor RPV water level may be caused by instrumentation and/orpower failures, or water level dropping below the range of available instrumentation. Ifwater level cannot be monitored, operators may determine that an inventory loss isoccurring by observing changes in sump and/or tank levels. Sump and/or tank levelchanges must be evaluated against other potential sources of water flow to ensure theyare indicative of leakage from the RPV.The 15-minute duration for the loss of level indication was chosen because it is half ofthe EAL duration specified in IC CS6If the RPV water level continues to lower, then escalation to Site Area Emergency wouldbe via IC CS6.Basis Reference(s):1. NEI 99-01 Rev 6, CA12. USAR 5.2.5, Detection of Leakage through Reactor Coolant Pressure Boundary3. Technical Specification 3.3.5.1, Emergency Core Cooling System (ECCS)Instrumentation4. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines5. DEOP 100 RPV Control6. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log7. DAN 902(3)-4 A-17 Drywell Equip Sump Lvl HI-HI8. DAN 902(3)-4 H-18 Drywell Floor Drn Sump Lvl HI-HI9. DOA 0040-01 Slow Leak10. DOP 2000-24 Drywell Sump OperationMonth 20XXDR 3-127EP-AA-1004 (Revision XX) fnari4mn Annov=wn1^n K1"&-1AmnrRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU6Initiating Condition:UNPLANNED loss of RPV inventory for 15 minutes or longer.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED loss of reactor coolant results in the inability to restore and maintainRPV water level above the procedurally established lower limit for > 15 minutes.OR2. a. RPV water level unknownANDb. Loss of RPV inventory per Table C3 indications.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise*" UNPLANNED Torus level rise*" UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.Month 20XXDR 3-128EP-AA-1004 (Revision XX) | |||
Dresden Annex Ex..lon NuceIa.rRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU6 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses the inability to restore and maintain water level to a requiredminimum level (or the lower limit of a level band), or a loss of the ability to monitor RPVwater level concurrent with indications of coolant leakage. Either of these conditions isconsidered to be a potential degradation of the level of safety of the plant.The procedurally established lower limit is not an operational band established abovethe procedural limit to allow for operator action prior to exceeding the procedural limit,but it is the procedurally established lower limit.Refueling evolutions that lower RCS water inventory are carefully planned andcontrolled. An UNPLANNED event that results in water level decreasing below aprocedurally required limit warrants the declaration of an Unusual Event due to thereduced water inventory that is available to keep the core covered.EAL #1 recognizes that the minimum required RPV water level can change severaltimes during the course of a refueling outage as different plant configurations andsystem lineups are implemented. This EAL is met if the minimum level, specified for thecurrent plant conditions, cannot be maintained for 15 minutes or longer. The minimumlevel is typically specified in the applicable operating procedure but may be specified inanother controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions torestore and maintain the expected water level. This criterion excludes transientconditions causing a brief lowering of water level.EAL #2 addresses a condition where all means to determine RPV water level havebeen lost. In this condition, operators may determine that an inventory loss is occurringby observing changes in sump and/or tank levels. Sump and/or tank level changesmust be evaluated against other potential sources of water flow to ensure they areindicative of leakage from the RPV.Continued loss of RCS inventory may result in escalation to the Alert emergencyclassification level via either IC CA6 or CA5.Month 20XXDR 3-129EP-AA-1004 (Revision XX) | |||
Nr~rga~n Annayflr~~,~ut Ancv Fvinn NucleIarRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU6 (cont)Basis Reference(s):1. NEI 99-01, Rev. 6 CU12. USAR 5.2.5, Detection of Leakage through Reactor Coolant Pressure Boundary3. Technical Specifications 3.4.44. Technical Specifications 3.4.55. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log6. DAN 902(3)-4 A-17 Drywell Equip Sump LvI HI-HI7. DAN 902(3)-4 H-18 Drywell Floor Drn Sump Lvl HI-HI8. DOA 0040-01 Slow Leak9. DOP 2000-24 Drywell Sump Operation10. DGP 02-02 Reactor Vessel Slow Fill11. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines12. DEOP 0100-00 RPV Control, Table A13. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level Instrumentation14. Technical Specifications Table 3.3.5.1 1Month 20XXDR 3-130EP-AA-1004 (Revision XX) | |||
Dresden AnnexExallon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1Initiating Condition:HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:1, 2,3,4,5, DEmergency Action Level (EAL):1. A notification from the Security Force that a HOSTILE ACTION is occurring orhas occurred within the PROTECTED AREA.AND2. a. ANY Table H1 safety function cannot be controlled or maintained.ORb. Damage to spent fuel has occurred or is IMMINENTTable H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.Month 20XXDR 3-131EP-AA-1004 (Revision XX) | |||
Dresden AnnexExellon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1Basis (cont):IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.This IC addresses an event in which a HOSTILE FORCE has taken physical control ofthe facility to the extent that the plant staff can no longer operate equipment necessaryto maintain key safety functions. It also addresses a HOSTILE ACTION leading to aloss of physical control that results in actual or IMMINENT damage to spent fuel due to1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls,etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot bemaintained.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].Basis Reference(s):1. NEI 99-01, Rev. 6 HG12. Station Security Plan -Appendix CMonth 20XXDR 3-132EP-AA-1004 (Revision XX) nroarian AnnovMvm1^n KI"r-haftrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS1Initiating Condition:HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:1, 2,3,4,5, DEmergency Action Level (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTEDAREA. This event will require rapid response and assistance due to the possibility fordamage to plant equipment.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].Month 20XXDR 3-133EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHSI (cont)Basis (cont):As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Site Area Emergency declaration will mobilize OROresources and have them available to develop and implement public protective actionsin the unlikely event that the attack is successful in impairing multiple safety functions.This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTEDAREA located outside the plant PROTECTED AREA; such an attack should beassessed using IC HA1. It also does not apply to incidents that are accidental events,acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by aHOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters,physical disputes between employees, etc. Reporting of these types of events isadequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR§ 50.72.Escalation of the emergency classification level would be via IC HG1.Basis Reference(s):1. NEI 99-01 Rev 6, HS13. Station Security Plan -Appendix CMonth 20XXDR 3-134EP-AA-1004 (Revision XX) | |||
AnnexrDresden Annex Fvalnn Niinanr~IRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA1Initiating Condition:HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threatwithin 30 minutes.Operating Mode Applicability:1,2,3,4,5, DEmergency Action Level (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutes fromthe site.OR2. Notification by the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the OWNER CONTROLED AREA.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.OWNER CONTROLLED AREA (OCA): The property associated with the station andowned by the company. Access is normally limited to persons entering for officialbusiness.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.Month 20XXDR 3-135EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA1 (cont)Basis (cont):This IC addresses the occurrence of a HOSTILE ACTION within the OWNERCONTROLLED AREA or notification of an aircraft attack threat. This event will requirerapid response and assistance due to the possibility of the attack progressing to thePROTECTED AREA, or the need to prepare the plant and staff for a potential aircraftimpact.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Alert declaration will also heighten the awareness ofOffsite Response Organizations, allowing them to be better prepared should it benecessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience,or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputesbetween employees, etc. Reporting of these types of events is adequately addressedby other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL #1 BasisAddresses the threat from the impact of an aircraft on the plant, and the anticipatedarrival time is within 30 minutes. The intent of this EAL is to ensure that threat-relatednotifications are made in a timely manner so that plant personnel and OROs are in aheightened state of readiness. This EAL is met when the threat-related information hasbeen validated in accordance with DOA 0010-18, Escalated Security Event/HostileForce Intrusion.EAL #2 BasisIs applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNERCONTROLLED AREA. This includes any action directed against an ISFSI that islocated outside the plant PROTECTED AREA.The NRC Headquarters Operations Officer (HOO) will communicate to the licensee ifthe threat involves an aircraft. The status and size of the plane may be provided byNORAD through the NRC.Month 20XXDR 3-136EP-AA-1004 (Revision XX) | |||
Dresden AnnexExellon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHAI (cont)Basis (cont):In some cases, it may not be readily apparent if an aircraft impact within the OWNERCONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected,although not certain, that notification by an appropriate Federal agency to the site wouldclarify this point. In this case, the appropriate federal agency is intended to be NORAD,FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs,should not be unduly delayed while awaiting notification by a Federal agency.Escalation of the emergency classification level would be via IC HS1.Basis Reference(s):1. NEI 99-01 Rev 6, HA12. Station Security Plan -Appendix C3. DOA 0010-18, Escalated Security Event/Hostile Force IntrusionMonth 20XXDR 3-137EP-AA-1004 (Revision XX) | |||
AnnovMLwv~nn on nrl-Lmr-* ~ * | |||
* F* ** *~St ~ ~. ...t. -~RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU1Initiating Condition:Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:1, 2,3,4,5, DEmergency Action Level (EAL):1. Notification of a credible security threat directed at the site as determined perSY-AA-1 01-132, Security Assessment and Response to Unusual Activities.OR2. A validated notification from the NRC providing information of an aircraft threat.OR3. Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.Basis:SECURITY CONDITION: Any Security Event as listed in the approved securitycontingency plan that constitutes a threat/compromise to site security, threat/risk to sitepersonnel, or a potential degradation to the level of safety of the plant. A SECURITYCONDITION does not involve a HOSTILE ACTIONSAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.Month 20XXDR 3-138EP-AA-1004 (Revision XX) | |||
AnnexrDresde~n Annexw FYAlln NuclerIAmRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHUI (cont)Basis (cont):This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEMequipment, and thus represent a potential degradation in the level of plant safety.Security events which do not meet one of these EALs are adequately addressed by therequirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed asHOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Classification of these events will initiate appropriate threat-related notifications to plantpersonnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 BasisAddresses the receipt of a credible security threat. The credibility of the threat isassessed in accordance with SY-AA-101-132.EAL #2 BasisAddresses the threat from the impact of an aircraft on the plant. The NRCHeadquarters Operations Officer (HOO) will communicate to the licensee if the threatinvolves an aircraft. The status and size of the plane may also be provided by NORADthrough the NRC. Validation of the threat is performed in accordance with DOA 0010-18, Escalated Security Event/Hostile Force IntrusionEAL #3 BasisReferences Security Force because these are the individuals trained to confirm that asecurity event is occurring or has occurred. Training on security event confirmation andclassification is controlled due to the nature of Safeguards and 10 CFR § 2.39information.Escalation of the emergency classification level would be via IC HA1.Basis Reference(s):1. NEI 99-01 Rev 6, HU12. SY-AA-1 01-132, Security Assessment and Response to Unusual Activities3. Station Security Plan -Appendix C4. NRC Safeguards Advisory 10/6/015. Letter from Mr. B. A. Boger (NRC) to Ms. Lynette Hendricks (NEI) dated 2/4/026. DOA 0010-18, Escalated Security Event/Hostile Force IntrusionMonth 20XXDR 3-139EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS2Initiating Condition:Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per DSSP 0100-CR, Hot Shutdown Procedure-Control Room Evacuation.AND2. Control of ANY Table H1 key safety function is not reestablished in < 30 minutes.Table HI Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Basis:The time period to establish control of the plant starts when either:a. Control of the plant is no longer maintained in the Main Control RoomORb. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations, and the control of a key safety function cannot bereestablished in a timely manner. The failure to gain control of a key safety functionfollowing a transfer of plant control to alternate locations is a precursor to a challenge toany fission product barriers within a relatively short period of time.Month 20XXDR 3-140EP-AA-1004 (Revision XX) | |||
Dresden AnnexExellon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS2 (cont)Basis (cont):The determination of whether or not "control" is established at the remote safeshutdown location(s) is based on Emergency Director judgment. The EmergencyDirector is expected to make a reasonable, informed judgment within 30 minuteswhether or not the operating staff has control of key safety functions from the remotesafe shutdown location(s).Escalation of the emergency classification level would be via IC FG1 or CG6.Basis Reference(s):1. NEI 99-01, Rev 6 HS62. DSSP 0100-CR, Hot Shutdown Procedure -Control Room EvacuationMonth 20XXDR 3-141EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA2Initiating Condition:Control Room evacuation resulting in transfer of plant control to alternate locations.Operating Mode Applicability:1,2,3, 4,5, DEmergency Action Level (EAL):A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per DSSP 0100-CR, Hot Shutdown Procedure -Control Room Evacuation.Basis:This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations outside the Control Room. The loss of the ability to controlthe plant from the Control Room is considered to be a potential substantial degradationin the level of plant safety.Following a Control Room evacuation, control of the plant will be transferred to alternateshutdown locations. The necessity to control a plant shutdown from outside the ControlRoom, in addition to responding to the event that required the evacuation of the ControlRoom, will present challenges to plant operators and other on-shift personnel.Activation of the ERO and emergency response facilities will assist in responding tothese challenges.Escalation of the emergency classification level would be via IC HS2.Basis Reference(s):1. NEI 99-01, Rev 6 HA62. DSSP 0100-CR, Hot Shutdown Procedure -Control Room EvacuationMonth 20XXDR 3-142EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3Initiating Condition:FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Note:9 The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of thefollowing FIRE detection indications:" Report from the field (i.e., visual observation)* Receipt of multiple (more than 1) fire alarms or indications* Field verification of a single fire alarmTable H2 Vital Areas" Reactor Building (when inerted the Drywell is exempt)* Aux Electric Room* Control Room* Unit and Shared Emergency Diesel Generator Rooms* 4KV ECCS Switchgear Area (includes Bus 23, 24, 33 and 34 only)* CRD & CCSW Pump Rooms* Turbine Building Cable Tunnel* Turbine Building Safe Shutdown Areas as follows:1 B- Train Control Room HVAC Room* Battery Rooms and DC Distribution Areas1) U2 Battery Room (includes DC switchgear, 125V, and 250V battery rooms)2) U3 Battery Room, Battery Cage area, and U3 Battery Charger Room(all on U3 TB 538)* Crib HouseOR2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indicationsof a FIRE).ANDb. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.ORMonth 20XXDR 3-143EP-AA-1004 (Revision XX) | |||
Dresden AnnexDlresden Annex Fv.vIn i.Ir~vA.RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)Emergency Action Level (EAL) (cont):3. A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes ofthe initial report, alarm or indication.OR4. A FIRE within the plant PROTECTED AREA that requires firefighting support byan offsite fire response agency to extinguish.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of apotential degradation of the level of safety of the plant.EAL #1 BasisThe intent of the 15-minute duration is to size the FIRE and to discriminate againstsmall FIRES that are readily extinguished (e.g., smoldering waste paper basket). Inaddition to alarms, other indications of a FIRE could be a drop in fire main pressure,automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial firealarm, indication, or report. For EAL assessment purposes, the emergency declarationclock starts at the time that the initial alarm, indication, or report was received, and notthe time that a subsequent verification action was performed. Similarly, the fire durationclock also starts at the time of receipt of the initial alarms, indication or report.EAL #2 BasisThis EAL addresses receipt of a single fire alarm, and the existence of a FIRE is notverified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt,operators will take prompt actions to confirm the validity of a single fire alarm. For EALassessment purposes, the 30-minute clock starts at the time that the initial alarm wasreceived, and not the time that a subsequent verification action was performed.Month 20XXDR 3-144EP-AA-1004 (Revision XX) nro*arian AnnayP:vgmltnn N, ig--a-rflr~~rI~n Ann~v FvaIr~n Mu.~I~~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)Basis (cont):A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipmentfailure or a spurious activation, and not an actual FIRE. For this reason, additional timeis allowed to verify the validity of the alarm. The 30-minute period is a reasonableamount of time to determine if an actual FIRE exists; however, after that time, andabsent information to the contrary, it is assumed that an actual FIRE is in progress.If an actual FIRE is verified by a report from the field, then EAL #1 is immediatelyapplicable, and the emergency must be declared if the FIRE is not extinguished within15-minutes of the report. If the alarm is verified to be due to an equipment failure or aspurious activation, and this verification occurs within 30-minutes of the receipt of thealarm, then this EAL is not applicable and no emergency declaration is warranted.EAL #3 BasisIn addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plantPROTECTED AREA not extinguished within 60-minutes may also potentially degradethe level of plant safetyEAL #4 BasisIf a FIRE within the plant PROTECTED AREA is of sufficient size to require a responseby an offsite firefighting agency (e.g., a local town Fire Department), then the level ofplant safety is potentially degraded. The dispatch of an offsite firefighting agency to thesite requires an emergency declaration only if it is needed to actively support firefightingefforts because the fire is beyond the capability of the Fire Brigade to extinguish.Declaration is not necessary if the agency resources are placed on stand-by, orsupporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix RAppendix R to 10 CFR 50, states in part:Criterion 3 of Appendix A to this part specifies that "Structures, systems, andcomponents important to safety shall be designed and located to minimize,consistent with other safety requirements, the probability and effect of fires andexplosions."When considering the effects of fire, those systems associated withachieving and maintaining safe shutdown conditions assume major importance tosafety because damage to them can lead to core damage resulting from loss ofcoolant through boil-off.Month 20XXDR 3-145EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)Basis (cont):Because fire may affect safe shutdown systems and because the loss of functionof systems used to mitigate the consequences of design basis accidents underpost-fire conditions does not per se impact public safety, the need to limit firedamage to systems required to achieve and maintain safe shutdown conditions isgreater than the need to limit fire damage to those systems required to mitigatethe consequences of design basis accidents.In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of1-hour fire barriers for the enclosure of cable and equipment and associated non-safetycircuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify asingle alarm is well within this worst-case 1-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA2 or MA5.Basis Reference(s):1. NEI 99-01, Rev 6 HU42. UFSAR 3.2, Classification of Structures, Components, and Systems3. UFSAR 3.5.34. General Arrangement Drawings M-3, M-4, M-4A, M-5 and M-10Month 20XXDR 3-146EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU4Initiating Condition:Seismic event greater than OBE levels.Operating Mode Applicability:1,2,3,4,5, DEmergency Action Level (EAL):1. Control Room personnel feel an actual or potential seismic event.AND2. The occurrence of a seismic event is confirmed in a manner deemed appropriate bythe Shift Manager or Emergency Director.Basis:This IC addresses a seismic event that results in accelerations at the plant site greaterthan those specified for an Operating Basis Earthquake (OBE)1.An earthquake greaterthan an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have nosignificant impact on safety-related systems, structures and components; however,some time may be required for the plant staff to ascertain the actual post-eventcondition of the plant (e.g., performs walk-downs and post-event inspections). Giventhe time necessary to perform walk-downs and inspections, and fully understand anyimpacts, this event represents a potential degradation of the level of safety of the plant.Event verification with external sources should not be necessary during or following anOBE. Earthquakes of this magnitude should be readily felt by on-site personnel andrecognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).EAL #2 is included to ensure that a declaration does not result from felt vibrationscaused by a non-seismic source (e.g., a dropped load). The Shift Manager orEmergency Director may seek external verification if deemed appropriate (e.g., call toUSGS, check internet source, etc.) however, the verification action must not preclude atimely emergency declaration. This EAL wording recognizes that it may cause the site todeclare an Unusual Event while another site similarly affected but with readily availableOBE indications in the Control Room, may not.Depending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA2 or MA5.1 An OBE is vibratory ground motion for which those features of a nuclear power plantnecessary for continued operation without undue risk to the health and safety of thepublic will remain functional.An SSE is vibratory ground motion for which certain (generally, safety-related)structures, systems, and components must be designed to remain functional.Month 20XXDR 3-147EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU4 (cont)Basis Reference(s):1. NEI 99-01, Rev 6 HU22. DOA 0010-03, EarthquakesMonth 20XXDR 3-148EP-AA-1004 (Revision XX) | |||
Dresden AnnexDresen AnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5Initiating Condition:Gaseous release impeding access to equipment necessary for normal plant operations,cooldown or shutdown.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Note:* If the equipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emergency classification iswarranted.1. Release of a toxic, corrosive, asphyxiant or flammable gas in a Table H3 area.Table H3Areas with Entry Related Mode ApplicabilityArea Entry Related Mode ApplicabilityReactor Building* Modes 3, 4, and 5*Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impededBasis:This IC addresses an event involving a release of a hazardous gas that precludes orimpedes access to equipment necessary to transition the plant from normal plantoperation to cooldown and shutdown as specified in normal plant procedures. Thiscondition represents an actual or potential substantial degradation of the level of safetyof the plant.Table H3 is a list of plant rooms or areas with entry-related mode applicability thatcontain equipment which require a manual/local action necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal operatingprocedures (establish shutdown cooling), where if this action is not completed the plantwould not be able to attain and maintain cold shutdown. This Table does not includerooms or areas for which entry is required solely to perform actions of an administrativeor record keeping nature (e.g., normal rounds or routine inspections).Month 20XXDR 3-149EP-AA-1 004 (Revision XX) | |||
Dry.dAn AnnRxDresden Annex Fvalnn NJiiear~IRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5 (cont)Basis (cont):This Table does not include the Control Room since adequate engineered safety/designfeatures are in place to preclude a Control Room evacuation due to the release of ahazardous gas.An Alert declaration is warranted if entry into the affected room/area is, or may be,procedurally required during the plant operating mode in effect and the gaseous releasepreclude the ability to place shutdown cooling in service. The emergency classificationis not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires theEmergency Director's judgment that the gas concentration in the affected room/area issufficient to preclude or significantly impede procedurally required access. Thisjudgment may be based on a variety of factors including an existing job hazard analysis,report of ill effects on personnel, advice from a subject matter expert or operatingexperience with the same or similar hazards. Access should be considered as impededif extraordinary measures are necessary to facilitate entry of personnel into the affectedroom/area (e.g., requiring use of protective equipment, such as SCBAs, that is notroutinely employed).An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the timeof the gaseous release). For example, the plant is in Mode 1 when the gaseousrelease occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4." The gas release is a planned activity that includes compensatory measures whichaddress the temporary inaccessibility of a room or area (e.g., fire suppressionsystem testing)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections).* The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerouslevels. Most commonly, asphyxiants work by merely displacing air in an enclosedenvironment. This reduces the concentration of oxygen below the normal level ofaround 19%, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that generate smoke, that automaticallyor manually activate a fire suppression system in an area, or to intentional inerting ofcontainment.Escalation of the emergency classification level would be via Recognition Category R, Cor F ICs.Month 20XXDR 3-150EP-AA-1004 (Revision XX) | |||
Dresden AnnexExellon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5 (cont)Basis Reference(s):1. NEI 99-01, Rev 6 HA52. UFSAR 3.5.33. UFSAR 3.24. General Arrangement Drawings M-3, M-4, M-4A, M-5 and M-10Month 20XXDR 3-151EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU6Initiating Condition:Hazardous EventOperating Mode Applicability:1, 2,3,4,5, DEmergency Action Level (EAL):Note:EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, orvehicle breakdowns or accidents.1. Tornado strike within the PROTECTED AREA.OR2. Internal room or area flooding of a magnitude sufficient to require manual orautomatic electrical isolation of a SAFETY SYSTEM component required byTechnical Specification for the current operating mode.OR3. Movement of personnel within the PROTECTED AREA is impeded due to an offsiteevent involving hazardous materials (e.g., an offsite chemical spill or toxic gasrelease).OR4. A hazardous event that results in on-site conditions sufficient to prohibit the plantstaff from accessing the site via personal vehicles.OR5. Abnormal River level, as indicated by EITHER:a. High river level > 509 ft.ORb. Low river level <501 ft. 6 inches.Basis:PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.Month 20XXDR 3-152EP-AA-1004 (Revision XX) pracrian AnnoyI=Yalnn N,,r-l,-orfl racrI~n Ann~v FvMnn Mm.rIc~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU6 (cont)Basis (cont):This IC addresses hazardous events that are considered to represent a potentialdegradation of the level of safety of the plant.EAL #1 BasisAddresses a tornado striking (touching down) within the Protected Area.EAL #2 BasisAddresses flooding of a building room or area that results in operators isolating power toa SAFETY SYSTEM component due to water level or other wetting concerns.Classification is also required if the water level or related wetting causes an automaticisolation of a SAFETY SYSTEM component from its power source (e.g., a breaker orrelay trip). To warrant classification, operability of the affected component must berequired by Technical Specifications for the current operating mode. Manual isolation ofpower to a SAFETY SYSTEM component as a result of leakage is an event of lesserimpact and would be expected to cause small and localized damage. The consequenceof this type of event is adequately assessed and addressed in accordance withTechnical Specifications.EAL #3 BasisAddresses a hazardous materials event originating at an offsite location and of sufficientmagnitude to impede the movement of personnel within the PROTECTED AREA.EAL #4 BasisAddresses a hazardous event that causes an on-site impediment to vehicle movementand significant enough to prohibit the plant staff from accessing the site using personalvehicles. Examples of such an event include site flooding caused by a hurricane, heavyrains, up-river water releases, dam failure, etc., or an on-site train derailment blockingthe access road.This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehiclebreakdowns or accidents, but rather to more significant conditions such as theHurricane Andrew strike on Turkey Point in 1992, the flooding around the CooperStation during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in2011.Escalation of the emergency classification level would be based on ICs in RecognitionCategories R, F, M, H or C.Month 20XXDR 3-153EP-AA-1004 (Revision XX) | |||
AnnoyvPvgmlrn Ki ,Al-orRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU6 (cont)Basis (cont):..EAL #5 Basis:The possible maximum flood (PMF) produces a peak flood to 528 ft el. This issignificantly above the grade elevation (517 ft) and the high river water level threshold,which is the lowest opening leading to safety-related equipment (509 ft el.). When thislevel is reached, the reactors are shutdown, the drywells are deinerted, and the vesselsare flooded and cooled to cold shutdown conditions as quickly as possible. If the waterlevel reaches 513 ft el., reactor cooldown is transferred to the Isolation Condensers,which thereafter maintain a safe shutdown condition until the flood waters recede andplant startup can be initiated.Minimum river water levels to assure pump suction are:* Circulating Water Pumps: 490 ft el." Service Water Pumps: 494 ft el." CCSW Pumps: 501 ft 6 in." Unit 2/3 Fire Pump: 498 ft 6 in.The low river water level threshold (501 ft. 6 in.) is based on the most limiting pumpsuction requirement (CCSW).Escalation of the emergency classification level would be based on ICs in RecognitionCategories R, F, M, H or C.Basis .Reference(s): ..... ........."1. NEI 99-01, Rev 6 HU32. DOA 0010-01 Dresden Lock and Dam Failure3. DOA 0010-04 Floods4. DOA 0010-02 Tornado Warning/Severe Winds5. DOA-0010-12, Toxic Gas/Chemical Release from Nearby Chemical FacilitiesMonth 20XXDR 3-154EP-AA-1 004 (Revision XX) | |||
AnnAxDlresden Annex Fva'inn Nmmr-IonrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a GENERAL EMERGENCY.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which involve actual or IMMINENT substantialcore degradation or melting with potential for loss of containment integrity or HOSTILEACTION that results in an actual loss of physical control of the facility. Releases can bereasonably expected to exceed EPA Protective Action Guideline exposure levels offsitefor more than the immediate site area.Basis:IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for aGeneral Emergency.Basis Reference(s):1. NEI 99-01, Rev 6 HG7Month 20XXDR 3-155EP-AA-1004 (Revision XX) | |||
Exelon NuclearDresden Annex Exelon NuclIearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a SITE AREA EMERGENCY.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which involve actual or likely major failures ofplant functions needed for protection of the public or HOSTILE ACTION that results inintentional damage or malicious acts, (1) toward site personnel or equipment that couldlead to the likely failure of or, (2) that prevent effective access to equipment needed forthe protection of the public. Any releases are not expected to result in exposure levelswhich exceed EPA Protective Action Guideline exposure levels beyond the siteboundary.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for a SiteArea Emergency.Basis Reference(s):1. NEI 99-01, Rev 6 HS7Month 20XXDR 3-156EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearDlresden Annex Exelnn Nuclea~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an ALERT Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Other conditions exist which, in the judgment of the Emergency Director, indicate thatevents are in progress or have occurred which involve an actual or potential substantialdegradation of the level of safety of the plant or a security event that involves probablelife threatening risk to site personnel or damage to site equipment because of HOSTILEACTION. Any releases are expected to be limited to small fractions of the EPAProtective Action Guideline exposure levels.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anAlert.Basis Reference(s):1. NEI 99-01, Rev 6 HA7Month 20XXDR 3-157EP-AA-1004 (Revision XX) | |||
IDri__dp~n AnnivDresden Annex Evainn N"rhmnrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an UNUSUAL EVENT.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which indicate a potential degradation of thelevel of safety of the plant or indicate a security threat to facility protection has beeninitiated. No releases of radioactive material requiring offsite response or monitoring areexpected unless further degradation of safety systems occurs.Basis:This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anUNUSUAL EVENT.Basis Reference(s):1. NEI 99-01, Rev 6 HU7Month 20XXDR 3-158EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYISFSI MALFUNCTIONSE-HU1Initiating ConditionDamage to a loaded cask CONFINEMENT BOUNDARY.Operating Mode Applicability:1,2,3,4,5, DEmergency Action Level (EAL):Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contactradiation reading:1. EAST HI-STAR:* > 160 mrem/hr (neutron + gamma) on the top of the OverpackOR0 > 250 mrem/hr (neutron+ gamma) on the side of the OverpackOR2. EAST HI-STORM:0 > 20 mrem/hr (neutron+ gamma) on the top of the OverpackOR* >100 mrem/hr (neutron+ gamma) on the side of the OverpackOR* > 45 mrem/hr (neutron+ gamma) at the inlet and outlet vent ducts of theOverpackOR3. WEST HI-STORM:* > 40 mremlhr (neutron+ gamma) on the top of the OverpackOR* >100 mrem/hr (neutron+ gamma) on the side of the Overpack, excluding inletand outlet ducts.Basis:CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) betweenareas containing radioactive substances and the environment.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) : A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.Month 20XX DR 3-159 EP-AA-1004 (Revision XX) | |||
Dresden AnnexExelon NuclearRECOGNITION CATEGORYISFSI MALFUNCTIONSE-HUI (cont).Basis (cont):This IC addresses an event that results in damage to the CONFINEMENT BOUNDARYof a storage cask containing spent fuel. It applies to irradiated fuel that is licensed fordry storage beginning at the point that the loaded storage cask is sealed. The wordcask, as used in this EAL, refers to the storage container in use at the site for drystorage of irradiated fuel. The issues of concern are the creation of a potential or actualrelease path to the environment, degradation of any fuel assemblies due toenvironmental factors, and configuration changes which could cause challenges inremoving the cask or fuel from storage.The existence of "damage" is determined by radiological survey. The technicalspecification multiple of "2 times", which is also used in Recognition Category R IC RU1,is used here to distinguish between non-emergency and emergency conditions. Theemphasis for this classification is the degradation in the level of safety of the spent fuelcask and not the magnitude of the associated dose or dose rate. It is recognized that inthe case of extreme damage to a loaded cask, the fact that the "on-contact" dose ratelimit is exceeded may be determined based on measurement of a dose rate at somedistance from the cask.Security-related events for ISFSls are covered under ICs HU1 and HAl.Basis Reference(s):1. NEI 99-01, Rev 6 E-HU12. Certificate of Compliance No. 1014 Appendix A, Section 5.7 (WEST HI-STORM)3. Certificate of Compliance No. 1014 Appendix A, Section 3.2.3 (EAST HI-STORM)4. Certificate of Compliance No. 1008 Appendix A, Amendment 2, Section 2.2.1(EAST HI-STAR)Month 20XXDR 3-160EP-AA-1004 (Revision XX)}} | |||
Revision as of 05:31, 28 June 2018
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Dresden Nuclearfresden Annex ExeIon NuclearwRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSU76Initiating Condition:Loss of all On-site or Off-site communications capabilities.Operating Mode Applicability:1,2,3Emergency Acton Level (EAL):1. Loss of ALL Table M3 Onsite communications capability affecting the ability toperform routine operations.OR2. Loss of ALL Table M3 Offsite communication capability affecting the ability toperform offsite notifications.OR3. Loss of ALL Table M3 NRC communication capability affecting the ability toperform NRC notifications.Table M3 Communications CapabilitySystem Onsite Offsite NRCPlant Radio XPlant Paae XSound Powered Phones XAll telephone Lines (Commercial and microwave) X X XCellular Phones X XENS X XHPN X XSatellite Phones X XF i I I
- mI f II w1. 6066 OT A66 of the followine onco communicav nion moetnoc:(cite-specifie Of communications method2 Less of ALL of the fallowinn ORQ Gemmuninations s) moetheds: -"" "3 ...............v wI ...........(c,*ite snocifi lirt ofcomnainsmtdsMonth 20XXDR 3-77EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS3. Lecs of ALL of the following NRC 1 OMMUniIatiens (cite specific list Of communications moethod&)Basis:This IC addresses a significant loss of on-site._-w-offsite, or NRC communicationscapabilities. While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs. and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 BasisaAddresses a total loss of the communications methods used in support of routine plantoperations.EAL #2 BasisaAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in procedure EP-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) Form. (see-Develope-Notes).EAL #3 BasisaAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, SU62. EP-MW-1 24-1001 Facilities Inventories and Equipment Tests3. UFSAR 9.5.24. DOA 0010-14 Loss of Off-Site Telephone Communication SystemsMonth 20XXDR 3-78EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCA12Initiating Condition:I Loss of all offsite and all onsite AC power to emergency bussesbuses for 15 minutes orlonger.Operating Mode Applicability:4,5, DEmergency Acton Level (EAL):Note:* The Emeraencv Director should declare the event nromntlv UDOn determinina thatthe applicable time has been exceeded, or will likely be exceeded.'=I'L A r%*- -A-- -t- .1-j 1--- AL- 61-ý -at. -J'A *-'-- A.L-A 4ýuC .TCUIL iuirtruiuu.~r i ~utuuiu. ur UUIIII1 ILýýn 1.-- ...!IE ~ -L.---mluit Has been ..ueeu.. , OFr Will 11...ly be ec..... .1. Loss of ALL offsite AC power to unit ECCS buses.AND2. Failure of DG 2(3). shared DG 2/3 and SBO DG 2(30 emeraencv dieselgenerators to supply power to unit EGGS buses.AND3. Failure to restore power to at least one unit EGGS bus in < 15 minutes from thetime of loss of both offsite and onsite AC power.Z AN I "-!. --ll Ak I 51 % M~I -- ----------- ... -L0C~ 01 ~LL OTTCI!0 ano :'.LL OflEliC :~L i-'owor 10 (SIlO SDOCITIC omoroancv DUCOCI IOU IDm:inuto or lnger.N r-1ý JBasis:SAFETY SYSTEM: A system reauired for safe plant operation, coolina down the plantand/or placing it in the cold shutdown condition, including the EGGS. These aretypically systems classified as safety-relatedThis IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergencycore cooling, containment heat removal/pressure control, spent fuel heat removal andthe ultimate heat sink.I When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas a Site Area Emergency because of the increased time available to restore anMonth 20XXDR 3-79EP-AA-1004 (Revision XX)
NuelAarfrAetden Annex Exelnn NucleasrRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSemergency bus to service. Additional time is available due to the reduced core decayheat load, and the lower temperatures and pressures in various plant systems. Thus,when in these modes, this condition represents an actual or potential substantialdegradation of the level of safety of the plant.I Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via IC CS61- or RAS1.Basis Reference(s):1. NEI 99-01 Rev 6, CA22. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 KV System and 345 KV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-147. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-1 2 Partial or Complete Loss of AC PowerMonth 20XXDR 3-80EP-AA-1004 (Revision XX)
AnnoyfrA-qd~fn Ann~x Exelnn Nucler~IRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCU12Initiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:4,5, DEmergency Acton Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.The Emoregcncy Director should declare the Unusual Event promptly upondeteminig that 15 mninutes has been exceeded, Or Will likely be exceeded.1. AC Power capability to unit ECCS buses reduced to only one of the following powersources for > 15 minutes." Reserve auxiliary Transformer TR-22 (TR-32)" Unit auxiliary transformer TR-21 (TR-31)* Unit Emergency Diesel Generator DG 2(3)" Shared Emergency Diesel Generator DG 2/3* Station Blackout Diesel Generator DG 2(3)" Unit crosstie breakersAND2. Any additional single power source failure will result in a loss of ALL AC power toSAFETY SYSTEMS.a. AC power capability to (sitespecific emer.gency buses) is reduced to a singlepower for 15 minutes or .ANDb. Any additional single pwer failure will result in loss of all A power t9SAFEII SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.Month 20XXDR 3-81EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSThis IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS. In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment.When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas an Alert because of the increased time available to restore another power source toservice. Additional time is available due to the reduced core decay heat load, and thelower temperatures and pressures in various plant systems. Thus, when in thesemodes, this condition is considered to be a potential degradation of the level of safety ofthe plant.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below.-A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).-A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator.-A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.The subsequent loss of the remaining single power source would escalate the event toan Alert in accordance with IC CA12.Basis Reference(s):1. NEI 99-01 Rev 6 CU22. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 KV System and 345 KV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout GeneratorTies to Plant Auxiliary Electric System7. UFSAR 9.5.9 Station Blackout System8. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-82EP-AA-1004 (Revision XX)
Dresden Nuclearfr= d=n Ann nv Ex vlon NuclearvIRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSMonth 20XXDR 3-83EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCA26Initiating Condition:I Hazardous event affecting SAFETY SYSTEM needed-required for the current operatingmode.Operating Mode Applicability:4,5Emergency Acton Level (EAL):1. a,. The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)" Internal or external flooding event" High winds or tornado strike" FIRE" EXPLOSION" (site sepoific hazards)" Other events with similar hazard characteristics as determined by theShift ManagerAND2.b. EITHER of the following:a.__,. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM needed required byTechnical Specifications for the current operating mode.ORb._2L. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure needed-required by TechnicalSpecifications for the current operating mode.Basis:FIRE: Combustion characterized by heat and liqht. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization. A release of steam (from hiqhenerqy lines or components) or an electrical component failure (caused by short circuits,grounding, arcing, etc.) should not automatically be considered an explosion. Suchevents may require a post-event inspection to determine if the attributes of an explosionare present.Month 20XXDR 3-84EP-AA-1004 (Revision XX)
AnnoyP:v-alnn im, rlarRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSSAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.VISIBLE DAMAGE: Damage to a component or structure that is readily observablewithout measurements, testing, or analysis. The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components, needed-required for the currentoperating mode, "required", i.e. required to be operable by Technical Specifications forthe current operating mode. This condition significantly reduces the margin to a loss orpotential loss of a fission product barrier, and therefore represents an actual or potentialsubstantial degradation of the level of safety of the plant. Manual or automatic electricalisolation of safety equipment due to flooding, in and of itself, does not constitutedegraded performance and is classified under HU6.EAL 41b7-#2.a Basis-aAddresses damage to a SAFETY SYSTEM train that is required to be operable byTechnical Specifications for the current operating mode, and is in SeF~4e perationsince indications for it will be readily available. The indications of degradedperformance should be significant enough to cause concern regarding the operability orreliability of the SAFETY SYSTEM train.EAL 4-42#2..b Basis-aAddresses damage to a SAFETY SYSTEM component that is required to be operableby Technical Specifications for the current operating mode, and is not inSeeive/operation or readily apparent through indications alone, or to a structurecontaining SAFETY SYSTEM components. Operators will make this determinationbased on the totality of available event and damage report information. This is intendedto be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC CS6-- or RAS1.If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):1. NEI 99-01 Rev 6, CA6Month 20XXDR 3-85EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCU34Initiating Condition:Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:4,5Emergency Acton Level (EAL):Note:= The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.The E.morgoncy Diroctor Should doc-laro the Unusual Event prom~ptly upondtrmnnthat 15 mninutos time has bcen exccoded, Or Will likely be oxceododVoltage is < 105 VDC on required 125 VDC battery buses #2 and #3for > 15 minutes.Indicated is loss than (site specific bus value) required \Vital DGbusos for 15 m inutes Or longor.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a loss of Vital DC power which compromises the ability to monitorand control operable SAFETY SYSTEMS when the plant is in the cold shutdown orrefueling mode. In these modes, the core decay heat load has been significantlyreduced, and coolant system temperatures and pressures are lower; these conditionsinefeaserise the time available to restore a vital DC bus to service. Thus, this conditionis considered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to supportoperation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.For example, if Train A is out-of-service (inoperable) for scheduled outage maintenancework and Train B is in-service (operable), then a loss of Vital DC power affecting Train Bwould require the declaration of an Unusual Event. A loss of Vital DC power to Train Awould not warrant an emergency classification.I Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Depending upon the event, escalation of the emergency classification level would be viaIC CA64- or CA53, or an IC in Recognition Category BA.Month 20XXDR 3-86EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSBasis Reference(s):1. NEI 99-01 Rev 6, CU42. UFSAR 8.3.2.2.1 Safety Related 125-V System3. DOA 6900-02(3) Failure of Unit 2(3) 125 VDC Power Supply4. Technical Specification Basis B.3.8.5, DC Power Sources -Shutdown5. Technical Specification Basis B.3.8.4, DC Power Sources -OperatingMonth 20XXDR 3-87EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCU4"Initiating Condition:Loss of all onsite or offsite communications capabilities.Operating Mode Applicability:4,5, DEmergency Acton Level (EAL):1. Loss of ALL Table C1 Onsite communications capabilitv affectinQ the abilitv toDerform routine oWerations.OR2. Loss of ALL Table Cl Offsite communication capability affecting the ability toperform offsite notifications.OR3. Loss of ALL Table C1 NRC communication capability affecting the ability toperform NRC notifications.TahkoIM (1 (nmmuini-atinne fon~ahilituSystem Onsite Offsite NRCPlant Radio XPlant Page XSound Powered Phones XAll telephone Lines (Commercial and microwave) X X XCellular Phones X XENS X XHPN X XSatellite Phones X X5 .~ ~. ~ %~. SB *~ S ~I5~*U*I B------- J[ I-- -- --I -- -(i-6te coec-Gific list Of communications mnethods)I l iI I I IVi 2. Loss of ALL Of the folloWing ORO communications methods:(cite-ssccfic list Of communications mnethods)Month 20XXDR 3-88EP-AA-1 004 (Revision XX)
AnnexI=xolon fresden Annex Exellon Nuclea~rRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONS3. Lss- of ALL of the NRC ormmuni.ations methods(siteo Sp icl St Of cO',n'Rammu-nic'.0,-ations moI,' lthed)Basis:This IC addresses a significant loss of on-site_-er-offsite, or NRC communicationscapabilities. While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 BasisaAddresses a total loss of the communications methods used in support of routine plantoperations.EAL #2 BasisaAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in procedure EP-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) Formkseer. .. .,.Netes.EAL #3 BasisaAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, CU52. EP-MW-1 24-1001 Facilities Inventories and Equipment Tests3. UFSAR 9.5.24. DOA 0010-14 Loss of Off-Site Telephone Communication SystemsMonth 20XXDR 3-89EP-AA-1004 (Revision XX)
Exelon NuclearDresden Annex Eeo ulaRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCA53Initiating Condition:Inability to maintain the plant in cold shutdown.Operating Mode Applicability:4,5Emergency Acton Level (EAL):Note:e The Emergency Director should declare the event promptly upon determining thatthe apolicable time has been exceeded. or will likely be exceeded.rL... I~.ii=- =I-z ýIIiui t Liu i 1Iu~ 1 ~ t 1i. :.:u.zu -: .............. ....the a,"li,,able imo has beon .....d.d, or will likely oX.eedod.UNPLANNED rise in RCS temperature > 212°F due to loss of decay heat removal for >Table C2 duration.Table C2 RCS Heat-up Duration ThresholdsRCS Containment Closure Heat-upStatus Status DurationIntact Not Applicable 60 minutes*Not Intact Established 20 minutes*Not Established 0 minutes* If an RCS heat removal system is in operation withinthis time frame and RCS temperature is beina reduced,then EAL #1 is not applicable.OR2. UNPLANNED RPV pressure rise > 10 psig as a result of temperature rise due toloss of decay heat removal.1. UNPLANNED ir- cre-e in RCS tmprater, to greater than Q ^^fifm.ýa~ tI%! ý- "p~, ko Arlptin~, *P~nrP pratIi UI if fP1 nnte fh n +6^duration specified in the fGollIin table.Lm m Lm ....... I "--" Month 20XXDR 3-90EP-AA-1004 (Revision XX) rmafltun AnnovFvtulnn ":,AaarfDlrne I tln II nnvp FA~rVI I. mIaVI~pRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSTable: RCS HMoat-Up Durtation Throohol,RCS Status Containment Clocure Heat-up DuratiOnStatusreduced inyentoy No i 6- Iil utNot intact (r Oat reduced Ebloh, 20, *iwente-fPi [R") Not E ;stabli Fhd
- If an RCS heat removal 6ystemn is in operation within this time frameand RCS temperature is bein~g reduced, the EAL is not applicable..~J 1] LPd'.'r.~t~IJ iiii'- nro~uro incro~e aroa~nr man miTo ~nncmc orn~surn '.-~ -~w.v~.~plirrýi _15-t ý1- Al Ae ~~ i..rr a~~r'~alr~~w.w......... 0ý ...... ........[PKRJ)lBasis:UNPLANNED: A parameter chanae or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment (primary or secondary) and its associated structures, systems, andcomponents as a functional barrier to fission product release under shutdownconditions.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.a. no freeze seals, or steam line nozzle Dluas. etc.).This IC addresses conditions involving a loss of decay heat removal capability or anaddition of heat to the RCS in excess of that which can currently be removed. Eithercondition represents an actual or potential substantial degradation of the level of safetyof the plant.A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.The RCS Heat-up Duration Thresholds table addresses an iRe-easerise in RCStemperature when CONTAINMENT CLOSURE is established but the RCS is not intact._iOr RCS in'...ent,; (e.g., mid-loop operation in PWRs). The 20-minuteMonth 20XXDR 3-91EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONScriterion was included to allow time for operator action to address the temperatureiris___nse.The RCS Heat-up Duration Thresholds table also addresses an inr, eeaserise in RCStemperature with the RCS intact. The status of CONTAINMENT CLOSURE is notcrucial in this condition since the intact RCS is providing a high pressure barrier to afission product release. The 60-minute time frame should allow sufficient time toaddress the temperature i..reaserise without a substantial degradation in plant safety.Finally, in the case where there is an in RCS temperature, the RCS is notintact Or is at ..d..d inv.nt..y [P-VrI, and CONTAINMENT CLOSURE is notestablished, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) theevaporated reactor coolant may be released directly into the Containment atmosphereand subsequently to the environment, and 2) there is reduced reactor coolant inventoryabove the top of irradiated fuel.EAL #2 provides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS6 or RAS1.Basis Reference(s):1. NEI 99-01 Rev 6, CA32. Technical Specifications 3.6.1.13. Technical Specifications 3.6.4.14. OU-AA-103 Shutdown Safety Management Program5. DGP 02-01 Unit Shutdown6. DOA 0201-04 Loss of Vessel Flange, Shell, or Recirculation (Recirc) LoopTemperature Recorders During Heatup or Cooldown7. DGP 02-02 Reactor Vessel Slow Fill8. DIS 0263-19 Reactor Wide Range Pressure Transmitter Calibration Eq.Maintenance InspectionMonth 20XXDR 3-92EP-AA-1 004 (Revision XX)
Nuclearflmsden Annex FvieInn Nucler!IRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSInitiating Condition:UNPLANNED ieeaee in RCS temperatureOperating Mode Applicability:4,5Emergency Acton Level (EAL):Note:CU53* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.The EmergncRy the Unusual Event promptly upon determiningthat 15 m*inutes has boon eXceeded, Or Will likely be exced.d.1. UNPLANNED rise in RCS temperature > 212°F due to loss of decay heatremoval.OR2. Loss of the following for > 15 minutes.* ALL RCS temperature indicationsAND* ALL RPV water level indications1. UNPLA.NNED increasorise in RCS temperatu to greater than (cite specificTechnical Spciiato cod hu-tdown%~f temper-ature limit).22. Losss of ALL RCS t9emperature and reactor vossoL'RCS level indic-atioen for 15mninutes or longer.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchanae or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment (primary or secondary) and its associated structures, systems, andcomponents as a functional barrier to fission product release under shutdownconditions.Month 20XXDR 3-93EP-AA-1004 (Revision XX)
AnnoyI:xAIon frawign Anniax Exelnn NuleIasrRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSI This IC addresses an UNPLANNED ineFeaserise in RCS temperature above theTechnical Specification cold shutdown temperature limit, or the inability to determineRCS temperature and level, represents a potential degradation of the level of safety ofthe plant. If the RCS is not intact and CONTAINMENT CLOSURE is not establishedduring this event, the Emergency Director should also refer to IC CA53.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs. etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.EAL #1 involves a loss of decay heat removal capability, or an addition of heat to theRCS in excess of that which can currently be removed, such that reactor coolanttemperature cannot be maintained below the cold shutdown temperature limit specifiedin Technical Specifications. During this condition, there is no immediate threat of fueldamage because the core decay heat load has been reduced since the cessation ofpower operation.During an outage, the level in the reactor vessel will normally be maintained above thereactor vessel flange. Refueling evolutions that lower water level below the reactorvessel flange are carefully planned and controlled. A loss of forced decay heat removalat reduced inventory may result in a rapid iGireaserise in reactor coolant temperaturedepending on the time after shutdown.EAL #2 reflects a condition where there has been a significant loss of instrumentationcapability necessary to monitor RCS conditions and operators would be unable tomonitor key parameters necessary to assure core decay heat removal. During thiscondition, there is no immediate threat of fuel damage because the core decay heatload has been reduced since the cessation of power operation.I Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.I Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA53 basedon exceeding plant configuration-specific time criteria.Month 20XXDR 3-94EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSBasis Reference(s):1. NEI 99-01 Rev 6, CU32. Technical Specifications Table 1.1-13. DGP 02-01 UNIT SHUTDOWN4. DOA 0201-04, Loss of Vessel Flange, Shell, or Recirculation (Recirc) LoopTemperature Recorders During Heatup or Cooldown5. DGP 02-02 Reactor Vessel Slow Fill6. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines7. DEOP 100 RPV Control, Table A8. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level InstrumentationMonth 20XXDR 3-95EP-AA-1004 (Revision XX)
Annoyflmsden Annex Exelon NucleI~arRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCG6-Initiating Condition:Loss of RPV inventory affecting fuel clad integrity with containment challenged.Operating Mode Applicability:4,5Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.The Emcrgoncy DircctOr should dcclare- tho Goncral EmorgoncY promnptly upondotrmiRRng that 30 miRutes has be,, or will likely be vcdod.,1. a. RPV water level < -143 inches (TAF) for > 30 minutes.ANDb. Any Containment Challenge Indication (Table 04)OR2. a. RPV water level unknown for > 30 minutes.ANDb. Core uncovery is indicated by any of the following:* Table C3 indications of a sufficient magnitude to indicate coreuncovery.OR" Refuel Floor Hi Range ARM >3000 mR/hr.ANDc. Any Containment Challenge Indication (Table 04)Table C3 Indications of RCS Leakaqe" UNPLANNED floor or equipment sump level rise*" UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise" Observation of leakage or inventory lossMonth 20XXDR 3-96EP-AA-1004 (Revision XX)
Dresden AnnexI::xelon NuclearDresdn Annex iYlAorn NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONS*Rise in level is attributed to a loss in RPV inventory.Table C4 Containment Challen-ce Indications* Primary Containment Hydrogen Concentration > 6% and Oxvqen > 5%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established** Any Secondary Containment radiation monitor > DEOP 300-1 MaximumSafe operating level.* if CONTAINMENT CLOSURE is re-established prior to exceedina the 30-minutecore uncovery time limit, then escalation to a General Emergency is not required.1 .a. (Reactor uvossoVRCS level loss than (sito spocifi levol) for 30 minutes OFlonger.ANDb. ANY indiction fromn the Conta.nment Challenge Table (seo below).2. a. Reactnor ......oelnRCS level cannot be mon-,itoed for 30 minutes Or Ionger.IAN1b. Core uncovery is indicated by ANY of the following:-f oLLL Ojl.'kl ^ "ýta zttaf. flflfllrLJ1 ranaltSII b tial \O1L v 'L A
- v AA- 4F.1 5 511 F* Effatte SOUrree Fafige MORHOF tBut6ittIORD f J .m .1 %e U.NPLANNEDhI inerease int (ste specitic sume anE.or- tank) levels of sut~icient(Other Site speeific indicationRs)Month~~~~~~D 3-9E7A- 04(eiso XMonth 20XXEP-AA-1004 (Revision XX)
Dresden Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING MALFUNCTIONSAMDG. n ication fr o-m tho Colntaimeent t. Ch a lle e T abl1,e (s e .e ContainmInt Challng1 TabJlCONTAINMENT CLOSURE not establishedt(Explosive miAr'Ie) e1ists inside containmentUNPLANNED increase in eentainment pr-essufe*If CONTAINMVENT CLOSURE is ro cetablishod p~Or to eXceeding the 30 minute timeBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment (primary or secondary for BWR) and its associated structures,systems, and components as a functional barrier to fission product release undershutdown conditions.This IC addresses the inability to restore and maintain reactor vessel level above thetop of active fuel with containment challenged. This condition represents actual orIMMINENT substantial core degradation or melting with potential for loss of containmentintegrity. Releases can be reasonably expected to exceed EPA Protective ActionGuidelines (PAGI exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a directand unmonitored release of radioactivity to the environment. If CONTAINMENTCLOSURE is re-established prior to exceeding the 30-minute time limit, then declarationof a General Emergency is not required.The existence of an explosive mixture means, at a minimum, that the containmentatmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity. Ittherefore represents a challenge to Containment integrity.Month 20XXDR 3-98EP-AA-1 004 (Revision XX)
Dresden AnnexExellon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSIn the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to acore uncovery could result in an explosive gas mixture in containment. If all installedhydrogen gas monitors are out-of-service during an event leading to fuel claddingdamage, it may not be possible to obtain a containment hydrogen gas concentrationreading as ambient conditions within the containment will preclude personnel access.During periods when installed containment hydrogen gas monitors are out-of-service,operators may use the other listed indications to assess whether or not containment ischallenged.bi:-EAL 2-b#1 Basis,-Ihe 30-minute criterion is tied to a readily recognizable event start time (i.e., the totalloss of ability to monitor level), and allows sufficient time to monitor, assess andcorrelate reactor and plant conditions to determine if core uncovery has actuallyoccurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor RPV-IeveIRPV water level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the RPV.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Basis Reference(s):1. NEI 99-01 Rev 6, CG12. DEOP 0100-00 RPV Control3. Technical Specifications 3.3.1.24. DOS 0700-01 SRM Functional Test5. DAN 902(3)-5 E-4 SRM Short Period6. DEOP 0200-01 Primary Containment Control7. DEOP 0200-02 Hydrogen Control8. DEOP 0300-01 Secondary Containment Control9. USAR Table 6.2-110. EP-EAL-0501Month 20XXDR 3-99EP-AA-1004 (Revision XX)
Nuel@Arfres~den Annex ExAelon NucleanrRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSInitiating Condition:Loss of RPV inventory affecting core decay heat removal capability.Operating Mode Applicability:4,5Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.The Em;ergency D~irector should declare the Site Aroa EmergencGy promptly upondetWmining that 30 minutes has been esaieded, or will likely be e 6ecdesd.1. With CONTAINMENT CLOSURE not established, RPV water level < -60 inchesOR2. With CONTAINMENT CLOSURE established. RPV water level < -143 inches(TAF)* OR3. a. RPV water level unknown for > 30 minutesANDb. Core uncovery is indicated by any of the following:* Table C3 indications of a sufficient magnitude to indicate core uncovery.OR" Refueling Floor Hi Range ARM >3000 mR/hr.Table C3 Indications of RCS Leaka e" UNPLANNED floor or eguipment sump level rise** UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss in RPV inventory..a. CONTAINMENT CLOSURE not established.Month 20XXDR 3-100EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSm. (Rai r- Ve s E O L'rRCI fe~ I 1 or N P-1r.' ~ v i lovel0- ioAP mAA F An n o D0 icV --L ..... 3l ll l l;j. a. GGurT INP~ MENJ "LUO U11P esiaDi~sna.AANDLlit __ __ __JL _ _,IE-~,%f. rr~IiIrYI ~ I rFtArwI~ ,~, *. .U. I.!A..19. i-earior voesevmriu5 :I'e Jr or F --' Pd J IP5 level less than ske-eP e f G e ert __ lit __ __ __JL,, n r ,.. r wln ,ý % r 1 %6A ffA- iI I.. I.. .. L .. -1. .1 ..-^ ^vr-- z a =CV12 f-- a =- ý.. zf2z' 2minutes or longer.ANMI i IRID f IB fm Ab. 6 Q Fel-'AGoyew 16 'AG11Ga;eei PY A
- OT tne T9110MAW!e (Site sneeifie r-adiatieft foeniter-) madine ffeater- than (site seeeifie v-V--+,- , ---rDIXIDIt J .1%* UNPLANNED iftervase ia ýsite sf amVer- tafwj ieveis of suffietentmagnitude to indieate eafe uneever-ye (Other- site speeifie indieations)ABasis:CONTAINMENT CLOSURE: The Procedurally defined conditions or actions taken tosecure containment (prima!y or seconda!y for BWR) and its associated structures,§ystems, and components as a functional barrier to fission product release undershutdown conditions.UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parametechange or event may be known or unknown.This lG addFesser, a signifiGant and pmlenged loss of RPV inventeFy Gentrel andFnakeUp Gapabolity leading to 1MMINENT fuel damage. The lost inventory may be due toa RCS component failure, a loss of configuration control or prolonged boiling of reactorcoolant. These conditions entail major failures of plant functions needed for protectionof the public and thus warrant a Site Area Emergency declaration.I Following an extended loss of core decay heat removal and inventory makeup, decayMonth 20XXDR 3-101EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.Outage/shutdown contingency plans typically provide for re-establishing or verifyingCONTAINMENT CLOSURE following a loss of heat removal or RCS inventory controlfunctions. The difference in the specified RCS/reactor vessel levels of EALs 1 .b and 2.breflect the fact that with CONTAINMENT CLOSURE established, there is a lowerprobability of a fission product release to the environment.In EAL #3.a, the 30-minute criterion is tied to a readily recognizable event start time(i.e., the total loss of ability to monitor level), and allows sufficient time to monitor,assess and correlate reactor and plant conditions to determine if core uncovery hasactually occurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor RPV-levelRPV water level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the RPV.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Escalation of the emergency classification level would be via IC CG1-6 or ARGI.Basis Reference(s):1. NEI 99-01 Rev 6, CS12. Technical Specifications Table 3.3.5.1 13. UFSAR 5.2.54. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines5. DEOP 0100-00 RPV Control6. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log7. DAN 902(3)-4 A-17 rywetlDrywell Equip Sump Lvl HI-HI8. DAN 902(3)-4 H-18 D Dywe~lrywell Floor Drn Sump Lvl HI-HI9. DOA 0040-01 Slow Leak10. DOP 2000-24 r..ywe. .rywel, Sump OperationMonth 20XXDR 3-102EP-AA-1004 (Revision XX)
Exelon NuclearDresden Annex Eeo ulaRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONS11. Technical Specifications 3.3.1.212 DOS 0700-01 SRM Functional Test13. DAN 902(3)-5 E-4 SRM Short PeriodMonth 20XXDR 3-103EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCA64-Initiating Condition:Loss of RPV inventory.Operating Mode Applicability:4,5Emergency Acton Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.I E A B nThnneimenrrirFnr" nmrtnr itniu nnie the~ Alert nrnmm.' iinon Ennmimnine tha~t.4 Crvn inta+ kn knn 14,nnjr Ar H! Mes'n! ka a 1na4r -.-~, ~ .....a. Loss of RPV inventory as indicated by level < -54 inches.OR1. a. RPV water level unknown for > 15 minutes.ANDb. Loss of RPV inventory per Table C3 indications.Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise*" UNPLANNED Torus level rise*" UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss in RPV inventory.I4 ----A-. .i.ý re _ ..1_ 1__1 I --LL___ /-.'.L- __ _=level),drJ2. a. Reactor sVeVeVVVR level cannot be moFnitored 9fo 15 m nuto or longerANDL I IklIPJ'tl A !_=I av! -11 IA I I ý__D uL.W'IIIW inrn-AwI MINNT MDCI! Eum ==I~o awlK I6VCIEo~z OUZ0a-------- ----V -- --V beSS nO reacrtonr yosccvt9iV 6 inVeniorV.Month 20XXDR 3-104EP-AA-1004 (Revision XX)
I::xAInn fresfd.en Annex Exelon Nucler~IRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.IC addresses conditions that are precursors to a loss of the ability toadequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier).This condition represents a potential substantial reduction in the level of plant safety.F-r-EAL #1 Basis--a lowering of water level below -54 inches (site cpo.ific le'.'el) indicates that operatoractions have not been successful in restoring and maintaining RPV water level. Theheat-up rate of the coolant will iPAeaserise as the available water inventory is reduced.A continuing deGiease rop in water level will lead to core uncovery.Although related, EAL #1 is concerned with the loss of RCS inventory and not thepotential concurrent effects on systems needed for decay heat removal (e.g., loss of aResidual Heat Removal suction point). AA ieieaeerise in RCS temperature caused bya loss of decay heat removal capability is evaluated under IC CA53.Fer-EAL #2 Basis,-tThe inability to monitor RPV-IeveIRPV water level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the RPV.The 15-minute duration for the loss of level indication was chosen because it is half ofthe EAL duration specified in IC CS64-If the RPV inentwy water level continues to lower, then escalation to Site AreaEmergency would be via IC CS6-1-.Basis Reference(s):1. NEI 99-01 Rev 6, CA12. USAR 5.2.5, Detection of Leakage through Reactor Coolant Pressure Boundary3. Technical Specification 3.3.5.1, Emergency Core Cooling System (ECCS)Instrumentation4. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines5. DEOP 100 RPV ControlMonth 20XXDR 3-105EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING MALFUNCTIONS6. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log7. DAN 902(3)-4 A-17 D~ywellDrywell Equip Sump Lvl HI-HI8. DAN 902(3)-4 H-18 Dyweg#Drywell Floor Drn Sump Lvl HI-HI9. DOA 0040-01 Slow Leak10. DOP 2000-24 Diywe#Drywell Sump OperationMonth 20XXDR 3-106EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSCU61-Initiating Condition:UNPLANNED loss of RPV inventory for 15 minutes or longer.Operating Mode Applicability:4,5Emergency Acton Level (EAL):Note:9 The Emerqency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Trkmf Cmmvrt~ F-linn,4r~ ,ehidA AI, 1 *hk H 1r C' n+I r" r ~i,^1 % i r I I EV m*k.,, 4 mn..* ksr kna A.,nnr r *fH! !lu6k! knA A~ ~ ~ ~ t wwr ln wc v , Orl IyV V I7 VV llV V V V I!11Il VI =7w= ý .V 1. UNPLANNED loss of reactor coolant results in the inability to restore andmaintain RPV water level above the procedurally established lower limit for >15 minutes.OR2. a. RPV water level unknownANDb. Loss of RPV inventory per Table C3 indications.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss in RPV inventory.I lr'l k &1ýIP I-. .__ ....I ---__ IL .... J _ " ...... 1 I2 A -r %, ,;rr In.,,nr lran ; f r 1 iZ ,y% n fir Innrmn r0 D n.~n+nr ~,nt.enl IDt' Q mi In I ~ ri nn* ha mrir~i*r.rnAANDk I IKIDI AKIKIM r ;r^ ;n .msr" ^ntr4/ar *-AnIAIael~Month 20XX1row glDR 3-107vm EP-AA-1004 (Revision XX)
Dregden Annexfresden Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the Parameterchange or event may be known or unknown.This IC addresses the inability to restore and maintain water level to a requiredminimum level (or the lower limit of a level band), or a loss of the ability to monitor RPVIeveIRPV water level concurrent with indications of coolant leakage. Either of theseconditions is considered to be a potential degradation of the level of safety of the plant.The procedurally established lower limit is not an operational band established abovethe procedural limit to allow for operator action prior to exceeding the procedural limit,but it is the procedurally established lower limit.Refueling evolutions that deGreaselower RCS water inventory are carefully planned andcontrolled. An UNPLANNED event that results in water level decreasing below aprocedurally required limit warrants the declaration of an Unusual Event due to thereduced water inventory that is available to keep the core covered.EAL #1 BasisiRecognizes that the minimum required RPV-leveIRPV water level can change severaltimes during the course of a refueling outage as different plant configurations andsystem lineups are implemented. This EAL is met if the minimum level, specified for thecurrent plant conditions, cannot be maintained for 15 minutes or longer. The minimumlevel is typically specified in the applicable operating procedure but may be specified inanother controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions torestore and maintain the expected water level. This criterion excludes transientconditions causing a brief lowering of water level.EAL #2 BasisaAddresses a condition where all means to determine RP-V-IeleIRPV water level havebeen lost. In this condition, operators may determine that an inventory loss is occurringby observing changes in sump and/or tank levels. Sump and/or tank level changesmust be evaluated against other potential sources of water flow to ensure they areindicative of leakage from the RPV.Continued loss of RCS inventory may result in escalation to the Alert emergencyclassification level via either IC CA6 or CA53.Month 20XXDR 3-108EP-AA-1004 (Revision XX)I Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING MALFUNCTIONSBasis Reference(s):1. NEI 99-01, Rev. 6 CUl2. USAR 5.2.5, Detection of Leakage through Reactor Coolant Pressure Boundary3. Technical Specifications 3.4.44. Technical Specifications 3.4.55. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log6. DAN 902(3)-4 A-17 DiyweUDrywell Equip Sump Lvi HI-HI7. DAN 902(3)-4 H-18 Dlywel4Drywell Floor Drn Sump Lvl HI-HI8. DOA 0040-01 Slow Leak9. DOP 2000-24 .Sump Operation10. DGP 02-02 Reactor Vessel Slow Fill11. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines12. DEOP 0100-00 RPV Control, Table A13. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level Instrumentation14. Technical Specifications Table 3.3.5.1 1Month 20XXDR 3-109EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1Initiating Condition:HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):1. A notification from the Security Force that a HOSTILE ACTION is occurring orhas occurred within the PROTECTED AREA.AND2. a. ANY Table H1 safety function cannot be controlled or maintained.ORb. Damage to spent fuel has occurred or is IMMINENTTable H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)A Unf 1CTII r ArTTIrnIM ;o r,, e ,mrnrr, err kn r~,^i irrrer4 t&,ifhki r kr DDn, TIT[=I-AREA as e,,povd by the (,it. \ p.,ifi hift ,up""' ii")...ANIDk C11ruc f +k f i! i k^A-%7 v %. .....rig..L I ,o r..... .I. L .... Jl.==ll--.J --=4. ANi of the roitowing safety; WRUnionc cannot Be GGnroIF onaRtaRed-7* Reactivity controel0 enar ennlinnWW UTRPV PP' ef level~ 03"1 WUP9 RCS heat removal-. -,OR, -*- IL AllI, ll"J r~96.amage te speRt fuel riaS 9cUrUUFFd OF IS 1MM1ivir=r1I.Month 20XXDR 3-110EP-AA-1004 (Revision XX)
Oresden AnnexN.r-lAarDresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy eguipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.IMMINENT: The traiectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE FORCE: Any individuals who are engaaed in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.This IC addresses an event in which a HOSTILE FORCE has taken physical control ofthe facility to the extent that the plant staff can no longer operate equipment necessaryto maintain key safety functions. It also addresses a HOSTILE ACTION leading to aloss of physical control that results in actual or IMMINENT damage to spent fuel due to1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls,etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot bemaintained.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].EFm=eFrgny plans and implementing pro edures are public documents; EALss~hould no incorporat SecuiySenitiVe nomain This includos information thatmay be advantageu toaptntial adversary, such as the particulars concerning a-mu~~~~~~~~~~~ .~i .i .1: .~i .i .iu~ ..t i .i .t .r : .: .Iu .I .~u ..~ .~ ..1-Month 20XXDR 3-111EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYcontained on non public documen8t6 such as the Security Plan.Basis Reference(s):1. NEI 99-01, Rev. 6 HG15. Station Security Plan -Appendix CMonth 20XXDR 3-112EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS1Initiating Condition:HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.1. A HOSTILE ACTION ic occurring Or hac occrroF~d within tho PRO--GTECTEDAPREA acroportod by the (site-spccifiG cocrit hiftspcr:wisn).Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTEDAREA. This event will require rapid response and assistance due to the possibility fordamage to plant equipment.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Month 20XXDR 3-113EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYSecurity plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Site Area Emergency declaration will mobilize OROresources and have them available to develop and implement public protective actionsin the unlikely event that the attack is successful in impairing multiple safety functions.This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTEDAREA located outside the plant PROTECTED AREA; such an attack should beassessed using IC HA1. It also does not apply to incidents that are accidental events,acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by aHOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters,physical disputes between employees, etc. Reporting of these types of events isadequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR§ 50.72.Emorgoncy plans and implmerneting prOcodures arc public documents; theroforo, E=ALs-should not incorporae Security sencitivo nomain This inldsifrainthat_ay be advantageour, to a potenial adversaFy, such as the paticularS concerning aspecific throat Or throat location. Security-sensitive information should be contained inEscalation of the emergency classification level would be via IC HG1.Basis Reference(s):1. NEI 99-01 Rev 6, HS13. Station Security Plan -Appendix CMonth 20XXDR 3-114EP-AA-1004 (Revision XX) fl ma t4n Anniav=:vimlnn Kii,^lg--rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA1Initiating Condition:HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threatwithin 30 minutes.Operating Mode Applicability:1, 2,3,4,5, DEmergency Acton Level (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutes fromthe site.1. A HOST-ILE ACTION is cccufrring er has eccurred within the OWNEROR2. Notification by the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the OWNER CONTROLED AREA.A validatod rntificao-n ARfrom IRc , of an oircraft attack within 30 mnut ofthe steBasis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy eguipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An oboect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.OWNER CONTROLLED AREA (OCA): The property associated with the station andowned by the company. Access is normally limited to persons entering for officialbusiness.Month 20XXDR 3-115EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYPROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.This IC addresses the occurrence of a HOSTILE ACTION within the OWNERCONTROLLED AREA or notification of an aircraft attack threat. This event will requirerapid response and assistance due to the possibility of the attack progressing to thePROTECTED AREA, or the need to prepare the plant and staff for a potential aircraftimpact.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Alert declaration will also heighten the awareness ofOffsite Response Organizations, allowing them to be better prepared should it benecessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience,or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputesbetween employees, etc. Reporting of these types of events is adequately addressedby other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL 2 #1 BasisAaddresses the threat from the impact of an aircraft on the plant, and the anticipatedarrival time is within 30 minutes. The intent of this EAL is to ensure that threat-relatednotifications are made in a timely manner so that plant personnel and OROs are in aheightened state of readiness. This EAL is met when the threat-related information hasbeen validated in accordance with DOA 0010-18, Escalated Security Event/HostileForce Intrusio pr-edure)h.EAL #2 Basis4--4s applicable for any HOSTILE ACTION occurring, or that has occurred, in theOWNER CONTROLLED AREA. This includes any action directed against an ISFSI thatis located outside the plant PROTECTED AREA.Month 20XXDR 3-116EP-AA-1004 (Revision XX)
Dresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYEAL #2 addresses the threat 4rom the impact of an aircraft on the plant, and theanticipated arrival tome is within 30 mninutoc. The intent of this EAL is to onsuro thathroat-rolatoed notfific-ations arc mnade in a timely manner SO that plant personnel andare in a heightened st.e, Of readiness. This E..L is. Uet whe n the has heen validated in %Ajfk,; fft- r^^,ft4,,infII
- n mULISH nThe NRC Headquarters Operations Officer (HOO) will communicate to the licensee ifthe threat involves an aircraft. The status and size of the plane may be provided byNORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNERCONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected,although not certain, that notification by an appropriate Federal agency to the site wouldclarify this point. In this case, the appropriate federal agency is intended to be NORAD,FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs,should not be unduly delayed while awaiting notification by a Federal agency.plans and implementing proedures are pu .blic EAI.sshould- not incorpoate Security scncitive information. This includes information thatma" be advantageou toapoetial adversary, SUch as the particulars concrnig asp9cific throat Or threat locatýion. Security sensitiye information should be contained innon public documents such as the Security Plan.Escalation of the emergency classification level would be via IC HS1.Basis Reference(s):1. NEI 99-01 Rev 6, HA12. Station Security Plan -Appendix C3. DOA 0010-18, Escalated Security Event/Hostile Force IntrusionMonth 20XXDR 3-117EP-AA-1004 (Revision XX)
Dresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU1Initiating Condition:Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):* Notification of a credible security threat directed at the site as determined perSY-AA-1 01-132, Security Assessment and Response to Unusual Activities.p A SECURITY CONDITION that does not inv..olve a H.STILE ACTION as r-eported bthe (site spenific security shift superCrisicn).OR" A validated notification from the NRC providing information of an aircraft threat." Notification of a credible security threat directed at the site.OR" Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.*A notific-ation fromn the NRG proViding infO.r.mAtion of an throat.Basis:SECURITY CONDITION: Any Security Event as listed in the approved securitycontingency plan that constitutes a threat/compromise to site security, threat/risk to sitepersonnel, or a potential degradation to the level of safely of the plant. A SECURITYCONDITION does not involve a HOSTILE ACTIONSAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.Month 20XXDR 3-118EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYPROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEMequipment, and thus represent a potential degradation in the level of plant safety.Security events which do not meet one of these EALs are adequately addressed by therequirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed asHOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Classification of these events will initiate appropriate threat-related notifications to plantpersonnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 BasisAddresses the receipt of a credible security threat. The credibility of the threat isassessed in accordance with SY-AA-101-132. -rfor.n.... ('ito ..p.eifi. c:u..ty chift,up,.-,e;.) bo.a-, o th.-o,- --r tho -I,-,-;_. tr-in; d to -onfirm that a' ,-,u, it;, o'.' 4 i.urinEAL #2 BasisaAddresses the threat from the impact of an aircraft on the plant. The NRCHeadquarters Operations Officer (HOO) will communicate to the licensee if the threatinvolves an aircraft. The status and size of the plane may also be provided by NORADthrouah the NRC. Validation of the threat is Derformed in accordance with DOA 0010-_ ....... I ..... \ -- --its tzscaiaiea ,:ecuriiy -venuriosiiie r-orce inirusiontsi'e spgf--adreses....... J1110 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~~i aOlTO ronnscsi'. noT In rafhITJO fDira E PCesseg in---------. -accodanc wit (cie e~eific roceedure).EAL #3 Basis"i I "tlf ererences Securiwy -orcmf',ds MG :ssurtey GR.- 6Upe"-f%"o -Decause tnese arethe individuals trained to confirm that a securitv event is occurring or has occurred.Training on security event confirmation and classification is controlled due to the natureof Safeguards and 10 CFR § 2.39 information.. th thr"ot from tho impa.t ofan irrarft on tho plant. Tho hNrC Hoadguartora Oporotinnc Officer (HOD) Ilcemmunipto to tho 4ioncoo- if tho throat nolocanaircrft. Th -ot -~tc and cizto of therilao ma.' aco b Dre.'idd hi: hnORA. throahci thci NC. 11alidation of the thr-oatiV.70p. ..ermod in a.crdnc ...... \c procedure)Month 20XXDR 3-119EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYEmergency plans and imlmnigprOceduroc arc pu blic documonts; therefore, EAI~sshould not increporate Security-sensitk'c information. T-hic inclu-doc- inforFmation thatmay be advantageous to a potential advcrsar,', such as the patiGiulaFGRG cocrin a.pecific threat or threat l.,atie,. Security sensitive info. ..ation should bo containedinnon public documentS such as the Security Plan.Escalation of the emergency classification level would be via IC HA1.Basis Reference(s):1. NEI 99-01 Rev 6, HU12. SY-AA-1 01-132, Security Assessment and Response to Unusual Activities3. Station Security Plan -Appendix C4. NRC Safeguards Advisory 10/6/015. Letter from Mr. B. A. Boger (NRC) to Ms. Lynette Hendricks (NEI) dated 2/4/026. DOA 0010-18, Escalated Security Event/Hostile Force IntrusionMonth 20XXDR 3-120EP-AA-1 004 (Revision XX)
Dresden AnnexExalon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS26Initiating Condition:Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:1,2, 3, 4,5, DEmergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.The E.mergency Diroctor Ashould docnlaare the Site Area EmFergencyoVent prom~ptly Upondetemining that (site-specific number of minutes) has boon oXcoodod, Or willlikely be Xexededd.1. A Control Room eacuation has resulted in plant control being transferred from theControl Room to alternate locations per DSSP 0100-CR. Hot Shutdown Procedure-Control Room Evacuation.AND2. Control of ANY Table Hi key safety function is not reestablished in < 30 minutes.Table Hi Safety Functions" Reactivity Control (ability to shut down the reactor and keep it shutdown)" RPV Water Level (ability to cool the core)" RCS Heat Removal (ability to maintain heat sink)1. a. An ovcnt has resulted in plant control being transferred panels and localcontrol stations). fromn the Control Room to (site-specific remoete shutdownb. Control o-f ANY. of the floigkey safety functions is not Feestablishcdwithin (site-specific numbwer f minutess).* ReactiVity controa- Core cooling [PVVR] ý RPV water level [9144Ao RCS heat removalMonth 20XXDR 3-121EP-AA-1004 (Revision XX) nrimarign AnngavFva~lnn Na -harlrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:The time period to establish control of the plant starts when either:a. Control of the plant is no longer maintained in the Main Control RoomORb. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations, and the control of a key safety function cannot bereestablished in a timely manner. The failure to gain control of a key safety functionfollowing a transfer of plan control to alternate locations is a precursor to a challenge toono or morcany fission product barriers within a relatively short period of time.The determination of whether or not "control" is established at the remote safeshutdown location(s) is based on Emergency Director judgment. The EmergencyDirector is expected to make a reasonable, informed judgment within timefG 30 minutes whether or not the operating staff has control of key safetyfunctions from the remote safe shutdown location(s).Escalation of the emergency classification level would be via IC FG1 or CG6-1-.Basis Reference(s):1. NEI 99-01, Rev 6 HS62. DSSP 0100-CR Hot Shutdown Procedure -Control Room EvacuationMonth 20XXDR 3-122EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA26Initiating Condition:Control Room evacuation resulting in transfer of plant control to alternate locations.Operating Mode Applicability:1,2, 3, 4,5, DEmergency Acton Level (EAL):A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per DSSP 0100-CR, Hot Shutdown Procedure -Control Room Evacuation.An event has resulted in plant contrl being transferred from the GContel Room to (site-specific r~emte shutdown panels and local conrol1 stations).Basis:This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations outside the Control Room. The loss of the ability to controlthe plant from the Control Room is considered to be a potential substantial degradationin the level of plant safety.Following a Control Room evacuation, control of the plant will be transferred to alternateshutdown locations. The necessity to control a plant shutdown from outside the ControlRoom, in addition to responding to the event that required the evacuation of the ControlRoom, will present challenges to plant operators and other on-shift personnel.Activation of the ERO and emergency response facilities will assist in responding tothese challenges.Escalation of the emergency classification level would be via IC HS26.Basis Reference(s):1. NEI 99-01, Rev 6 HA62. DSSP 0100-CR, Hot Shutdown Procedure -Control Room EvacuationMonth 20XXDR 3-123EP-AA-1004 (Revision XX) nranlrin AnnovP~v--Inn k, ,,-IaorRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU34Initiating Condition:FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):Note:* The Emergency Director should declare the event Promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.The Emnergency Director should decl-are the Unusual Event promnptly Uponthat the applicable time has boon oXcoodd, OFr Wi11 likely be8XGeeded.1. A FIRE in any Table H2 area is not extinguished in < 15-minutes of ANY of thefollowing FIRE detection indications:" Report from the field (i.e., visual observation)" Receipt of multiple (more than 1) fire alarms or indications* Field verification of a single fire alarmTable H2 Vital Areas" Reactor Building (when inerted the Drywell is exempt)* Aux Electric Room* Control Room* Unit and Shared Emergency Diesel Generator Rooms* 4KV ECCS Switchgear Area (includes Bus 23, 24, 33 and 34 only)* CRD & CCSW Pump Rooms* Turbine Building Cable Tunnel" Turbine Building Safe Shutdown Areas as follows:* B- Train Control Room HVAC Room* Battery Rooms and DC Distribution Areas1) U2 Battery Room (includes DC switchgear, 125V, and 250V battery rooms)2) U3 Battery Room, Battery Cage area, and U3 Battery Charger Room (all on U3 TB 538)* Crib House-lORMonth 20XXDR 3-124EP-AA-1004 (Revision XX)
AnnAxNuelAarfresd=n Anne NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY2. a. Receipt of a single fire alarm in any Table H2 area (i.e., no other indicationsof a FIRE).ANDb. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.OR3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes ofthe initial report, alarm or indication.OR4 A FIRE within the plant PROTECTED AREA that reguires firefighting support byan offsite fire response agency to extinguish.(1) a. A FIRE is NOT ,hinguishd within 15 _minutes of ANYI of tkhe followingFIRE d-etecntion indications:;"Report fromR the field (i.e., visual observation)" Receipt of multiple (mor~e than 1) fire alarms OrFniain" Field Yerification of a single fire alarmANDb. The FIRE ie located within ANY of the follow8 ng plant roomAs or a~reas:(cite-specific list of plant rooms Or areas)(2) a. Recoipt of a single fire alarm (i.e., no other indic-ations of a FIRE)-.ANDb. The FIRE is lcated within ANY of the follo g rlant room, or OrFas(site-specific list of plant rooms Or areas)ANDG. The of a FIRE is not ,,;rifi;d within 30 minutcs of alarm (3) A FIRE withiOn the plant or- ISF1S [fr plants with an ISF-S! outside the plnPrqtected Area] PROTECTED AREA Rot extiRgu-shed within 60 mninutes ofthI I I r+rs~lI4 St 'ru " *g flA at l 11 1 --1Month 20XXDR 3-125EP-AA-1004 (Revision XX)
Dresden AnnexNuelAarfresden Annex Exelon NucilearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY(1) A FIRE within the plant or- ISFSI [for- plants with an ISFSI outside the planiP-ratected Afral PROTECTEFD AREA that roguirec firofighting cupport by anoffeite fire resepnco agency to e~inguishBasis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippinqdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of apotential degradation of the level of safety of the plant.EAL #1 BasisThe intent of the 15-minute duration is to size the FIRE and to discriminate againstsmall FIRES that are readily extinguished (e.g., smoldering waste paper basket). Inaddition to alarms, other indications of a FIRE could be a drop in fire main pressure,automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial firealarm, indication, or report. For EAL assessment purposes, the emergency declarationclock starts at the time that the initial alarm, indication, or report was received, and notthe time that a subsequent verification action was performed. Similarly, the fire durationclock also starts at the time of receipt of the initial alarms, indication or report.EAL #2 BasisThis EAL addresses receipt of a single fire alarm, and the existence of a FIRE is notverified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt,operators will take prompt actions to confirm the validity of a single fire alarm. For EALassessment purposes, the 30-minute clock starts at the time that the initial alarm wasreceived, and not the time that a subsequent verification action was performed.A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipmentfailure or a spurious activation, and not an actual FIRE. For this reason, additional timeis allowed to verify the validity of the alarm. The 30-minute period is a reasonableamount of time to determine if an actual FIRE exists; however, after that time, andabsent information to the contrary, it is assumed that an actual FIRE is in progress.Month 20XXDR 3-126EP-AA-1004 (Revision XX) nrgaadgn Anngav5:i:%1r~n Nhir-lgar*
- S r5 SR S *5 S S *RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYIf an actual FIRE is verified by a report from the field, then EAL #1 is immediatelyapplicable, and the emergency must be declared if the FIRE is not extinguished within15-minutes of the report. If the alarm is verified to be due to anequipment failure or a spurious activation, and this verification occurs within 30-minutesof the receipt of the alarm, then this EAL is not applicable and no emergencydeclaration is warranted.EAL #3 BasisIn addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plantPROTECTED AREA not extinguished within 60-minutes may also potentially degradethe level of plant safety. This bais extends to a FIRE '. cur ..thin thsPROTECTED AREA of an ISFSI, the pl,,t POTECTED ARE.A.[Sentonco for plant-s wita.h aQn ISFSIoutsi the plant Protected Area]EAL #4 BasisIf a FIRE within the plant or ISFS1 [for-plants with an ISF,' "utskd; the plant Pro-tocd-AF-a]-PROTECTED AREA is of sufficient size to require a response by an offsitefirefighting agency (e.g., a local town Fire Department), then the level of plant safety ispotentially degraded. The dispatch of an offsite firefighting agency to the site requiresan emergency declaration only if it is needed to actively support firefighting effortsbecause the fire is beyond the capability of the Fire Brigade to extinguish. Declarationis not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix RAppendix R to 10 CFR 50, states in part:Criterion 3 of Appendix A to this part specifies that "Structures, systems, andcomponents important to safety shall be designed and located to minimize,consistent with other safety requirements, the probability and effect of fires andexplosions."When considering the effects of fire, those systems associated with achievingand maintaining safe shutdown conditions assume major importance to safetybecause damage to them can lead to core damage resulting from loss of coolantthrough boil-off.Because fire may affect safe shutdown systems and because the loss of functionof systems used to mitigate the consequences of design basis accidents underpost-fire conditions does not per se impact public safety, the need to limit firedamage to systems required to achieve and maintain safe shutdown conditions isMonth 20XXDR 3-127EP-AA-1004 (Revision XX)
Dry.dAn AnnexDlresden Annex ExAeron Nuc~lerRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYgreater than the need to limit fire damage to those systems required to mitigatethe consequences of design basis accidents.In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of1-hour fire barriers for the enclosure of cable and equipment and associated non-safetycircuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify asingle alarm is well within this worst-case 1-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA26 or MA5SA9.Basis Reference(s):1. NEI 99-01, Rev 6 HU42. UFSAR 3.2, Classification of Structures, Components, and Systems3. UFSAR 3.5.34. General Arrangement Drawings M-3, M-4, M-4A, M-5 and M-10Month 20XXDR 3-128EP-AA-1004 (Revision XX)
Dresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU42Initiating Condition:Seismic event greater than OBE levels.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):1. Control Room personnel feel an actual or potential seismic event.AND2. The occurrence of a seismic event is confirmed in a manner deemed appropriate bythe Shift Manager or Emergency Director.SeismniG event greater than Operating B3asis Earthquake (01BE) as, indicated by:.a. (cito spocific IndIIation that a seismic i5Int met Or exceeded OBE limits)Basis:This IC addresses a seismic event that results in accelerations at the plant site greaterthan those specified for an Operating Basis Earthquake (OBE)1.An earthquake greaterthan an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have nosignificant impact on safety-related systems, structures and components; however,some time may be required for the plant staff to ascertain the actual post-eventcondition of the plant (e.g., performs walk-downs and post-event inspections). Giventhe time necessary to perform walk-downs and inspections, and fully understand anyimpacts, this event represents a potential degradation of the level of safety of the plant.Event verification with external sources should not be necessary during or following anOBE. Earthquakes of this magnitude should be readily felt by on-site personnel andrecognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).Tho Shift Manager Or Emergency Director Ma" sook e~dernal Yorific-ation if doomo~dappropiate (e.g., a call to tho USGS, chock internet news sourcGes, etc.); however, thevorifiatination must not preclude a timecly emergency declaration.EAL #2 is included to ensure that a declaration does not result from felt vibrationscaused by a non-seismic source (e.g.. a dropped load). The Shift Manager orEmergency Director may seek external verification if deemed appropriate (e.g.. call toUSGS, check internet source. etc.) however, the verification action must not preclude atimely emergency declaration. This EAL wording recognizes that it may cause the site to1 An OBE is vibratory ground motion for which those features of a nuclear power plantnecessary for continued operation without undue risk to the health and safety of thepublic will remain functional.An SSE is vibratory ground motion for which certain (generally, safety-related)structures, systems, and components must be designed to remain functional.Mot 2OXX DR -12lEPAA- 00 (Revison XXMonth 20XXDR 3-129EP-AA-1004 (Revision XX)
Exelan NuclearDresden Annex Eeo ulaRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYdeclare an Unusual Event while another site similarly affected but with readily availableOBE indications in the Control Room, may not.Depending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA26 or MA5SAG.Basis Reference(s):1. NEI 99-01, Rev 6 HU22. DOA 0010-03 EarthquakesMonth 20XXDR 3-130EP-AA-1 004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5Initiating Condition:Gaseous release impeding access to equipment necessary for normal plant operations,cooldown or shutdown.Operating Mode Applicability:1,2,3, 4,5, DEmergency Acton Level (EAL):Note:* If the equipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emeraencv classification iswarranted.1. Release of a toxic, corrosive, asphyxiant or flammable qas in a Table H3 area.Table H3Areas with Entry Related Mode ADplicabilityArea Entry Related ModeApplicabilityReactor Building* Modes 3, 4, and 5*Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impededNote: if the equipment in the listed roomA or arca was already inepcrable Or Out-of cor.ice beforo the event occUrrod, then no- eomogency classification ~waRranted7-(1) a. Reloase of a toxic, corrose, asphyxiant o.r flam.mabl. gar, int any of thefollowing plant roms oraeaqs:.(site-specific list of plant rooms Or areas with entry related moedeapp-licaiinidniid--ANDI P I I I IIl l19. t--ntr; into tne room or area is pronilimee or impeaaMonth 20XXDR 3-131EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:This IC addresses an event involving a release of a hazardous gas that precludes orimpedes access to equipment necessary to transition the plant from normal plantoperation to cooldown and shutdown as specified in normal plant proceduresmaintainno"mal plant .p.atin o .r....rod f!O a normal plant co,1,dwn and shutdown. Thiscondition represents an actual or potential substantial degradation of the level of safetyof the plant.Table H3 is a list of plant rooms or areas with entry-related mode applicability thatcontain equipment which require a manual/local action necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal operatingprocedures (establish shutdown cooling), where if this action is not completed the plantwould not be able to attain and maintain cold shutdown.This Table does not include rooms or areas for which entry is required solely to performactions of an administrative or record keeping nature (e.g., normal rounds or routineinspections).This Table does not include the Control Room since adequate enqineered safety/designfeatures are in place to preclude a Control Room evacuation due to the release of ahazardous gas.An Alert declaration is warranted if entry into the affected room/area is, or may be,procedurally required during the plant operating mode in effect and the gaseous releasepreclude the ability to place shutdown cooling in ser*iceat the time of the ga..ourelease. The emergency classification is not contingent upon whether entry is actuallynecessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires theEmergency Director's judgment that the gas concentration in the affected room/area issufficient to preclude or significantly impede procedurally required access. Thisjudgment may be based on a variety of factors including an existing job hazard analysis,report of ill effects on personnel, advice from a subject matter expert or operatingexperience with the same or similar hazards. Access should be considered as impededif extraordinary measures are necessary to facilitate entry of personnel into the affectedroom/area (e.g., requiring use of protective equipment, such as SCBAs, that is notroutinely employed).An emergency declaration is not warranted if any of the following conditions apply.* The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the timeof the gaseous release). For example, the plant is in Mode 1 when the gaseousrelease occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4.Month 20XXDR 3-132EP-AA-1004 (Revision XX) nrmQarn AnniavFvalnn hhu-ImarRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY" The gas release is a planned activity that includes compensatory measures whichaddress the temporary inaccessibility of a room or area (e.g., fire suppressionsystem testing)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerouslevels. Most commonly, asphyxiants work by merely displacing air in an enclosedenvironment. This reduces the concentration of oxygen below the normal level ofaround 19%, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that generate smoke, that automaticallyor manually activate a fire suppression system in an area, or to intentional inerting ofcontainment.I Escalation of the emergency classification level would be via Recognition Category RA,C or F ICs.Basis Reference(s):1. NEI 99-01, Rev 6 HA52. UFSAR 3.5.33. UFSAR 3.24. General Arrangement Drawings M-3, M-4, M-4A, M-5 and M-10Month 20XXDR 3-133EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU63Initiating Condition:Hazardous EventOperating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):Note:* EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, orvehicle breakdowns or accidents.1. Tornado strike within the PROTECTED AREA.OR2. Internal room or area flooding of a magnitude sufficient to require manual orautomatic electrical isolation of a SAFETY SYSTEM component reguired byTechnical Specifications for the current operating mode.OR3. Movement of Dersonnel within the PROTECTED AREA is impeded due to an offsiteevent involving hazardous materials (e.,q., an offsite chemical spill or toxic gasrelease).OR4. A hazardous event that results in on-site conditions sufficient to prohibit the plantstaff from accessing the site via personal vehicles.OR5. Abnormal River level, as indicated by EITHER:a. High river level > 509 ft.ORb. Low river level < 501 ft. 6 inches.aa PAL A2 daz nnt~ a *I~ tn~ muin traff~i. k, wh a'o' lrnr' antr1r, y-----------------------------------V -V"H4UM A &tr~tWVJ... W i ...~&L:... 4L.-0) 10FRu.GuO W~ine~ WKHLIRl Iul r-ri'.jvr -i-., ArI ;..(~ Intr~rn~d room or ~ro~i floodino of ~ mnnitjdo riiffiriont to rrwniirn m~niioI or'-IMl iniarnal rnnFn nF anna finnd4nn of amagnitude r,- dffr-iAnt ta nual ecurnt nt operating mXde.Month 2OXXDR 3-134EP-AA-1004 (Revision XX)
Dresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY(3) Moveoment of porconnol within the PROTECTED AREA is impeded duo to an( f4) t. eye naadous .. atorials (e.g., an offito cGhemial spill Or toxi. -(1) A hazardous eVont that reSUltS in on site conditions sufficisent to prohibit the plantI ~SUR tFGFn aGGeS61AQ IR9 Site Via PeFSGAal VeHIGIes.II-~.. -/f-\An ane69o M louiii at. u n-atur-a or ionnio -ai z-Aru uvuniwT\ ..... rBasis:PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity Drotected area fence.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses hazardous events that are considered to represent a potentialdegradation of the level of safety of the plant.EAL #1 BasisaAddresses a tornado striking (touching down) within the Protected Area.EAL #2 BasisaAddresses flooding of a building room or area that results in operators isolating powerto a SAFETY SYSTEM component due to water level or other wetting concerns.Classification is also required if the water level or related wetting causes an automaticisolation of a SAFETY SYSTEM component from its power source (e.g., a breaker orrelay trip). To warrant classification, operability of the affected component must berequired by Technical Specifications for the current operating mode. Manual isolation ofpower to a SAFETY SYSTEM component as a result of leakage is an event of lesserimpact and would be expected to cause small and localized damage. The consequenceof this type of event is adequately assessed and addressed in accordance withTechnical Specifications.EAL #3 BasisaAddresses a hazardous materials event originating at an offsite location and ofsufficient magnitude to impede the movement of personnel within the PROTECTEDAREA.EAL #4 BasisaAddresses a hazardous event that causes an on-site impediment to vehicle movementand significant enough to prohibit the plant staff from accessing the site using personalMonth 20XXDR 3-135EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYvehicles. Examples of such an event include site flooding caused by a hurricane, heavyrains, up-river water releases, dam failure, etc., or an on-site train derailment blockingthe access road.This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehiclebreakdowns or accidents, but rather to more significant conditions such as theHurricane Andrew strike on Turkey Point in 1992, the flooding around the CooperStation during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in2011.EAL #5 Basis:The possible maximum flood (PMF) produces a peak flood to 528 ft el. This issignificantly above the grade elevation (517 ft) and the high river water level threshold,which is the lowest opening leading to safety-related eguipment (509 ft el.). When thislevel is reached, the reactors are shutdown, the drywells are deinerted, and the vesselsare flooded and cooled to cold shutdown conditions as guickly as possible. If the waterlevel reaches 513 ft el., reactor cooldown is transferred to the Isolation Condensers,which thereafter maintain a safe shutdown condition until the flood waters recede andplant startup can be initiated.Minimum river water levels to assure pump suction are:" Circulating Water Pumps: 490 ft el." Service Water Pumps: 494 ft el.* CCSW Pumps: 501 ft 6 in." Unit 2/3 Fire Pump: 498 ft 6 in.The low river water level threshold (501 ft. 6 in.) is based on the most limiting pumpsuction requirement (CCSW).EAL #6 addrccccc (site cpeoific deoVipt Escalation of the emergency classification level would be based on lCs in RecognitionCategories RA, F, MS, H or C.Basis Reference(s):1. NEI 99-01, Rev 6 HU32. DOA 0010-01 Dresden Lock and Dam Failure3. DOA 0010-04 Floods4. DOA 0010-02 Tornado Warning/Severe Winds5. DOA-0010-12, Toxic Gas/Chemical Release from Nearby Chemical FacilitiesMonth 20XXDR 3-136EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a GENERAL EMERGENCY.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):4( Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or IMMINENTsubstantial core degradation or melting with potential for loss of containment integrity orHOSTILE ACTION that results in an actual loss of physical control of the facility.Releases can be reasonably expected to exceed EPA Protective Action Guidelineexposure levels offsite for more than the immediate site area.Basis:IMMINENT: The traiectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy eguirpment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for aGeneral Emergency.Basis Reference(s):1. NEI 99-01, Rev 6 HG7Month 20XXDR 3-137EP-AA-1004 (Revision XX)
I=yAInn flmttrien Annpx Exeinn NucleIarRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a SITE AREA EMERGENCY.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):(-14 Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or likely major failuresof plant functions needed for protection of the public or HOSTILE ACTION that results inintentional damage or malicious acts, (1) toward site personnel or equipment that couldlead to the likely failure of or, (2) that prevent effective access to equipment needed forthe protection of the public. Any releases are not expected to result in exposure levelswhich exceed EPA Protective Action Guideline exposure levels beyond the siteboundary.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy eguipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for a SiteArea Emergency.Basis Reference(s):1. NEI 99-01, Rev 6 HS7Month 20XXDR 3-138EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an ALERT Operating Mode Applicability:1,2,3, 4,5, DEmergency Acton Level (EAL):(-1-) Other conditions exist which, in the judgment of the Emergency Director, indicatethat events are in progress or have occurred which involve an actual or potentialsubstantial degradation of the level of safety of the plant or a security event thatinvolves probable life threatening risk to site personnel or damage to site equipmentbecause of HOSTILE ACTION. Any releases are expected to be limited to smallfractions of the EPA Protective Action Guideline exposure levels.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anAlert.Basis Reference(s):1. NEI 99-01, Rev 6 HA7Month 20XXDR 3-139EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an EVENT.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):(-1) Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which indicate a potential degradation ofthe level of safety of the plant or indicate a security threat to facility protection has beeninitiated. No releases of radioactive material requiring offsite response or monitoring areexpected unless further degradation of safety systems occurs.Basis:This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anNOUEUNUSUAL EVENT.Basis Reference(s):1. NEI 99-01, Rev 6 HU7Month 20XXDR 3-140EP-AA-1004 (Revision XX)
Dr@sden AnnexDlresden Annex ExeIon NucilearRECOGNITION CATEGORYISFSI MALFUNCTIONSE-HU1Initiating ConditionDamage to a loaded cask CONFINEMENT BOUNDARY.Operating Mode Applicability:1,2,3,4,5, DEmergency Acton Level (EAL):Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contactradiation reading:1. EAST HI-STAR:9 > 160 mrem/hr (neutron + gamma) on the top of the OvermackOR0 > 250 mrem/hr (neutron+ gamma) on the side of the OverpackOR2. EAST HI-STORM:* > 20 mrem/hr (neutron+ gamma) on the top of the OverpackOR* >100 mrem/hr (neutron+ gamma) on the side of the OverpackOR* > 45 mrem/hr (neutron+ gamma) at the inlet and outlet vent ducts of theOverpackOR3. WEST HI-STORM:* > 40 mrem/hr (neutron+ gamma) on the top of the OverpackOR* >100 mrem/hr (neutron+ gamma) on the side of the Overpack, excluding inletand outlet ducts-(1)----Damage to a loaded cask CONFINEMV=ENT BOUNDARY as indiatcd by an ont radiatioGnA ading greatc, than (2 ti;mes the site specific cask specific specification allowable radiation level) on the su~faco of tho spent fuel cask.Basis:CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) betweenareas containing radioactive substances and the environment.Month 20XX DR 3-141 EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYISFSI MALFUNCTIONSINDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)* A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.This IC addresses an event that results in damage to the CONFINEMENT BOUNDARYof a storage cask containing spent fuel. -It applies to irradiated fuel that is licensed fordry storage beginning at the point that the loaded storage cask is sealed. The wordcask, as used in this EAL, refers to the storage container in use at the site for drystorage of irradiated fuel. The issues of concern are the creation of a potential or actualrelease path to the environment, degradation of one Or moreany fuel assemblies due toenvironmental factors, and configuration changes which could cause challenges inremoving the cask or fuel from storage.The existence of "damage" is determined by radiological survey. The technicalspecification multiple of "2 times", which is also used in Recognition Category RA ICRAU1, is used here to distinguish between non-emergency and emergency conditions.The emphasis for this classification is the degradation in the level of safety of the spentfuel cask and not the magnitude of the associated dose or dose rate. It is recognizedthat in the case of extreme damage to a loaded cask, the fact that the "on-contact" doserate limit is exceeded may be determined based on measurement of a dose rate atsome distance from the cask.Security-related events for ISFSIs are covered under ICs HU1 and HAl.Basis Reference(s):1. NEI 99-01, Rev 6 E-HU12. Certificate of Compliance No. 1014 Appendix A, Section 5.7 (WEST HI-STORM)3. Certificate of Compliance No. 1014 Appendix A, Section 3.2.3 (EAST HI-STORM)4. Certificate of Compliance No. 1008 Appendix A, Amendment 2, Section 2.2.1(EAST HI-STAR)Month 20XXDR 3-142EP-AA-1004 (Revision XX)
Dresden AnnexI:xelnn Dresden Annex FvaeInn N~uclarRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS* RG1Initiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRemTEDE or 5000 mRem thyroid CDE.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessmentusing actual meteorology are available.1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+09 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidORMonth 20XXDR 3-33EP-AA-1 004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRGI (cont)Emergency Action Level (EAL) (cont):3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for60 minutes of inhalation.Basis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to the EPA Protective Action Guides (PAGs). Itincludes both monitored and un-monitored releases. Releases of this magnitude willrequire implementation of protective actions for the public.Radiological effluent EALs are also included to provide a basis for classifying eventsand conditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at the EPA PAG of 1000 mRem while the 5000 mRem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Basis Reference(s):1. NE 199-01 Rev 6, AG12. EP-AA-1 12-500 Emergency Environmental Monitoring3. ODCM Section 12.4 Gaseous Effluents and Total Dose4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From theUnit 2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous EffluentEAL Threshold Values Dresden Station6. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-34EP-AA-1004 (Revision XX) nractin Annoyflr~Qrg~n An~w Fvinn NucleIarRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSRS1Initiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDEor 500 mRem thyroid CDE.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessmentusing actual meteorology are available.1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+08 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 100 mRem TEDEORb. > 500 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >100 mR/hr are expected to continuefor > 60 minutes.b. OR Analyses of field survey samples indicate > 500 mRem CDE Thyroidfor 60 minutes of inhalation.Month 20XXDR 3-35EP-AA-1004 (Revision XX)
Dresden AnnexNuclearDlresden Annex Exellnn N~uclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRS1 (cont)Basis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).It includes both monitored and un-monitored releases. Releases of this magnitude areassociated with the failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying eventsand conditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at 10% of the EPA PAG of 1000 mRem while the 500 mRemthyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDEand thyroid CDE.Escalation of the emergency classification level would be via IC RG1.Basis Reference(s):1. NEI 99-01 Rev 6, AS12. EP-AA-1 12-500 Emergency Environmental Monitoring3. ODCM Section 12.4 Gaseous Effluents and Total Dose4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From theUnit 2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous EffluentEAL Threshold Values Dresden Station6. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-36EP-AA-1004 (Revision XX) nroau4an Annav=,v--Irhn Klorl--mr-.~ ~* * *-.. ...~,t ~fl~in t.* in
- Uti -*t.t.inRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA1Initiating Condition:Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRemTEDE or 50 mRem thyroid CDE.Operating Mode Applicability:1,2,3, 4,5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessmentusing actual meteorology are available.1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+07 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 50 mRem CDE ThyroidORMonth 20XXDR 3-37EP-AA-1 004 (Revision XX)
Dresden AnnexDresden Annex ExceInn Nmu~clarRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA1 (cont)Emergency Action Level (EAL) (cont):3. Analysis of a liquid effluent sample indicates a concentration or release rate thatwould result in doses greater than EITHER of the following at or beyond the siteboundarya. 10 mRem TEDE for 60 minutes of exposureORb. 50 mRem CDE Thyroid for 60 minutes of exposureOR4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mR/hr are expected tocontinue for a 60 minutes.ORb. Analyses of field survey samples indicate > 50 mRem CDEThyroid for 60 minutes of inhalation.Basis:This IC addresses a release of gaseous or liquid radioactivity that results in projected oractual offsite doses greater than or equal to 1% of the EPA Protective Action Guides(PAGs). It includes both monitored and un-monitored releases. Releases of thismagnitude represent an actual or potential substantial degradation of the level of safetyof the plant as indicated by a radiological release that significantly exceeds regulatorylimits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying eventsand conditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at 1% of the EPA PAG of 1000 mRem while the 50 mRem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Escalation of the emergency classification level would be via IC RS1.Month 20XXDR 3-38EP-AA-1004 (Revision XX)
Dresden AnnexI:yelnn NuclearDlresden Annex FwAllnn Nuclea~rRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRAI (cont)Basis Reference(s):1. NEI 99-01 Rev 6, AA12. ODCM Section 12.3 Liquid Effluents3. ODCM Section 12.4 Gaseous Effluents4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From theUnit 2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. UNIT 2/3 DAN 2223-6 A-12 "2/3 RADWASTE DISCHARGE HIGH RADIATION"6. UNIT 2/3 DOP 2000-110, Radioactive Waste Discharge to River With the Off-Stream Liquid Effluent Monitor Operable7. UNIT 2/3 DOP 2000-109, Waste Surge Tank Batching for a Radwaste RiverDischarge8. Structural Drawing B-01A Composite Site Plan Dresden Station Units 1, 2 & 39. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous EffluentEAL Threshold Values Dresden Station10. DEOP 300-2, Radioactivity Release Control11. EP-EAL-0620 Revision 0, Dresden Criteria for Choosing Radiological LiquidEffluent EAL Threshold ValuesMonth 20XXDR 3-39EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU1Initiating Condition:Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60minutes or longer.Operating Mode Applicability:1,2, 3,4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 60 minutes.* Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.1. Reading on ANY of the following effluent monitors > 2 times alarm setpointestablished by a current radioactive release discharge permit for ?: 60 minutes." Radwaste Effluent Monitor 2/3-2001-948OR" Discharge Permit specified monitorOR2. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 9.02 E+05 uCi/sec for > 60 minutes (as determined by DOP 1700-10 orPPDS -Total Noble Gas Release Rate).OR3. Confirmed sample analyses for gaseous or liquid releases indicateconcentrations or release rates > 2 times ODCM Limit with a release duration of> 60 minutes.Month 20XXDR 3-40EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU1 (cont)Basis:This IC addresses a potential decrease in the level of safety of the plant as indicated bya low-level radiological release that exceeds regulatory commitments for an extendedperiod of time (e.g., an uncontrolled release). It includes any gaseous or liquidradiological release, monitored or un-monitored, including those for which a radioactivitydischarge permit is normally prepared.Nuclear power plants incorporate design features intended to control the release ofradioactive effluents to the environment. Further, there are administrative controlsestablished to prevent unintentional releases, and to control and monitor intentionalreleases. The occurrence of an extended, uncontrolled radioactive release to theenvironment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying eventsand conditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.Releases should not be prorated or averaged. For example, a release exceeding 4times release limits for 30 minutes does not meet the EAL.EAL #1 BasisThis EAL addresses radioactivity releases that cause effluent radiation monitor readingsto exceed 2 times the limit established by a radioactivity discharge permit. This EAL willtypically be associated with planned batch releases from non-continuous releasepathways (e.g., radwaste, waste gas).The effluent monitors listed are those normally used for planned discharges. If adischarge is performed using a different flowpath or effluent monitor other than thoselisted (e.g., a portable or temporary effluent monitor), then the declaration criteria will bebased on the monitor specified in the Discharge Permit.EAL #2 BasisThis EAL addresses normally occurring continuous radioactivity releases frommonitored gaseous effluent pathways.EAL #3 BasisThis EAL addresses uncontrolled gaseous or liquid releases that are detected bysample analyses or environmental surveys, particularly on unmonitored pathways (e.g.,spills of radioactive liquids into storm drains, heat exchanger leakage in river watersystems, etc.).Escalation of the emergency classification level would be via IC RAI.Month 20XXDR 3-41EP-AA-1004 (Revision XX)
Dresden AnnexExalon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRUI (cont)Basis Reference(s):1. NEI 99-01 Rev 6, AU12. ODCM Section 12.3 Liquid Effluents3. ODCM Section 12.4 Gaseous Effluents4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From theUnit 2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. UNIT 2/3 DAN 2223-6 A-12 "2/3 RADWASTE DISCHARGE HIGH RADIATION"6. UNIT 2/3 DOP 2000-110, Radioactive Waste Discharge to River With the Off-Stream Liquid Effluent Monitor Operable7. UNIT 2/3 DOP 2000-109, Waste Surge Tank Batching for a Radwaste RiverDischarge8. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous EffluentEAL Threshold Values Dresden Station9. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-42EP-AA-1004 (Revision XX)
N Hr.lp_;irDlresden Annex Exelon NuclerIArRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA2Initiating Condition:Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel asindicated by ANY Table R1 Radiation Monitor reading >1000 mRem/hr.Table RIFuel Handling Incident Radiation Monitors" Refuel Floor High Range ARM Station #2(4)* Fuel Pool Radiation MonitorBasis:REFUELING PATHWAY: all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) betweenareas containing radioactive substances and the environment.This IC addresses events that have caused IMMINENT or actual damage to anirradiated fuel assembly. These events present radiological safety challenges to plantpersonnel and are precursors to a release of radioactivity to the environment. As such,they represent an actual or potential substantial degradation of the level of safety of theplant.This IC applies to irradiated fuel that is licensed for dry storage up to the point that theloaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss ofthe CONFINEMENT BOUNDARY is classified in accordance with IC E-HUI.Month 20XXDR 3-43EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA2 (cont)Initiating Condition:EAL #1 BasisThis EAL escalates from RU2 in that the loss of level, in the affected portion of theREFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery ofirradiated fuel. Indications of irradiated fuel uncovery may include direct or indirectvisual observation (e.g., reports from personnel or camera images), as well assignificant changes in water and radiation levels, or other plant parameters.Computational aids may also be used (e.g., a boil-off curve). Classification of an eventusing this EAL should be based on the totality of available indications, reports andobservations.While an area radiation monitor could detect a rise in a dose rate due to a lowering ofwater level in some portion of the REFUELING PATHWAY, the reading may not be areliable indication of whether or not the fuel is actually uncovered. To the degreepossible, readings should be considered in combination with other available indicationsof inventory loss.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.EAL #2 BasisThis EAL addresses a release of radioactive material caused by mechanical damage toirradiated fuel. Damaging events may include the dropping, bumping or binding of anassembly, or dropping a heavy load onto an assembly. Spent fuel uncovery representsa major ALARA concern in that radiation levels could exceed 10,000 R/hr on the refuelbridge when fuel uncovery begins. The value of 1000 mR/hr was conservatively chosenfor classification purposes. A rise in readings on radiation monitors should beconsidered in conjunction with in-plant reports or observations of a potential fueldamaging event (e.g., a fuel handling accident).Escalation of the emergency would be based on either Recognition Category Ror C ICs.Basis Reference(s):1. NE 199-01 Rev 6, AA22. DAN 902(3)-3 C-1 6(E-16) Reactor Building Fuel Pool Hi Radiation3. DAN 902(3)-3 B-1 Refuel Floor Hi Radiation4. DAN 902(3)-3 A-3(F-14) Reactor building Vent Hi-Hi Radiation5. UFSAR 9.16. DAN 902(3)-4 D-24 Fuel Pool Skimmer Tank Level Lo7. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level Instrumentation8. DFP 0850-01 Water Level Loss in SFP or Cavity9. DOP 1900-03 Reactor Cavity, Dryer/Separator Storage Pit and Fuel Pool LevelControlMonth 20XXDR 3-44EP-AA-1004 (Revision XX)
Dresden AnnexI=xelnn NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU2Initiating Condition:UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:1, 2,3,4,5, DEmergency Action Level (EAL):1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated byANY of the following:" Refueling Cavity water level < 466 in. (Refuel Outage Reactor Vesseland Cavity Level Instrument LI 2(3)-263-114)OR* Spent Fuel Pool water level < 19 ft. above the fuel (< 33 ft. 9 in.indicated level).OR* Indication or report of a drop in water level in the REFUELINGPATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable RI.Table RIFuel Handling Incident Radiation Monitors" Refuel Floor High Range ARM Station #2(4)" Fuel Pool Radiation MonitorMonth 20XXDR 3-45EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU2 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.REFUELING PATHWAY: all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.This IC addresses a loss in water level above irradiated fuel sufficient to cause elevatedradiation levels. This condition could be a precursor to a more serious event and is alsoindicative of a minor loss in the ability to control radiation levels within the plant. It istherefore a potential degradation in the level of safety of the plant.A water level loss will be primarily determined by indications from available levelinstrumentation. Other sources of level indications may include reports from plantpersonnel (e.g., from a refueling crew) or video camera observations (if available) orfrom any other temporarily installed monitoring instrumentation. A significant drop in thewater level may also cause a rise in the radiation levels of adjacent areas that can bedetected by monitors in those locations.The effects of planned evolutions should be considered. For example, a refuelingbridge area radiation monitor reading may rise due to planned evolutions such as liftingof the reactor vessel head or movement of a fuel assembly. Note that this EAL isapplicable only in cases where the elevated reading is due to an UNPLANNED loss ofwater level.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RA2.Month 20XXDR 3-46EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU2 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, AU22. RP-AA-203 Exposure Control and Authorization3. Technical Specifications 3.7.84. Technical Specifications 3.9.65. UFSAR 9.16. DAN 902(3)-4 D-24 Fuel Pool Skimmer Tank Level Lo7. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level Instrumentation8. DFP 0850-01 Water Level Loss in SFP or Cavity9. DOP 1900-03 Reactor Cavity, Dryer/Separator Storage Pit and Fuel Pool LevelControl10. DGP 02-02, Reactor Vessel Slow Fill11. DAN 902(3)-3 C-16(E-16) Reactor Building Fuel Pool Hi Radiation12. DAN 902(3)-3 B-1 Refuel Floor Hi Radiation13. DAN 902(3)-3 A-3(F-14) Reactor building Vent Hi-Hi RadiationMonth 20XXDR 3-47EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA3Initiating Condition:Radiation levels that impede access to equipment necessary for normal plantoperations, cooldown or shutdown.Operating Mode Applicability:1,2,3, 4,5, DEmergency Action Level (EAL):Note:* If the equipment in the room or area listed in Table R3 was already inoperable, orout of service, before the event occurred, then no emergency classification iswarranted.1. Dose rate > 15 mR/hr in ANY of the following Table R2 areas:Table R2Areas Requiring Continuous Occupancy" Main Control Room (Unit 2 ARM Station #22)* Central Alarm Station -(by survey)OR2. UNPLANNED event results in radiation levels that prohibit or significantly impedeaccess to ANY of the following Table R3 plant rooms or areas:Table R3Areas with Entry Related Mode ApplicabilityArea Entry Related Mode ApplicabilityReactor Building* Modes 3, 4, and 5*Areas required to establish shutdown coolingMonth 20XXDR 3-48EP-AA-1004 (Revision XX)
Dresden AnnexDresden Annex Exelnn Nucler~IRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA3 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient topreclude or impede personnel from performing actions necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal plantprocedures. As such, it represents an actual or potential substantial degradation of thelevel of safety of the plant. The Emergency Director should consider the cause of theincreased radiation levels and determine if another IC may be applicable.Table R3 is a list of plant rooms or areas with entry-related mode applicability thatcontain equipment which require a manual/local action necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal operatingprocedures (establish shutdown cooling), where if this action is not completed the plantwould not be able to attain and maintain cold shutdown. This Table does not includerooms or areas for which entry is required solely to perform actions of an administrativeor record keeping nature (e.g., normal rounds or routine inspections).Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including theControl Room.For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, ormay be, procedurally required during the plant operating mode in effect and theelevated radiation levels preclude the ability to place shutdown cooling in service. Theemergency classification is not contingent upon whether entry is actually necessary atthe time of the increased radiation levels. Access should be considered as impeded ifextraordinary measures are necessary to facilitate entry of personnel into the affectedroom/area (e.g., installing temporary shielding beyond that required by procedure,requiring use of non-routine protective equipment, requesting an extension in doselimits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply.* The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the timeof the elevated radiation levels). For example, the plant is in Mode 1 when theradiation rise occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4.The increased radiation levels are a result of a planned activity that includescompensatory measures which address the temporary inaccessibility of a room or area(e.g., radiography, spent filter or resin transfer, etc.).Month 20XXDR 3-49EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA3 (cont)Basis (cont):" The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category R, Cor F ICs.Basis Reference(s):1. NEI 99-01 Rev 6, AA32. DOP 1800-01 Area Radiation Monitors3. FSAR Section 3.2 Classification of Structures, Components and Systems4. General Arrangement Drawings M-3, M-4, M-4A, M-5 and M-105. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-50EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU3Initiating Condition:Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):1. Offgas system radiation monitor HI-HI alarm.OR2. Specific coolant activity > 4.0 uCI/gm Dose equivalent 1-131.Basis:This IC addresses a reactor coolant activity value that exceeds an allowable limitspecified in Technical Specifications. This condition is a precursor to a more significantevent and represents a potential degradation of the level of safety of the plant.Conditions that cause the specified monitor to alarm that are not related to fuel claddegradation should not result in the declaration of an Unusual Event.This EAL addresses site-specific radiation monitor readings that provide indication of adegradation of fuel clad integrity.An Unusual Event is only warranted when actual fuel clad damage is the cause of theelevated coolant sample activity (as determined by laboratory confirmation). Fuel claddamage should be assumed to be the cause of elevated Reactor Coolant activity unlessanother cause is known.Escalation of the emergency classification level would be via ICs FA1 or theRecognition Category R ICs.Basis Reference(s):1. NEI 99-01 Rev 6, SU32. Technical Specifications 3.4.6, RCS Specific Activity3. DAN 902(3)-3 C-2(D-2) Off Gas Rad Monitor Hi-Hi4. Technical Specifications 3.7.6, Main Condenser Offgas5. DGA 16 Coolant High Activity/Fuel Element FailureMonth 20XXDR 3-51EP-AA-1004 (Revision XX)
AnnexDlresden Annex FvA-Inn Nuci--r~IRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFG1Initiating Condition:Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-52EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFS1Initiating Condition:Loss or Potential Loss of ANY two barriers.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-53EP-AA-1004 (Revision XX)
AnnexD .resden Annex Eineln NIuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFAIInitiating Condition:ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Alert classification level, Fuel Cladding and RCS barriers are weighted moreheavily than the Containment barrier. Unlike the Containment barrier, loss or potentialloss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactivematerials or degradation of core cooling capability. Note that the loss or potential loss ofContainment barrier in combination with loss or potential loss of either Fuel Cladding orRCS barrier results in declaration of a Site Area Emergency under EAL FSI.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-54EP-AA-1004 (Revision XX) nroadian AnnavI:::vg1ln n me.,rlarRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC1Initiating Condition:RCS ActivityOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSCoolant activity > 300 uCi/gm Dose Equivalent 1-131.Basis:This threshold indicates that RCS radioactivity concentration is greater than 300 PiCi/gmdose equivalent 1-131. Reactor coolant activity above this level is greater than thatexpected for iodine spikes and corresponds to an approximate range of 2% to 5% fuelclad damage. Since this condition indicates that a significant amount of fuel claddamage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highlyelevated activity levels could require several hours to complete. Nonetheless, asample-related threshold is included as a backup to other indications.There is no Potential Loss threshold associated with RCS Activity.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. DGA-16, Coolant High Activity / Fuel Element FailureMonth 20XXDR 3-55EP-AA-1004 (Revision XX)
Dresden AnnexI=xelon NuclearDresden Annex Exelnn Nucla~rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC2Initiating Condition:RPV Water LevelOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. Plant conditions indicate Primary Containment flooding is required.POTENTIAL LOSS2. RPV water level cannot be restored and maintained > -143 inches (TAF)OR3. RPV water level cannot be determined.Basis:RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions. Compensated values may be used inaccordance with the Technical Support Guidelines.Loss Threshold #1 BasisThe Loss threshold represents the EOP requirement for primary containment flooding.This is identified in the BWROG EPGs/SAMGs when the phrase, "Primary ContainmentFlooding Is Required," appears. Since a site-specific RPV water level is not specifiedhere, the Loss threshold phrase, "Primary containment flooding required," alsoaccommodates the EOP need to flood the primary containment when RPV water levelcannot be determined and core damage due to inadequate core cooling is believed tobe occurring.Potential Loss Threshold #2 and #3 BasisThis water level corresponds to the top of the active fuel and is used in the EOPs toindicate a challenge to core cooling.The RPV water level threshold is the same as RCS Barrier RC2 Loss threshold. Thus,this threshold indicates a Potential Loss of the Fuel Clad barrier and a Loss of the RCSbarrier that appropriately escalates the emergency classification level to a Site AreaEmergency.This threshold is considered to be exceeded when, as specified in the site-specificEOPs, RPV water level cannot be restored and maintained above the specified levelfollowing depressurization of the RPV (either manually, automatically or by failure of theRCS barrier) or when procedural guidance or a lack of low pressure RPV injectionsources preclude Emergency RPV depressurization.Month 20XXDR 3-56EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC2 (cont)Basis (cont):EOPs allow the operator a wide choice of RPV injection sources to consider whenrestoring RPV water level to within prescribed limits. EOPs also specifydepressurization 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 leveluntil pressure drops below the shutoff heads of available injection sources. Therefore,this Fuel Clad barrier Potential Loss is met only after either: 1) the RPV has beendepressurized, or required emergency RPV depressurization has been attempted,giving the operator an opportunity to assess the capability of low-pressure injectionsources to restore RPV water level or 2) no low pressure RPV injection systems areavailable, precluding RPV depressurization in an attempt to minimize loss of RPVinventory.The term "cannot be restored and maintained above" means the value of RPV waterlevel is not able to be brought above the specified limit (top of active fuel). Thedetermination requires an evaluation of system performance and availability in relationto the RPV water level value and trend. A threshold prescribing declaration when athreshold value cannot be restored and maintained above a specified limit does notrequire immediate action simply because the current value is below the top of activefuel, but does not permit extended operation below the limit; the threshold must beconsidered reached as soon as it is apparent that the top of active fuel cannot beattained.Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator todeliberately lower RPV water level in order to reduce reactor power. Although suchaction is a challenge to core cooling and the Fuel Clad barrier, the immediate need toreduce reactor power is the higher priority. For such events, ICs MA3 or MS3 will dictatethe need for emergency classification.Since the loss of ability to determine if adequate core cooling is being provided presentsa significant challenge to the fuel clad barrier, a potential loss of the fuel clad barrier isspecified.Month 20XXDR 3-57EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC2 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. DEOP 100 RPV Control3. DEOP 400-5 Failure to Scram4. DEOP 400-1 RPV Flooding5. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines6. Technical Support GuidelinesMonth 20XXDR 3-58EP-AA-1 004 (Revision XX) n'ra*crian Annoy=,v'ft1rn Khir-IgmrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC5Initiating Condition:Primary Containment RadiationOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSDrywell radiation monitor reading > 6.70 E+02 R/hr (670 R/hr).Basis:The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that reactor coolant activityequals 300 p.Ci/gm dose equivalent 1-131. Reactor coolant activity above this level isgreater than that expected for iodine spikes and corresponds to an approximate rangeof 2% to 5% fuel clad damage. Since this condition indicates that a significant amountof fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.The radiation monitor reading in this threshold is higher than that specified for RCSBarrier RC5 Loss Threshold since it indicates a loss of both the Fuel Clad Barrier andthe RCS Barrier. Note that a combination of the two monitor readings appropriatelyescalates the emergency classification level to a Site Area Emergency.There is no Fuel Clad Barrier Potential Loss threshold associated with PrimaryContainment Radiation.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. Core Damage Assessment Methodology (CDAM)Month 20XXDR 3-59EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC7Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. Any condition in the opinion of the Emergency Director that indicates Loss of the FuelClad Barrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergency Director that indicates Potential Lossof the Fuel Clad Barrier.Basis:Loss Threshold #1 BasisThis threshold addresses any other factors that are to be used by the EmergencyDirector in determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold #2 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-60EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC2Initiating Condition:RPV Water LevelOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. RPV water level cannot be restored and maintained > -143 inches (TAF)OR2. RPV water level cannot be determined.Basis:RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions. Compensated values may be used inaccordance with the Technical Support Guidelines.This water level corresponds to the Top of Active Fuel (TAF) and is used in the EOPs toindicate challenge to core cooling.The RPV water level threshold is the same as Fuel Clad Barrier FC2 Potential Lossthreshold. Thus, this threshold indicates a Loss of the RCS barrier and Potential Loss ofthe Fuel Clad barrier and that appropriately escalates the emergency classification levelto a Site Area Emergency.This threshold is considered to be exceeded when, as specified in the site-specificEOPs, RPV water level cannot be restored and maintained above the specified levelfollowing depressurization of the RPV (either manually, automatically or by failure of theRCS barrier) or when procedural guidance or a lack of low pressure RPV injectionsources preclude Emergency RPV depressurization EOPs allow the operator a widechoice of RPV injection sources to consider when restoring RPV water level to withinprescribed limits. EOPs also specify depressurization of the RPV in order to facilitateRPV water level control with low-pressure injection sources. In some events, elevatedRPV pressure may prevent restoration of RPV water level until pressure drops belowthe shutoff heads of available injection sources. Therefore, this RCS barrier Loss is metonly after either: 1) the RPV has been depressurized, or required emergency RPVdepressurization has been attempted, giving the operator an opportunity to assess thecapability of low-pressure injection sources to restore RPV water level or 2) no lowpressure RPV injection systems are available, precluding RPV depressurization in anattempt to minimize loss of RPV inventory.Month 20XXDR 3-61EP-AA-1 004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC2 (cont)Basis (cont):The term, "cannot be restored and maintained above," means the value of RPV waterlevel is not able to be brought above the specified limit (top of active fuel). Thedetermination requires an evaluation of system performance and availability in relationto the RPV water level value and trend. A threshold prescribing declaration when athreshold value cannot be restored and maintained above a specified limit does notrequire immediate action simply because the current value is below the top of activefuel, but does not permit extended operation beyond the limit; the threshold must beconsidered reached as soon as it is apparent that the top of active fuel cannot beattained.Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator todeliberately lower RPV water level in order to reduce reactor power. Although suchaction is a challenge to core cooling and the Fuel Clad barrier, the immediate need toreduce reactor power is the higher priority. For such events, ICs MA3 or MS3 will dictatethe need for emergency classification.There is no RCS Potential Loss threshold associated with RPV Water Level.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. DEOP100 RPV Control3. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines4. Technical Support GuidelinesMonth 20XXDR 3-62EP-AA-1004 (Revision XX)
Dry.dAn AnnexDlresden Annexr ExceInn NuclerIArRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC3Initiating Condition:Primary Containment PressureOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. Drywell pressure >2.0 psig.AND2. Drywell pressure rise is due to RCS leakage.Basis:The > 2.0 psig primary containment pressure is the Drywell high pressure setpointwhich indicates a LOCA by automatically initiating ECCS.The second threshold condition focuses the fission product barrier loss threshold on afailure of the RCS instead of the non-LOCA malfunctions that may adversely affectprimary containment pressure. Pressures of this magnitude can be caused by non-LOCA events such as a loss of Drywell cooling or inability to control primarycontainment vent/purge.The release of mass from the RCS due to the as-designed/expected operation of anyrelief valve does not warrant an emergency classification.A stuck-open Electromatic relief valve (ERV)/Target Rock SRV or ERV/ Target RockSRV leakage is not considered either identified or unidentified leakage by TechnicalSpecifications and, therefore, is not applicable to this EAL.There is no Potential Loss threshold associated with Primary Containment Pressure.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. Technical Specifications Table 3.3.5.1-13. DAN 902(3)-5 D-114. DEOP 100 RPV Control5. DEOP 200-1 Primary Containment ControlMonth 20XXDR 3-63EP-AA-1 004 (Revision XX)
Dresden AnneaxI=xelnn NuclearD.......Ann.x mExelnn Nuici.earRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC4Initiating Condition:RCS Leak RateOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. UNISOLABLE Main Steam Line (MSL), Isolation Condenser, HPCI, Feedwater, orRWCU line break.OR2. Emergency RPV Depressurization is required.POTENTIAL LOSS3. UNISOLABLE primary system leakage that results in EITHER of the following:a. Secondary Containment area temperature > DEOP 300-1 Maximum Normaloperating levels.ORb. Secondary Containment area radiation level > DEOP 300-1 Maximum Normaloperating level.Basis:UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.Classification of a system break over system leakage is based on information availableto the Control Room from the event. Indications that should be considered are:* Reports describing magnitude of steam or water release.* Use of system high flow alarms / indications, if available," Significant changes in makeup requirements,* Abnormal reactor water level changes in response to the event.The use of the above indications provides the Control Room the bases to determine thatthe on going event is more significant than the indications that would be expected fromsystem leakage and therefore should be considered a system break.Month 20XXDR 3-64EP-AA-1004 (Revision XX)
Dresden AnnexI=xelon N Dresden Annex Exelnn Nucler~IRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC4 (cont)Basis (cont):Loss Threshold #1 BasisLarge high-energy lines that rupture outside primary containment can dischargesignificant amounts of inventory and jeopardize the pressure-retaining capability of theRCS until they are isolated. If it is determined that the ruptured line cannot be promptlyisolated, the RCS barrier Loss threshold is met.Loss Threshold #2 BasisEmergency RPV Depressurization in accordance with the EOPs is indicative of a loss ofthe RCS barrier. If Emergency RPV Depressurization is performed, the plant operatorsare directed to open safety relief valves (SRVs) and keep them open. Even though theRCS is being vented into the Torus, a Loss of the RCS barrier exists due to thediminished effectiveness of the RCS to retain fission products within its boundary.Potential Loss Threshold #3 BasisPotential loss of RCS based on primary system leakage outside the primarycontainment is determined from EOP temperature or radiation Max Normal Operatingvalues in areas such as main steam line tunnel, HPCI, etc., which indicate a direct pathfrom the RCS to areas outside primary containment.A Max Normal Operating value is the highest value of the identified parameter expectedto occur during normal plant operating conditions with all directly associated supportand control systems functioning properly.The indicators reaching the threshold barriers and confirmed to be caused by RCSleakage from a primary system warrant an Alert classification. A primary system isdefined to be the pipes, valves, and other equipment which connect directly to the RPVsuch that a reduction in RPV pressure will effect a decrease in the steam or water beingdischarged through an unisolated break in the system.In general, multiple indications should be used to determine if a primary system isdischarging outside Primary Containment. For example, a high area radiation conditiondoes not necessarily indicate that a primary system is discharging into the ReactorBuilding since this may be caused by radiation shine from nearby steam lines or themovement of radioactive materials. Conversely, a high area radiation condition inconjunction with other indications (e.g. room flooding, high area temperatures, reports ofsteam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpectedMain Turbine Control Valve closure) may indicate that a primary system is discharginginto the Reactor Building.An UNISOLABLE leak which is indicated by Max Normal Operating values escalates toa Site Area Emergency when combined with Containment Barrier CT6 Loss Threshold#1 (after a containment isolation) and a General Emergency when the Fuel Clad Barriercriteria is also exceeded.Month 20XXDR 3-65EP-AA-1004 (Revision XX)
Dresden AnnexFxplnn NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC4 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. M-12, M-345, Main steam piping3. Technical Specifications 3.4.4 RCS Operational LEAKAGE4. Technical Specifications Section 3.4.5, RCS Leakage Detection Instrumentation5. DAN 902(3)-4 A-17 DRYWELL EQUIP SUMP LVL HI-HI6. DAN 902(3)-4 H-18 DRYWELL FLOOR DRN SUMP LVL HI-HI7. DOA 0040-01 SLOW LEAK8. DOP 2000-24 DRYWELL SUMP OPERATION9. DEOP 300-1, Secondary Containment Control10. UFSAR Section 5.2.5Month 20XXDR 3-66EP-AA-1 004 (Revision XX)
Annp.xNuclearDlresden Annex~ FYAlnn Nucler~IRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC5Initiating Condition:Primary Containment radiationOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. Drywell radiation monitor reading > 100 R/hr (>1.00 E+02 R/hr).Basis:The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that reactor coolant activityequals Technical Specification allowable limits. This value is lower than that specifiedfor Fuel Clad Barrier FC5 Loss Threshold since it indicates a loss of the RCS Barrieronly.There is no RCS Potential Loss threshold associated with Primary ContainmentRadiation.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. EP-EAL-061 1, Criteria for Choosing Containment Radiation Monitor ReadingIndicative of loss of the RCS Barrier.Month 20XXDR 3-67EP-AA-1 004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC7Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. Any condition in the opinion of the EmergencyBarrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergencyof the RCS Barrier.Basis:Loss Threshold #1 BasisDirector that indicates Loss of the RCSDirector that indicates Potential LossThis threshold addresses any other factors that are to be used by the EmergencyDirector in determining whether the RCS Barrier is lost.Potential Loss Threshold #2 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the RCS Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-68EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT2Initiating Condition:RPV Water LevelOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:POTENTIAL LOSSPlant conditions indicate Primary Containment flooding is required.Basis:The Potential Loss threshold is identical to the Fuel Clad Barrier RC2 Loss thresholdRPV Water Level. The Potential Loss requirement for Primary Containment Floodingindicates adequate core cooling cannot be restored and maintained and that coredamage is possible. BWR EPGs/SAMGs specify the conditions that require primarycontainment flooding. When primary containment flooding is required, the EPGs areexited and SAMGs are entered. Entry into SAMGs is a logical escalation in response tothe inability to restore and maintain adequate core cooling.PRA studies indicate that the condition of this Potential Loss threshold could be a coremelt sequence which, if not corrected, could lead to RPV failure and increased potentialfor primary containment failure. In conjunction with the RPV water level Loss thresholdsin the Fuel Clad and RCS barrier columns, this threshold results in the declaration of aGeneral Emergency.There is no Loss Threshold associated with this IC.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. Severe Accident Management Guidelines3. DEOP 0100, RPV Control4. DEOP 0400-01, RPV Flooding5. DEOP 0400-05, Failure to ScramMonth 20XXDR 3-69EP-AA-1004 (Revision XX)
Dresden AnnexExallon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT3Initiating Condition:Primary Containment ConditionsOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. UNPLANNED rapid drop in Drywell pressure following Drywell pressure rise.OR2. Drywell pressure response not consistent with LOCA conditions.POTENTIAL LOSS3. Drywell pressure > 62 psig and rising.OR4. a. Drywell or torus hydrogen concentration > 6%.ANDb. Drywell or torus oxygen concentration > 5%.OR5. Heat Capacity Limit (DEOP 200-1, Fig.M) exceeded.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.Loss Threshold #1 and #2 BasisRapid UNPLANNED loss of primary containment pressure (i.e., not attributable toDrywell spray or condensation effects) following an initial pressure rise indicates a lossof primary containment integrity. Primary containment pressure should rise as a result ofmass and energy release into the primary containment from a LOCA. Thus, primarycontainment pressure not increasing under these conditions indicates a loss of primarycontainment integrity.These thresholds rely on operator recognition of an unexpected response for thecondition and therefore a specific value is not assigned. The unexpected(UNPLANNED) response is important because it is the indicator for a containmentbypass condition. A pressure suppression bypass path would not be an indication of acontainment breach.Month 20XXDR 3:70EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT3 (cont)Basis (cont):Potential Loss Threshold #3 BasisThe threshold pressure is the primary containment internal design pressure. Structuralacceptance testing demonstrates the capability of the primary containment to resistpressures greater than the internal design pressure. A pressure of this magnitude isgreater than those expected to result from any design basis accident and, thus,represent a Potential Loss of the Containment barrier.Potential Loss Threshold #4 BasisIf hydrogen concentration reaches or exceeds the lower flammability limit, as defined inplant EOPs, in an oxygen rich environment, a potentially explosive mixture exists. If thecombustible mixture ignites inside the primary containment, loss of the Containmentbarrier could occur.Potential Loss Threshold #5 BasisThe HCTL is a function of RPV pressure, Torus temperature and Torus water level. It isutilized to preclude failure of the containment and equipment in the containmentnecessary for the safe shutdown of the plant and therefore, the inability to maintainplant parameters below the limit constitutes a potential loss of containment.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. UFSAR 6.2.1.3.2.13. UFSAR Table 6.2-34. UFSAR 15.6.55. UFSAR 6.2.1.16. DEOP 200-1 Primary Containment Control7. DEOP 200-2 Hydrogen ControlMonth 20XXDR 3-71EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclaarRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT5Initiating Condition:Primary Containment RadiationOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:POTENTIAL LOSS1. Drywell radiation monitor reading > 1.60 E+03 R/hr (1600 R/hr).Basis:There is no Loss threshold associated with Primary Containment Radiation.The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that 20% of the fuel cladding hasfailed. This level of fuel clad failure is well above that used to determine the analogousFuel Clad Barrier Loss and RCS Barrier Loss thresholds.NUREG-1 228, Source Estimations During Incident Response to Severe Nuclear PowerPlant Accidents, indicates the fuel clad failure must be greater than approximately 20%in order for there to be a major release of radioactivity requiring offsite protectiveactions. For this condition to exist there must already have been a loss of the RCSBarrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as apotential loss of containment which would then escalate the emergency classificationlevel to a General Emergency.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. Core Damage Assessment Methodology (CDAM)Month 20XXDR 3-72EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT6Initiating Condition:Primary Containment Isolation FailureOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. UNISOLABLE direct downstream pathway to the environment exists after primarycontainment isolation signal.OR2. Intentional Primary Containment venting/purging per EOPs or SAMGs due toaccident conditions.OR3. UNISOLABLE primary system leakage that results in EITHER of the following:a. Secondary Containment area temperature > DEOP 300-1, Maximum Safeoperating levels.ORb. Secondary Containment area radiation level > DEOP 300-1, Maximum Safeoperating levels.Basis:UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.These thresholds address incomplete containment isolation that allows anUNISOLABLE direct release to the environment.Loss Threshold #1 BasisThe use of the modifier "direct" in defining the release path discriminates againstrelease paths through interfacing liquid systems or minor release pathways, such asinstrument lines, not protected by the Primary Containment Isolation System (PCIS).Leakage into a closed system is to be considered only if the closed system is breachedand thereby creates a significant pathway to the environment. Examples includeunisolable Main Steamline, HPCI steamline breaks, unisolable RWCU system breaks,and unisolable containment atmosphere vent paths.Examples of "downstream pathway to the environment" could be through theTurbine/Condenser, or direct release to the Turbine or Reactor Building.Month 20XXDR 3-73EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT6 (cont)Basis (cont):The existence of a filter is not considered in the threshold assessment. Filters do notremove fission product noble gases. In addition, a filter could become ineffective due toiodine and/or particulate loading beyond design limits (i.e., retention ability has beenexceeded) or water saturation from steam/high humidity in the release stream.Following the leakage of RCS mass into primary containment and a rise in primarycontainment pressure, there may be minor radiological releases associated withallowable primary containment leakage through various penetrations or systemcomponents. Minor releases may also occur if a primary containment isolation valve(s)fails to close but the primary containment atmosphere escapes to an enclosed system.These releases do not constitute a loss or potential loss of primary containment butshould be evaluated using the Recognition Category R ICs.Loss Threshold #2 BasisEOPs may direct primary containment isolation valve logic(s) to be intentionallybypassed, even if offsite radioactivity release rate limits will be exceeded. Under theseconditions with a valid primary containment isolation signal, the containment should alsobe considered lost if primary containment venting is actually performed.Intentional venting of primary containment for primary containment pressure orcombustible gas control to the secondary containment and/or the environment is a Lossof the Containment. Venting for primary containment pressure control when not in anaccident situation (e.g., to control pressure below the Drywell high pressure scramsetpoint) does not meet the threshold condition.Loss Threshold #3 BasisThe Max Safe Operating Temperature and the Max Safe Operating Radiation Level areeach the highest value of these parameters at which neither: (1) equipment necessaryfor the safe shutdown of the plant will fail, nor (2) personnel access necessary for thesafe shutdown of the plant will be precluded. EOPs utilize these temperatures andradiation levels to establish conditions under which RPV depressurization is required.The temperatures and radiation levels should be confirmed to be caused by RCSleakage from a primary system. A primary system is defined to be the pipes, valves, andother equipment which connect directly to the RPV such that a reduction in RPVpressure will effect a decrease in the steam or water being discharged through anunisolated break in the system.Month 20XXDR 3-74EP-AA-1004 (Revision XX)
I=xelnn flreQrIn Annex FvAlnn NmuclIanrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT6 (cont)Basis (cont):In general, multiple indications should be used to determine if a primary system isdischarging outside Primary Containment. For example, a high area radiation conditiondoes not necessarily indicate that a primary system is discharging into the ReactorBuilding since this may be caused by radiation shine from nearby steam lines or themovement of radioactive materials. Conversely, a high area radiation condition inconjunction with other indications (e.g. room flooding, high area temperatures, reports ofsteam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpectedMain Turbine Control Valve closure) may indicate that a primary system is discharginginto the Reactor Building.In combination with RCS Barrier RC4 Potential Loss Threshold #3 this threshold wouldresult in a Site Area Emergency.There is no Potential Loss threshold associated with Primary Containment IsolationFailure.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. DEOP 200-1 Primary Containment Control3. DEOP 200-2 Hydrogen Control4. DEOP 500-4 Containment Venting5. DEOP 300-1 Secondary Containment ControlMonth 20XXDR 3-75EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT7Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. Any condition in the opinion of the EmergencyContainment Barrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergencyof the Containment Barrier.Basis:Loss Threshold #1 Basis:Director that indicates Loss of theDirector that indicates Potential LossThis threshold addresses any other factors that are to be used by the EmergencyDirector in determining whether the Containment Barrier is lost.Potential Loss Threshold #2 Basis:This threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is potentially lost. The EmergencyDirector should also consider whether or not to declare the barrier potentially lost in theevent that barrier status cannot be monitored.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-76EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG1Initiating Condition:Prolonged loss of all Off-site and all On-Site AC power to emergency buses.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1 Loss of ALL offsite AC power to unit ECCS buses.AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators tosupply power to unit ECCS buses.AND3. EITHER of the following:a. Restoration of at least one unit ECCS bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely.ORb. RPV water level cannot be restored and maintained > -164 inches.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a prolonged loss of all power sources to AC emergency buses. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiringelectric power including those necessary for emergency core cooling, containment heatremoval/pressure control, spent fuel heat removal and the ultimate heat sink. Aprolonged loss of these buses will lead to a loss of any fission product barriers. Inaddition, fission product barrier monitoring capabilities may be degraded under theseconditions.RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.The EAL should require declaration of a General Emergency prior to meeting thethresholds for IC FG1. This will allow additional time for implementation of offsiteprotective actions.Month 20XXDR 3-77EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG1 (cont)Basis (cont):Escalation of the emergency classification from Site Area Emergency will occur if it isprojected that power cannot be restored to at least one AC emergency bus by the endof the analyzed station blackout coping period. Beyond this time, plant responses andevent trajectory are subject to greater uncertainty, and there is an increased likelihoodof challenges to multiple fission product barriers.The estimate for restoring at least one emergency bus should be based on a realisticappraisal of the situation. Mitigation actions with a low probability of success should notbe used as a basis for delaying a classification upgrade. The goal is to maximize thetime available to prepare for, and implement, protective actions for the public.The EAL will also require a General Emergency declaration if the loss of AC powerresults in parameters that indicate an inability to adequately remove decay heat fromthe core.Basis Reference(s):1. NEI 99-01 Rev 6, SG12. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure5. DOA 6500-01 4-KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout GeneratorTies to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4-KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC Power10. DEOP100 RPV Control11. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Proceduresand Severe Accident Management GuidelinesMonth 20XXDR 3-78EP-AA-1004 (Revision XX)
Dresden AnnawExelon NuclearDresde AnnexExelon NuclIearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS1Initiating Condition:Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:e The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC Power to unit ECCS buses.AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators tosupply power to unit ECCS buses.AND3. Failure to restore power to at least one ECCS bus in < 15 minutes from the time ofloss of both offsite and onsite AC power.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergencycore cooling, containment heat removal/pressure control, spent fuel heat removal andthe ultimate heat sink. In addition, fission product barrier monitoring capabilities may bedegraded under these conditions. This IC represents a condition that involves actual orlikely major failures of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RG1, FG1, MG1, orMG2.Month 20XXDR 3-79EP-AA-1004 (Revision XX)
Dresden AnnexN rDresden Annex Exellon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS1 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, SS12. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout GeneratorTies to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-80EP-AA-1 004 (Revision XX)
Dresden AnnexDlresden Annex Fvalnn Nucler~IRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA1Initiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. AC power capability to unit ECCS buses reduced to only one of the following powersources for > 15 minutes.* Reserve auxiliary Transformer TR-22 (TR-32)* Unit auxiliary transformer TR-21 (TR-31)* Unit Emergency Diesel Generator DG 2(3)* Shared Emergency Diesel Generator DG 2/3* Station Blackout Diesel Generator DG 2(3)* Unit crosstie breakersAND2. ANY additional single power source failure will result in a loss of ALL AC power toSAFETY SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS. In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment. This IC provides an escalation path from ICMUl.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below.* A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).Month 20XXDR 3-81EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA1 (cont)Basis (cont):" A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being fed from the unitmain generator." A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.Escalation of the emergency classification level would be via IC MS1.Basis Reference(s):1. NEI 99-01 Rev 6, SA12. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 KV System and 345 KV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout GeneratorTies to Plant Auxiliary Electric System7. UFSAR 9.5.9 Station Blackout System8. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-82EP-AA-1004 (Revision XX) rlr,-erl--n AnnovKlmmlnnrlrflra~rI~n A nnav I t~v~ LI. I l~ rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU1Initiating Condition:Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Loss of ALL offsite AC power capability to unit ECCS buses for > 15 minutes.Basis:This IC addresses a prolonged loss of offsite power. The loss of offsite power sourcesrenders the plant more vulnerable to a complete loss of power to AC emergency buses.This condition represents a potential reduction in the level of safety of the plant.For emergency classification purposes, "capability" means that an offsite AC powersource(s) is available to the emergency buses, whether or not the buses are poweredfrom it. (e.g. unit cross-tie breakers)Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof offsite power.Escalation of the emergency classification level would be via IC MAI.Basis Reference(s):1. NEI 99-01 Rev 6, SU12. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 kV System and 345 kV Alternate Supply Failure5. DOA 6500-01 4kV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout GeneratorTies to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4kV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-83EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG2Initiating Condition:Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to unit ECCS buses.AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generatorsto supply power to vital buses.AND3. Voltage is < 105 VDC on 125 VDC battery buses #2 and #3.AND4. ALL AC and Vital DC power sources have been lost for > 15 minutes.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiringelectric power including those necessary for emergency core cooling, containment heatremoval/pressure control, spent fuel heat removal and the ultimate heat sink. A loss ofVital DC power compromises the ability to monitor and control SAFETY SYSTEMS. Asustained loss of both AC and DC power will lead to multiple challenges to fissionproduct barriers.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses. The 15-minute emergency declaration clock begins at the point when all EALconditions are met.Month 20XXDR 3-84EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG2 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, SG82. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout GeneratorTies to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC Power10. UFSAR 8.3.211. DOA 6900-02(3) Failure of Unit 2(3) 125 VDC Power Supply12. Technical Specification B.3.8.4, DC Power Sources -OperatingMonth 20XXDR 3-85EP-AA-1004 (Revision XX)
AnnoyDresden Annex Pvalnn Kiiii-borRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS2Initiating Condition:Loss of all vital DC power for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Voltage is < 105 VDC on 125 VDC battery buses #2 and #3 for > 15 minutes.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a loss of Vital DC power which compromises the ability to monitorand control SAFETY SYSTEMS. In modes above Cold Shutdown, this conditioninvolves a major failure of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RG1, FG1 or MG2.Basis Reference(s):1. NEI 99-01 Rev 6, SS82. UFSAR 8.3.23. DOA 6900-02(3) Failure of Unit 2(3) 125 VDC Power Supply4. Technical Specification B.3.8.4, DC Power Sources -OperatingMonth 20XXDR 3-86EP-AA-1004 (Revision XX)
AnnoyDlresden Annex Fvplnn N"H~IanrRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS3Initiating Condition:Inability to shutdown the reactor causing a challenge to core cooling or RCS heatremoval.Operating Mode Applicability:1,2Emergency Action Level (EAL):1. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 6%.AND2, ALL manual / ARI actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 6%.AND3. EITHER of the following conditions exist:* RPV water level cannot be restored and maintained > -164 inchesOR* Heat Capacity Limit (DEOP 200-1, Fig. M) exceeded.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, all subsequent operator manualactions, both inside and outside the Control Room including driving in control rods andboron injection, are unsuccessful, and continued power generation is challenging thecapability to adequately remove heat from the core and/or the RCS. This condition willlead to fuel damage if additional mitigation actions are unsuccessful and thus warrantsthe declaration of a Site Area Emergency.In some instances, the emergency classification resulting from this IC/EAL may behigher than that resulting from an assessment of the plant responses and symptomsagainst the Recognition Category F ICs/EALs. This is appropriate in that theRecognition Category F ICs/EALs do not address the additional threat posed by afailure to shutdown the reactor. The inclusion of this IC and EAL ensures the timelydeclaration of a Site Area Emergency in response to prolonged failure to shutdown thereactor.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.Escalation of the emergency classification level would be via IC RG1 or FG1.Month 20XXDR 3-87EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS3 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, SS52. DEOP 100 RPV Control3. DEOP 400-5 Failure to Scram4. DEOP 200-1 Primary Containment Control5. Technical Support GuidelinesMonth 20XXDR 3-88EP-AA-1004 (Revision XX)
Dresden AnnexDresden Annex Exelnn Nule a~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA3Initiating Condition:Automatic or manual scram fails to shutdown the reactor, and subsequent manualactions taken at the reactor control consoles are not successful in shutting down thereactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note:* A manual action is any operator action, or set of actions, which causes the controlrods to be rapidly inserted into the core, and does not include manually driving incontrol rods or implementation of boron injection strategies.1. Automatic or manual scram did not shutdown the reactor as indicated by ReactorPower > 6%.AND2. Manual / ARI actions taken at the reactor control consoles are not successful inshutting down the reactor as indicated by Reactor Power > 6%.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and subsequent operator manualactions taken at the reactor control consoles to shutdown the reactor are alsounsuccessful. This condition represents an actual or potential substantial degradationof the level of safety of the plant. An emergency declaration is required even if thereactor is subsequently shutdown by an action taken away from the reactor controlconsoles since this event entails a significant failure of the RPS.A manual action at the reactor control consoles is any operator action, or set of actions,which causes the control rods to be rapidly inserted into the core (e.g., initiating amanual reactor scram. This action does not include manually driving in control rods orimplementation of boron injection strategies. If this action(s) is unsuccessful, operatorswould immediately pursue additional manual actions at locations away from the reactorcontrol consoles (e.g., locally opening breakers). Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the reactor consoles".Taking the Reactor Mode Switch to Shutdown is considered to be a manual scramaction.Month 20XXDR 3-89EP-AA-1 004 (Revision XX)
Dresden AnnexExelon NuclearDresden Annex Exellon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA3 (cont)Basis (cont):The plant response to the failure of an automatic or manual reactor scram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If the failure to shutdown the reactor is prolongedenough to cause a challenge to the RPV water level or RCS heat removal safetyfunctions, the emergency classification level will escalate to a Site Area Emergency viaIC MS3. Depending upon plant responses and symptoms, escalation is also possiblevia IC FS1. Absent the plant conditions needed to meet either IC MS3 or FS1, an Alertdeclaration is appropriate for this event.It is recognized that plant responses or symptoms may also require an Alert declarationin accordance with the Recognition Category F ICs; however, this IC and EAL areincluded to ensure a timely emergency declaration.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Basis Reference(s):1. NEI 99-01 Rev 6, SA52. DEOP 100 RPV Control3. DEOP 400-5 Failure to Scram4. DEOP 200-1 Primary Containment ControlMonth 20XXDR 3-90EP-AA-1004 (Revision XX) nrgmrtn AnngnyC-re%10%n K111AAMnrflr~av4~m, A mi ii~v I ~i Ma us r a ~
- s-s. ...~a ~ -I I I~ -~ IRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU3Initiating Condition:Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note:* A manual action is any operator action, or set of actions, which causes the controlrods to be rapidly inserted into the core, and does not include manually driving incontrol rods or implementation of boron injection strategies.1. a. Automatic scram did not shutdown the reactor as indicated by Reactor Power> 6%.ANDb. Subsequent manual / ARI action taken at the reactor control consoles issuccessful in shutting down the reactor.OR2. a. Manual scram did not shutdown the reactor as indicated by Reactor Power> 6%.ANDb. EITHER of the following:1. Subsequent manual / ARI action taken at the reactor control consoles issuccessful in shutting down the reactor.OR2. Subsequent automatic scram / ARI is successful in shutting down thereactor.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and either a subsequent operatormanual action taken at the reactor control consoles or an automatic scram is successfulin shutting down the reactor. This event is a precursor to a more significant conditionand thus represents a potential degradation of the level of safety of the plant.Month 20XXDR 3-91EP-AA-1004 (Revision XX)
Dresden AnnexI::Yplnn Dresden Annex FYAlnn Nut-h-a~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU3 (cont)Basis (cont):EAL #1 BasisFollowing the failure on an automatic reactor scram, operators will promptly initiatemanual actions at the reactor control consoles to shutdown the reactor (e.g., initiate amanual reactor scram). If these manual actions are successful in shutting down thereactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.EAL #2 BasisIf an initial manual reactor trip is unsuccessful, operators will promptly take manualaction at another location(s) on the reactor control consoles to shutdown the reactor(e.g., initiate a manual reactor scram / ARI using a different switch). Depending uponseveral factors, the initial or subsequent effort to manually scram the reactor, or aconcurrent plant condition, may lead to the generation of an automatic reactor scramsignal. If a subsequent manual or automatic scram / ARI is successful in shutting downthe reactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.A manual action at the reactor control consoles is any operator action, or set of actions,which causes the control rods to be rapidly inserted into the core (e.g., initiating amanual reactor scram). This action does not include manually driving in control rods orimplementation of boron injection strategies. Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the reactor consoles".Taking the Reactor Mode Switch to Shutdown is considered to be a manual scramaction.The plant response to the failure of an automatic or manual reactor scram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If subsequent operator manual actions taken at thereactor control consoles are also unsuccessful in shutting down the reactor, then theemergency classification level will escalate to an Alert via IC MA3. Depending upon theplant response, escalation is also possible via IC FAI. Absent the plant conditionsneeded to meet either IC MA3 or FAI, an Unusual Event declaration is appropriate forthis event.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Month 20XXDR 3-92EP-AA-1004 (Revision XX)
Dresden AnnexN Dresden Annex Fvalnn NucleIazrRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU3 (cont)Basis (cont):Should a reactor scram signal be generated as a result of plant work (e.g., RPS setpointtesting), the following classification guidance should be applied." If the signal generated as a result of plant work causes a plant transient that createsa real condition that should have included an automatic reactor scram and the RPSfails to automatically shutdown the reactor, then this IC and the EALs are applicable,and should be evaluated." If the signal generated as a result of plant work does not cause a plant transient butshould have generated an RPS scram signal and the scram failure is determinedthrough other means (e.g., assessment of test results), then this IC and the EALsare not applicable and no classification is warranted.Basis Reference(s):1. NEI 99-01 Rev 6, SU52. Technical Specifications Table 3.3.1.1-13. DEOP 100 RPV Control4. DEOP 400-5 Failure to ScramMonth 20XXDR 3-93EP-AA-1004 (Revision XX) rnnri=rl-" A snn--rfl rnal~vi A~ui~vFvainn NucleIa2rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA4Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED event results in the inability to monitor ANY Table M1 parameter fromwithin the Control Room for > 15 minutes.Table M1 Control Room Parameters* Reactor Power" RPV Water Level" RPV Pressure* Primary Containment Pressure* Torus Level* Torus TemperatureAND2. ANY Table M2 transient in progress.Table M2 Significant Transients* Turbine Trip" Reactor Scram* ECCS Activation" Recirc. Runback > 25% Reactor Power Change* Thermal Power oscillations > 10% Reactor Power ChangeMonth 20XXDR 3-94EP-AA-1004 (Revision XX)
Exelon NuclearDresden Annex Exelon NuclIearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA4 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses the difficulty associated with monitoring rapidly changing plantconditions during a transient without the ability to obtain SAFETY SYSTEM parametersfrom within the Control Room. During this condition, the margin to a potential fissionproduct barrier challenge is reduced. It thus represents a potential substantialdegradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for any of the listedparameters cannot be determined from within the Control Room. This situation wouldrequire a loss of all of the Control Room sources for the given parameter(s). Forexample, the reactor power level cannot be determined from any analog, computerpoint, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)to determine if an NRC event report is required. The event would be reported if itsignificantly impaired the capability to perform emergency assessments. In particular,emergency assessments necessary to implement abnormal operating procedures,emergency operating procedures, and emergency plan implementing proceduresaddressing emergency classification, accident assessment, or protective actiondecision-making.This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity control, RPV water level and RCS heat removal. The lossof the ability to determine any of these parameters from within the Control Room isconsidered to be more significant than simply a reportable condition. In addition, if allindication sources for any of the listed parameters are lost, then the ability to determinethe values of other SAFETY SYSTEM parameters may be impacted as well. Forexample, if the value for RPV water level cannot be determined from the indications andrecorders on a main control board, the SPDS or the plant computer, the availability ofother parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation of the emergency classification level would be via ICs FS1 or IC RS1.Basis Reference(s):1. NEI 99-01 Rev 6, SA2Month 20XXDR 3-95EP-AA-1004 (Revision XX)
AnnAyDlreden Annex Fwalnn Nur~clarRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU4Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.UNPLANNED event results in the inability to monitor ANY Table M1 parameter fromwithin the Control Room for > 15 minutes.Table M1 Control Room Parameters* Reactor Power" RPV Water Level* RPV Pressure" Primary Containment Pressure* Torus Level* Torus TemperatureBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses the difficulty associated with monitoring normal plant conditionswithout the ability to obtain SAFETY SYSTEM parameters from within the ControlRoom. This condition is a precursor to a more significant event and represents apotential degradation in the level of safety of the plant.Month 20XXDR 3-96EP-AA-1 004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU4 (cont)Basis (cont):As used in this EAL, an "inability to monitor" means that values for any of the listedparameters cannot be determined from within the Control Room. This situation wouldrequire a loss of all of the Control Room sources for the given parameter(s). Forexample, the reactor power level cannot be determined from any analog, digital andrecorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)to determine if an NRC event report is required. The event would be reported if itsignificantly impaired the capability to perform emergency assessments. In particular,emergency assessments necessary to implement abnormal operating procedures,emergency operating procedures, and emergency plan implementing proceduresaddressing emergency classification, accident assessment, or protective actiondecision-making.This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity control, core cooling and RCS heat removal. The loss ofthe ability to determine any of these parameters from within the Control Room isconsidered to be more significant than simply a reportable condition. In addition, if allindication sources for any of the listed parameters are lost, then the ability to determinethe values of other SAFETY SYSTEM parameters may be impacted as well. Forexample, if the value for reactor vessel level cannot be determined from the indicationsand recorders on a main control board, the SPDS or the plant computer, the availabilityof other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation of the emergency classification level would be via IC MA4.Basis Reference(s):1. NEI 99-01 Rev 6, SU2Month 20XXDR 3-97EP-AA-1004 (Revision XX)
AnnexFxelon NuclearDpresden Annex Exe..n.Nu.l.a.RECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA5Initiating Condition:Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):1. The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)" Internal or external flooding event* High winds or tornado strike* FIRE" EXPLOSION" Other events with similar hazard characteristics as determined by theShift ManagerAND2. EITHER of the following:a. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM required by TechnicalSpecification for the current operating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure required by Technical Specification for thecurrent operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization. A release of steam (from highenergy lines or components) or an electrical component failure (caused by short circuits,grounding, arcing, etc.) should not automatically be considered an explosion. Suchevents may require a post-event inspection to determine if the attributes of an explosionare present.Month 20XXDR 3-98EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA5 (cont)Basis (cont):SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.VISIBLE DAMAGE: Damage to a component or structure that is readily observablewithout measurements, testing, or analysis. The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components, required for the current operatingmode, "required", i.e. required to be operable by Technical Specifications for the currentoperating mode. This condition significantly reduces the margin to a loss or potentialloss of a fission product barrier, and therefore represents an actual or potentialsubstantial degradation of the level of safety of the plant. Manual or automatic electricalisolation of safety equipment due to flooding, in and of itself, does not constitutedegraded performance and is classified under HU6.EAL #2.a BasisThis EAL addresses damage to a SAFETY SYSTEM train that is required to beoperable by Technical Specifications for the current operating mode, and is in operationsince indications for it will be readily available. The indications of degradedperformance should be significant enough to cause concern regarding the operability orreliability of the SAFETY SYSTEM train.EAL #2.b BasisThis EAL addresses damage to a SAFETY SYSTEM component that is required to beoperable by Technical Specifications for the current operating mode, and is not inoperation or readily apparent through indications alone, as well as damage to astructure containing SAFETY SYSTEM components. Operators will make thisdetermination based on the totality of available event and damage report information.This is intended to be a brief assessment not requiring lengthy analysis or quantificationof the damage.Escalation of the emergency classification level would be via IC FS1 or RS1.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):1. NEI 99-01, Rev 6 SA9Month 20XXDR 3-99EP-AA-1004 (Revision XX)
Dresden Annexl:xelnn N rDresden Annex Fxelnn NucleIarRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU6Initiating Condition:RCS leakage for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage in the Drywell > 10 gpm for> 15 minutes.OR2. RCS identified leakage in the Drywell >25 gpm for > 15 minutes.OR3. Leakage from the RCS to a location outside the Drywell >25 gpm for > 15 minutes.Basis:UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.This IC addresses RCS leakage which may be a precursor to a more significant event.In this case, RCS leakage has been detected and operators, following applicableprocedures, have been unable to promptly isolate the leak. This condition is consideredto be a potential degradation of the level of safety of the plant.EAL #1 and EAL #2 BasisThese EALs are focused on a loss of mass from the RCS due to "unidentified leakage","pressure boundary leakage" or "identified leakage" (as these leakage types are definedin the plant Technical Specifications).EAL #3 BasisThis EAL addresses an RCS mass loss caused by an UNISOLABLE leak through aninterfacing system.These EALs thus apply to leakage into the containment, a secondary-side system or alocation outside of containment.Month 20XXDR 3-100EP-AA-1004 (Revision XX)
Dresden AnnexNuclearDresden Annex FxeInn NuclerIsrRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU6 (cont)Basis (cont):The leak rate values for each EAL were selected because they are usually observablewith normal Control Room indications. Lesser values typically require time-consumingcalculations to determine (e.g., a mass balance calculation). EAL #1 uses a lower valuethat reflects the greater significance of unidentified or pressure boundary leakage.The release of mass from the RCS due to the as-designed/expected operation of anyrelief valve does not warrant an emergency classification.A stuck-open Electromatic relief valve (ERV)/Target Rock SRV or ERV/ Target RockSRV leakage is not considered either identified or unidentified leakage by TechnicalSpecifications and, therefore, is not applicable to this EAL.The 15-minute threshold duration allows sufficient time for prompt operator actions toisolate the leakage, if possible.Escalation of the emergency classification level would be via ICs of RecognitionCategory R or F.Basis Reference(s):1. NEI 99-01 Rev 6, SU42. Technical Specification 3.4.4, RCS Operational Leakage3. UFSAR 5.2.5, Detection of Leakage through Reactor Coolant Pressure Boundary4. Technical Specifications 3.4.55. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log6. DAN 902(3)-4 A-17 Drywell Equip Sump LvI HI-HI7. DAN 902(3)-4 H-18 Drywell Floor Drn Sump LvI HI-HI8. DOA 0040-01 Slow Leak9. DOP 2000-24 Drywell Sump Operation10. DGP 02-02 Reactor Vessel Slow FillMonth 20XXDR 3-101EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU7Initiating Condition:Loss of all On-site or Off-site communications capabilities.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):" Loss of ALL Table M3 Onsite communications capability affecting the ability toperform routine operations.OR" Loss of ALL Table M3 Offsite communication capability affecting the ability toperform offsite notifications.OR" Loss of ALL Table M3 NRC communication capability affecting the ability toperform NRC notifications.Table M3 Communications CapabilitySystem Onsite Offsite NRCPlant Radio XPlant Page XSound Powered Phones XAll telephone Lines (Commercial and microwave) X X XENS X XHPN X XSatellite Phones X XBasis:This IC addresses a significant loss of on-site, offsite, or NRC communicationscapabilities. While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).Month 20XXDR 3-102EP-AA-1004 (Revision XX)
Dresden AnnexDresden Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU7 (cont)Basis (cont):EAL #1 BasisAddresses a total loss of the communications methods used in support of routine plantoperations.EAL #2 BasisAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in procedure EP-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) Form.EAL #3 BasisAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, SU62. EP-MW-124-1001 Facilities Inventories and Equipment Tests3. UFSAR 9.5.24. DOA 0010-14 Loss of Off-Site Telephone Communication SystemsMonth 20XXDR 3-103EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCAIInitiating Condition:Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:4,5, DEmergency Action Level (EAL):Note:" The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded." Loss of ALL offsite AC power to unit ECCS buses.AND" Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency dieselgenerators to supply power to unit ECCS buses.AND" Failure to restore power to at least one unit ECCS bus in < 15 minutes from thetime of loss of both offsite and onsite AC power.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-relatedThis IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergencycore cooling, containment heat removal/pressure control, spent fuel heat removal andthe ultimate heat sink.When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas a Site Area Emergency because of the increased time available to restore anemergency bus to service. Additional time is available due to the reduced core decayheat load, and the lower temperatures and pressures in various plant systems. Thus,when in these modes, this condition represents an actual or potential substantialdegradation of the level of safety of the plant.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via IC CS6 or RS1.Month 20XXDR 3-104EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA1 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CA22. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 KV System and 345 KV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-147. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-105EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSculInitiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:4,5, DEmergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. AC power capability to unit ECCS buses reduced to only one of the followingpower sources for > 15 minutes.* Reserve auxiliary Transformer TR-22 (TR-32)* Unit auxiliary transformer TR-21 (TR-31)* Unit Emergency Diesel Generator DG 2(3)* Shared Emergency Diesel Generator DG 2/3* Station Blackout Diesel Generator DG 2(3)* Unit crosstie breakersAND2. ANY additional single power source failure will result in a loss of ALL AC power toSAFETY SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS. In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment.Month 20XXDR 3-106EP-AA-1004 (Revision XX)
Dresden rDlresden Annex FwAlnn Nui~clarRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCUI (cont)Basis (cont):When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas an Alert because of the increased time available to restore another power source toservice. Additional time is available due to the reduced core decay heat load, and thelower temperatures and pressures in various plant systems. Thus, when in thesemodes, this condition is considered to be a potential degradation of the level of safety ofthe plant.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below." A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator)." A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator." A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.The subsequent loss of the remaining single power source would escalate the event toan Alert in accordance with IC CAl.Basis Reference(s):1. NEI 99-01 Rev 6 CU22. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 KV System and 345 KV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout GeneratorTies to Plant Auxiliary Electric System7. UFSAR 9.5.9 Station Blackout System8. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-107EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA2Initiating Condition:Hazardous event affecting SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:4,5Emergency Action Level (EAL):1. The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)" Internal or external flooding event" High winds or tornado strike" FIRE" EXPLOSION" Other events with similar hazard characteristics as determined by theShift ManagerAND2. EITHER of the following:a. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM required by TechnicalSpecifications for the current operating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure required by Technical Specifications for thecurrent operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization. A release of steam (from highenergy lines or components) or an electrical component failure (caused by short circuits,grounding, arcing, etc.) should not automatically be considered an explosion. Suchevents may require a post-event inspection to determine if the attributes of an explosionare present.Month 20XXDR 3-108EP-AA-1004 (Revision XX)
Dresden AnnexDresen AnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA2 (cont)Basis (cont):SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.VISIBLE DAMAGE: Damage to a component or structure that is readily observablewithout measurements, testing, or analysis. The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components, needed for the current operatingmode, "needed", i.e. required to be operable by Technical Specifications for the currentoperating mode. This condition significantly reduces the margin to a loss or potentialloss of a fission product barrier, and therefore represents an actual or potentialsubstantial degradation of the level of safety of the plant. Manual or automatic electricalisolation of safety equipment due to flooding, in and of itself, does not constitutedegraded performance and is classified under HU6.EAL #2.a BasisAddresses damage to a SAFETY SYSTEM train that is "needed", i.e. required to beoperable by Technical Specifications for the current operating mode, and is in operationsince indications for it will be readily available. The indications of degradedperformance should be significant enough to cause concern regarding the operability orreliability of the SAFETY SYSTEM train.EAL #2.b BasisAddresses damage to a SAFETY SYSTEM component that is "needed", i.e. required tobe operable by Technical Specifications for the current operating mode, and is not inoperation or readily apparent through indications alone, or to a structure containingSAFETY SYSTEM components. Operators will make this determination based on thetotality of available event and damage report information. This is intended to be a briefassessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC CS6 or RSI.If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):1. NEI 99-01 Rev 6, CA6Month 20XXDR 3-109EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU3Initiating Condition:Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.Voltage is < 105 VDC on required 125 VDC battery busses #2 and #3 for > 15 minutes.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a loss of Vital DC power which compromises the ability to monitorand control operable SAFETY SYSTEMS when the plant is in the cold shutdown orrefueling mode. In these modes, the core decay heat load has been significantlyreduced, and coolant system temperatures and pressures are lower; these conditionsrise the time available to restore a vital DC bus to service. Thus, this condition isconsidered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to supportoperation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.For example, if Train A is out-of-service (inoperable) for scheduled outage maintenancework and Train B is in-service (operable), then a loss of Vital DC power affecting Train Bwould require the declaration of an Unusual Event. A loss of Vital DC power to Train Awould not warrant an emergency classification.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Depending upon the event, escalation of the emergency classification level would be viaIC CA6 or CA5, or an IC in Recognition Category R.Month 20XXDR 3-110EP-AA-1004 (Revision XX)
Annexflresrh-n Annex FvAlnn NucleIiarRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU3 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CU42. UFSAR 8.3.2.2.1 Safety Related 125-V System3. DOA 6900-02(3) Failure of Unit 2(3) 125 VDC Power Supply4. Technical Specification Basis B.3.8.5, DC Power Sources -Shutdown5. Technical Specification Basis B.3.8.4, DC Power Sources -OperatingMonth 20XXDR 3-111EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU4Initiating Condition:Loss of all onsite or offsite communications capabilities.Operating Mode Applicability:4,5, DEmergency Action Level (EAL):1. Loss of ALL Table C1 Onsite communications capability affecting the ability toperform routine operations.OR2. Loss of ALL Table C1 Offsite communication capability affecting the ability toperform offsite notifications.OR3. Loss of ALL Table C1 NRC communication capability affecting the ability toperform NRC notifications.Table C1 Communications CapabilitySystem Onsite Offsite NRCPlant Radio XPlant Page XSound Powered Phones XAll telephone Lines (Commercial and microwave) X X XENS X XHPN X XSatellite Phones X XBasis:This IC addresses a significant loss of on-site, offsite, or NRC communicationscapabilities. While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 BasisAddresses a total loss of the communications methods used in support of routine plantoperations.Month 20XXDR 3-112EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU4 (cont)Basis (cont):EAL #2 BasisAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in procedure EP-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) Form.EAL #3 BasisAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, CU52. EP-MW-124-1001 Facilities Inventories and Equipment Tests3. UFSAR 9.5.24. DOA 0010-14 Loss of Off-Site Telephone Communication SystemsMonth 20XXDR 3-113EP-AA-1004 (Revision XX) nradin AnnavPvtalnn k, ,-l,-nrRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA5Initiating Condition:Inability to maintain the plant in cold shutdown.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature > 212°F due to loss of decay heat removalfor > Table C2 duration.Table C2 RCS Heat-up Duration ThresholdsRCS Containment Closure Heat-upStatus Status DurationIntact Not Applicable 60 minutes*Not Intact Established 20 minutes*Not Established 0 minutes* If an RCS heat removal system is in operation withinthis time frame and RCS temperature is being reduced,then EAL #1 is not applicable.OR2. UNPLANNED RPV pressure rise > 10 psig as a result of temperature rise due toloss of decay heat removal.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment (primary or secondary) and its associated structures, systems, andcomponents as a functional barrier to fission product release under shutdownconditions.Month 20XXDR 3-114EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearD...s.en..Annex.Exelon Nulea.rRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA5 (cont)Basis (cont):RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs, etc.).This IC addresses conditions involving a loss of decay heat removal capability or anaddition of heat to the RCS in excess of that which can currently be removed. Eithercondition represents an actual or potential substantial degradation of the level of safetyof the plant.A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperaturewhen CONTAINMENT CLOSURE is established but the RCS is not intact. The 20-minute criterion was included to allow time for operator action to address thetemperature rise.The RCS Heat-up Duration Thresholds table also addresses a rise in RCS temperaturewith the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in thiscondition since the intact RCS is providing a high pressure barrier to a fission productrelease. The 60-minute time frame should allow sufficient time to address thetemperature rise without a substantial degradation in plant safety.Finally, in the case where there is a rise in RCS temperature, the RCS is not intact andCONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0minutes). This is because 1) the evaporated reactor coolant may be released directlyinto the Containment atmosphere and subsequently to the environment, and 2) there isreduced reactor coolant inventory above the top of irradiated fuel.EAL #2 provides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS6 or RSI.Month 20XXDR 3-115EP-AA-1004 (Revision XX)
AnnexDresden Annex FvAlnn MNuir-larRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA5 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CA32. Technical Specifications 3.6.1.13. Technical Specifications 3.6.4.14. OU-AA-103 Shutdown Safety Management Program5. DGP 02-01 Unit Shutdown6. DOA 0201-04 Loss of Vessel Flange, Shell, or Recirculation (Recirc) LoopTemperature Recorders During Heatup or Cooldown7. DGP 02-02 Reactor Vessel Slow Fill8. DIS 0263-19 Reactor Wide Range Pressure Transmitter Calibration Eq.Maintenance InspectionMonth 20XXDR 3-116EP-AA-1004 (Revision XX)
AnnexrDlresden Annex ExeInn NuclarIcrRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCU5Initiating Condition:UNPLANNED rise in RCS temperatureOperating Mode Applicability:4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature > 212°F due to loss of decay heat removal.OR2. Loss of the following for >15 minutes.* ALL RCS temperature indicationsAND" ALL RPV water level indicationsBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment (primary or secondary) and its associated structures, systems, andcomponents as a functional barrier to fission product release under shutdownconditions.This IC addresses an UNPLANNED rise in RCS temperature above the TechnicalSpecification cold shutdown temperature limit, or the inability to determine RCStemperature and level, represents a potential degradation of the level of safety of theplant. If the RCS is not intact and CONTAINMENT CLOSURE is not established duringthis event, the Emergency Director should also refer to IC CA5.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs, etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.Month 20XXDR 3-117EP-AA-1004 (Revision XX)
Dresden AnnexNuclearDresden Annex FwceInn NucleiarRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU5 (cont)Basis (cont):EAL #1 involves a loss of decay heat removal capability, or an addition of heat to theRCS in excess of that which can currently be removed, such that reactor coolanttemperature cannot be maintained below the cold shutdown temperature limit specifiedin Technical Specifications. During this condition, there is no immediate threat of fueldamage because the core decay heat load has been reduced since the cessation ofpower operation.During an outage, the level in the reactor vessel will normally be maintained above thereactor vessel flange. Refueling evolutions that lower water level below the reactorvessel flange are carefully planned and controlled. A loss of forced decay heat removalat reduced inventory may result in a rapid rise in reactor coolant temperature dependingon the time after shutdown.EAL #2 reflects a condition where there has been a significant loss of instrumentationcapability necessary to monitor RCS conditions and operators would be unable tomonitor key parameters necessary to assure core decay heat removal. During thiscondition, there is no immediate threat of fuel damage because the core decay heatload has been reduced since the cessation of power operation.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA5 based onexceeding plant configuration-specific time criteria.Basis Reference(s):1. NEI 99-01 Rev 6, CU32. Technical Specifications Table 1.1-13. DGP 02-01 UNIT SHUTDOWN4. DOA 0201-04, Loss of Vessel Flange, Shell, or Recirculation (Recirc) LoopTemperature Recorders During Heatup or Cooldown5. DGP 02-02 Reactor Vessel Slow Fill6. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines7. DEOP 100 RPV Control, Table A8. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level InstrumentationMonth 20XXDR 3-118EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCG6Initiating Condition:Loss of RPV inventory affecting fuel clad integrity with containment challenged.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. a. RPV water level < -143 inches (TAF) for > 30 minutes.ANDb. Any Containment Challenge Indication (Table C4)OR2. a. RPV water level unknown for > 30 minutes.ANDb. Core uncovery is indicated by ANY of the following:" Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Refuel Floor Hi Range ARM >3000 mR/hr.ANDc. ANY Containment Challenge Indication (Table C4)Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise*" UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.Month 20XXDR 3-119EP-AA-1004 (Revision XX) nrgcu{an Annov=wn1rn Kbir-Lanr-.~a--. 5'* *~ 'en fl~ I I., I I U t -i*RECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCG6 (cont)Emergency Action Level (EAL) (cont):Table C4 Containment Challenge Indications* Primary Containment Hydrogen Concentration > 6% and Oxygen > 5%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established** ANY Secondary Containment radiation monitor > DEOP 300-1 MaximumSafe operating level.* if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minutecore uncovery time limit, then escalation to a General Emergency is not required.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment (primary or secondary for BWR) and its associated structures,systems, and components as a functional barrier to fission product release undershutdown conditions.This IC addresses the inability to restore and maintain reactor vessel level above thetop of active fuel with containment challenged. This condition represents actual orIMMINENT substantial core degradation or melting with potential for loss of containmentintegrity. Releases can be reasonably expected to exceed EPA Protective ActionGuidelines (PAG) exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a directand unmonitored release of radioactivity to the environment. If CONTAINMENTCLOSURE is re-established prior to exceeding the 30-minute time limit, then declarationof a General Emergency is not required.Month 20XXDR 3-120EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCG6 (cont)Basis (cont):The existence of an explosive mixture means, at a minimum, that the containmentatmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity. Ittherefore represents a challenge to Containment integrity.In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to acore uncovery could result in an explosive gas mixture in containment. If all installedhydrogen gas monitors are out-of-service during an event leading to fuel claddingdamage, it may not be possible to obtain a containment hydrogen gas concentrationreading as ambient conditions within the containment will preclude personnel access.During periods when installed containment hydrogen gas monitors are out-of-service,operators may use the other listed indications to assess whether or not containment ischallenged.EAL #1 BasisThe 30-minute criterion is tied to a readily recognizable event start time (i.e., the totalloss of ability to monitor level), and allows sufficient time to monitor, assess andcorrelate reactor and plant conditions to determine if core uncovery has actuallyoccurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor RPV water level may be caused by instrumentation and/orpower failures, or water level dropping below the range of available instrumentation. Ifwater level cannot be monitored, operators may determine that an inventory loss isoccurring by observing changes in sump and/or tank levels. Sump and/or tank levelchanges must be evaluated against other potential sources of water flow to ensure theyare indicative of leakage from the RPV.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Month 20XXDR 3-121EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCG6 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CG12. DEOP 0100-00 RPV Control3. Technical Specifications 3.3.1.24. DOS 0700-01 SRM Functional Test5. DAN 902(3)-5 E-4 SRM Short Period6. DEOP 0200-01 Primary Containment Control7. DEOP 0200-02 Hydrogen Control8. DEOP 0300-01 Secondary Containment Control9. USAR Table 6.2-110. EP-EAL-0501Month 20XXDR 3-122EP-AA-1 004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCS6Initiating Condition:Loss of RPV inventory affecting core decay heat removal capability.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. With CONTAINMENT CLOSURE not established, RPV water level< -60 inchesOR2. With CONTAINMENT CLOSURE established, RPV water level< -143 inches (TAF)OR3. a. RPV water level unknown for > 30 minutesANDb. Core uncovery is indicated by ANY of the following:* Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Refueling Floor Hi Range ARM >3000 mR/hr.Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise** UNPLANNED Torus level rise*" UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.Month 20XXDR 3-123EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCS6 (cont)Basis:CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment (primary or secondary for BWR) and its associated structures,systems, and components as a functional barrier to fission product release undershutdown conditions.UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.The lost inventory may be due to a RCS component failure, a loss of configurationcontrol or prolonged boiling of reactor coolant. These conditions entail major failures ofplant functions needed for protection of the public and thus warrant a Site AreaEmergency declaration.Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.Outage/shutdown contingency plans typically provide for re-establishing or verifyingCONTAINMENT CLOSURE following a loss of heat removal or RCS inventory controlfunctions. The difference in the specified RCS/reactor vessel levels of EALs 1 and 2reflect the fact that with CONTAINMENT CLOSURE established, there is a lowerprobability of a fission product release to the environment.In EAL #3.a, the 30-minute criterion is tied to a readily recognizable event start time(i.e., the total loss of ability to monitor level), and allows sufficient time to monitor,assess and correlate reactor and plant conditions to determine if core uncovery hasactually occurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor RPV water level may be caused by instrumentation and/orpower failures, or water level dropping below the range of available instrumentation. Ifwater level cannot be monitored, operators may determine that an inventory loss isoccurring by observing changes in sump and/or tank levels. Sump and/or tank levelchanges must be evaluated against other potential sources of water flow to ensure theyare indicative of leakage from the RPV.Month 20XXDR 3-124EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCS6 (cont)Basis (cont):These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Escalation of the emergency classification level would be via IC CG6 or RG1.Basis Reference(s):1. NEI 99-01 Rev 6, CS12. Technical Specifications Table 3.3.5.1 13. UFSAR 5.2.54. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines5. DEOP 0100-00 RPV Control6. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log7. DAN 902(3)-4 A-17 Drywell Equip Sump LvI HI-HI8. DAN 902(3)-4 H-18 Drywell Floor Drn Sump Lvl HI-HI9. DOA 0040-01 Slow Leak10. DOP 2000-24 Drywell Sump Operation11. Technical Specifications 3.3.1.212 DOS 0700-01 SRM Functional Test13. DAN 902(3)-5 E-4 SRM Short PeriodMonth 20XXDR 3-125EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA6Initiating Condition:Loss of RPV inventory.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. Loss of RPV inventory as indicated by level < -54 inches.OR2. a. RPV water level unknown for > 15 minutes.ANDb. Loss of RPV inventory per Table C3 indications.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus level rise*" UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses conditions that are precursors to a loss of the ability to adequatelycool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). Thiscondition represents a potential substantial reduction in the level of plant safety.Month 20XXDR 3-126EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA6 (cont)Basis (cont):EAL #1 BasisA lowering of water level below -54.15 inches indicates that operator actions have notbeen successful in restoring and maintaining RPV water level. The heat-up rate of thecoolant will rise as the available water inventory is reduced. A continuing drop in waterlevel will lead to core uncovery.Although related, EAL #1 is concerned with the loss of RCS inventory and not thepotential concurrent effects on systems needed for decay heat removal (e.g., loss of aResidual Heat Removal suction point). A rise in RCS temperature caused by a loss ofdecay heat removal capability is evaluated under IC CA5.EAL #2 BasisThe inability to monitor RPV water level may be caused by instrumentation and/orpower failures, or water level dropping below the range of available instrumentation. Ifwater level cannot be monitored, operators may determine that an inventory loss isoccurring by observing changes in sump and/or tank levels. Sump and/or tank levelchanges must be evaluated against other potential sources of water flow to ensure theyare indicative of leakage from the RPV.The 15-minute duration for the loss of level indication was chosen because it is half ofthe EAL duration specified in IC CS6If the RPV water level continues to lower, then escalation to Site Area Emergency wouldbe via IC CS6.Basis Reference(s):1. NEI 99-01 Rev 6, CA12. USAR 5.2.5, Detection of Leakage through Reactor Coolant Pressure Boundary3. Technical Specification 3.3.5.1, Emergency Core Cooling System (ECCS)Instrumentation4. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines5. DEOP 100 RPV Control6. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log7. DAN 902(3)-4 A-17 Drywell Equip Sump Lvl HI-HI8. DAN 902(3)-4 H-18 Drywell Floor Drn Sump Lvl HI-HI9. DOA 0040-01 Slow Leak10. DOP 2000-24 Drywell Sump OperationMonth 20XXDR 3-127EP-AA-1004 (Revision XX) fnari4mn Annov=wn1^n K1"&-1AmnrRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU6Initiating Condition:UNPLANNED loss of RPV inventory for 15 minutes or longer.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED loss of reactor coolant results in the inability to restore and maintainRPV water level above the procedurally established lower limit for > 15 minutes.OR2. a. RPV water level unknownANDb. Loss of RPV inventory per Table C3 indications.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise*" UNPLANNED Torus level rise*" UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.Month 20XXDR 3-128EP-AA-1004 (Revision XX)
Dresden Annex Ex..lon NuceIa.rRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU6 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses the inability to restore and maintain water level to a requiredminimum level (or the lower limit of a level band), or a loss of the ability to monitor RPVwater level concurrent with indications of coolant leakage. Either of these conditions isconsidered to be a potential degradation of the level of safety of the plant.The procedurally established lower limit is not an operational band established abovethe procedural limit to allow for operator action prior to exceeding the procedural limit,but it is the procedurally established lower limit.Refueling evolutions that lower RCS water inventory are carefully planned andcontrolled. An UNPLANNED event that results in water level decreasing below aprocedurally required limit warrants the declaration of an Unusual Event due to thereduced water inventory that is available to keep the core covered.EAL #1 recognizes that the minimum required RPV water level can change severaltimes during the course of a refueling outage as different plant configurations andsystem lineups are implemented. This EAL is met if the minimum level, specified for thecurrent plant conditions, cannot be maintained for 15 minutes or longer. The minimumlevel is typically specified in the applicable operating procedure but may be specified inanother controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions torestore and maintain the expected water level. This criterion excludes transientconditions causing a brief lowering of water level.EAL #2 addresses a condition where all means to determine RPV water level havebeen lost. In this condition, operators may determine that an inventory loss is occurringby observing changes in sump and/or tank levels. Sump and/or tank level changesmust be evaluated against other potential sources of water flow to ensure they areindicative of leakage from the RPV.Continued loss of RCS inventory may result in escalation to the Alert emergencyclassification level via either IC CA6 or CA5.Month 20XXDR 3-129EP-AA-1004 (Revision XX)
Nr~rga~n Annayflr~~,~ut Ancv Fvinn NucleIarRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU6 (cont)Basis Reference(s):1. NEI 99-01, Rev. 6 CU12. USAR 5.2.5, Detection of Leakage through Reactor Coolant Pressure Boundary3. Technical Specifications 3.4.44. Technical Specifications 3.4.55. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log6. DAN 902(3)-4 A-17 Drywell Equip Sump LvI HI-HI7. DAN 902(3)-4 H-18 Drywell Floor Drn Sump Lvl HI-HI8. DOA 0040-01 Slow Leak9. DOP 2000-24 Drywell Sump Operation10. DGP 02-02 Reactor Vessel Slow Fill11. DEOP 0010-00 Guidelines for Use or Dresden Emergency Operating Proceduresand Severe Accident Management Guidelines12. DEOP 0100-00 RPV Control, Table A13. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level Instrumentation14. Technical Specifications Table 3.3.5.1 1Month 20XXDR 3-130EP-AA-1004 (Revision XX)
Dresden AnnexExallon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1Initiating Condition:HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:1, 2,3,4,5, DEmergency Action Level (EAL):1. A notification from the Security Force that a HOSTILE ACTION is occurring orhas occurred within the PROTECTED AREA.AND2. a. ANY Table H1 safety function cannot be controlled or maintained.ORb. Damage to spent fuel has occurred or is IMMINENTTable H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.Month 20XXDR 3-131EP-AA-1004 (Revision XX)
Dresden AnnexExellon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1Basis (cont):IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.This IC addresses an event in which a HOSTILE FORCE has taken physical control ofthe facility to the extent that the plant staff can no longer operate equipment necessaryto maintain key safety functions. It also addresses a HOSTILE ACTION leading to aloss of physical control that results in actual or IMMINENT damage to spent fuel due to1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls,etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot bemaintained.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].Basis Reference(s):1. NEI 99-01, Rev. 6 HG12. Station Security Plan -Appendix CMonth 20XXDR 3-132EP-AA-1004 (Revision XX) nroarian AnnovMvm1^n KI"r-haftrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS1Initiating Condition:HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:1, 2,3,4,5, DEmergency Action Level (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTEDAREA. This event will require rapid response and assistance due to the possibility fordamage to plant equipment.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].Month 20XXDR 3-133EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHSI (cont)Basis (cont):As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Site Area Emergency declaration will mobilize OROresources and have them available to develop and implement public protective actionsin the unlikely event that the attack is successful in impairing multiple safety functions.This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTEDAREA located outside the plant PROTECTED AREA; such an attack should beassessed using IC HA1. It also does not apply to incidents that are accidental events,acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by aHOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters,physical disputes between employees, etc. Reporting of these types of events isadequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR§ 50.72.Escalation of the emergency classification level would be via IC HG1.Basis Reference(s):1. NEI 99-01 Rev 6, HS13. Station Security Plan -Appendix CMonth 20XXDR 3-134EP-AA-1004 (Revision XX)
AnnexrDresden Annex Fvalnn Niinanr~IRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA1Initiating Condition:HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threatwithin 30 minutes.Operating Mode Applicability:1,2,3,4,5, DEmergency Action Level (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutes fromthe site.OR2. Notification by the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the OWNER CONTROLED AREA.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.OWNER CONTROLLED AREA (OCA): The property associated with the station andowned by the company. Access is normally limited to persons entering for officialbusiness.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.Month 20XXDR 3-135EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA1 (cont)Basis (cont):This IC addresses the occurrence of a HOSTILE ACTION within the OWNERCONTROLLED AREA or notification of an aircraft attack threat. This event will requirerapid response and assistance due to the possibility of the attack progressing to thePROTECTED AREA, or the need to prepare the plant and staff for a potential aircraftimpact.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Alert declaration will also heighten the awareness ofOffsite Response Organizations, allowing them to be better prepared should it benecessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience,or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputesbetween employees, etc. Reporting of these types of events is adequately addressedby other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL #1 BasisAddresses the threat from the impact of an aircraft on the plant, and the anticipatedarrival time is within 30 minutes. The intent of this EAL is to ensure that threat-relatednotifications are made in a timely manner so that plant personnel and OROs are in aheightened state of readiness. This EAL is met when the threat-related information hasbeen validated in accordance with DOA 0010-18, Escalated Security Event/HostileForce Intrusion.EAL #2 BasisIs applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNERCONTROLLED AREA. This includes any action directed against an ISFSI that islocated outside the plant PROTECTED AREA.The NRC Headquarters Operations Officer (HOO) will communicate to the licensee ifthe threat involves an aircraft. The status and size of the plane may be provided byNORAD through the NRC.Month 20XXDR 3-136EP-AA-1004 (Revision XX)
Dresden AnnexExellon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHAI (cont)Basis (cont):In some cases, it may not be readily apparent if an aircraft impact within the OWNERCONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected,although not certain, that notification by an appropriate Federal agency to the site wouldclarify this point. In this case, the appropriate federal agency is intended to be NORAD,FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs,should not be unduly delayed while awaiting notification by a Federal agency.Escalation of the emergency classification level would be via IC HS1.Basis Reference(s):1. NEI 99-01 Rev 6, HA12. Station Security Plan -Appendix C3. DOA 0010-18, Escalated Security Event/Hostile Force IntrusionMonth 20XXDR 3-137EP-AA-1004 (Revision XX)
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- F* ** *~St ~ ~. ...t. -~RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU1Initiating Condition:Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:1, 2,3,4,5, DEmergency Action Level (EAL):1. Notification of a credible security threat directed at the site as determined perSY-AA-1 01-132, Security Assessment and Response to Unusual Activities.OR2. A validated notification from the NRC providing information of an aircraft threat.OR3. Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.Basis:SECURITY CONDITION: Any Security Event as listed in the approved securitycontingency plan that constitutes a threat/compromise to site security, threat/risk to sitepersonnel, or a potential degradation to the level of safety of the plant. A SECURITYCONDITION does not involve a HOSTILE ACTIONSAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.Month 20XXDR 3-138EP-AA-1004 (Revision XX)
AnnexrDresde~n Annexw FYAlln NuclerIAmRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHUI (cont)Basis (cont):This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEMequipment, and thus represent a potential degradation in the level of plant safety.Security events which do not meet one of these EALs are adequately addressed by therequirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed asHOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Classification of these events will initiate appropriate threat-related notifications to plantpersonnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 BasisAddresses the receipt of a credible security threat. The credibility of the threat isassessed in accordance with SY-AA-101-132.EAL #2 BasisAddresses the threat from the impact of an aircraft on the plant. The NRCHeadquarters Operations Officer (HOO) will communicate to the licensee if the threatinvolves an aircraft. The status and size of the plane may also be provided by NORADthrough the NRC. Validation of the threat is performed in accordance with DOA 0010-18, Escalated Security Event/Hostile Force IntrusionEAL #3 BasisReferences Security Force because these are the individuals trained to confirm that asecurity event is occurring or has occurred. Training on security event confirmation andclassification is controlled due to the nature of Safeguards and 10 CFR § 2.39information.Escalation of the emergency classification level would be via IC HA1.Basis Reference(s):1. NEI 99-01 Rev 6, HU12. SY-AA-1 01-132, Security Assessment and Response to Unusual Activities3. Station Security Plan -Appendix C4. NRC Safeguards Advisory 10/6/015. Letter from Mr. B. A. Boger (NRC) to Ms. Lynette Hendricks (NEI) dated 2/4/026. DOA 0010-18, Escalated Security Event/Hostile Force IntrusionMonth 20XXDR 3-139EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS2Initiating Condition:Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per DSSP 0100-CR, Hot Shutdown Procedure-Control Room Evacuation.AND2. Control of ANY Table H1 key safety function is not reestablished in < 30 minutes.Table HI Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Basis:The time period to establish control of the plant starts when either:a. Control of the plant is no longer maintained in the Main Control RoomORb. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations, and the control of a key safety function cannot bereestablished in a timely manner. The failure to gain control of a key safety functionfollowing a transfer of plant control to alternate locations is a precursor to a challenge toany fission product barriers within a relatively short period of time.Month 20XXDR 3-140EP-AA-1004 (Revision XX)
Dresden AnnexExellon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS2 (cont)Basis (cont):The determination of whether or not "control" is established at the remote safeshutdown location(s) is based on Emergency Director judgment. The EmergencyDirector is expected to make a reasonable, informed judgment within 30 minuteswhether or not the operating staff has control of key safety functions from the remotesafe shutdown location(s).Escalation of the emergency classification level would be via IC FG1 or CG6.Basis Reference(s):1. NEI 99-01, Rev 6 HS62. DSSP 0100-CR, Hot Shutdown Procedure -Control Room EvacuationMonth 20XXDR 3-141EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA2Initiating Condition:Control Room evacuation resulting in transfer of plant control to alternate locations.Operating Mode Applicability:1,2,3, 4,5, DEmergency Action Level (EAL):A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per DSSP 0100-CR, Hot Shutdown Procedure -Control Room Evacuation.Basis:This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations outside the Control Room. The loss of the ability to controlthe plant from the Control Room is considered to be a potential substantial degradationin the level of plant safety.Following a Control Room evacuation, control of the plant will be transferred to alternateshutdown locations. The necessity to control a plant shutdown from outside the ControlRoom, in addition to responding to the event that required the evacuation of the ControlRoom, will present challenges to plant operators and other on-shift personnel.Activation of the ERO and emergency response facilities will assist in responding tothese challenges.Escalation of the emergency classification level would be via IC HS2.Basis Reference(s):1. NEI 99-01, Rev 6 HA62. DSSP 0100-CR, Hot Shutdown Procedure -Control Room EvacuationMonth 20XXDR 3-142EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3Initiating Condition:FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Note:9 The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of thefollowing FIRE detection indications:" Report from the field (i.e., visual observation)* Receipt of multiple (more than 1) fire alarms or indications* Field verification of a single fire alarmTable H2 Vital Areas" Reactor Building (when inerted the Drywell is exempt)* Aux Electric Room* Control Room* Unit and Shared Emergency Diesel Generator Rooms* 4KV ECCS Switchgear Area (includes Bus 23, 24, 33 and 34 only)* CRD & CCSW Pump Rooms* Turbine Building Cable Tunnel* Turbine Building Safe Shutdown Areas as follows:1 B- Train Control Room HVAC Room* Battery Rooms and DC Distribution Areas1) U2 Battery Room (includes DC switchgear, 125V, and 250V battery rooms)2) U3 Battery Room, Battery Cage area, and U3 Battery Charger Room(all on U3 TB 538)* Crib HouseOR2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indicationsof a FIRE).ANDb. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.ORMonth 20XXDR 3-143EP-AA-1004 (Revision XX)
Dresden AnnexDlresden Annex Fv.vIn i.Ir~vA.RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)Emergency Action Level (EAL) (cont):3. A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes ofthe initial report, alarm or indication.OR4. A FIRE within the plant PROTECTED AREA that requires firefighting support byan offsite fire response agency to extinguish.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of apotential degradation of the level of safety of the plant.EAL #1 BasisThe intent of the 15-minute duration is to size the FIRE and to discriminate againstsmall FIRES that are readily extinguished (e.g., smoldering waste paper basket). Inaddition to alarms, other indications of a FIRE could be a drop in fire main pressure,automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial firealarm, indication, or report. For EAL assessment purposes, the emergency declarationclock starts at the time that the initial alarm, indication, or report was received, and notthe time that a subsequent verification action was performed. Similarly, the fire durationclock also starts at the time of receipt of the initial alarms, indication or report.EAL #2 BasisThis EAL addresses receipt of a single fire alarm, and the existence of a FIRE is notverified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt,operators will take prompt actions to confirm the validity of a single fire alarm. For EALassessment purposes, the 30-minute clock starts at the time that the initial alarm wasreceived, and not the time that a subsequent verification action was performed.Month 20XXDR 3-144EP-AA-1004 (Revision XX) nro*arian AnnayP:vgmltnn N, ig--a-rflr~~rI~n Ann~v FvaIr~n Mu.~I~~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)Basis (cont):A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipmentfailure or a spurious activation, and not an actual FIRE. For this reason, additional timeis allowed to verify the validity of the alarm. The 30-minute period is a reasonableamount of time to determine if an actual FIRE exists; however, after that time, andabsent information to the contrary, it is assumed that an actual FIRE is in progress.If an actual FIRE is verified by a report from the field, then EAL #1 is immediatelyapplicable, and the emergency must be declared if the FIRE is not extinguished within15-minutes of the report. If the alarm is verified to be due to an equipment failure or aspurious activation, and this verification occurs within 30-minutes of the receipt of thealarm, then this EAL is not applicable and no emergency declaration is warranted.EAL #3 BasisIn addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plantPROTECTED AREA not extinguished within 60-minutes may also potentially degradethe level of plant safetyEAL #4 BasisIf a FIRE within the plant PROTECTED AREA is of sufficient size to require a responseby an offsite firefighting agency (e.g., a local town Fire Department), then the level ofplant safety is potentially degraded. The dispatch of an offsite firefighting agency to thesite requires an emergency declaration only if it is needed to actively support firefightingefforts because the fire is beyond the capability of the Fire Brigade to extinguish.Declaration is not necessary if the agency resources are placed on stand-by, orsupporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix RAppendix R to 10 CFR 50, states in part:Criterion 3 of Appendix A to this part specifies that "Structures, systems, andcomponents important to safety shall be designed and located to minimize,consistent with other safety requirements, the probability and effect of fires andexplosions."When considering the effects of fire, those systems associated withachieving and maintaining safe shutdown conditions assume major importance tosafety because damage to them can lead to core damage resulting from loss ofcoolant through boil-off.Month 20XXDR 3-145EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)Basis (cont):Because fire may affect safe shutdown systems and because the loss of functionof systems used to mitigate the consequences of design basis accidents underpost-fire conditions does not per se impact public safety, the need to limit firedamage to systems required to achieve and maintain safe shutdown conditions isgreater than the need to limit fire damage to those systems required to mitigatethe consequences of design basis accidents.In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of1-hour fire barriers for the enclosure of cable and equipment and associated non-safetycircuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify asingle alarm is well within this worst-case 1-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA2 or MA5.Basis Reference(s):1. NEI 99-01, Rev 6 HU42. UFSAR 3.2, Classification of Structures, Components, and Systems3. UFSAR 3.5.34. General Arrangement Drawings M-3, M-4, M-4A, M-5 and M-10Month 20XXDR 3-146EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU4Initiating Condition:Seismic event greater than OBE levels.Operating Mode Applicability:1,2,3,4,5, DEmergency Action Level (EAL):1. Control Room personnel feel an actual or potential seismic event.AND2. The occurrence of a seismic event is confirmed in a manner deemed appropriate bythe Shift Manager or Emergency Director.Basis:This IC addresses a seismic event that results in accelerations at the plant site greaterthan those specified for an Operating Basis Earthquake (OBE)1.An earthquake greaterthan an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have nosignificant impact on safety-related systems, structures and components; however,some time may be required for the plant staff to ascertain the actual post-eventcondition of the plant (e.g., performs walk-downs and post-event inspections). Giventhe time necessary to perform walk-downs and inspections, and fully understand anyimpacts, this event represents a potential degradation of the level of safety of the plant.Event verification with external sources should not be necessary during or following anOBE. Earthquakes of this magnitude should be readily felt by on-site personnel andrecognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).EAL #2 is included to ensure that a declaration does not result from felt vibrationscaused by a non-seismic source (e.g., a dropped load). The Shift Manager orEmergency Director may seek external verification if deemed appropriate (e.g., call toUSGS, check internet source, etc.) however, the verification action must not preclude atimely emergency declaration. This EAL wording recognizes that it may cause the site todeclare an Unusual Event while another site similarly affected but with readily availableOBE indications in the Control Room, may not.Depending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA2 or MA5.1 An OBE is vibratory ground motion for which those features of a nuclear power plantnecessary for continued operation without undue risk to the health and safety of thepublic will remain functional.An SSE is vibratory ground motion for which certain (generally, safety-related)structures, systems, and components must be designed to remain functional.Month 20XXDR 3-147EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU4 (cont)Basis Reference(s):1. NEI 99-01, Rev 6 HU22. DOA 0010-03, EarthquakesMonth 20XXDR 3-148EP-AA-1004 (Revision XX)
Dresden AnnexDresen AnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5Initiating Condition:Gaseous release impeding access to equipment necessary for normal plant operations,cooldown or shutdown.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Note:* If the equipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emergency classification iswarranted.1. Release of a toxic, corrosive, asphyxiant or flammable gas in a Table H3 area.Table H3Areas with Entry Related Mode ApplicabilityArea Entry Related Mode ApplicabilityReactor Building* Modes 3, 4, and 5*Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impededBasis:This IC addresses an event involving a release of a hazardous gas that precludes orimpedes access to equipment necessary to transition the plant from normal plantoperation to cooldown and shutdown as specified in normal plant procedures. Thiscondition represents an actual or potential substantial degradation of the level of safetyof the plant.Table H3 is a list of plant rooms or areas with entry-related mode applicability thatcontain equipment which require a manual/local action necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal operatingprocedures (establish shutdown cooling), where if this action is not completed the plantwould not be able to attain and maintain cold shutdown. This Table does not includerooms or areas for which entry is required solely to perform actions of an administrativeor record keeping nature (e.g., normal rounds or routine inspections).Month 20XXDR 3-149EP-AA-1 004 (Revision XX)
Dry.dAn AnnRxDresden Annex Fvalnn NJiiear~IRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5 (cont)Basis (cont):This Table does not include the Control Room since adequate engineered safety/designfeatures are in place to preclude a Control Room evacuation due to the release of ahazardous gas.An Alert declaration is warranted if entry into the affected room/area is, or may be,procedurally required during the plant operating mode in effect and the gaseous releasepreclude the ability to place shutdown cooling in service. The emergency classificationis not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires theEmergency Director's judgment that the gas concentration in the affected room/area issufficient to preclude or significantly impede procedurally required access. Thisjudgment may be based on a variety of factors including an existing job hazard analysis,report of ill effects on personnel, advice from a subject matter expert or operatingexperience with the same or similar hazards. Access should be considered as impededif extraordinary measures are necessary to facilitate entry of personnel into the affectedroom/area (e.g., requiring use of protective equipment, such as SCBAs, that is notroutinely employed).An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the timeof the gaseous release). For example, the plant is in Mode 1 when the gaseousrelease occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4." The gas release is a planned activity that includes compensatory measures whichaddress the temporary inaccessibility of a room or area (e.g., fire suppressionsystem testing)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections).* The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerouslevels. Most commonly, asphyxiants work by merely displacing air in an enclosedenvironment. This reduces the concentration of oxygen below the normal level ofaround 19%, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that generate smoke, that automaticallyor manually activate a fire suppression system in an area, or to intentional inerting ofcontainment.Escalation of the emergency classification level would be via Recognition Category R, Cor F ICs.Month 20XXDR 3-150EP-AA-1004 (Revision XX)
Dresden AnnexExellon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5 (cont)Basis Reference(s):1. NEI 99-01, Rev 6 HA52. UFSAR 3.5.33. UFSAR 3.24. General Arrangement Drawings M-3, M-4, M-4A, M-5 and M-10Month 20XXDR 3-151EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU6Initiating Condition:Hazardous EventOperating Mode Applicability:1, 2,3,4,5, DEmergency Action Level (EAL):Note:EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, orvehicle breakdowns or accidents.1. Tornado strike within the PROTECTED AREA.OR2. Internal room or area flooding of a magnitude sufficient to require manual orautomatic electrical isolation of a SAFETY SYSTEM component required byTechnical Specification for the current operating mode.OR3. Movement of personnel within the PROTECTED AREA is impeded due to an offsiteevent involving hazardous materials (e.g., an offsite chemical spill or toxic gasrelease).OR4. A hazardous event that results in on-site conditions sufficient to prohibit the plantstaff from accessing the site via personal vehicles.OR5. Abnormal River level, as indicated by EITHER:a. High river level > 509 ft.ORb. Low river level <501 ft. 6 inches.Basis:PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.Month 20XXDR 3-152EP-AA-1004 (Revision XX) pracrian AnnoyI=Yalnn N,,r-l,-orfl racrI~n Ann~v FvMnn Mm.rIc~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU6 (cont)Basis (cont):This IC addresses hazardous events that are considered to represent a potentialdegradation of the level of safety of the plant.EAL #1 BasisAddresses a tornado striking (touching down) within the Protected Area.EAL #2 BasisAddresses flooding of a building room or area that results in operators isolating power toa SAFETY SYSTEM component due to water level or other wetting concerns.Classification is also required if the water level or related wetting causes an automaticisolation of a SAFETY SYSTEM component from its power source (e.g., a breaker orrelay trip). To warrant classification, operability of the affected component must berequired by Technical Specifications for the current operating mode. Manual isolation ofpower to a SAFETY SYSTEM component as a result of leakage is an event of lesserimpact and would be expected to cause small and localized damage. The consequenceof this type of event is adequately assessed and addressed in accordance withTechnical Specifications.EAL #3 BasisAddresses a hazardous materials event originating at an offsite location and of sufficientmagnitude to impede the movement of personnel within the PROTECTED AREA.EAL #4 BasisAddresses a hazardous event that causes an on-site impediment to vehicle movementand significant enough to prohibit the plant staff from accessing the site using personalvehicles. Examples of such an event include site flooding caused by a hurricane, heavyrains, up-river water releases, dam failure, etc., or an on-site train derailment blockingthe access road.This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehiclebreakdowns or accidents, but rather to more significant conditions such as theHurricane Andrew strike on Turkey Point in 1992, the flooding around the CooperStation during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in2011.Escalation of the emergency classification level would be based on ICs in RecognitionCategories R, F, M, H or C.Month 20XXDR 3-153EP-AA-1004 (Revision XX)
AnnoyvPvgmlrn Ki ,Al-orRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU6 (cont)Basis (cont):..EAL #5 Basis:The possible maximum flood (PMF) produces a peak flood to 528 ft el. This issignificantly above the grade elevation (517 ft) and the high river water level threshold,which is the lowest opening leading to safety-related equipment (509 ft el.). When thislevel is reached, the reactors are shutdown, the drywells are deinerted, and the vesselsare flooded and cooled to cold shutdown conditions as quickly as possible. If the waterlevel reaches 513 ft el., reactor cooldown is transferred to the Isolation Condensers,which thereafter maintain a safe shutdown condition until the flood waters recede andplant startup can be initiated.Minimum river water levels to assure pump suction are:* Circulating Water Pumps: 490 ft el." Service Water Pumps: 494 ft el." CCSW Pumps: 501 ft 6 in." Unit 2/3 Fire Pump: 498 ft 6 in.The low river water level threshold (501 ft. 6 in.) is based on the most limiting pumpsuction requirement (CCSW).Escalation of the emergency classification level would be based on ICs in RecognitionCategories R, F, M, H or C.Basis .Reference(s): ..... ........."1. NEI 99-01, Rev 6 HU32. DOA 0010-01 Dresden Lock and Dam Failure3. DOA 0010-04 Floods4. DOA 0010-02 Tornado Warning/Severe Winds5. DOA-0010-12, Toxic Gas/Chemical Release from Nearby Chemical FacilitiesMonth 20XXDR 3-154EP-AA-1 004 (Revision XX)
AnnAxDlresden Annex Fva'inn Nmmr-IonrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a GENERAL EMERGENCY.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which involve actual or IMMINENT substantialcore degradation or melting with potential for loss of containment integrity or HOSTILEACTION that results in an actual loss of physical control of the facility. Releases can bereasonably expected to exceed EPA Protective Action Guideline exposure levels offsitefor more than the immediate site area.Basis:IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for aGeneral Emergency.Basis Reference(s):1. NEI 99-01, Rev 6 HG7Month 20XXDR 3-155EP-AA-1004 (Revision XX)
Exelon NuclearDresden Annex Exelon NuclIearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a SITE AREA EMERGENCY.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which involve actual or likely major failures ofplant functions needed for protection of the public or HOSTILE ACTION that results inintentional damage or malicious acts, (1) toward site personnel or equipment that couldlead to the likely failure of or, (2) that prevent effective access to equipment needed forthe protection of the public. Any releases are not expected to result in exposure levelswhich exceed EPA Protective Action Guideline exposure levels beyond the siteboundary.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for a SiteArea Emergency.Basis Reference(s):1. NEI 99-01, Rev 6 HS7Month 20XXDR 3-156EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearDlresden Annex Exelnn Nuclea~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an ALERT Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Other conditions exist which, in the judgment of the Emergency Director, indicate thatevents are in progress or have occurred which involve an actual or potential substantialdegradation of the level of safety of the plant or a security event that involves probablelife threatening risk to site personnel or damage to site equipment because of HOSTILEACTION. Any releases are expected to be limited to small fractions of the EPAProtective Action Guideline exposure levels.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anAlert.Basis Reference(s):1. NEI 99-01, Rev 6 HA7Month 20XXDR 3-157EP-AA-1004 (Revision XX)
IDri__dp~n AnnivDresden Annex Evainn N"rhmnrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an UNUSUAL EVENT.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which indicate a potential degradation of thelevel of safety of the plant or indicate a security threat to facility protection has beeninitiated. No releases of radioactive material requiring offsite response or monitoring areexpected unless further degradation of safety systems occurs.Basis:This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anUNUSUAL EVENT.Basis Reference(s):1. NEI 99-01, Rev 6 HU7Month 20XXDR 3-158EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYISFSI MALFUNCTIONSE-HU1Initiating ConditionDamage to a loaded cask CONFINEMENT BOUNDARY.Operating Mode Applicability:1,2,3,4,5, DEmergency Action Level (EAL):Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contactradiation reading:1. EAST HI-STAR:* > 160 mrem/hr (neutron + gamma) on the top of the OverpackOR0 > 250 mrem/hr (neutron+ gamma) on the side of the OverpackOR2. EAST HI-STORM:0 > 20 mrem/hr (neutron+ gamma) on the top of the OverpackOR* >100 mrem/hr (neutron+ gamma) on the side of the OverpackOR* > 45 mrem/hr (neutron+ gamma) at the inlet and outlet vent ducts of theOverpackOR3. WEST HI-STORM:* > 40 mremlhr (neutron+ gamma) on the top of the OverpackOR* >100 mrem/hr (neutron+ gamma) on the side of the Overpack, excluding inletand outlet ducts.Basis:CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) betweenareas containing radioactive substances and the environment.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) : A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.Month 20XX DR 3-159 EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYISFSI MALFUNCTIONSE-HUI (cont).Basis (cont):This IC addresses an event that results in damage to the CONFINEMENT BOUNDARYof a storage cask containing spent fuel. It applies to irradiated fuel that is licensed fordry storage beginning at the point that the loaded storage cask is sealed. The wordcask, as used in this EAL, refers to the storage container in use at the site for drystorage of irradiated fuel. The issues of concern are the creation of a potential or actualrelease path to the environment, degradation of any fuel assemblies due toenvironmental factors, and configuration changes which could cause challenges inremoving the cask or fuel from storage.The existence of "damage" is determined by radiological survey. The technicalspecification multiple of "2 times", which is also used in Recognition Category R IC RU1,is used here to distinguish between non-emergency and emergency conditions. Theemphasis for this classification is the degradation in the level of safety of the spent fuelcask and not the magnitude of the associated dose or dose rate. It is recognized that inthe case of extreme damage to a loaded cask, the fact that the "on-contact" dose ratelimit is exceeded may be determined based on measurement of a dose rate at somedistance from the cask.Security-related events for ISFSls are covered under ICs HU1 and HAl.Basis Reference(s):1. NEI 99-01, Rev 6 E-HU12. Certificate of Compliance No. 1014 Appendix A, Section 5.7 (WEST HI-STORM)3. Certificate of Compliance No. 1014 Appendix A, Section 3.2.3 (EAST HI-STORM)4. Certificate of Compliance No. 1008 Appendix A, Amendment 2, Section 2.2.1(EAST HI-STAR)Month 20XXDR 3-160EP-AA-1004 (Revision XX)