ML16055A227

Catawba, Units 1 and 2 - Response to Request for Additional Information and Emergency Action Level Technical Bases Document, Revision 1, Redline Version. Part 1 of 4

ML16055A227
Person / Time
Site:	Catawba
Issue date:	02/19/2016
From:	Henderson K Duke Energy Carolinas
To:	Office of Nuclear Reactor Regulation
Shared Package
ML16055A223	List: CNS-16-010, Response to Request for Additional Information and Emergency Action Level Technical Bases Document, Revision 1, Clean Version. Part 4 of 4 ML16055A226 ML16055A227 ML16055A228 ML16055A230
References
CNS-16-010, TAC MF6166, TAC MF6167
Download: ML16055A227 (104)

Text

Enclosure 1Response to Request for Additional InformationCatawba Nuclear Station, Unit I and 2Docket Nos. 50-413 and 50-414 U.S. Nuclear Regulatory CommissionCNS-1 6-010Enclosure IPage 1 of 13By letter dated April 30, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15125A149), Duke Energyrequested approval of a proposed change to the Emergency Action Levels (EALs) used at Catawba Nuclear Station (CNS) which would revise thecurrent CNS EAL scheme to one based upon Nuclear Energy Institute (NEI) document NEI 99-01, "Development of Emergency Action Levels forNon-Passive Reactors," Revision 6 (ADAMS Accession No. ML1 2326A805). The NRC staff reviewed the request and determined that additionalinformation is needed to complete their review. A letter requesting additional information was sent on January 20, 2016(ADAMS Accession No. MLI16014A71 0).Duke Energy provides the following response to the request for additional information (RAI) regarding the License Amendment Request to revisethe CNS EAL Scheme to one based on NEI 99-01, Revision 6. Changes to the CNS Technical Bases document as a result of this RAI are identifiedwithin the CNS RA! Response in the table below. Changes were also made to the CNS Technical Bases Document that were not the result of anRAI. These additional changes are described in a table below the RAI response, with an explanation of why each change was deemed necessary.The revised CNS EAL Technical Bases Document is provided in Enclosure 2 with revision bars indicating changes from the original submittal.Revision 1, clean version of CNS EAL Technical Bases Document is provided in Enclosure 3.RAI # SECTION!/usinCSRsosCNS- EALQusinCSR poeFor Section 1.0, please clarify what change control process CNS has added the following to Section 1.0:will be used to maintain this document. If appropriate, add "eas h nfraini ai ouetcnafclanguage to this section stating that this document will be emrncclsicaondiin-kng(g.th1 1. mantaied n acordncewith10 FR 5.54q).Emergency Coordinator refers to it during an event), theNRC staff expects that changes to the basis document willbe evaluated in accordance with the provisions of10 CFR 50.54(q)."2 GENERAL Section 2.5, "Technical Basis Information," includes a The CNS site specific and NEI 99-01 generic bases sections U.S. Nuclear Regulatory CommissionCNS-1 6-010Enclosure IPage 2 of 13RAI # TSECTION/ usinCSRsosCNS- EALQusinCSRpoePlant-Specific (CNS) basis section, in addition to a Generic(NEI 99-01) basis section. One of the enhancementsprovided in Revision 6 to NEI 99-01 is a separation of thedeveloper's notes from the bases information. This changewas made to facilitate the use of bases information for thetwo distinct purposes, development and classification.Considering that the EAL Technical Basis is provided tosupport proper emergency classification decision making,please explain why a Generic (NEI 99-01) basis section isprovided rather than incorporated into Plant-Specific (CNS)basis section.have been combined into a single bases section for eachEAL. Section 2.5 "Technical Bases Information" has beenrevised accordingly.Redundant bases, where applicable, have been deleted.Escalation statements have been revised where appropriateto site specific EAL number.RA1 .3 bases has been revised to only reference liquideffluents.RA1 .3 and RA1 .4 bases was revised to delete the citedparagraph related to effluent monitors.Specific examples include the following:* Escalation should refer to CNS EAL numbering vicegeneric NEI 99-01 EAL numbering to facilitate timelyassessments by the Emergency Coordinator.*The Plant-Specific (CNS) basis section informationshould be specific to each EAL provided by thelicensee. The following are examples of apparentinconsistencies:oFor the proposed RAI1.3, the NEI 99-01 basisdiscussion includes reference to gaseousradioactivity while the proposed RA1 .3 only appliesto liquid effluent samples.

U.S. Nuclear Regulatory CommissionCNS-1 6-010Enclosure 1Page 3 of 13RAI # SECTION/ usinCSRsosCNS- EALQusinCSRpoea For the proposed RA1 .3 and RA1 .4, the lastparagraph of the NEI 99-01 basis discussionincludes reference to effluent radiation monitorswhile the EAL only applies to field survey results.For Section 4.1, it appears to reference an incorrect CNS has revised the referenced ADAMS Accession NumberADAMS number for the endorsed version of NEI 99-01, to ML1 2326A805.3 4.1 Revision 6. The endorsed version is ML12326A805.Please clarify the reference or correct this instance as wellas others, if used later in the document as well.Section 4.3, "Instrumentation Used for EALs," to NEI 99-01, ONS has confirmed that all setpoints and indications used inRevision 6, states (in part): "Scheme developers should the proposed EAL scheme are within the calibrated range(s)ensure that specific values used as EAL setpoints are of the stated instrumentation and that the resolution of thewithin the calibrated range of the referenced instrumentation is appropriate for the setpointlindication.4 N/A instrumentation." Please confirm that all setpoints andindications used in the proposed EAL scheme are withinthe calibrated range(s) of the stated instrumentation andthat the resolution of the instrumentation is appropriate forthe setpoint/indication.Section 5.0, "Definitions," does not include definitions for The following definitions have been added to Section 5.0550 the following: consistent with NEI 99-01 Revision 6:* Alert,

• Alert,* Notification of Unusual Event,

• Unusual Event, U.S. Nuclear Regulatory CommissionCNS-1 6-010Enclosure 1Page 4 of 13RAI # SECTION/ usinCSRsosCNS- EALQusinCSRpoe* Site Area Emergency,

• Site Area Emergency,* General Emergency,

• General/Emergency,* Emergency Action Level,

• Emergency Action Level,* Emergency Classification Level,

• Emergency Classification Level,* Fission Product Barrier Threshold,

• Fission Product Barrier Threshold,* Initiating Condition, and

• Initiating Condition, and* Independent Spent Fuel Storage Installation.

• Independent Spent Fuel Storage Installation.Please provide justification for omitting these definitions, orrevise to incorporate these definitions consistent with NEI99-01, Revision 6.For the following EALs, please explain why the listed CNS has deleted Note 3 from RAl1.2, RS1 .2 and RG1 .2.RA1.2, NOTEs were included, or revise accordingly:6 RS1.2,

• RAI.2 -NOTE-3RG1.2

• RS1.2- NOTE-3* RG1 .2- NOTE-3For EAL RA2.2, the information in the NEI 99-01 Basis CNS has re-instated the following text to the RA2.2 bases:secton oesnot ontin ll f th acualinfomaton rom "This EAL applies to irradiated fuel that is licensed for dryNEI 99-01, as it is germane to this particular EAL. Please storage up to the point that the loaded storage cask is7 RA2.2 explain why this information was omitted, or revise sae.Oc eld aaet oddcs asnaccordngly.loss of the CONFINEMENT BOUNDARY is classified inaccordance with EAL EUI. 1."

U.S. Nuclear Regulatory CommissionCNS-1 6-010Enclosure 1Page 5 of 13RAI # SECTION!/usinCSRsosCNS- EALQusinCSRpoeFor EALs CU1 .2, CA1 .2, CS1 .1 and OGI .1, please provide CNS has revised EALs CUl1.2, CA1 .2, CS1 .1 and CGI .1, tofurther detail as to why additional sumps and tanks cannot add a new Table C-6 that includes the following additionalCUi1.2, be used for these EALs, or revise accordingly. sumps and tanks:8 CA1.2, Sumps: Residual Heat Removal/Containment SprayCS1.1 (ND/NS)CGI.1Tanks: Reactor Coolant Drain Tank (NCDT)Pressure Relief Tank (PRT)Please provide further detail as to why CS1.1 and CS1.2 Although the current NUMARC/NESP-007 Rev. 2 basedfrom NEI 99-01, Revision 6, cannot be adequately EALs provide thresholds utilizing NCS narrow range waterdeveloped. A review of the current CNS EAL scheme level below the bottom of the hot leg, the design andshows that, while limited, CNS does have NCS water level operation of the CNS water level instrumentation is suchCS1 .1, monitoring capability. Please provide further justification for that the "site-specific level" (6" below the bottom ID of theCSl .2 the removal of these EALs from the proposed CNS EAL NCS loop and Top of Active Fuel) cannot be determined atscheme, or revise accordingly. all times during Cold Shutdown or Refueling modes becausethe RVLIS instrumentation is not available at all times duringthese modes. There are no alternative means of assessingNCS water below the bottom of the NCS loop.For EALs CU2.1, SAlI.1, The incorporation of SATA Train CNS has revised Tables C-2 and S-1 to condition credit forCU2.1, A, and SATA Train B, into Table C-2, must include, as a SATA (Train A) and SATB (Train B) only if already aligned.10 CA1.1, note or as part of the table, that consideration for these ACS~l.1 Power Sources can only be given if they are alreadyaligned, otherwise please remove from the table.

U.S. Nuclear Regulatory CommissionCNS-1 6-010Enclosure 1Page 6 of 13RAI # SECTION!IusinCSRsosCNS- EALQusinCSRpoeFor EALs CA2.1, SS1.1, SG1.1, and SG1.2, Tables 0-2 CNS has deleted reference to Table 0-2/S-I AC powerand S-I, "AC Power Sources" were included. These tables source tables from CA2.1, SS1.1, SGI .1 and SGI1.2.are limited to those power supplies that are capable ofCA1.1, providing power to the essential buses. However, the11 SG.1 licensee may establish the capability to power an essentialSGI .1, bus from an alternate power supply during the additionalSG1 .2 time that may be potentially available. Please justifyincluding Tables C-2 and S-I for CA2.1, S1.1, SGI.1, andSG1 .2 or revise accordingly.For EAL CA3.1, please explain why the CNS Basis has a CNS has added new Note 9 to CA3.1 that reads:statmen reate towha to o wen elibleNOS"In the absence of reliable NCS temperature indication12 CA3.1 temperature indication is absent. If this is an accuratecasdbthlosfdeyhetrmolcpbltystatement, then please explain why this is not provided as a clsicaonhudbeaedntmeobilaawennNOTE for the EAL, or revise accordingly. Mode 5 and 6"For EAL HU2.1, please explain in further detail the process Immediate control room alarm indication of an earthquake ofused to determine if the seismic activity has exceeded the either 0.08 g horizontal or 0.053 g vertical or greater isOperating Basis Earthquake (OBE) threshold and its annunciated through the system's network control centerclassification timeliness. If the OBE threshold (vertical) is (NCC), following seismic trigger actuation by at least two13 HU2.1 not recognized in a timely fashion from indications in, or accelerographs (vertical switch settings are 2/3 of thenear, the Control Room, then explain why the alternative respective horizontal switch settings). Therefore exceedingEAL was not developed in accordance with NEI 99-01, either the horizontal or vertical OBE thresholds actuates theRevision 6, or revise accordingly. specified alarm.Classification is based upon receipt of this alarm.

U.S. Nuclear Regulatory CommissionCNS-1 6-010Enclosure 1Page 7 of 13RAI # SECTION/QusonCSRpneCNS- EAL esinNSepoeThe HU2.1 bases has been revised to clarify that the OBEalarm is received based on exceeding either acceleration.Please explain why there was no EAL developed, possibly There is no site-specific lake level threat that is notas HU3.5, for ultimate heat sink (i.e., lake level) level adequately addressed through other Hazard and/or System14 HU3 issues, or revise accordingly. Malfunction EALs. High ultimate heat sink (i.e. lake level) isadequately addressed by HU3.4. Low lake level (loss ofheat sink) is adequately addressed by CU3.1.For EALs HU4.1 and HU4.2, the areas listed in Table H-i Table H-i Fire Areas are based on CNS-1465.00-00-0006seem to be vague or too all-encompassing. Please explain Design Basis Specification for the Plant Fire Protection andif the listed areas are all the areas that contain equipment AP/0/A/5500/045 Plant Fire. Table H-i Fire Areas includeneeded for safe operation, safe shutdown and safe cool- those structures containing functions and systems requireddown, and if these areas can be fine-tuned to limit for safe operation, shutdown and cooldown of the plantconsideration for these EALs, or revise accordingly. (SAFETY SYSTEMS).A balance must be established between defining major plant15 HU4.1, structures containing safe shutdown equipment as fire areasHU4.2 versus a detailed list of areas for every safety systemcomponent location. The Table H-i list of fire areasachieves that balance in support of timely and accurateemergency classification for the end-user.The list of areas could be further refined based on the PostFire Safe Shutdown analyzed Fire Areas as given in theSafe Shutdown Design Basis Specification (CNS-i1435.00-00-0002). However, further refinement would not result in U.S. Nuclear Regulatory CommissionCNS-1 6-010Enclosure 1Page 8 of 13RAI # SECTION/ usinCSRsosCNS- EALQusinCSRpoeany changes in how reporting would be performed.For EALs HU4.3 and HU4.4, please confirm that the The CNS ISFSI is contained wholly within the plant16 HU4.3, Independent Spent Fuel Storage Installation (ISFSI) would Protected Area. Therefore the ISFSI would be applicable to16 HU4.4 be an area applicable to these EALs, or revise accordingly. EALs HU4.3 and HU4.4 for fires within the plant ProtectedArea.For EAL HA5.1, please note in the CNS Basis that this EAL The following note has been added to the HA5.1 bases tois typically applicable in all operating modes, but is limited ensure HA5.1 mode applicability remains in alignment withto operating mode 4 based upon a review of applicable Table H-2 Room/Area mode applicability:areas of concern. However, if the plant is modified such "NOTE: IC HA5 mode applicability has been limited to thethat additional areas and/or operating modes becomeaplcleodsintfdinTleH2SeOerin&applicable, this EAL must be revised accordingly. Please applicabl modes/identi/fie ind abe H-2 Slafe operationgexplain what process is in place which ensures that future ShtonRmsAe.Ifdeopltoerigplan chnge ar cosidred or the thn oeraingprocedure or plant configuration changes, the applicableplant changesre cosierdoroterthn.peatn plant modes specified in Table H-2 are changed, a17 HA5.1 corresponding change to Attachment 3 'Safe Operation &Shutdown Areas Tables R-2 & H-2 Bases' and to IC HA5mode applicability is required."Operations procedure group will use their trackingmechanism to ensure that whenever "Controlling Procedurefor Unit Shutdown," (OP/1/A/6100/002 or OP/2/A/6100/002)are revised, Emergency Planning (EP) will be required toreview the changes to ensure that the changes are validatedagainst HA5.1. Based on review by EP, if changes have________________been made such that additional areas and/or operating U.S. Nuclear Regulatory CommissionCNS-1 6-010Enclosure 1Page 9 of 13RAI # SECTION/QusonCSRpneCNS- EAL esinCSepoemodes become applicable, EAL will be revised accordingly.For EAL HS6.1, please explain why the operating mode CNS has revised HS6.1 mode applicability from ALL tospecificity to the key safety functions listed in the EAL was Modes 1 -6.not incorporated, or revise accordingly. CNS has revised HS6.1 based upon an assessment ofapplicable modes for each of the listed safety function asfollows:'An event has resulted in plant control being transferred18 HS6.1 from the Control Room to the Auxiliary Shutdown Panels orStandby Shutdown Facility (SSF)ANDCon trol of any of the following key safety functions is notreestablished within 15 min. (Note 1):* Reactivity (Modes 1, 2 and 3 only)* Core Cooling* NCS heat removal"Under Category E -Independent Spent Fuel Storage CNS has deleted the following cited statement from theInstallation (ISFSI) guidance, the statement: "Formal offsite Category E introductionplanning is not required because the postulated worst-case "Formal offsite planning is not required because the19 U .1 accident involving an ISFSI has insignificant consequences postulated worst-case accident involving an ISFSI has19 EI. 1 to the public health and safety," is not applicable to thisproposed EAL scheme. Please provide further justification insignificant consequences to the public health and safety."for this statement or revise accordingly to remove. Revised the ISFSI category introduction to read:_____In addition, please incorporate guidance related to the fact "The CNS ISFSI is contained wholly within the plant U.S. Nuclear Regulatory CommissionCNS-1 6-010Enclosure 1Page 10 of 13RAI # SECTIONI/usinCSRsosCNS- EALQusinNSRpoethat EALs HU1 and HAl are also considered for events that Protected Area. Therefore a security event related to theoccur at the ISFSI, or explain basis for not including. ISFSI would be applicable to EALs HUl.1, HAI.landHSI. 1."For EAL SU8.1, please explain why the information from The bases discussion related to declaration timing providesthe ON Basis related to the timing of the declaration is not background on containment cooling system operatingin the actual EAL or as a note, or revise accordingly. design. The EAL threshold "... one full train of containmentcooling operating per design for > 15 min." includes thedescribed operating characteristics and is fully understoodby Control Room operators.20 SU8.1 CNS has added new Note 10 to SU8.1 and ContainmentPotential Loss D.3 to re-inforce the bases information:"If the loss of containment cooling threshold is exceededdue to loss of both trains of VX-CARF, this EAL onlyapplies if at least one train of VX-CARF is not operating,per design, after the 10 minute actuation delay for greaterthan or equal to 15 minutes"Under the Fission Product Barrier (FPB) Matrix, the cited As per response to RAI-CNS-2, the CNS site specific andNEI 99-01 Basis sections for several of the FPB criteria are NEI 99-01 Revision 6 bases have been unified.PB not from the NRC-endorsed NEI 99-01, Revision 6. Please21 Mtrix either revise to what has actually been endorsed or,Bases depending on the response to RAI-03, unify the basissections into one.

U.S. Nuclear Regulatory CommissionCNS-1 6-010Enclosure 1Page 11 ofl13RAI # SECTION/QusinCSRpoeCNS- EALQusinCSRpoeFor the Fission Barrier Matrix, please provide thedocumentation supporting the values from Table F-2.22FPBMatrixBasesTable F-2The values presented in Table F-2 were derived from CNSCore Damage Assessment Guidelines (RPIOIAI5000101 5).The figures in RP/0/A/5000/015 are based on values derivedin CNS Estimated Sample Dose and CDAG SetpointCalculation in Support of PASS Elimination (DPC-1 229.00-00-0006).Table F-2 values are derived from RP/0/A/5000/015 Figures1 and 3 as follows:FC LossColumn FC Loss represents, based on core damageassessment procedure, the expected containment high rangeradiation monitor (EMF53A & B) response based on a LOCA,for periods of 1, 2, 8 and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> after shutdown, no spraysand NCS pressure < 1600 psig with -2% fuel failure.The value is derived as follows:RP/0/A/5000/015 Figure 3 Containment Radiation Level vs.Time for 100% Clad Damage 1, 2, 8 and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> aftershutdown without spray and NCS pressure < 1600 psig x0.02 (rounded).NCS LossThe value specified represents, based on core damageassessment procedure RP/0/A/5000/015 Figure 1, the U.S. Nuclear Regulatory CommissionCNS-1 6-010Enclosure 1Page 12 of 13RAI # SECTION/QusinCSRpoeCNS- EALQusinCSRpoeexpected containment high range radiation monitor (EMF53A& B) response based on a LOCA, for periods of 1, 2, 8 and16 hours after shutdown with no fuel failure.The value is derived as follows:RP/0/A/5000/01 5 Figure 1 Containment Radiation Level vs.Time for RCS Release for periods of 1, 2, 8 and 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />safter shutdown (rounded).CMT Pot. LossThe Table F-2 values, column CMT Potential Lossrepresents, based on core damage assessment procedure,the expected containment high range radiation monitor(EMF53A & B) response based on a LOCA, for periods of 1,2, 8 and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> after shutdown, no sprays and NOSpressure < 1600 psig with '-20% fuel failure.The value is derived as follows:RP/0/A15000/015 Figure 3 Containment Radiation Level vs.Time for 100% Clad Damage 1, 2, 8 and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> aftershutdown with no spray and NCS pressure < 1600 psig x0.20 (rounded).

U.S. Nuclear Regulatory CommissionCNS-1 6-010Enclosure 1'Page 13 of 13Attachment ASummary of EAL Changes Not Associated with RAI ResponsesThe table below summarizes changes that have been incorporated into the EAL Technical Bases Document contained in Enclosure 2 that are notinvolved in the NRC RAI response.EAL Tech Basis#Change? DescriptionHU1 .1 Yes Split EAL HUl1.1 into three separate EALs: HU1 .1, HUl1.2 and HU1 .3 to better support the offsitenotification process.HA1 .1 Yes Split EAL HAl1.1 into two separate EALs: HAl1.1 and HAl1.2 to better support the offsite notificationprocess.SU4.1 Yes Revised SU4.1 to clarify NCS coolant activity limits to encompass Facility Operating License limits.:"NCS activity > Technical Specification 3.4.16 limits or Facility Operating License limits (151/1 59),whichever is more restrictive"

Enclosure

2Catawba Nuclear StationEmergency Action Level Technical Bases DocumentRevision 1 (Redline Version)

• ,, DUKECATAWBA NUCLEAR STATIONEMERGENCY ACTION LEVEL TECHNICAL BASESRevision 1Redline VersionIRPII/o500oo1oo01 Rev. 1 IPage 1 of 247 TABLE OF CONTENTSSECTION PAGE1.0 PURPOSE .............................................................................................. 32.0 DISCUSSION ........................................................................................... 32.1 Background ........................................................................................... 32.2 Fission Product Barriers ............................................................................. 42.3 Fission Product Barrier Classification Criteria...................................................... 42.4 EAL Organization..................................................................................... 52.5 Technical Bases Information ........................................................................ 72.6 Operating Mode Applicability........................................................................ 83.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS ..................................... 93.1 General Considerations ............................................................................ 103.2 Classification Methodology......................................................................... 104.0 REFERENCES........................................................................................ 144.1 Developmental ...................................................................................... 144.2 Implementing........................................................................................ 145.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS ................................................. 156.0 CNS TO NEI 99-01 Rev. 6 EAL CROSS-REFERENCE ........................................... 247.0 ATTACHMENTS ...................................................................................... 281 Emergency Action Level Technical Bases ................................................. 29Cateciory R Abnormal Rad Release / Rad Effluent.................................. 29Cateiqory C Cold Shutdown / Refueling System Malfunction ....................... 71Catecqorv H Hazards ................................................................. 108Categiory S System Malfunction..................................................... 153Cate~qory E ISFSI .................................................................... 197Cateciorv F Fission Product Barrier Degradation.................................. 2002 Fission Product Barrier Loss / Potential LossMatrix and Bases ........................................................................... 2053 Safe Operation & Shutdown Rooms/Areas Tables R-2 & H-2 Bases................... 253IRP/OIA/5000/O01 I Rev. 1I Page 2 of 247 1.0 PURPOSEThis document provides an explanation and rationale for each Emergency Action Level (EAL)included in the EAL Upgrade Project for Catawba Nuclear Station (CNS). It should be used tofacilitate review of the CNS EALs and provide historical documentation for future reference.Decision-makers responsible for implementation of RP/OIA/5000/O01 Classification ofEmergency, may use this document as a technical reference in support of EAL interpretation.This information may assist the Emergency Coordinator in making classifications, particularlythose involving judgment or multiple events. The basis information may also be useful intraining and for explaining event classifications to off-site officials.The expectation is that emergency classifications are to be made as soon as conditions arepresent and recognizable for the classification, but within 15 minutes or less in all cases ofconditions present. Use of this document for assistance is not intended to delay theemergency classification.Because the information in a basis document can affect emergency classification decision-making (e.g., the Emergency Coordinator refers to it during an event), the NRC staff expectsthat changes to the basis document will be evaluated in accordance with the provisions of10 CFR 50.54(q).2.0 DISCUSSION2.1 BackgroundEALs are the plant-specific indications, conditions or instrument readings that are utilized toclassify emergency conditions defined in the CNS Emergency Plan.In 1992, the NRC endorsed NUMARC/NESP-007 "Methodology for Development ofEmergency Action Levels" as an alternative to NUREG-0654 EAL guidance.NEI 99-01 (NUMARC/NESP-007) Revisions 4 and 5 were subsequently issued for industryimplementation. Enhancements over earlier revisions included:* Consolidating the system malfunction initiating conditions and example emergencyaction levels which address conditions that may be postulated to occur during plantshutdown conditions.* Initiating conditions and example emergency action levels that fully address conditionsthat may be postulated to occur at permanently Defueled Stations and IndependentSpent Fuel Storage Installations (ISFSIs).* Simplifying the fission product barrier EAL threshold for a Site Area Emergency.Subsequently, Revision 6 of NEI 99-01 has been issued which incorporates resolutions tonumerous implementation issues including the NRC EAL Frequently Asked Questions (FAQs).Using NEI 99-01 Revision 6, "Methodology for the Development of Emergency Action Levelsfor Non-Passive Reactors," November 2012 (ADAMS Accession Number )VlL1 2326A805) (ref. Deleted:" ML1102403244.1.1), CNS conducted an EAL implementation upgrade project that produced the EALsdiscussed herein.IRPIOIAI5000I100 Rev. 1 IPage 3 of 247 2.2 Fission Product BarriersFission product barrier thresholds represent threats to the defense in depth design conceptthat precludes the release of radioactive fission products to the environment. This conceptrelies on multiple physical barriers, any one of which, if maintained intact, precludes therelease of significant amounts of radioactive fission products to the environment.Many of the EALs derived from the NEI methodology are fission product barrier thresholdbased. That is, the conditions that define the EALs are based upon thresholds that representthe loss or potential loss of one or more of the three fission product barriers. "Loss" and"Potential Loss" signify the relative damage and threat of damage to the barrier. A "Loss"threshold means the barrier no longer assures containment of radioactive materials. A"Potential Loss" threshold implies an increased probability of barrier loss and decreasedcertainty of maintaining the barrier.The primary fission product barriers are:A. Fuel Clad (FC): The Fuel Clad Barrier consists of the cladding material that contains thefuel pellets.B. Reactor Coolant System (NCS): The NCS Barrier includes the NCS primary side and itsconnections up to and including the pressurizer safety and relief valves, and otherconnections up to and including the primary isolation valves.C. Containment (CMT): The Containment Barrier includes the containment building andconnections up to and including the outermost containment isolation valves. This barrieralso includes the main steam, feedwater, and blowdown line extensions outside thecontainment building up to and including the outermost secondary side isolation valve.Containment Barrier thresholds are used as criteria for escalation of the EmergencyClassification Level (ECL) from Alert to a Site Area Emergency or a General Emergency2.3 Fission Product Barrier Classification CriteriaThe following criteria are the bases for event classification related to fission product barrierloss or potential loss:Alert:Any loss or any potential loss of either Fuel Clad or NCS barrierSite Area Emergqency:Loss or potential loss of any two barriersGeneral Emergqency:Loss of any two barriers and loss or potential loss of the third barrierR.P/0/15s000/100 Rev. 1 Page 4of 247 2.4 EAL OrganizationThe CNS EAL scheme includes the following features:* Division of the EAL set into three broad groups:o EALs applicable under all plant operating modes -This group would be reviewedby the EAL-user any time emergency classification is considered.o EALs applicable only under hot operating modes -This group would only bereviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby,Startup, or Power Operation mode.o EALs applicable only under cold operating modes -This group would only bereviewed by the EAL-user when the plant is in Cold Shutdown, Refueling orDefueled mode.The purpose of the groups is to avoid review of hot condition EALs when the plant is ina cold condition and avoid review of cold condition EALs when the plant is in a hotcondition. This approach significantly minimizes the total number of EALs that must bereviewed by the EAL-user for a given plant condition, reduces EAL-user reading burdenand, thereby, speeds identification of the EAL that applies to the emergency.* Within each group, assignment of EALs to categories and subcategories:Category and subcategory titles are selected to represent conditions that are operationallysignificant to the EAL-user. The CNS EAL categories are aligned to and represent the NEI 99-01"Recognition Categories." Subcategories are used in the CNS scheme as necessary tofurther divide the EALs of a category into logical sets of possible emergency classificationthresholds. The CNS EAL categories and subcategories are listed below.IRPIO/A150001001 IRev. 1I Page 5 of 247 EAL Groups, Categories and SubcategoriesEAL Group/Category _[EAL SubcategoryAny Operatinga Mode:R -Abnormal Rad Levels / Rad Effluent 1 -Radiological Effluent2 -Irradiated Fuel Event3- Area Radiation LevelsH -Hazards and Other Conditions 1 -SecurityAffecting Plant Safety 2 -Seismic Event3 -Natural or Technological Hazard4 -Fire5 -Hazardous Gas6 -Control Room Evacuation7 -Emergency Coordinator JudgmentE -Independent Spent Fuel Storage 1-CnieetBudrInstallation (ISFSI) 1-CnieetBudrHot Conditions:S -System Malfunction 1 -Loss of Essential AC Power2 -Loss of Vital DC Power3 -Loss of Control Room Indications4 -NCS Activity5 -NCS Leakage6 -RPS Failure7 -Loss of Communications8 -Containment Failure9 -Hazardous Event Affecting Safety SystemsF -Fission Product Barrier Degradation NoneCold Conditions:C -Cold Shutdown / Refueling System 1 -NCS LevelMalfunction 2 -Loss of Essential AC Power3 -NCS Temperature4 -Loss of Vital DC Power5 -Loss of Communications6 -Hazardous Event Affecting Safety SystemsThe primary tool for determining the emergency classification level is the EAL ClassificationMatrix. The user of the EAL Classification Matrix may (but is not required to) consult the EALTechnical Bases Document in order to obtain additional information concerning the EALsunder classification consideration. The user should consult Section 3.0 and Attachments 1 & 2of this document for such information.2.5 Technical Bases InformationIRPIOIAI50001001 Rev. 1 Page 6 of 247 EAL technical bases are provided in Attachment 1 for each EAL according to EAL group (Any,Hot, Cold), EAL category (R, C, H, 5, F and E) and EAL subcategory. A summary explanationof each category and subcategory is given at the beginning of the technical bases discussionsof the EALs included in the category. For each EAL, the following information is provided:Cateaqory Letter & TitleSubcatecqory Number & TitleInitiatingq Condition (IC)Site-specific description of the generic IC given in NEI 99-01 Rev. 6.EAL Identifier (enclosed in rectangqle)Each EAL is assigned a unique identifier to support accurate communication of theemergency classification to onsite and offsite personnel. Four characters define each EALidentifier:1. First character (letter): Corresponds to the EAL category as described above (R, C,H, S, F or E)2. Second character (letter): The emergency classification (G, 5, A or U)G =General EmergencyS = Site Area EmergencyA = AlertU = Unusual Event3. Third character (number): Subcategory number within the given category.Subcategories are sequentially numbered beginning with the number one (1). If acategory does not have a subcategory, this character is assigned the number one(1).4. Fourth character (number): The numerical sequence of the EAL within the EALsubcategory. If the subcategory has only one EAL, it is given the number one (1).Classification (enclosed in rectangqle):Unusual Event (U), Alert (A), Site Area Emergency (5) or General Emergency (G)EAL (enclosed in rectangqle)Exact wording of the EAL as it appears in the EAL Classification MatrixIRPIOIAI50001001 Rev. 1 Page 7 of 247 Mode ApplicabilityiOne or more of the following plant operating conditions comprise the mode to which eachEAL is applicable: 1 -Power Operation, 2 -Startup, 3 -Hot Standby, 4 -Hot Shutdown, 5 -Cold Shutdown, 6 -Refueling, D -Defueled, or All. (See Section 2.6 for operating modedefinitions)Definitions:If the EAL wording contains a defined term, the definition of the term is included in thissection. These definitions can also be found in Section 5.1.Basis:A basis section that provides CNS-re!levant information concerning the EAL~ps well as a Dlte:Plant-Spcifcdescription of the rationale for the EAL as provided in NEI 99-01 Rev. 6. eee' hi sf~wdb[Generic basis section that providesCNS Basis Reference(s):Site-specific source documentation from which the EAL is derived2.6 Operating Mode Applicability (ref. 4.1.7)1 Power OperationKeff> 0.99 and reactor thermal power > 5%2 Startup_Keff > 0.99 and reactor thermal power < 5%3 Hot StandbyKeff < 0.99 and average coolant temperature > 350°F3 Hot ShutdownKeff < 0.99 and average coolant temperature 3500F > Tavg > 200 0F4 Cold ShutdownKeff < 0.99 and average coolant temperature < 2000F5 RefuelinciOne or more reactor vessel head closure bolts are less than fully tensionedo DefueledReactor vessel contains no irradiated fuelThe plant operating mode that exists at the time that the event occurs (prior to any protectivesystem or operator action being initiated in response to the condition) should be compared tothe mode applicability of the EALs. If a lower or higher plant operating mode is reached beforethe emergency classification is made, the declaration shall be based on the mode that existedat the time the event occurred.SRP/0/A/5000/001 [Rev. 1 Page 8 of 247 3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS3.1 General ConsiderationsWhen making an emergency classification, the Emergency Coordinator must consider allinformation having a bearing on the proper assessment of an Initiating Condition (IC). Thisincludes the Emergency Action Level (EAL) plus the associated Operating Mode Applicability,Notes, and the informing basis information. In the Recognition Category F matrices, EALs arebased on loss or potential loss of Fission Product Barrier Thresholds.3.1.1 Classification TimelinessNRC regulations require the licensee to establish and maintain the capability to assess,classify, and declare an emergency condition within 15 minutes after the availability ofindications to plant operators that an emergency action level has been exceeded and topromptly declare the emergency condition as soon as possible following identification of theappropriate emergency classification level. The NRC staff has provided guidance onimplementing this requirement in NSIR/DPR-ISG-01, 'Interim Staff Guidance, EmergencyPlanning for Nuclear Power Plants" (ref. 4.1.12).3.1.2 Valid IndicationsAll emergency classification assessments shall be based upon valid indications, reports orconditions. A valid indication, report, or condition, is one that has been verified throughappropriate means such that there is no doubt regarding the indicator's operability, thecondition's existence, or the report's accuracy. For example, verification could beaccomplished through an instrument channel check, response on related or redundantindicators, or direct observation by plant personnel.An indication, report, or condition is considered to be valid when it is verified by (1) aninstrument channel check, or (2) indications on related or redundant indicators, or (3) by directobservation by plant personnel, such that doubt related to the indicator's operability, thecondition's existence, or the report's accuracy is removed. Implicit in this definition is the needfor timely assessment.3.1.3 Imminent ConditionsFor Its and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), theEmergency Coordinator should not wait until the applicable time has elapsed, but shoulddeclare the event as soon as it is determined that the condition has exceeded, or will likelyexceed, the applicable time. If an ongoing radiological release is detected and the releasestart time is unknown, it should be assumed that the release duration specified in the IC/EALhas been exceeded, absent data to the contrary.3.1.4 Planned vs. Unplanned EventsA planned work activity that results in an expected event or condition which meets or exceedsan EAL does not warrant an emergency declaration provided that: 1 ) the activity proceeds asplanned, and 2) the plant remains within the limits imposed by the operating license. Suchactivities include planned work to test, manipulate, repair, maintain or modify a system orcomponent. In these cases, the controls associated With the planning, preparation andexecution of the work Will ensure that compliance is maintained with all aspects of theoperating license provided that the activity proceeds and concludes as expected. Events orconditions of this type may be subject to the reporting requirements of 10 § CFR 50.72 (ref.4.1.4).IRPIOIA/50001001 Rev. 1 Page 9 of 247 3.1.5 Classification Based on AnalysisThe assessment of some EALs is based on the results of analyses that are necessary toascertain whether a specific EAL threshold has been exceeded (e.g., dose assessments,chemistry sampling, NCS leak rate calculation, etc.). For these EALs, the EAL wording or theassociated basis discussion will identify the necessary analysis. In these cases, the 15-minutedeclaration period starts with the availability of the analysis results that show the threshold tobe exceeded (i.e., this is the time that the EAL information is first available). The NRC expectslicensees to establish the capability to initiate and complete EAL-related analyses within areasonable period of time (e.g., maintain the necessary expertise on-shift).3.1.6 Emergency Coordinator JudgmentWhile the EALs have been developed to address a full spectrum of possible events andconditions which may warrant emergency classification, a provision for classification based onoperator/management experience and judgment is still necessary. The NEI 99-01 EALscheme provides the Emergency Coordinator with the ability to classify events and conditionsbased upon judgment using EALs that are consistent with the Emergency Classification Level(ECL) definitions (refer to Category H). The Emergency Coordinator will need to determine ifthe effects or consequences of the event or condition reasonably meet or exceed a particularECL definition. A similar provision is incorporated in the Fission Product Barrier Tables;judgment may be used to determine the status of a fission product barrier.3.2 Classification MethodologyTo make an emergency classification, the user will compare an event or condition (i.e., therelevant plant indications and reports) to an EAL(s) and determine if the EAL has been met orexceeded. The evaluation of an EAL must be consistent with the related Operating ModeApplicability and~ Notes. If an EAL has been met or exceeded, the associated IC is likewisemet, the emergency classification process "clock" starts, and the ECL must be declared inaccordance with plant procedures no later than fifteen minutes after the process "clock"started.When assessing an EAL that specifies a time duration for the off-normal condition, the 'clock"for the EAL time duration runs concurrently with the emergency classification process "clock."For a full discussion of this timing requirement, refer to NSIR/DPR-ISG-01 (ref. 4.1.14).3.2.1 Classification of Multiple Events and ConditionsWhen multiple emergency events or conditions are present, the user will identify all met orexceeded EALs. The highest applicable ECL identified during this review is declared. Forexample:* If an Alert EAL and a Site Area Emergency EAL are met, whether at one unit or at twodifferent units, a Site Area Emergency should be declared.There is no "additive" effect from multiple EALs meeting the same ECL. For example:* If two Alert EALs are met, whether at one unit or at two different units, an Alert shouldbe declared.Related guidance concerning classification of rapidly escalating events or conditions isprovided in Regulatory Issue Summary (RIS) 2007-02, Clarification of NRC Guidance forEmergency Notifications During Quickly Changing Events (ref. 4.1.2).3.2.2 Consideration of Mode Changes During ClassificationIRP/O/N50001001 Rev. 1 Page 10 of 247I The mode in effect at the time that an event or condition occurred, and prior to any plant oroperator response, is the mode that determines whether or not an IC is applicable. If an eventor condition occurs, and results in a mode change before the emergency is declared, theemergency classification level is still based on the mode that existed at the time that the eventor condition was initiated (and not when it was declared). Once a different mode is reached,any new event or condition, not related to the original event or condition, requiring emergencyclassification should be evaluated against the ICs and EALs applicable to the operating modeat the time of the new event or condition.For events that occur in Cold Shutdown or Refueling, escalation is via EALs that are applicablein the Cold Shutdown or Refueling modes, even if Hot Shutdown (or a higher mode) is enteredduring the subsequent plant response. In particular, the fission product barrier EALs areapplicable only to events that initiate in the Hot Shutdown mode or higher.3.2.3 Classification of Imminent ConditionsAlthough EALs provide specific thresholds, the Emergency Coordinator must remain alert toevents or conditions that could lead to meeting or exceeding an EAL within a relatively shortperiod of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the EmergencyCoordinator, meeting an EAL is IMMINENT, the emergency classification should be made as ifthe EAL has been met. While applicable to all emergency classification levels, this approach isparticularly important at the higher emergency classification levels since it provides additionaltime for implementation of protective measures.3.2.4 Emergency Classification Level Upgrading and DowngradingAn ECL may be downgraded when the event or condition that meets the highest IC and EALno longer exists, and other site-specific downgrading requirements are met. If downgradingthe ECL is deemed appropriate, the new ECL would then be based on a lower applicable IC(s)and EAL(s). The ECL may also simply be terminated.As noted above, guidance concerning classification of rapidly escalating events or conditions isprovided in RIS 2007-02 (ref. 4.1.2).3.2.5 Classification of Short-Lived EventsEvent-based ICs and EALs define a variety of specific occurrences that have potential oractual safety significance. By their nature, some of these events may be short-lived and, thus,over before the emergency classification assessment can be completed. If an event occursthat meets or exceeds an EAL, the associated ECL must be declared regardless of itscontinued presence at the time of declaration. Examples of such events include anearthquake or a failure of the reactor protection system to automatically trip the reactorfollowed by a successful manual trip.3.2.6 Classification of Transient ConditionsMany of the ICs and/or EALs employ time-based criteria. These criteria will require that theIC/EAL conditions be present for a defined period of time before an emergency declaration iswarranted. In cases where no time-based criterion is specified, it is recognized that sometransient conditions may cause an EAL to be met for a brief period of time (e.g., a few secondsto a few minutes). The following guidance should be applied to the classification of theseconditions.EAL momentarily met duringq expected plant response -In instances where an EAL is brieflymet during an expected (normal) plant response, an emergency declaration is not warrantedRP0/1I0/01Rev. 1 IPage 11 of 247I provided that associated systems and components are operating as expected, and operatoractions are performed in accordance with procedures.EAL momentarily met but the condition is corrected prior to an emercqency declaration -If anoperator takes prompt manual action to address a condition, and the action is successful incorrecting the condition prior to the emergency declaration, then the applicable EAL is notconsidered met and the associated emergency declaration is not required. For illustrativepurposes, consider the following example:An ATWS occurs and the high pressure ECCS systems fail to automatically start. RPVlevel rapidly decreases and the plant enters an inadequate core cooling condition (apotential loss of both the fuel clad and NCS barriers). If an operator manually starts ahigh pressure EGGS system in accordance with an EOP step and clears the inadequatecore cooling condition prior to an emergency declaration, then the classification shouldbe based on the ATWS only.It is important to stress that the 15-minute emergency classification assessment period(process clock) is not a "grace period" during which a classification may be delayed to allowthe performance of a corrective action that would obviate the need to classify the event.Emergency classification assessments must be deliberate and timely, with no undue delays.The provision discussed above addresses only those rapidly evolving situations when anoperator is able to take a successful corrective action prior to the Emergency Coordinatorcompleting the review and steps necessary to make the emergency declaration. Thisprovision is included to ensure that any public protective actions resulting from the emergencyclassification are truly warranted by the plant conditions.3.2.7 After-the-Fact Discovery of an Emergency Event or ConditionIn some cases, an EAL may be met but the emergency classification was not made at the timeof the event or condition. This situation can occur when personnel discover that an event orcondition existed which met an EAL, but no emergency was declared, and the event orcondition no longer exists at the time of discovery. This may be due to the event or conditionnot being recognized at the time or an error that was made in the emergency classificationprocess.In these cases, no emergency declaration is warranted; however, the guidance contained inNUREG-1 022 (ref. 4.1.3) is applicable. Specifically, the event should be reported to the NRCin accordance with 10 CFR § 50.72 (ref. 4.1.4) within one hour of the discovery of theundeclared event or condition. The licensee should also notify appropriate State and localagencies in accordance with the agreed upon arrangements.3.2.8 Retraction of an Emergency DeclarationGuidance on the retraction of an emergency declaration reported to the NRC is discussed inNUREG-1022 (ref. 4.1.3).JRP/O/AI5000/O01 JRev. 1 Page 12 of 247 4.0 REFERENCES4.1 Developmental4.1.1 NEI 99-01 Revision 6, Methodology for the Development of Emergency ActionLevels for Non-Passive Reactors, ADAMS Accession NumberMlL12326A805_4.1.2 RIS 2007-02 Clarification of NRC Guidance for Emergency Notifications DuringQuickly Changing Events, February 2, 2007.4.1.3 NUREG-1022 Event Reporting Guidelines: 10CFR50.72 and 50.734.1.4 10 § CFR 50.72 Immediate Notification Requirements for Operating NuclearPower Reactors4.1.5 10 § CFR 50.73 License Event Report System4.1.6 CNS-SLC-16.11-16 Figure 16.11-16-1 Unrestricted Area and Site Boundary forRadioactive Effluents4.1.7 CNS UFSAR Figure 1-20 Plot Plan4.1.8 Technical Specifications Table 1.1-1 Modes4.1.9 OP/0/A/6100/014 Penetration Control for Modes 5, 6 and NO Mode -Enclosure4.7 Setting, Maintaining and Securing from Containment Penetration Control4.1.10 PRO-NGGC-0201 NGG Procedure Writers Guide4.1.11 NSIRIDPR-ISG-01 Interim Staff Guidance, Emergency Planning for NuclearPower Plants4.1.12 CNS ISFSI Certificates of Compliance4.1.13 CNS Emergency Plan4.2 Implementing4.2.1 RP/0/AN5000/001 Classification of Emergency4.2.2 NEI 99-01 Rev. 6 to CNS EAL Comparison Matrix4.2.3 CNS EAL MatrixDeleed:ML1 10240324IRPIOIA150001001 Rev. 1 1Page 13 of 247 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS5.1 Definitions (ref. 4.1.1 except as noted)Selected terms used in Initiating Condition and Emergency Action Level statements are set inall capital letters (e.g., ALL CAPS). These words are defined terms that have specificmeanings as used in this document. The definitions of these terms are provided below.AlertEvents 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 probable lifethreatening risk to site personnel or damage to site equipment because of hostile action. Anyreleases are expected to be small fractions of the EPA Protective Action Guideline exposurelevels.Confinement BoundaryThe barrier(s) between spent fuel and the environment once the spent fuel is processed for drystorage. As related to the CNS ISFSI, Confinement Boundary is defined as the TransportableStorage Canister (TSC) for both NAC-UMS and MAGNASTAR storage systems.Containment ClosureThe procedurally defined actions taken to secure containment and its associated structures,systems, and components as a functional barrier to fission product release under shutdownconditions.As applied to CNS, Containment Closure is established when the requirements ofOP/O/A/6100/014 Penetration Control for Modes 5, 6 and NO Mode -Enclosure 4.7 Setting,Maintaining and Securing from Containment Penetration Control are met (ref. 4.1.9).Emergency Action Level (EAL)A pre-determined, site-specific, observable threshold for an Initiating Condition that, when metor exceeded, places the plant in a given emergency classification level.Emergency Classification Level (ECL)One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC)for grouping off-normal events or conditions according to (1) potential or actual effects orconsequences, and (2) resulting onsite and offsite response actions. The emergencyclassification levels, in ascending order of severity, are:* Unusual Event (UE)* Alert* Site Area Emergency (SAE)* General Emergency (GE)EPA PAGsEnvironmental Protection Agency Protective Action Guidelines. The EPA PAGs are expressedin terms of dose commitment: 1 Remn TEDE or 5 Remn CDE Thyroid. Actual or projected offsiteexposures in excess of the EPA PAGs requires CNS to recommend protective actions for thegeneral public to offsite planning agencies.ExplosionIRP/O/N50001001 Rev. 1 Page 14 of 247 A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemicalreaction or overpressurization. A release of steam (from high energy lines or components) oran electrical component failure (caused by short circuits, grounding, arcing, etc.) should notautomatically be considered an explosion. Such events require a post-event inspection todetermine if the attributes of an explosion are present.FaultedThe term applied to a steam generator that has a steam leak on the secondary side ofsufficient size to cause an uncontrolled drop in steam generator pressure or the steamgenerator to become completely depressurized.Fission Product Barrier ThresholdA pre-determined, site-specific, observable threshold indicating the loss or potential loss of afission product barrier.FireCombustion characterized by heat and light. Sources of smoke such as slipping drive belts oroverheated electrical equipment do not constitute fires. Observation of flame is preferred butis NOT required if large quantities of smoke and heat are observed.FloodingA condition where water is entering a room or area faster than installed equipment is capableof removal, resulting in a rise of water level within the room or area.General EmergencyEvents are in progress or have occurred which involve actual or imminent substantial coredegradation or melting with potential for loss of containment integrity or hostile actions thatresult in an actual loss of physical control of the facility. Releases can be reasonably expectedto exceed EPA Protective Action Guideline exposure levels offsite for more than the immediatesite area.HostageA person(s) held as leverage against the station to ensure that demands will be met by thestation.Hostile ActionAn act toward CNS or its personnel that includes the use of violent force to destroy equipment,take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air,land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliverdestructive force. Other acts that satisfy the overall intent may be included. Hostile actionshould not be construed to include acts of civil disobedience or felonious acts that are not partof a concerted attack on CNS. Non-terrorism-based EALs should be used to address suchactivities (i.e., this may include violent acts between individuals in the owner controlled area).Hostile ForceOne or more individuals who are engaged in a determined assault, overtly or by stealth anddeception, equipped with suitable weapons capable of killing, maiming, or causing destruction.Imminent The trajectory of events or conditions is such that an EAL will be met within a relatively shortperiod of time regardless of mitigation or corrective actions.Impede(d)Personnel access to a room or area is hindered to an extent that extraordinary measures arenecessary to facilitate entry of personnel into the affected room/area (e.g., requiring use ofprotective equipment, such as SCBAs, that is not routinely employed).IntrusionThe act of entering without authorization. Discovery of a bomb in a specified area is indicationof intrusion into that area by a hostile force.Independent Spent Fuel Storage Installation (ISFSI)A complex that is designed and constructed for the interim storage of spent nuclear fuel andother radioactive materials associated with spent fuel storage.Initiating Condition (IC)An event or condition that aligns with the definition of one of the four emergency classificationlevels by virtue of the potential or actual effects or consequences.MaintainTake appropriate action to hold the value of an identified parameter within specified limits.R.P/01A1000/00 1 IRev. 1 Page 16 of 247 Normal LevelsAs applied to radiological IC/EALs, the highest reading in the past twenty-four hours excludingthe current peak value.Owner Controlled AreaArea outside the PROTECTED AREA fence that immediately surrounds the plant. Access tothis area is generally restricted to those entering on official business. (ref. 4.1.13).ProjectileAn object directed toward a Nuclear Power Plant that could cause concern for its continuedoperability, reliability, or personnel safety.Protected AreaAn area encompassed by physical barriers and to which access is controlled. The ProtectedArea refers to the designated security area around the process buildings and is depicted inCNS UFSAR Figure 1-20 Plot Plan (ref. 4.1.7).NCS IntactThe NCS should be considered intact when the NCS pressure boundary is in its normalcondition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams).Refueling PathwayThe reactor refueling cavity, spent fuel pool and fuel transfer canal comprise the refuelingpathway.RupturedThe condition of a steam generator in which primary-to-secondary leakage is of sufficientmagnitude to require a safety injection.RestoreTake the appropriate action required to return the value of an identified parameter to theapplicable limitsSafety SystemA system required for safe plant operation, cooling down the plant and/or placing it in the coldshutdown condition, including the EGGS. These are typically systems classified as safety-related (as defined in 10CFR50.2):Those structures, systems and components that are relied upon to remain functional duringand following design basis events to assure:(1) The integrity of the reactor coolant pressure boundary;(2) The capability to shut down the reactor and maintain it in a safe shutdown condition;(3) The capability to prevent or mitigate the consequences of accidents which could resultin potential offsite exposures.Security ConditionAny security event as listed in the approved security contingency plan that constitutes athreat/compromise to site security, threat/risk to site personnel, or a potential degradation tothe level of safety of the plant. A security condition does not involve a hostile action.

Site Area EmergencyEvents are in progress or have occurred which involve actual or likely major failures of plantfunctions needed for protection of the public or HOSTILE ACTION that results in intentionaldamage or malicious acts; 1 ) toward site personnel or equipment that could lead to the likelyfailure of or; 2) that prevent effective access to, equipment needed for the protection of thepublic. Any releases are not expected to result in exposure levels which exceed EPA PAGexposure levels beyond the SITE BOUNDARY.Site BoundaryArea as depicted in CNS-SLC-16.1 1-16 Figure 16.1 1-16-1 Unrestricted Area and SiteBoundary for Radioactive Effluents (ref. 4.1.6).UnisolableAn open or breached system line that cannot be isolated, remotely or locally.UnplannedA parameter change or an event that is not 1) the result of an intended evolution or 2) anexpected plant response to a transient. The cause of the parameter change or event may beknown or unknown.Unusual EventEvents are in progress or have occurred which indicate a potential degradation of the level ofsafety of the plant or indicate a security threat to facility protection has been initiated. Noreleases of radioactive material requiring offsite response or monitoring are expected unlessfurther degradation of SAFETY SYSTEMS occurs.ValidAn indication, report, or condition, is considered to be valid when it is verified by (1) aninstrument channel check, or (2) indications on related or redundant indicators, or (3) by directobservation by plant personnel, such that doubt related to the indicator's operability, thecondition's existence, or the report's accuracy is removed. Implicit in this definition is the needfor timely assessment.Visible DamageDamage to a component or structure that is readily observable without measurements, testing,or analysis. The visual impact of the damage is sufficient to cause concern regarding theoperability or reliability of the affected component or structure.IRP/O/AI5000/O001 Rev. 1 Page 18 of 247I 5.2 Abbreviations/Acronyms0F........................................................................... Degrees Fahrenheit°..................................................................................... DegreesAC........................................................................... Alternating CurrentAP............................................................. Abnormal Operating ProcedureATWS................................................... Anticipated Transient Without ScramCA.......................................................................... Auxiliary FeedwaterCNS.................................................................. Catawba Nuclear StationCDE............................................................... Committed Dose EquivalentCFR ...................................................... Code of Federal RegulationsCSFST ................................................... Critical Safety Function Status TreeDBA..................................................................... Design Basis AccidentDC ................................................................................ Direct CurrentEAL ................................................................... Emergency Action LevelECCS....................................................... Emergency Core Cooling SystemEC..................................................................... Emergency CoordinatorECL........................................................... Emergency Classification LevelEOF ........................................................... Emergency Operations FacilityFOP ......................................................... Emergency Operating ProcedureEPA......................................................... Environmental Protection AgencyERG.......................................................... Emergency Response GuidelineEPIP .............................................. Emergency Plan Implementing ProcedureESFE................................................................ Engineered Safety FeatureFAA ........................................................... Federal Aviation AdministrationFBI ............................................................ Federal Bureau of InvestigationFEMA.............................................. Federal Emergency Management AgencyFSAR............................................................. Final Safety Analysis ReportGE ......................................................................... General EmergencyIC ............................................................................ Initiating ConditionIPEEE............. Individual Plant Examination of External Events (Generic Letter 88-20)ISFSI ........................................... Independent Spent Fuel Storage InstallationKeff..................................................... Effective Neutron Multiplication FactorLCO ........................................................... Limiting Condition of OperationLER..................................................................... Licensee Event ReportLOCA ................................................................ Loss of Coolant AccidentLWR........................................................................ Light Water ReactorMPC..................................................................... Multi-Purpose CanisterMSIV............................................................... Main Steam Isolation ValveMSL ........................................................................... Main Steam LinemR, mRem, mrem, mREM.................................. milli-Roentgen Equivalent ManSRP/0/A/5000/001 Rev. 1 Page 19 of 247 MW .................................................................................... MegawattNCS................................................................... Reactor Coolant SystemNEI .................................................................... Nuclear Energy InstituteNESP................................................. National Environmental Studies ProjectNPP ....................................................................... Nuclear Power PlantNRC.......................................................... Nuclear Regulatory CommissionNSSS .......................................................... Nuclear Steam Supply SystemNORAD ..................................... North American Aerospace Defense Command(NO)UE .......................................................... Notification of Unusual EventOBE .............................................................. Operating Basis EarthquakeOCA..................................................................... Owner Controlled AreaODCM ....................................................... Off-site Dose Calculation ManualOR0 .......................................................... Offsite Response OrganizationPA................................................................................ Protected AreaPAG................................................................ Protective Action GuidelinePRAIPSA................ Probabilistic Risk Assessment / Probabilistic Safety AssessmentPWR ............................................................... Pressurized Water ReactorPSIG.......................................................... Pounds per Square Inch GaugeR ....................................................................................... RoentgenRem, rem, REM.................................................... Roentgen Equivalent ManRPS................................................................ Reactor Protection SystemRV............................................................................... Reactor VesselRVLIS ............................................... Reactor Vessel Level Indicating SystemSAR..................................................................... Safety Analysis ReportSBGTS ..................................................... Stand-By Gas Treatment SystemSBO ............................................................................ Station BlackoutSCBA.................................................... Self-Contained Breathing ApparatusSG ............................................................................ Steam GeneratorSI................................................................................ Safety InjectionSLC .......................................................... Selected Licensee CommitmentSPDS ...................................................... Safety Parameter Display SystemSRO................................................................... Senior Reactor OperatorSSF ..................................................................... Safe Shutdown FacilityTEDE ......................................................... Total Effective Dose EquivalentTOAF ........................................................................ Top of Active FuelTSC ................................................................. Technical Support CenterWOG ............................................................ Westinghouse Owners GroupSRP/0/A/5000/001 Rev. 1 Page 20 of 247 6.0 CNS-TO-NEI 99-01 Rev. 6 EAL CROSS-REFERENCEThis cross-reference is provided to facilitate association and location of a CNS EAL within theNEI 99-01 IC/EAL identification scheme. Further information regarding the development of theCNS EALs based on the NEI guidance can be found in the EAL Comparison Matrix.CNS NEI 99-01 Rev. 6EAL IC ExampleEALRU1.1 AU1 1, 2RU1.2 AU1 3RU2.1 AU2 1RA1.1 AAI 1RA1.2 AA1 2RA1.3 AAI 3RA1.4 AA1 4RA2.1 AA2 IRA2.2 AA2 2RA2.3 AA2 3RA3.1 AA3 IRA3.2 AA3 2RSI.1 ASI IRS1.2 AS1 2RS1.3 AS1 3RS2.1 AS2 IRG1.1 AGI 1RGI.2 AGi 2RG1.3 AGI 3RG2.1 AG2 1SRP/0/A/5000/001 Rev. I Page 21 of 247I CNS NEI 99-01 Rev. 6EAL IC ExampleEALCU1.1 CU1 1CU1.2 CU1 2CU2.1 CU2 1CU3.1 CU3 1CU3.2 CU3 2CU4.1 CU4 1CU5.1 CU5 1, 2, 3CAI.1 CA1 1CAI.2 CA1 2CA2.1 CA2 1CA3.1 CA3 1, 2CA6.1 CA61CS1.1 CS1 3CG1.1 CGi 2FAI.1 FA1 1FS1.1 FSI IFGI.1 FG1 1HU1.1 HUl 1,2 3HU2.1 HU2 1HU3.1 HU3 1HU3,2 HU3 2HU3,3 HU3 3HU3.4 HU3 4HU4.1 HU4 1HU4.2 HU4 2= " i, i , i,,' {I.!tIRPIoIAIooo0ooOQ1 Rev. 1 Page 22 of 2471 CNS NEI 99-01 Rev. 6EAL IC ExampleEAL ICEALHU4.3 HU4 3HU4.4 HU4 4HU7.1 HU7 1HA1.1 HA1 1, 2HA5.1 HA5 1HA6.1 HA6 1HA7.1 HA7 1HS1.1 HSl 1HS6.1 HS6 1HS7.1 HS7 1HG1.1 HG1 1HG7.1 HG7 1SU1.1 SU1 1SU3.1 SU2 ISU4.1 SU3 1SU4.2 SU3 2SU5.1 SU4 1, 2, 3SU6.1 SU5 1SU6.2 SU5 2SU7.1 SU6 1,2, 3SU8.1 SU7 1,2SA1.1 SA1 1SA3.1 SA2 1SA6.1 SA5 1SA9.1 SA9 1iv,¸SRP/0/A/5000/001 Rev. 1 Page 23 of 247 CNS NEI 99-01 Rev. 6EAL IC ExampleEALSS1.1 SS1 1SS2.1 SS8 1SS6.1 SS5 1SG1.1 SG1 1SG1.2 SG8 IEU1I. E-HUi 1SRP/oA15ooo/ool IRev. 1 IPage 24 of 2471 7.0 ATTACHMENTS7.17.2Attachment 1, Emergency Action Level Technical BasesAttachment 2, Fission Product Barrier Matrix and Basis:- -o ..il[SRP/0/A/5000/001 Rev. 1 Page 25 of 247I ATTACHMENT 1EAL BasesCategory R -Abnormal Rad Release / Rad EffluentEAL Group: ANY (EALs in this category are applicable toany plant condition, hot or cold.)Many EALs are based on actual or potential degradation of fission product barriers becauseof the elevated potential for offsite radioactivity release. Degradation of fission productbarriers though is not always apparent via non-radiological symptoms. Therefore, directindication of elevated radiological effluents or area radiation levels are appropriate symptomsfor emergency classification.At lower levels, abnormal radioactivity releases may be indicative of a failure of containmentsystems or precursors to more significant releases. At higher release rates, offsite radiologicalconditions may result which require offsite protective actions. Elevated area radiation levels inplant may also be indicative of the failure of containment systems or preclude access to plantvital equipment necessary to ensure plant safety.Events of this category pertain to the following subcategories:1. Radiologqical EffluentDirect indication of effluent radiation monitoring systems provides a rapid assessmentmechanism to determine releases in excess of classifiable limits. Projected offsite doses,actual offsite field measurements or measured release rates via sampling indicate dosesor dose rates above classifiable limits.2. Irradiated Fuel EventConditions indicative of a loss of adequate shielding or damage to irradiated fuel maypreclude access to vital plant areas or result in radiological releases that warrantemergency classification.3. Area Radiation LevelsSustained general area radiation levels which may preclude access to areas requiringcontinuous occupancy also warrant emergency classification.SRP/0I/ 5000/001 Rev. 1 Page 26 of 2471 ATTACHMENT 1 EAL BasesCategory: R -Abnormal Rad Levels I Rad EffluentSubcategory: 1 -Radiological EffluentInitiating Condition: Release of gaseous or liquid radioactivity > 2 times the SLC/TS limitsfor 60 minutes or longer EAL:RUI.1 Unusual Event 'Reading on any Table R-1 effluent radiation monitor > column "UE" for ->60 mmn...(Notes 1, 2, 3)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit hasbeen exceeded, or will likely be exceeded.Note 2: If an ongoing release is detected and the release start time is unknown, assume that the releaseduration has exceeded the specified time limit.Note 3: If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path isisolated, the effluent monitor reading is no longer VALID for classification purposes.Table R-I Effluent Monitor Classification ThresholdsRelease Point Monitor J GE [ SAE [ Alert I UEUnit Vent Noble Gas Low 1/2EMF36L .....4.1 8E+6 cpm 5.75E+3 cprnwUnit Vent Noble Gas High 1/2EMF36H 2.21 E+4 cpm 2.22E+3 cpm 2.42E+2 cpm ...~Liquid Waste Effluent Line 0EMF49L ....... 4.50E+6 cpm'Monitor Tank Discharge 0EMF57L ....... 4.97E+5 cpmMode Applicability:AllDefinition(s):NoneBasis:The column "UE" gaseous and liquid release values in Table R-1 represent two times theappropriate SLC and Technical Specification release rate and concentration limits associatedwith the specified monitors (ref. 2, 3, 4, 7).,I¸ SRP/0/A/5000/001 Rev. 1 Page 27 of 247I ATTACHMENT 1EAL BasesGaseous ReleasesInstrumentation that may be used to assess this EAL is listed below (ref. 1, 5):* Unit Vent Noble Gas Low Range -1/2EMF36L has a range of 101 -107 cpmLiquid ReleasesInstrumentation that may be used to assess this EAL is listed below (ref. 1, 6):° Liquid Waste Effluent Line Monitor -0EMF49L (batch release) has a range of 101 -I107cpm° Monitor Tank Discharge Monitor -OEM F57L has a range of 101 -1 0z cpmThis IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time(e.g., an uncontrolled release). It includes any gaseous or liquid radiological release,monitored or un-monitored, including those for which a radioactivity discharge permit isnormally prepared.Nuclear power plants incorporate design features intended to control the release of radioactiveeffluents to the environment. Further, there are administrative controls established to preventunintentional releases, and to control and monitor intentional releases. The occurrence of anextended, uncontrolled radioactive release to the environment is indicative of degradation inthese features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditionsalone. The inclusion of both plant condition and radiological effluent EALs more fully addressesthe spectrum of possible accident events and conditions.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 to havestopped due to actions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.Releases should not be prorated or averaged. For example, a release exceeding 4 timesrelease limits for 30 minutes does not meet the EAL.This EAL addresses normally occurring continuous radioactivity releases from monitoredgaseous or liquid effluent pathways.Escalation of the emergency classification level would be via IC RAl.CNS Basis Reference(s):1. CNS ODOM Section 3.0 Setpoint Calculations2. CNS-SLC 16.11-1 Liquid Effluents3. CNS-SLC 16.11-6 Gaseous Effluents4. EP-EALCALC-CNS-1401 CNS Radiological Effluent EAL Values, Rev. 05. UFSAR Table 11-20 Airborne Process Radiation Monitoring Equipment6. UFSAR Table 11-19 Liquid Process Radiation Monitoring Equipment7. Technical Specifications Section 5.5.5 Radioactive Effluent Controls ProgramIRPI0/A/5000/001 Rev. 1 Page 28 of 247 ATTACHMENT 1EAL Bases8. NEI 99-01 AU11i[t}: .....t i "i"[{! i ;i[ ,i,[,! , ,[ ",: *i ', o:,* ? .... ,,o ;RP/0/A15000/001 Rev. I Page 29 of 247 ATTACHMENT 1 , ... .EAL Bases ..Category: R -Abnormal Rad Levels!/ Rad EffluentSubcategory: 1 -Radiological EffluentInitiating Condition: Release of gaseous or liquid radioactivity greater than 2 times theSLC/TC limits for 60 minutes or longer.EAL:RU1.2 Unusual EventSample analysis for a gaseous or liquid release indicates a concentration or release rate> 2 x SLC/TO limits for -> 60 min. (Notes 1, 2)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit hasbeen exceeded, or will likely be exceeded.Note 2: If an ongoing release is detected and the release start time is unknown, assume that the releaseduration has exceeded the specified time limit.Mode Applicability:AllDefinition(s):NoneBasis:This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time(e.g., an uncontrolled release). It includes any gaseous or liquid radiological release,monitored or un-monitored, including those for which a radioactivity discharge permit isnormally prepared.Nuclear power plants incorporate design features intended to control the release of radioactiveeffluents to the environment. Further, there are administrative controls established to preventunintentional releases, and to control and monitor intentional releases. The occurrence of anextended, uncontrolled radioactive release to the environment is indicative of degradation inthese features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditionsalone. The inclusion of both plant condition and radiological effluent EALs more fully addressesthe spectrum of possible accident events and conditions.Releases should not be prorated or averaged. For example, a release exceeding 4 timesrelease limits for 30 minutes does not meet the EAL.This EAL addresses uncontrolled gaseous or liquid releases that are detected by sampleanalyses or environmental surveys, particularly on unmonitored pathways (e.g., spills ofradioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).Escalation of the emergency classification level would be via IC RAl.IRP/o/A/5000/001 Rev. I Page 30 of 2471 ATTACHMENT IEAL BasesCNS Basis Reference(s):1. CNS Offsite Dose Calculation Manual2. CNS-SLC 16.11-1 Liquid Effluents3. CNS-SLC 16.11-6 Gaseous Effluents4. Technical Specifications Section 5.5.5 Radioactive Effluent Controls Program5. AD-RP-ALL-2003 Investigation of Unusual Radiological Occurences6. NEI 99-01 AU1t,t _}=: ..... , :, ,,-,,.- ,'AIRP/0/A/5000/001 Rev. 1 Page 31 of 247I ATTACHMENT 1EAL BasesCategory: R -Abnormal Rad Levels I Rad EffluentSubcategory:1 -Radiological EffluentInitiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dosegreater than 10 mrem TEDE or 50 mrem thyroid CDE ,EAL:RA1.1 AlertReading on any Table R-1 effluent radiation monitor > column "ALERT" for > 15 min.(Notes 1, 2, 3,4),Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release lduration has exceeded the specified time limit.Note 3: If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path isisolated, the effluent monitor reading is no longer VALID for classification purposes. ;Note 4 The pre-calculated effluent monitor values presented in EALs RAI .1, RS1I.1 and RG1I.1 should be usedfor emergency classification assessments until the results from a dose assessment using actual ..meteorology are available.Table R-1 Effluent Monitor Classification ThresholdsRelease Point [Monitor GE SAE [ Alert ] UESUnit Vent Noble Gas Low 1/2EMF36L .....4.18E+6 cpm 5.75E+3 cpmCoUnit Vent Noble Gas High 1/2EMF36H 2.21 E+4 cpm 2.22E+3 cpm 2.42E+2 cpm ..-o Liquid Waste Effluent Line 0EMF4gL .........4.50E+6 cpm" Monitor Tank Discharge 0EMF57L .........4.97E+'5 cpmMode Applicability:AllIRP/0/A/5000/001 Rev. 1I Page 32 of 247 ATTACHMENT 1EAL BasesDefinition(s):NoneBasis:This EAL address gaseous radioactivity releases, that for whatever reason, cause effluentradiation monitor readings corresponding to site boundary doses that exceed either:* 10 mRemTEDE* 50 mRem ODE ThyroidThe column "ALERT" gaseous effluent release values in Table R-1 correspond to calculateddoses of 1% (10% of the SAE thresholds) of the EPA Protective Action Guidelines (TEDE orODE Thyroid) (ref. 3, 4).Instrumentation that may be used to assess this EAL is listed below (ref. 1, 2):* Unit Vent Noble Gas High Range -EMF36H has a range of 101 -106 cpmThis IC addresses a release of gaseous or liquid radioactivity that results in projected or actualoffsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). Itincludes both monitored and un-monitored releases. Releases of this magnitude represent anactual or potential substantial degradation of the level of safety of the plant as indicated by aradiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolledrelease).Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditionsalone. The inclusion of both plant condition and radiological effluent EALs more fully addressesthe spectrum of possible accident events and conditions.The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid ODEwas established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE.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 to havestopped due to actions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.Escalation of the emergency classification level would be via IC RSI.SRP/OIA/50001001 IRev. 1 Page 33 of 247 ATTACHMENT 1 i,;.:; ' :- : :EAL Bases i .... o _CNS Basis Reference(s):1. CNS ODCM Section 3.0 Setpoint Calculations2. UFSAR Table 11-20 Airborne Process Radiation Monitoring Equipment3. EP-EALCALC-CNS-1401 CNS Radiological Effluent EAL Values, Rev. 04. SDQA-70400-COM Unified RASCAL Interface (URI)5. NEI 99-01 AA11,i" 5 'i-14[RP/0/AJ5000/001 1Rev. 1 Page 34 of 2471 Category:Subcategory:Initiating Condition:ATTACHMENT 1EAL BasesR -Abnormal Rad Levels / Rad EffluentI -Radiological EffluentRelease of gaseous or liquid radioactivity resulting in offsite dosegreater than 10 mrem TEDE or 50 mrem thyroid ODEEAL:RA1.2 AlertDose assessment using actual meteorology indicates doses > 10 mrem TEDE or 50 mremthyroid ODE at or beyond the SITE BOUNDARY (Note,44)*Note 4: The pre-calculated effluent monitor values presented in EALs RAI .1, RSl .1 and RGI .1 should be used Ifor emergency classification assessments until the results from a dose assessment using actualmeteorology are available.Mode Applicability:AllDeleted:......, _Deleted: Note 3: If the effluent" 1 flow past an effluent monitor isl known to have stopped, indicatingthat the release path is isolated, the.] effluent monitor reading is no Ionge", L VALID for classification purposes.¶Definition(s):SITE BOUNDARY -Area as depicted in CNS-SLC-1 6.11-16 Figure 16.11-16-1 UnrestrictedArea and Site Boundary for Radioactive Effluents.Basis:Dose assessments are performed by computer-based methods (ref. 1, 2)This IC addresses a release of-gaseous or liquid radioactivity that results in projected or actualoffsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). Itincludes both monitored and un-monitored releases. Releases of this magnitude represent anactual or potential substantial degradation of the level of safety of the plant as indicated by aradiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolledrelease).Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditionsalone. The inclusion of both plant condition and radiological effluent EALs more fully addressesthe spectrum of possible accident events and conditions.SRP/0/A/5000/001 Rev. I Page 35 of 247t ATTACHMENT 1EAL BasesThe TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid ODEwas established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE.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 to havestopped due to actions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.Escalation of the emergency classification level would be via IC RS1.CNS Basis Reference(s):1. HP/0/B/1 009/026 On-Shift Offsite Dose Assessment2. AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment3. NEI 99-01 AA1{}, i"i}* [SRP/0/A1o000/001 Rev. I Page 36 of 2471 ATTACHMENT 1EAL BasesR -Abnormal Rad Levels / Rad Effluent1 -Radiological EffluentCategory:Subcategory:Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dosegreater than 10 mrem TEDE or 50 mrem thyroid CDEEAL:RA1 .3 AlertAnalysis of a liquid effluent sample indicates a concentration or release rate that wouldresult in doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITEBOUNDARY for 60 min. of exposure (Notes 1, 2)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit hasbeen exceeded, or will likely be exceeded.Note 2: If an ongoing release is detected and the release start time is unknown, assume that the releaseduration has exceeded the specified time limit.Mode Applicability:AllDefinition(s):SITE BOUNDARY- Area as depicted in CNS-SLC-16.11-16 Figure 16.11-16-1 UnrestrictedArea and Site Boundary for Radioactive Effluents.Basis:Dose assessments based on liquid releases are performed per Offsite Dose CalculationManual (ref. 1).This ,EAL addresses a release ofjliquid radio._ac_ tivity that results in projected or actual offsite....doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includesboth monitored and un-monitored releases. Releases of this magnitude represent an actual orpotential substantial degradation of the level of safety of the plant as indicated by a radiologicalrelease that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditionsalone. The inclusion of both plant condition and radiological effluent EALs more fully addressesthe spectrum of possible accident events and conditions.The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDEwas established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.,Escalation of the emergency cla~ssification level would be via IC RS1. .. .CNS Basis Reference(s):1. CNS Offsite Dose Calculation Manual2. NEI 99-01 MA1ed:I-tDlee:gaeu orefletmntrreadings assumes tha"a release path to the environment isestablished. If the effluent flow past aneffluent monitor Is known to havestopped due to actions to isolate thereading is no longer valid fortclassifiation p r e ...... ..... ........ ATTACHMENT 1EAL BasesCategory: R -Abnormal Rad Levels / Rad EffluentSubcategory: 1 -Radiological EffluentInitiating Condition: Reiease of gaseous or liquid radioactivity resulting in offsite dosegreater than 10 mrem TEDE or 50 mrem thyroid CDEEAL:RA1.4 AlertField survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:* Closed window dose rates > 10 mR/hr expected to continue for 60 min.* Analyses of field survey samples indicate thyroid CDE > 50 mrem for 60 mmi. ofinhalation.(Notes 1, 2)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit hasbeen exceeded, or will likely be exceeded.Note 2: If an ongoing release is detected and the release start time is unknown, assume that the releaseduration has exceeded the specified time limit.Mode Applicability:AllDefinition(s):SITE BOUNDARY- Area as depicted in CNS-SLC-16.11-16 Figure 16.11-16-1 UnrestrictedArea and Site Boundary for Radioactive Effluents.Basis:HP/0/B/1 009/004, Environmental Monitoring for Emergency Conditions Within the Ten MileRadius of CNS provides guidance for emergency or post-accident radiological environmentalmonitoring (ref. 1).This IC addresses a release of gaseous or liquid radioactivity that results in projected or actualoffsite doses greater than or equal to 1 % of the EPA Protective Action Guides (PAGs). Itincludes both monitored and un-monitored releases. Releases of this magnitude represent anactual or potential substantial degradation of the level of safety of the plant as indicated by aradiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolledrelease).Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditionsalone. The inclusion of both plant condition and radiological effluent EALs more fully addressesthe spectrum of possible accident events and conditions.The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDEwas established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE.Iation of the emergency classification level would be via IC RS!...................IRP/0/A15000/001 IRev. 1 IPage 38 of 2477.//1.'(IDeleted: Classirication based oneffluent monitor readings assumes thaa release path to the environment isestablished, If the effluent flow past aneffluent monitor is known to havestopped due to actions to isolate therelease path, then the effluent monitorreading is no longer valid forclassification purposes.¶f ATTACHMENT 1EAL BasesCNS Basis Reference(s):1. HPIOIBI1I009/004 Environmental Monitoring for Emergency Conditions Within the Ten MileRadius of CNS2. NEI 99-01 AA1{i}SRP/o/A15ooo/oo01 Rev. I Page 39of2471 Category:Subcategory:Initiating Condition:ATTACHMENT 1EAL BasesR -Abnormal Rad Levels / Rad EffluentI -Radiological EffluentRelease of gaseous radioactivity resulting in offsite dose greater than100 mrem TEDE or 500 mrem thyroid ODEEAL:RSI.1 Site Area EmergencyReading on any Table R-1 effluent radiation monitor > column "SAE" for > 15 min.(Notes 1, 2, 3,4)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit hasbeen exceeded, or will likely be exceeded. .Note 2: If an ongoing release is detected and the release start time is unknown, assume that the releaseduration has exceeded the specified time limit.Note 3: If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path isisolated, the effluent monitor reading is no longer VALID for classification purposes.Note 4: The pre-calculated effluent monitor values presented in EALs RAI .1, RSI .1 and RGI .1 should be usedfor emergency classification assessments until the results from a dose assessment using actualmeteorology are available.Table R-1 Effluent Monitor Classification ThresholdsK- Release Point IMonitor [ GE I SAE I Alert [ UESUnit Vent Noble Gas Low 1/2EMF36L ........- 4.18E+6 cpm 5.75E+3 cpmcn Unit Vent Noble Gas High 1/2EMF36H 2.21 E+4 cpm 2.22E+3 cpm 2.42E+2 cpm ...'9 Liquid Waste Effluent Line OEMF49L .........4.50E+6 cpmSMonitor Tank Discharge 0EMF57L ..........-- 4.97E+5 cpmMode Applicability:AllDefinition(s):NoneIRP/O/A/5000/O01 Rev. 1I Page 40 of 247 ATTACHMENT 1EAL BasesBasis:This EAL address gaseous radioactivity releases, that for whatever reason, cause effluentradiation monitor readings corresponding to site boundary doses that exceed either:* 100 mRemTEDE* 500 mRem ODE ThyroidThe column "SAE" gaseous effluent release value in Table R,-1 corresponds to calculateddoses of 10% of the EPA Protective Action Guidelines (TEDE or ODE Thyroid) (ref. 1, 2).Instrumentation that may be used to assess this EAL is Unit Vent Noble Gas High Range-Monitor -EMF36H and has a range of 101 -106 cpm (ref 3, 4).This IC addresses a release of gaseous radioactivity that results in projected or actual offsitedoses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includesboth monitored and un-monitored releases. Releases of this magnitude are associated withthe failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditionsalone. The inclusion of both plant condition and radiological effluent EALs more fully addressesthe spectrum of possible accident events and conditions.The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid ODEwas established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE.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 to havestopped due to actions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.Escalation of the emergency classification level would be via IC RGI.CNS Basis Reference(s):1. EP-EALCALC-CNS-1401 CNS R~adiological Effluent EAL Values, R~ev. 02. SDQA-70400-COM Unified RASCAL Interface (URI)3. ONS ODOM Section 3.0 Setpoint Calculations4. UFSAR, Table 11-20 Airborne Process Radiation Monitoring Equipment5. NEI 99-01 AS1RP/PIOA/50001001 R Pev. 1 Page 41 of 247I ATTACHMENT 1 iEAL Bases ..... .... ... ... .iCategory: R -Abnormal Rad Levels / Rad Effluent ... ..." '"Subcategory: 1 -Radiological Effluent .. .Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than , ':100 mrem TEDE or 500 mrem thyroid CDEEA L: i * ........RS1.2 Site Area Emergency .......Dose assessment using actual meteorology indicates doses > 100 mrem TEDE or .....500 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note,4) Deleted: s 3,*Note 4: The pre-calculated effluent monitor values presented in EALs RAlI.1, RS1I.1 and RGI .1 should be used .Deleted:aNtea:n f h effluent mntrfor emergency classification assessments until the results from a dose assessment using actual i '[known to have stopped, indicatingmetoroogyareavalabe., that the release path is isolated, theVALID for classification purposes.¶fAllDefinition(s):SITE BOUNDARY -Area as depicted in CNS-SLC-1 6.11-16 Figure 16.11-16-1 UnrestrictedArea and Site Boundary for Radioactive Effluents.Basis:Dose assessments are performed by computer-based methods (ref. 1, 2)This IC addresses a release of gaseous radioactivity that results in projected or actual offsitedoses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includesboth monitored and un-monitored releases. Releases of this magnitude are associated withthe failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditionsalone. The inclusion of both plant condition and radiological effluent EALs more fully addressesthe spectrum of possible accident events and conditions.The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDEwas established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.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 to havestopped due to actions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.Escalation of the emergency classification level would be via IC RG1.CNS Basis Reference(s):1. SDQA-70400-COM Unified RASCAL Interface (URI)2. AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment3. NEI 99-01 ASIRP/0/A/5000/001 I Rev. 1 I Page 42 of 247 I* , ' }tI " .. .. .. i i[I I -I ATTACHMENT 1EAL Bases! -I,-of, .,i ,SRPIOIA/50001001 Rev. 1 IPage 43 of 247 ATTACHMENT 1EAL BasesCategory: R -Abnormal Rad Levels / Rad EffluentSubcategory: 1 -Radiological EffluentInitiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than100 mrem TEDE or 500 mrem thyroid CDEEAL:RS1.3 Site Area EmergencyField survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:* Closed window dose rates > 100 mR/hr expected to continue for > 60 min.* Analyses of field survey samples indicate thyroid CDE > 500 mrem for 60 min. ofinhalation.(Notes 1,2)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit hasbeen exceeded, or will likely be exceeded.Note 2: If an ongoing release is detected and the release start time is unknown, assume that the releaseduration has exceeded the specified time limit.Mode Applicability:AllDefinition(s):SITE BOUNDARY -Area as depicted in CNS-SLC-1 6.11-16 Figure 16.11-16-1 UnrestrictedArea and Site Boundary for Radioactive Effluents.Basis:HP/0/B/1 009/004, Environmental Monitoring for Emergency Conditions Within the Ten MileRadius of CNS provides guidance for emergency or post-accident radiological environmentalmonitoring (ref. 1).This IC addresses a release of gaseous radioactivity that results in projected or actual offsitedoses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includesboth monitored and un-monitored releases. Releases of this magnitude are associated withthe failure of plant systems needed for the protection of the public.IRP/OIA15000/O01 Rev. 1 IPage 44 of 247 ATTACHMENT 1EAL BasesRadiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditionsalone. The inclusion of both plant condition and radiological effluent EALs more fully addressesthe spectrum of possible accident events and conditions.The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid ODEwas established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE.Escalation of the emergency classification level would be via IC RGI.CNS Basis Reference(s):1. HP/0/B/1 009/004 Environmental Monitoring for Emergency Conditions Within the Ten MileRadius of CNS2. NEI 99-01 AS1* :,,,, , o,,,RP/0/A/5000/001 Rev. 1 Page 45 of 247 ATTACHMENT 1I.... ..EAL Bases ... Category: R -Abnormal Rad Levels / Rad Effluent "Subcategory: 1 -Radiological Effluent .... .Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than...1,000 mrem TEDE or 5,000 mrem thyroid ODE .....EAL: ..RGI.1 General EmergencyReading on any Table R-1 effluent radiation monitor > column "GE" for > 15 min... .(Notes 1,2, 3, 4) ...Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has .. ..'. .been exceeded, or will likely be exceeded. .. ..Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release !,duration has exceeded the specified time limit.,,,Note 3: If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is ... ...isolated, the effluent monitor reading is no longer VALID for classification purposes. I..Note 4: The pre-caiculated effluent monitor values presented in EALs RAI .1, RSI .1 and RG1I.1 should be usedfor emergency classification assessments until the results from a dose assessment using actual ; ""'. .meteorology are available. ... .:Table R-1 Effluent Monitor ClassificationThresholds :' ' ...Release Point Monitor GE SAE Alert UESUnit Vent Noble Gas Low 1/2EMF36L .......4.18E+6 cpm 5.75E+3 cpmSUnit Vent Noble Gas High 1J2EMF36H 2.21 E+4 cpm 2.22E+3 cpm 2.42E+2 cpm ...~Liquid Waste Effluent Line 0EMF49L ............ 4.50E+6 cpmSMonitor Tank Discharge 0EMF57L ........... 4.97E+5 cpm iMode Applicability:AllDefinition(s):NoneBasis:This EAL address gaseous radioactivity releases, that for whatever reason, cause effluentradiation monitor readings corresponding to site boundary doses that exceed either:* 1000 mRem TEDE* 5000 mRem CDE Thyroid}RP/OIA15000/O01 Rev. I Page 46 of 247 ATTACHMENT 1EAL BasesThe column "GE" gaseous effluent release values in Table R-1 correspond to calculated dosesof 100% of the EPA Protective Action Guidelines (TEDE or CDE Thyroid) (ref. 1, 2).Instrumentation that may be used to assess this EAL is Unit Vent Noble Gas High RangeMonitor -EMF36H and has a range of 101 -106 cpm (ref 3, 4).This IC addresses a release of gaseous radioactivity that results in projected or actual offsite :doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both ,monitored and un-monitored releases. Releases of this magnitude will require implementationof protective actions for the public. 'Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditionsalone. The inclusion of both plant condition and radiological effluent EALs more fully addressesthe spectrum of possible accident events and conditions.The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE wasestablished in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.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 to havestopped due to actions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.CNS Basis Reference(s): i1. EP-EALCALC-CNS-1401 CNS Radiological Effluent EAL Values, Rev. 02. SDQA-70400-COM Unified RASCAL Interface (URI)3. CNS 0DCM Section 3.0 Setpoint Calculations4. UFSAR Table 11-20 Airborne Process Radiation Monitoring Equipment5. NEI 99-01 AG1iSRP/0/A/5000/001 Rev. 1 Page 47 of 247 Category:Subcategory:Initiating Condition:ATTACHMENT 1EAL BasesR -Abnormal Rad Levels / Rad Effluent1 -Radiological EffluentRelease of gaseous radioactivity resulting in offsite dose greater than1,000 mrem TEDE or 5,000 mrem thyroid CDEEAL:RG1.2 General EmergencyDose assessment using actual meteorology indicates doses > 1,000 mrem TEDE or5,000 mrem thyroid ODE at or beyond the SITE BOUNDARY (Note,4)*Note 4: The pre-calculated effluent monitor values presented in EALs RAlI.1, RS1I.1 and RGI .1 should be usedfor emergency classification assessments until the results from a dose assessment using actualmeteorology are available.Mode Applicability:AllDefinition(s):SITE BOUNDARY -Area as depicted in CNS-SLC-1 6.11-16 Figure 16.11-16-1 UnrestrictedArea and Site Boundary for Radioactive Effluents.Bas is:Dose assessments are performed by computer-based methods (ref. 1, 2)This IC addresses a release of gaseous radioactivity that results in projected or actual offsitedoses greater than or equal to the EPA Protective Action Guides (PAGs). It includes bothmonitored and un-monitored releases. Releases of this magnitude will require implementationof protective actions for the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditionsalone. The inclusion of both plant condition and radiological effluent EALs more fully addressesthe spectrum of possible accident events and conditions.The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid ODE wasestablished in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE.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 to havestopped due to actions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.CNS Basis Reference(s):1. SDQA-70400-COM Unified RASCAL Interface (URI)2. AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment3. NEI 99-01 AG1IRP/0/A/5000/001 Rev. 1 page 48 of 247Deleted: s 3,Deleted: Note 3: If the effluento, flow past an effluent monitor isknown to have stopped, indicatingi that the release path is isolated, theI effluent monitor reading is no longe' -VALID for classification purposes.¶ Category:Subcategory:Initiating Condition:ATTACHMENT 1EAL BasesR -Abnormal Rad Levels / Rad Effluent1 -Radiological EffluentRelease of gaseous radioactivity resulting in offsite dose greater than1,000 mrem TEDE or 5,000 mrem thyroid CDEEAL:RG1.3 General EmergencyField survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:* Closed window dose rates > 1,000 mR/hr expected to continue for > 60 min.* Analyses of field survey samples indicate thyroid CDE > 5,000 mrem for 60 mai. ofinhalation.(Notes 1, 2)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit hasbeen exceeded, or will likely be exceeded.Note 2: If an ongoing release is detected and the release start time is unknown, assume that the releaseduration has exceeded the specified time limit.Mode Applicability:AllDefinition(s):SITE BOUNDARY -Area as .depicted in CNS-SLC-1 6.11-16 Figure 16.11-16-1 UnrestrictedArea and Site Boundary for Radioactive Effluents.Basis:HP/0/B/1009/004, Environmental Monitoring for Emergency Conditions Within the Ten MileRadius of CNS provides guidance for emergency or post-accident radiological environmentalmonitoring (ref. 1).This IC addresses a release of gaseous radioactivity that results in projected or actual offsitedoses greater than or equal to the EPA Protective Action Guides (PAGs). It includes bothmonitored and un-monitored releases. Releases of this magnitude will require implementationof protective actions for the public.Radi0logical effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditionsalone. The inclusion of both plant condition and radiological effluent EALs more fully addressesthe spectrum of possible accident events and conditions.The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE wasestablished in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.CNS Basis Reference(s):1. HP/0/B/1 009/004 Environmental Monitoring for Emergency Conditions Within the Ten MileRadius of CNSRP/0/A/5000/001 Rev. 1 Page 49 of 247 ATTACHMENT 1EAL Bases2. NEJ 99-01 AG11I* I,ii;i' , * }SRPIoA/5ooo/ool Rev. 1 Page 50of,2471 ATTACHMENT 1EAL BasesR -Abnormal Rad Levels / Rad Effluent2 -Irradiated Fuel EventCategory:Subcategory:Initiating Condition: Unplanned loss of water level above irradiated fuelEAL:RU2.1 Unusual EventUNPLANNED water level drop in the REFUELING PATHWAY as indicated by low waterlevel alarm or indicationANDUNPLANNED rise in corresponding area radiation levels as indicated by any of thefollowing radiation monitors:* 1EMF15 (2EMF4) Spent Fuel Building Refueling Bridge* 1EMF17 (2EMF2) Reactor Building Refueling BridgeMode Applicability:AllDefinition(s):UNPLANNED-. A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameter changeor event may be known or unknown.REFUELING PATHWAY-. The reactor refueling cavity, spent fuel pool and fuel transfer canalcomprise the refueling pathway.Basis:The spent fuel pool low water level alarm setpoint is actuated by 1 (2)KFPS51 20 at a setpointof 39' (ref. 1). Water level restoration instructions are performed in accordance with AOPs (ref.2, 3).The specified radiation monitors are those expected to see increase area radiation levels as aresult of a loss of REFUELING PATHWAY inventory (ref. 2, 3). Increasing radiation indicationson these monitors in the absence of indications of decreasing REFUELING CAVITY level arenot classifiable under this EAL.When the spent fuel pool and reactor cavity are connected, there could exist the possibility ofuncovering irradiated fuel. Therefore, this EAL is applicable for conditions in which irradiatedfuel is being transferred to and from the reactor vessel and spent fuel pool.This IC addresses a decrease 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 is thereforea potential degradation in the level of safety of the plant.RP/OIA15000/001 Rev. 1 Page 51 of 247 ATTACHMENT 1EAL BasesA water level decrease will be primarily determined by indications from available levelinstrumentation. Other sources of level indications may include reports from plant personnel(e.g., from a refueling crew) or video camera observations (if available). A significant drop inthe water level may also cause an increase in the radiation levels of adjacent areas that can bedetected by monitors in those locations.The effects of planned evolutions should be considered. For example, a refueling bridge arearadiation monitor reading may increase due to planned evolutions such as lifting of the reactorvessel head or movement of a fuel assembly. Note that this EAL is applicable only in caseswhere the elevated reading is due to an unplanned loss of water level.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RA2.CNS Basis Reference(s):1. OPI1(2)1B16100/10 IN E12 Spent Fuel Pool Level Hi/Lo2. AP/1(2)/A/5500/026 Loss of Refueling Canal Level3. AP/1(2)/A/5500/041 Loss of Spent Fuel Cooling or Level4. NEI 99-01 AU2IRPI0/AI5000/001 Rev. I Page 52 of 247 ATTACHMENT 1EAL Bases " '": '* i:... Category: R -Abnormal Rad Levels!/ Rad Effluent I,Subcategory: 2 -Irradiated Fuel EventInitiating Condition: Significant lowering of water level above, or damage to, irradiated fuel iEAL:RA2.1 AlertUncovery of irradiated fuel in the REFUELING PATHWAY i"'Mode Applicability: !AllDefinition(s):REFUELING PATHWAY-. The reactor refueling cavity, spent fuel pool and fuel transfer canal "comprise the refueling pathway." ...:Basis: .. " ,. .'This IC addresses events that have caused imminent or actual damage to an irradiated fuel ...".... , "assembly, or a significant lowering of water level within the spent fuel pool. These present radiological safety challenges to plant personnel 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 the plant.This EAL escalates from RU2*I in that the loss of level, in the affected portion of theREFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated .....fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation ' .(e~g., reports from personnel or camera images), as well as significant changes in water andradiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil- ...' *" :. : ;off curve). Classification of an event using this EAL should be based on the totality of available ,,-....: *...... ......indications, reports and observations.While an area radiation monitor could detect an increase in a dose rate due to a lowering of -, "-water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable i. , .... 'indication of whether or not the fuel is actually uncovered. To the degree possible, readings ...should be considered in combination with other available indications of inventory loss. ,A drop in water level above irradiated fuel within the reactor vessel may be classified in... ,: ,, ,.accordance Recognition Category C during the Cold Shutdown and Refueling modes ......:, ... ...Escalation of the emergency classification level would be via IC RS1.CNS Basis Reference(s): ..1. AP/1 (2)/A/5500/026 Loss of Refueling Canal Level2. AP/1 (2)/A/5500/041 Loss of Spent Fuel Cooling or Level ....." '3. NEI 99-01 AA2 .' '" '... "SRP/0/A/5000/001 Rev. 1 Page 53 of 247 ATTACHMENT 1EAL BasesIRP/0/A/5000/001 Rev. 1 Page 54 of 247 ATTACHMENT 1EAL BasesCategory: R -Abnormal Rad Levels / Rad EffluentSubcategory: 2 -Irradiated Fuel EventInitiating Condition: Significant lowering of water level above, or damage to, irradiated fuelEAL:RA2.2 AlertDamage to irradiated fuel resulting in a release of radioactivityANDA Trip 2 radiation alarm on any of the following radiation monitor indications:* 1EMF15 (2EMF4) Spent Fuel Building Refueling Bridge* 1 EMF1 7 (2EMF2) Reactor Building Refueling Bridge* 1 EMF42 (2EMF42) Spent Fuel Pool Ventilation* 1 EMF39L (2EMF39L) Containment Noble GasMode Applicability:AllDefinition(s):NoneBasis:The specified radiation monitors are those expected to see increase area radiation levels as aresult of damage to irradiated fuel (ref. 1 ).The Trip 2 alarm setpoints for the radiation monitors are set to be indicative of significantincreases in area and/or airborne radiation (ref. 2).This IC addresses events that have caused imminent or actual damage to an irradiated fuelassembly, or a significant lowering of water level within the spent fuel pool. These eventspresent radiological safety challenges to plant personnel and are precursors to a release ofradioactivity to the environment. As such, they represent an actual or potential substantialdegradation of the level of safety of the plant.This EAL 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 of theCONFINEMENT BOUNDARY is classified in accordance with EAL EU1 .1.Escalation of the emergency would be based on either Recognition Category R or C ICs.This EAL addresses a release of radioactive material caused by mechanical damage toirradiated fuel. Damaging events may include the dropping, bumping or binding of anassembly, or dropping a heavy load onto an assembly. A rise in readings on radiationmonitors should be considered in conjunction with in-plant reports or observations of apotential fuel damaging event (e.g., a fuel handling accident).IRPIOIAI50001001I Rev. 1 Page 55 of 247 ATTACHMENT 1EAL BasesEscalation of the emergency classification level would be via IC RS1.CNS Basis Reference(s):1. AP/1 (2)/A/5500/025 Damaged Spent Fuel2. HP/0/B/1 000/010 Determination of Radiation Monitor Setpoints3. NEI 99-01 AA2[RPI/0/A5000/O01 Rev. 1 Page 56 of 247 ATTACHMENT IEAL BasesR -Abnormal Rad Levels / Rad Effluent2 -Irradiated Fuel EventCategory:Subcategory:Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuelEAL:RA2..3 AlertLowering of spent fuel pool level to 24.5 ft. (Level 2) on 1 (2)KFP5780 or 1 (2)NVP8790Mode Applicability:AllDefinition(s):NoneBasis:Post-Fukushima order EA-12-051 (ref.l) required the installation of reliable SEP levelindication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of thefuel racks (Level 2) and SEP level at the top of the fuel racks (Level 3).SEP level indicators 1(2)KFP5780 (radar) or 1(2)NVP8790 (pressure) located on the back of2MC7 provide continuous wide range SEP level indication to the top of the spent fuel racks(ref. 2).This IC addresses events that have caused imminent or actual damage to an irradiated fuelassembly, or a significant lowering of water level within the spent fuel pool. These eventspresent radiological safety challenges to plant personnel and are precursors to a release ofradioactivity to the environment. As such, they represent an actual or potential substantialdegradation of the level of safety of the plant.Escalation of the emergency would be based on either Recognition Category R or C ICs.Spent fuel pool water level at this value is within the lower end of the level range necessary toprevent significant dose consequences from direct gamma radiation to personnel performingoperations in the vicinity of the spent fuel pool. This condition reflects a significant loss ofspent fuel pool water inventory and thus it is also a precursor to a loss of the ability toadequately cool the irradiated fuel assembles stored in the pool.Escalation of the emergency classification level would be via IC RS1.RP/0/A/5000/001 Rev. 1 Page 57 of 247 ATTACHMENT 1EAL BasesCNS Basis Reference(s):1. NRC EA-12-51 Issuance of Order to Modify Licenses with Regard to Reliable Spent FuelPool Instrumentation2. EC1094133NEI 99-01 AA2SRP/0/A/5000/001 Rev. I Page 58 of 247I , ,,, .,, .ATTACHMENT 1EAL BasesCategory: R -Abnormal Rad Levels / Rad EffluentSubcategory: 2 -Irradiated Fuel EventInitiating Condition: Spent fuel pool level at the top of the fuel racksEAL:R S2.1 Site Area EmergencyLowering of spent fuel pool level to 14.5 ft. (Level 3) on 1 (2)KFP5780 or 1 (2)NVP8790Mode Applicability:AllDefinition(s):NoneBasis:Post-Fukushima order EA-1 2-051 (ref.1) required the installation of reliable SEP levelindication capable of identifying normal level (Level 1 ), SEP level 10 ft. above the top of thefuel racks (Level 2) and SEP level at the top of the fuel racks (Level 3).SEP level indicators 1 (2)KFP5780 (radar) or 1 (2)NVP8790 (pressure) located on the back of2MC7 provide continuous wide range SEP level indication to the top of the spent fuel racks(ref. 2).This EAL addresses a significant loss of spent fuel pool inventory control and makeupcapability leading to IMMINENT fuel damage. This condition entails major failures of plantfunctions needed for protection of the public and thus warrant a Site Area Emergencydeclaration.It is recognized that this IC would likely not be met until well after another Site Area EmergencyIC was met; however, it is included to provide classification diversity.Escalation of the emergency classification level would be via IC AG1 or RG2.CNS Basis Reference(s):1. NRC EA-12-51 Issuance of Order to Modify Licenses with Regard to Reliable Spent FuelPool Instrumentation2. EC1094133. NEI 99-01 AS2[t"' ,!i i,,, :,,.4' '!?,: .....t'£it"[_,., .................../ ISRP/O/AI50001001 Rev. 1I Page 59 of 247 ATTACHMENT 1EAL BasesCategory: R -Abnormal Rad Levels / Rad EffluentSubcategory: 2 -Irradiated Fuel EventInitiating Condition: Spent fuel pool level cannot be restored to at least the top of the fuelracks for 60 minutes or longerEAL:RG2.l General EmergencySpent fuel pool level cannot be restored to at least 14.5 ft. (Level 3) on 1(2)KFP5780 or1(2)NVP8790 for > 60 mnm. (Note 1)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit hasbeen exceeded, or will likely be exceeded.Mode Applicability:AllDefinition(s):NoneBasis:Post-Fukushima order EA-12-051 (ref.1) required the installation of reliable SFP levelindication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of thefuel racks (Level 2) and SEP level at the top of the fuel racks (Level 3).SEP level indicators 1(2)KFP5780 (radar) or 1(2)NVP8790 (pressure) located on the back of2MC7 provide continuous wide range SEP level indication to the top of the spent fuel racks(ref. 2).This EAL addresses a significant loss of spent fuel pool inventory control and makeupcapability leading to a prolonged uncovery of spent fuel. This condition will lead to fueldamage and a radiological release to the environment.It is recognized that this IC would likely not be met until well after another General EmergencyIC was met; however, it is included to provide classification diversity.CNS Basis Reference(s):1. NRC EA-12-51 Issuance of Order to Modify Licenses with Regard to Reliable Spent FuelPool Instrumentation2. EC1094133. NEI 99-01 AG2Category: R -Abnormal Rad Levels / Rad EffluentSubcategory: 3 -Area Radiation LevelsInitiating Condition: Radiation levels that IMPEDE access to equipment necessary fornormal plant operations, cooldown or shutdownEAL:IRP/0/A/5000/001 Rev. 1 [Page 60 of 247I ATTACHMENT 1EAL BasesRA3.1 AlertDose rates > 15 mR/hr in EITHER of the following areas:Control Room (EMF12)ORCentral Alarm Station (by survey)Mode Applicability:AllDefinition(s):IMPEDE(D) -Personnel access to a room or area is hindered to an extent that extraordinarymeasures are necessary to facilitate entry of personnel into the affected room/area(e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).Basis:Areas that meet this threshold include the Control Room and the Central Alarm Station (CAS).EMF Channel 12 monitors the Control room for area radiation (ref. 1). The CAS is included inthis EAL because of its' importance to permitting access to areas required to assure safe plantoperations.There is no permanently installed CAS area radiation monitors that may be used to assess thisEAL threshold. Therefore this threshold must be assessed via local radiation survey for theCAS.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to precludeor impede personnel from performing actions necessary to maintain normal plant operation, orto perform a normal plant cooldown and shutdown. As such, it represents an actual orpotential substantial degradation of the level of safety of the plant. The EmergencyCoordinator should consider the cause of the increased radiation levels and determine ifanother IC may be applicable.Escalation of the emergency classification level would be via Recognition Category R, C or FICs.CNS Basis Reference(s):1. OP/1(2)/B/6100/010Z C/2 Control Room2. NEI 99-01 AA3RP/0/A/5000/001 Rev. 1 Page 61 of 247 ATTACHMENT 1EAL BasesCategory: R -Abnormal Rad Levels / Rad EffluentSubcategory: 3 -Area Radiation LevelsInitiating Condition: Radiation levels that IMPEDE access to equipment necessary fornormal plant operations, cooldown or shutdownEAL:RA3.2 AlertAn UNPLANNED event results in radiation levels that prohibit or IMPEDE access to anyTable R-2 rooms or areas (Note 5)Note 5: If the equipment in the lsted room or area was already inoperable or out-of-service before the event occurred, thenno emergency ciassification is warranted.Table R-2 Safe Operation & Shutdown Rooms/AreasBldg. Elevation Unit 1 Room/Area Unit 2 Room/Area ModeRm 478 (1 EMXA) Rrn 469 (2EMXA) 4Rm 496 (1ETA) Rrm 486 (2ETA) 4uxiry Rm 496 (1 EMXS) Rm 486 (2EMXS) 4AB-577', J J-57 (1MXK) AB-577', J J-57 (2MXK) 4Rm 330(1 EMXJ) Rm 320 (2EMXJ) 4Auxiliary 560' Rm 372 (1 ETB) Rmn 362 (2ETB) 4Rm 372 (1 EMXD) Rrn 362 (2EMXD) 4Mode Applicability:AllDefinition(s):IMPEDE(D) -Personnel access to a room or area is hindered to an extent that extraordinarymeasures are necessary to facilitate entry of personnel into the affected room/area(e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).UNPLANNED -A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameter changeor event may be known or unknown.Basis:If the equipment in the listed room or area was already inoperable, or out-of-service, before theevent occurred, then no emergency should be declared since the event will have no adverseimpact beyond that already allowed by Technical Specifications at the time of the event.The list of plant rooms or areas with entry-related mode applicability identified specify thoserooms or areas that contain equipment which require a manual/local action as specified inoperating procedures used for normal plant operation, cooldown and shutdown. Rooms orareas in which actions of a contingent or emergency nature would be performed (e.g., anIRP/0/A/5000/O01 Rev. 1I Page 62 of 247 ATTACHMENT 1EAL Basesaction to address an off-normal or emergency condition such as emergency repairs, correctivemeasures or emergency operations) are not included. in addition, the list specifies the plantmode(s) during which entry would be required for each room or area (ref. 1 ).This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to precludeor impede personnel from performing actions necessary to maintain normal plant operation, or .to perform a normal plant cooldown and shutdown. As such, it represents an actual orpotential substantial degradation of the level of safety of the plant. The Emergency ..Coordinator should consider the cause of the increased radiation levels and determine ifanother IC may be applicable.For RA3.2, 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 at the time of the elevatedradiation levels. The emergency classification is not contingent upon whether entry is actuallynecessary at the time of the increased radiation levels. Access should be considered asimpeded if extraordinary measures are necessary to facilitate entry of personnel into theaffected room/area (e.g., installing temporary shielding, requiring use of non-routine protectiveequipment, requesting an extension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply:*The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the time ofthe elevated radiation levels). For example, the plant is in Mode 1 when the radiationincrease 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.).* 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, and wouldnot actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category R, C or FnCs. ,CNS Basis Reference(s): *i1. Attachment 3 Safe Operation & Shutdown Rooms/Areas Tables R-2 & H-2 Bases 2. NEI 99-01 AA3 RP/0/A/5000/001 Rev. I Page 63 of 247 ATTACHMENT 1EAL Bases,Category C -Cold Shutdown I Refueling System MalfunctionEAL Group: Cold Conditions (NCS temperature -< 200°F); EALs 'in this category are applicable only in one or morecold operating modes.Category C EALs are directiy associated with cold shutdown or refueling system safetyfunctions. Given the variability of plant configurations (e.g., systems out-of-service formaintenance, containment open, reduced AC power redundancy, time since shutdown) during ithese periods, the consequences of any given initiating event can vary greatly. For example, aloss of decay heat removal capability that occurs at the end of an extended outage has lesssignificance than a similar loss occurring during the first week after shutdown. Compoundingthese events is the likelihood that instrumentation necessary for assessment may also beinoperable. The cold shutdown and refueling system malfunction EALs are based onperformance capability to the extent possible with consideration given to NCS integrity,containment closure, and fuel clad integrity for the applicable operating modes (5 -ColdShutdown, 6 -Refueling, D -Defueled).The events of this category pertain to the following subcategories: !1. NCS LevelReactor Pressure Vessel water level is directly related to the status of adequate corecooling and, therefore, fuel clad integrity.2. Loss of Essential AC PowerLoss of essential plant electrical power can compromise plant safety system operabilityincluding decay heat removal and emergency core cooling systems which may benecessary to ensure fission product barrier integrity. This category includes loss of onsiteand offsite power sources for 4160 VAC emergency buses.3. NCS TemperatureUncontrolled or inadvertent temperature or pressure increases are indicative of a potentialloss of safety functions.4. Loss of Vital DC PowerLoss of emergency plant electrical power can compromise plant safety system operability ,including decay heat removal and emergency core cooling systems which may benecessary to ensure fission product barrier integrity. This category includes loss of power toor degraded voltage on the 125 VDC vital buses.IRP/0/A/5000/001 Rev. 1 Page 64 of 247 ATTACHMENT IEAL Bases5. Loss of CommunicationsCertain events that degrade plant operator ability to effectively communicate with essentialpersonnel within or external to the plant warrant emergency classification.6. Hazardous Event Affecting Safety SystemsCertain hazardous natural and technological events may result in visible damage to ordegraded performance of safety systems warranting classification.RPIOIAI50001001 Rev. 1 Page 65 of 247 ATTACHMENT 1EAL BasesCategory: C -Cold Shutdown / Refueling System MalfunctionSubcategory: 1 -NCS LevelInitiating Condition: UNPLANNED loss of NCS inventory for 15 minutes or longerEAL:CUI.l Unusual EventUNPLANNED loss of NCS inventory results in NCS water level less than a required lowerlimit for 15 mai. (Note 1)Note 1: The Emergency Coordinator should deciare the event promptly upon determining that time limit hasbeen exceeded, or will likely be exceeded.Mode Applicability:5 -Cold Shutdown, 6 -RefuelingDefinition(s):UNPLANNED-. A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameter changeor event may be known or unknown.Basis:NCS water level less than a required lower limit is meant to be less than the lower end of thelevel control band being procedurally maintained for the current condition or evolution.With the plant in Cold Shutdown, NCS water level is normally maintained above thepressurizer low level setpoint of 17% (ref. 1). However, if NCS level is being controlled belowthe pressurizer low level setpoint, or if level is being maintained in a designated band in thereactor vessel it is the inability to maintain level above the low end of the designated controlband due to a loss of inventory resulting from a leak in the NCS that is the concern.With the plant in Refueling mode, NCS water level is normally maintained at or above thereactor vessel flange (Technical Specification LCO 3.9.6 requires at least 23 ft of water abovethe top of the reactor vessel flange in the refueling cavity during refueling operations) (ref. 2).This IC addresses the inability to restore and maintain water level to a required minimum level(or the lower limit of a level band), or a loss of the ability to monitor NCS level concurrent withindications of coolant leakage. Either of these conditions is considered to be a potentialdegradation of the level of safety of the plant.Refueling evolutions that decrease NCS water inventory are carefully planned and controlled.An UNPLANNED event that results in water level decreasing below a procedurally requiredlimit warrants the declaration of an Unusual Event due to the reduced water inventory that isavailable to keep the core covered.This EAL recognizes that the minimum required NCS level can change several times duringthe course of a refueling outage as different plant configurations and system lineups areimplemented. This EAL is met if the minimum level, specified for the current plant conditions,IRP/0/A15000/001 Rev. 1 Page 66 of 247 ATTACHMENT 1EAL Basescannot be maintained for 15 minutes or longer. The minimum level is typically specified in theapplicable operating procedure but may be specified in another controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions to restoreand maintain the expected water level. This criterion excludes transient conditions causing abrief lowering of water level.Continued loss of NCS inventory may result in escalation to the Alert emergency classificationlevel via either IC CA1 or CA3.CNS Basis Reference(s):1. EP/I(2)/A/5000/FR-l.2 Response to Low Pressurizer Level2. CNS Technical Specifications Section 3.9.6 Refueling Cavity Water Level3. NEI 99-01 CUlIRPO/0/A50001001 Rev. 1 Page 67 of 247 ATTACHMENT 1EAL BasesC -Cold Shutdown / Refueling System Malfunction1 -NCS LevelCategory:Subcategory:Initiating Condition: UNPLANNED loss of NCS inventoryEAL:CU1.2 Unusual EventNCS water level cannot be monitoredAND EITHER* UNPLANNED increase in pyTable C-6 sump or tank level due to a loss of NCSinventory*Visual observation of UNISOLABLE NCS leakageI qupment Sump or lncore Sump(alarm)Table C-6 Sumps/Tanks* Containment Floor & Equipment Sump* Incore Sump (alarm)* ND/NS sump* NCDT* PRTMode Applicability:5 -Cold Shutdown, 6 -RefuelingDefinition(s):UN/SOLABLE -An open or breached system line that cannot be isolated, remotely or locally.UNPLANNED-. A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameter changeor event may be known or unknown.Basis:In Cold Shutdown mode, the NCS will normally be intact and standard NCS level monitoringmeans are available. NCS level in the Refueling mode is normally monitored using the sightglass.In this EAL, all water level indication is unavailable and the NCS inventory loss must bedetected by indirect leakage indications (ref. 1). Level increases must be evaluated againstother potential sources of leakage such as cooling water sources inside the containment toensure they are indicative of NCS leakage. If the make-up rate to the NCS unexplainably risesabove the pre-established rate, a loss of NCS inventory may be occurring even if the source ofthe leakage cannot be immediately identified. Visual observation of leakage from systemsconnected to the NCS that cannot be isolated could also be indicative of a loss of NCSinventory.The Incore Sump level cannot be monitored in the CR but alarms on high level.IRP/OIAI50001001 Rev. 1 Page 68 of 247 ATTACHMENT 1EAL BasesThis IC addresses the inability to restore and maintain water level to a required minimum level(or the lower limit of a level band), or a loss of the ability to monitor RPV level concurrent withindications of coolant leakage. Either of these conditions is considered to be a potentialdegradation of the level of safety of the plant.Refueling evolutions that decrease NCS water inventory are carefully planned and controlled.An UNPLANNED event that results in water level decreasing below a procedurally requiredlimit warrants the declaration of an Unusual Event due to the reduced water inventory that isavailable to keep the core covered.This EAL addresses a condition where all means to determine RPV level have been lost. Inthis condition, operators may determine that an inventory loss is occurring by observingchanges in sump and/or tank levels. Sump and/or tank level changes must be evaluatedagainst other potential sources of water flow to ensure they are indicative of leakage from theNCS.Continued loss of NCS inventory may result in escalation to the Alert emergency classificationlevel via either IC CA1 or CA3.CNS Basis Reference(s):1. AP/1 (2)/A/5500/010 Reactor Coolant Leak2. NEI 99-01 CU1IRPIO/A150001001 Rev. I Page 69 of 247 ATTACHMENT 1EAL BasesCategory: C -Cold Shutdown / Refueling System MalfunctionSubcategory: 1 -NCS LevelInitiating Condition: Loss of NCS inventoryEAL:CAl.1 AlertUNPLANNED loss of NCS inventory as indicated by NCS water level < 6.5% (wide range)Mode Applicability:5 -Cold Shutdown, 6 -RefuelingDefinition(s):UNPLANNED-. A parameter change or an event that is not 1 ) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameter changeor event may be known or unknown.Basis:6.5% wide range NCS level indication is the lowest level to assure adequate net positivesuction head and prevent ND pump cavitation for all flow rates (ref. 1).This IC addresses conditions that are precursors to a loss of the ability to adequately coolirradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This conditionrepresents a potential substantial reduction in the level of plant safety.For this EAL, a lowering of NCS water level below 6.5% indicates that operator actions havenot been successful in restoring and maintaining NCS water level. The heat-up rate of thecoolant will increase as the available water inventory is reduced. A continuing decrease inwater level will lead to core uncovery.Although related, this EAL is concerned with the loss of NCS inventory and not the potentialconcurrent effects on systems needed for decay heat removal (e.g., loss of a Decay HeatRemoval suction point). An increase in NCS temperature caused by a loss of decay heatremoval capability is evaluated under IC CA3.If NCS water level continues to lower, then escalation to Site Area Emergency would be via ICCS1.IRPIOIN000IO0O1 Rev., 1 Page 70 of 2471 ATTACHMENT 1EAL BasesCNS Basis Reference(s):1. OPI1(2)/A/6150/006 Draining the Reactor Coolant System2. NEI 99-01 CA1[RPIOIAI5000/100 Rev. 1I Page 71 of 247I ATTACHMENT 1EAL BasesCategory:Subcategory:C -Cold Shutdown / Refueling System Malfunction1 -NCS LevelInitiating Condition: Loss of NCS inventoryEAL:CA1.2 AlertNCS water level cannot be monitored for > 15 mmn. (Note 1)AND EITHER* UNPLANNED increase in any Table C-6 sump or tank leveldue to a loss of NCSinventory* Visual observation of UNISOLABLE NCS leakageLIDeleted: Containment Floor &IEquipment Sump or Incore Sump(alarm)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has beenexceeded, or will likely be exceeded.Table C-6 Sumps/Tanks* Containment Floor & Equipment Sump* Incore Sump (alarm)* ND/NS sump* NCDT* PRTMode Applicability:5 -Cold Shutdown, 6 -RefuelingDefinition(s):UNISOLABLE -An open or breached system line that cannot be isolated, remotely or locally.UNPLANNED-. A parameter change or an event that is not 1 ) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameter changeor event may be known or unknown.Basis:In Cold Shutdown mode, the NCS will normally be intact and standard NCS monitoring meansare available. In the Refuel mode, the NCS is not intact and NCS level may be monitored bydifferent means, including the ability to monitor level visually.In this EAL, all NCS water level indication would be unavailable for greater than 15 minutes,and the NCS inventory loss must be detected by indirect leakage indications (ref. 1). Sumplevel increases must be evaluated against other potential sources of leakage. If the make-uprate to the NCS unexplainably rises above the pre-established rate, a loss of NCS inventorymay be occurring even if the source of the leakage cannot be immediately identified. Visualobservation of leakage from systems connected to the NCS that cannot be isolated could alsobe indicative of a loss of NCS inventory.IRP/OIN50001001 Rev. 1 Page 72 of 247I ATTACHMENT 1EAL BasesThe Incore Sump level cannot be monitored in the CR but alarms on high level.This IC addresses conditions that are precursors to a loss of the ability to adequately coolirradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This conditionrepresents a potential substantial reduction in the level of plant safety.For this EAL, the inability to monitor NCS level may be caused by instrumentation and/orpower failures, or water level dropping below the range of available instrumentation. If waterlevel cannot be monitored, operators may determine that an inventory loss is occurring byobserving changes in sump and/or tank levels. Sump and/or tank level changes must beevaluated against other potential sources of water flow to ensure they are indicative of leakagefrom the NCS.The 15-minute duration for the loss of level indication was chosen because it is half of the EALduration specified in IC CSI.If the NCS inventory level continues to lower, then escalation to Site Area Emergency wouldbe via IC CS1.CNS Basis Reference(s):1. AP/1 (2)/A/5500/01 0 Reactor Coolant Leak2. NEI 99-01 CA1SRPIOIAI50001001 Rev. 1 Page 73 of 247 ATTACHMENT 1EAL BasesCategory:Subcategory:Initiating Condition:EAL:C -Cold Shutdown / Refueling System Malfunction1 -NCS LevelLoss of NCS inventory affecting core decay heat removal capabilityCSI1. Site Area EmergencyNCS water level cannot be monitored for > 30 min. (Note 1)ANDCore uncovery is indicated by any of the following:* UNPLANNED increase in any Table C-6 sump or tank leveldue to a loss of NCS ..inventory* Visual observation of UNISOLABLE NCS leakage* Reactor Building Refueling Bridge Monitor 1EMF17 (2EMF2) reading > 9,000 mR/hr* Erratic Source Range or Gamma Metric Monitor indicationcontainment Floor &Equipment Sump or Incore Sump(eaam~)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit hasbeen exceeded, or will likely be exceeded.Table C-6 Sumps/Tanks* Containment Floor & Equipment Sump* Incore Sump (alarm)* ND/NS sump* NCDT* PRTMode Applicability:5 -Cold Shutdown, 6 -RefuelingDefinition(s):UNISOLABLE -An open or breached system line that cannot be isolated, remotely or locally.UNPLANNED-. A parameter change or an event that is not 1I) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameter changeor event may be known or unknown.IRP/0/A/5000/001 IRev. I Page 74 of 247 ATTACHMENT 1EAL BasesBasis:The lowest measurable NCS level is the elevation of the NCS hot leg mid-loop. Therefore,NCS inventory loss relative to the NCS level elevation corresponding to the top of active fuelmust be detected by indirect leakage indications (ref. 1). Sump level increases must beevaluated against other potential sources of leakage. If the make-up rate to the NCSunexplainably rises above the pre-established rate, a loss of NCS inventory may be occurringeven if the source of the leakage cannot be immediately identified. Visual observation ofleakage from systems connected to the NCS in areas outside the containment that cannot beisolated could also be indicative of a loss of NCS inventory (ref. 2).The Incore Sump level cannot be monitored in the CR but alarms on high level.In the Refueling Mode, as water level in the reactor vessel lowers, the dose rate above thecore will increase. The dose rate due to this core shine should result in indications on installedarea radiation monitors. 1 EMF17 (2EMF2), Reactor Building Refueling Bridge Monitor islocated in the containment in proximity to the reactor cavity and is designed to providemonitoring of radiation due to a fuel handling event or loss of shielding during refuelingoperations. If this radiation monitor reaches and exceeds 9,000 mR/hr (90% of instrumentscale), a loss of inventory with potential to uncover the core is likely to have occurred.Post-TMI accident studies indicated that the installed PWR nuclear instrumentation will operateerratically when the core is uncovered and that this should be used as a tool for making suchdeterminations.This IC addresses a significant and prolonged loss of reactor vessel/NCS inventory control andmakeup capability leading to IMMINENT fuel damage. The lost inventory may be due to aNCS component failure, a loss of configuration control or prolonged boiling of reactor coolant.These conditions entail major failures of plant functions needed for protection of the public andthus warrant a Site Area Emergency declaration.Following an extended loss of core decay heat removal and inventory makeup, decay heat willcause reactor coolant boiling and a further reduction in reactor vessel level. If NCS levelcannot be restored, fuel damage is probable.The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss ofability to monitor level), and allows sufficient time to monitor, assess and correlate reactor andplant conditions to determine if core uncovery has actually occurred (i.e., to account for variousaccident progression and instrumentation uncertainties). It also allows sufficient time forperformance of actions to terminate leakage, recover inventory control/makeup equipmentand/or restore level monitoring.The inability to monitor NCS level may be caused by instrumentation and/or power failures, orwater level dropping below the range of available instrumentation. If water level cannot bemonitored, operators may determine that an inventory loss is occurring by observing changesin sump and/or tank levels. Sump and/or tank level changes must be evaluated against otherpotential sources of water flow to ensure they are indicative of leakage from the NCS.This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal;SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdownand Low-Power Operation at Commercial Nuclear Power Plants in the United States; andNUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.IRP/OIN50001001 1Rev. I Page 75 of 247 ATTACHMENT 1EAL BasesEscalation of the emergency classification level would be via IC CGI or RGICNS Basis Reference(s):1. OP/1 (2)/A/61 50/006 Draining the Reactor Coolant System2. AP/1(2)/A/5500/010 Reactor Coolant Leak3. NEI 99-01 CS1IRP/OIA15000/O01 Rev. 1 Page 76 of 247 ATTACHMENT 1EAL BasesCategory:Subcategory:Initiating Condition:C -Cold Shutdown / Refueling System Malfunction1 -NCS LevelLoss of NCS inventory affecting fuel clad integrity with containmentchallengedEAL:CG1.1 General EmergencyNCS level cannot be monitored for 30 min. (Note 1)ANDCore uncovery is indicated by any of the following:* UNPLANNED increase in any Table C-6 sump or tank leveldue to a loss of NCSinventory* Visual observation of UNISOLABLE NCS leakage* Reactor Building Refueling Bridge Monitor 1EMF17 (2EMF2) reading > 9,000 mR/hr* Erratic Source Range or Gamma Metric Monitor indicationANDAny Containment Challenge indication, Table C-iEquipment Sump or Incore Sump(alarm)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit hasbeen exceeded, or will likely be exceeded.Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declarationof a General Emergency is not required.Table C-I Containment Challenge Indications* CONTAINMENT CLOSURE not established (Note 6)* Containment hydrogen concentration > 6%* UNPLANNED rise in containment pressureTable C-6 SumpsrTanks* Containment Floor & Equipment Sump* Incore Sump (alarm)* ND/NS sump* NCDT* PRTIRP/0/A/5000/001 IRev. I Page 77'of2471 ATTACHMENT 1EAL BasesMode Applicability:5 -Cold Shutdown, 6 -RefuelingDefinition(s):CONTAINMENT CLOSURE -The procedurally defined conditions or actions taken to securePrimary or Secondary Containment and its associated structures, systems, and componentsas a functional barrier to fission product release under shutdown conditions.As applied to CNS, Containment Closure is established when the requirements ofOP/0/A/61 00/014 Penetration Control for Modes 5, 6 and NO Mode -Enclosure 4.7 Setting,Maintaining and Securing from Containment Penetration Control are met.UNISOLABLE -An open or breached system line that cannot be isolated, remotely or locally.UNPLANNED-. A parameter change or an event that is not 1 ) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameter changeor event may be known or unknown.Basis:The lowest measurable NCS level is the elevation of the NCS hot leg mid-loop. Therefore,NCS inventory loss relative to the NCS level elevation corresponding to the top of active fuelmust be detected by indirect leakage indications (ref. 1). Sump level increases must beevaluated against other potential sources of leakage. If the make-up rate to the NCSunexplainably rises above the pre-established rate, a loss of NCS inventory may be occurringeven if the source of the leakage cannot be immediately identified. Visual observation ofleakage from systems connected to the NCS in areas outside the containment that cannot beisolated could also be indicative of a loss of NCS inventory (ref. 2).The Incore Sump level cannot be monitored in the CR but alarms on high level.In the Refueling Mode, as water level in the reactor vessel lowers, the dose rate above thecore will increase. The dose rate due to this core shine should result in indications on installedarea radiation monitors. 1 EMF1 7 (2EMF2), Reactor Building Refueling Bridge Monitor islocated in the containment in proximity to the reactor cavity and is designed to providemonitoring of radiation due to a fuel handling event or loss of shielding during refuelingoperations. If this radiation monitor reaches and exceeds 9,000 mR/hr (90% of instrumentscale), a loss of inventory with potential to uncover the core is likely to have occurred.Post-TMI accident studies indicated that the installed PWR nuclear instrumentation will operateerratically when the core is uncovered and that this should be used as a tool for making suchdeterminations.Three conditions are associated with a challenge to containment integrity:* CONTAINMENT CLOSURE is not established (Ref. 3).* In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to acore uncovery could result in an explosive mixture of dissolved gases in thecontainment. However, containment monitoring and/or sampling should be performed toverify this assumption and a General Emergency declared if it is determined that anexplosive mixture exists. An explosive mixture can be formed when hydrogen gas[RP/O/A/5000/01 1 Rev. 1 Page 78 of 247 ATTACHMENT 1EAL Basesconcentration in the containment atmosphere is greater than 6% by volume in thepresence of oxygen (>5%).*Any unplanned increase in containment pressure in the Cold Shutdown or Refuelingmode indicates a potential loss of containment closure capability. Unplannedcontainment pressure increases indicates containment closure cannot be assured andthe containment cannot be relied upon as a barrier to fission product release.This IC addresses the inability to restore and maintain reactor vessel level above the top ofactive fuel with containment challenged. This condition represents actual or IMMINENTsubstantial core degradation or melting with potential for loss of containment integrity.Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for morethan the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decay heat willcause reactor coolant boiling and a further reduction in reactor vessel level. If NCS levelcannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a direct andunmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a GeneralEmergency is not required.The existence of an explosive mixture means, at a minimum, that the containment atmospherichydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagrationlimit). A hydrogen burn will raise containment pressure and could result in collateral equipmentdamage leading to a loss of containment integrity. It therefore represents a challenge toContainment integrity.In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a coreuncovery could result in an explosive gas mixture in containment. If all installed hydrogen gasmonitors are out-of-service during an event leading to fuel cladding damage, it may not bepossible to obtain a containment hydrogen gas concentration reading as ambient conditionswithin the containment will preclude personnel access. During periods when installedcontainment hydrogen gas monitors are out-of-service, operators may use the other listedindications to assess whether or not containment is challenged.The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss ofability to monitor level), and allows sufficient time to monitor, assess and correlate reactor andplant conditions to determine if core uncovery has actually occurred (i.e., to account for variousaccident progression and instrumentation uncertainties). It also allows sufficient time forperformance of actions to terminate leakage, recover inventory control/makeup equipmentand/or restore level monitoring.The inability to monitor NCS level may be caused by instrumentation and/or power failures, orwater level dropping below the range of available instrumentation. If water level cannot bemonitored, operators may determine that an inventory loss is occurring by observing changesin sump and/or tank levels. Sump and/or tank level changes must be evaluated against otherpotential sources of water flow to ensure they are indicative of leakage from theNCS.This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal;SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, ShutdownSRPIOIN/50001001 Rev. 1 Page 79 of 247] ATTACHMENT 1EAL Basesand Low-Power Operation at Commercial Nuclear Power Plants in the United States; andNUMARC 91-06, Guidelnes for Industry Actions to Assess Shutdown Management.CNS Basis Reference(s):1. OP/1(2)/A/6150/006 Draining the Reactor Coolant System2. AP/1 (2)/A/5500/01 0 Reactor Coolant Leak3. OPI/OA/61001014 Penetration Control for Modes 5, 6 and NO Mode. Enclosure 4.7 Setting,Maintaining and Securing from Containment Penetration Control4. NEI 99-01 CG1IRP/O/AI5000/O01 Rev. 1I Page 80 of 247 ATTACHMENT 1EAL BasesCategory:Subcategory:Initiating Condition:C -Cold Shutdown I Refueling System Malfunction2 -Loss of Essential AC PowerLoss of all but one AC power source to essential buses for 15 minutesor longerEAL:CU2.1 Unusual EventAC power capability, Table C-2, to essential 41 60V buses 1 (2)ETA and I (2)ETB reducedto a single power source for > 15 mmn. (Note 1)ANDAny additional single power source failure will result in loss of all AC power to SAFETYSYSTEMSNote 1: The Emergency Coordinator should declare the event promptly upon determining that time limit hasbeen exceeded, or will likely be exceeded.Table C-2 AC Power SourcesOffsite:* ATC (Train A)* SATA (Train A) (if already aligned)* ATD (Train B)* SATB (Train B) (if already aligned)Onsite:* D/G A(Train A)* DIG B (Train B)Mode Applicability:5 -Cold Shutdown, 6 -Refueling, D -DefueledIRPI/0A/5000/O01 IRev. 1 IPage 81 of 2471 ATTACHMENT 1EAL BasesDefinition(s):SAFETY SYSTEM -A system required for safe plant operation, cooling down the plant and/orplacing it in the cold shutdown condition, including the EGOS. These are typically systemsclassified as safety-related (as defined in 10OCFR50.2):Those structures, systems and components that are relied upon to remain functional duringand following design basis events to assure:(1) The integrity of the reactor coolant pressure boundary;(2) The capability to shut down the reactor and maintain it in a safe shutdown condition;(3) The capability to prevent or mitigate the consequences of accidents which could resultin potential offsite exposures.Basis:The 4160 VAC System provides the power requirements for operation and safe shutdown ofthe plant. The essential switchgear are buses ETA (Train A) and ETB (Train B) (ref. 1).The essential buses are normally powered from the 6.9KV offsite power system through theirrespective 6.9KV/41 60V Normal Auxiliary Transformers (ATC & ATD). Additionally, a standbysource of power to each 4160V essential bus is provided from the 6.9KV offsite power systemvia two separate and independent 6.9KV/4160V transformers (SATA & SATB). Thesetransformers are shared between the two units (ref. 1, 2). However, alignment of SATA orSATB to an essential bus takes longer than 15 minutes and therefore should only be credited ifalready aligned.Each essential bus has a dedicated diesel generator (DIG A & DIG B) to supply an onsiteemergency source of power to safe shutdown loads in the event of a loss of the normal powersource or loss of off-site power. The DIGs will automatically start and tie onto the essentialbuses if the normal power source or off-site power is lost (ref. 1 ).This cold condition EAL is equivalent to the hot condition EAL SAI .1.This IC describes a significant degradation of offsite and onsite AC power sources such thatany additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. Inthis condition, the sole AC power source may be powering one, or more than one, train ofsafety-related equipment.When in the cold shutdown, refueling, or defueled mode, this condition is not classified as anAlert because of the increased time available to restore another power source to service.Additional time is available due to the reduced core decay heat load, and the lowertemperatures and pressures in various plant systems. Thus, when in these modes, thiscondition is considered to be a potential degradation of the level of safety of the plant.An "AC power source" is a source recognized in AOPs and EOPs, and capable of supplyingrequired power to an essential bus. Some examples of this condition are presented 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 emergency power sources (e.g., onsite diesel generators) with a single train ofemergency buses being fed from an offsite power source.SRP/0/A/5000/001 Rev. 1 Page 82 of 247 ATTACHMENT 1EAL BasesFifteen minutes was selected as a threshold to exclude transient or momentary losses ofpower.The subsequent loss of the remaining single power source would escalate the event to an Alertin accordance with IC CA2.CNS Basis Reference(s):1. UFSAR Section 8.0 Electric Power2. AP/1(2)/A/5500/007 Loss of Normal Power3. NEI 99-0i CU21RPI/o100/0sooooo Rev. 1 Page 83 of2471 ATTACHMENT 1. ..EAL BasesCategory: C -Cold Shutdown / Refueling System Malfunction,Subcategory: 2 -Loss of Essential AC PowerInitiating Condition: Loss of all offsite and all onsite AC power to essential buses for 15minutes or longerEAL:CA2.1 AlertLoss of all offsite and all onsite AC power capability, to essential 4160V buses 1(2)ETA I .Deleted:, Table C-2,and 1(2)ETB for > 15 min. (Note 1)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit hasbeen exceeded, or will likely be exceeded.* ..... Deleted: ¶Mode Applicability: Table C-2 AC Power Sources5 -Cold Shutdown, 6 -Refueling, D -DefueledBasis:The 4160 VAC System provides the power requirements for operation and safe shutdown ofthe plant. The essential switchgear are buses ETA (Train A) and ETB (Train B) (ref. 1).The essential buses are normally powered from the 6.9KV offsite power system through theirrespective 6.9KV/4160V Normal Auxiliary Transformers (ATC & ATD). Additionally, a standbysource of power to each 4160V essential bus is provided from the 6.9KV offsite power systemvia two separate and independent 6.9KV/4160V transformers (SATA & SATB). Thesetransformers are shared between the two units (ref. 1, 2). However, alignment of SATA orSATB to an essential bus takes longer than 15 minutes and therefore should only be credited ifalready aligned.Each essential bus has a dedicated diesel generator (DIG A & D/G B) to supply an onsiteemergency source of power to safe shutdown loads in the event of a loss of the normal powersource or loss of off-site power. The D/Gs will automatically start and tie onto the essentialbuses if the normal power source or off-site power is lost (ref. 1 ).This cold condition EAL is equivalent to the hot condition loss of all offsite AC power EALSS1.1.This IC addresses a total loss of AC power that compromises the performance of all SAFETYSYSTEMS requiring electric power including those necessary for emergency core cooling,containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink.When in the cold shutdown, refueling, or defueled mode, this condition is not classified as aSite Area Emergency because of the increased time available to restore an essential bus toservice. Additional time is available due to the reduced core decay heat load, and the lowertemperatures and pressures in various plant systems. Thus, when in these modes, thiscondition represents an actual or potential substantial degradation of the level of safety of theplant.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.IRPIOIA/5000/O01 Rev. 1 Page 84 of 247 ATTACHMENT 1EAL BasesEscalation of the emergency classification level would be via IC CS1 or RSt.CNS Basis Reference(s):1. UFSAR Section 8.0 Electric Power2. AP/1(2)/A/5500/007 Loss of Normal Power3. ECA-0.0 EP/II(2)/5000IECA-0.0 Loss of All AC Power4. NEI 99-01 CA2IRPIO,/Aooo0oo0 I Rev. 1 Page 85 of 2471 ATTACHMENT 1EAL BasesCategory: C -Cold Shutdown / Refueling System MalfunctionSubcategory: 3 -NCS TemperatureInitiating Condition: UNPLANNED increase in NCS temperatureEAL:CU3.t Unusual EventUNPLANNED increase in NCS temperature to > 2000F due to loss of decay heat removalcapabilityMode Applicability:5 -Cold Shutdown, 6 -RefuelingDefinition(s):UNPLANNED-. A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameter changeor event may be known or unknown.Basis:Several instruments are capable of providing indication of NCS temperature with respect to theTechnical Specification cold shutdown temperature limit (200°F, ref. 1) including both hot legand cold leg RTDs and core exit TICs (ref. 2, 3).In the absence of reliable NCS temperature indication caused by a loss of decay heat removalcapability, classification should be based on EAL CU3.2 should NCS level indication besubsequently lost.This IC addresses an UNPLANNED increase in NCS temperature above the TechnicalSpecification cold shutdown temperature limitand represents a potential degradation of thelevel of safety of the plant. If the NCS is not intact and CONTAINMENT CLOSURE is notestablished during this event, the Emergency Coordinator should also refer to IC CA3.A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant a classification.This EAL involves a loss of decay heat removal capability, or an addition of heat to the NCS inexcess of that which can currently be removed, such that reactor coolant temperature cannotbe maintained below the cold shutdown temperature limit specified in Technical Specifications.During this condition, there is no immediate threat of fuel damage because the core decayheat load has been reduced since the cessation of power operation.During an outage, the level in the reactor vessel will normally be maintained at or above thereactor vessel flange. Refueling evolutions that lower water level below the reactor vesselflange are carefully planned and controlled. A loss of forced decay heat removal at reducedinventory may result in a rapid increase in reactor coolant temperature depending on the timeafter shutdown.Fifteen minutes was selected as a threshold to exclude transient or momentary losses ofindication.IRP/0/A/5000/001 Rev. 1 Page 86 of 247 ATTACHMENT 1EAL BasesEscalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based onexceeding plant configuration-specific time criteria.CNS Basis Reference(s):1. CNS Technical Specifications Table 1.1-12. CNS UFSAR Section 7,0 Instrumentation and Controls3. API1(2)1N55001019 Loss of Residual Heat Removal System4. NEI 99-01 CU3IRPIOIAJ5000I100 Rev. 1 Page 87 of 247 ATTACHMENT 1EAL BasesCategory: C -Cold Shutdown / Refueling System MalfunctionSubcategory: 3 -NCS TemperatureInitiating Condition: UNPLANNED increase in NCS temperatureEAL:CU3.2 Unusual EventLoss of all NCS temperature and NCS level indication for > 15 min. (Note 1 )Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit hasbeen exceeded, or will likely be exceeded.Mode Applicability:5 -Cold Shutdown, 6- RefuelingDefinition(s):NoneBasis:Several instruments are capable of providing indication of NCS temperature with respect to theTechnical Specification cold shutdown temperature limit (200°F, ref. 1) including both hot legand cold leg RTDs and core exit T/Cs (ref. 2, 3).NCS water level is normally monitored using various instruments including NC System narrowrange and wide range monitors, RVLIS, NC System sightglass, tygon tube and Pressurizerlevel instruments (ref. 4).This EAL addresses the inability to determine NCS temperature and level, and represents apotential degradation of the level of safety of the plant. If the NCS is not intact andCONTAINMENT CLOSURE is not established during this event, the Emergency Coordinatorshould also refer to IC CA3.This EAL reflects a condition where there has been a significant loss of instrumentationcapability necessary to monitor NCS conditions and operators would be unable to monitor keyparameters necessary to assure core decay heat removal. During this condition, there is noimmediate threat of fuel damage because the core decay heat load has been reduced sincethe cessation of power operation.Fifteen minutes was selected as a threshold to exclude transient or momentary losses ofindication.Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based onexceeding plant configuration-specific time criteria.CNS Basis Reference(s):1. CNS Technical Specifications Table 1.1-12. CNS UFSAR Section 7.0 Instrumentation and Controls3. AP/1(2)/A/5500/019 Loss of Residual Heat Removal SystemRP011I0/01Rev. 1 Page 88 of 247 ATTACHMENT 1EAL Bases4. OP/1 (2)/A/61 50/006 Draining the Reactor Coolant System5. NEI 99-01 CU3IRPIO/A150001001 Rev. I Page 89 of 247 }}