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{{#Wiki_filter:Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSU76Initiating Condition:Loss of all On-site or Off-site communications capabilities.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):1. Loss of ALL Table M3 Onsite communications capability affecting the ability toperform routine operations.OR2. Loss of ALL Table M3 Offsite communication capability affectina the abilitv toperform offsite notifications.OR3. Loss of ALL Table M3 NRC communication capability affecting the ability toperform NRC notifications.Table M3 Communications CaDabilitvSystem Onsite Offsite NRCRadios XPlant page XPlant Telephone System XSound Powered Phones XCommercial Telephones X X XNARS XENS X XHPN X XSatellite phones _ X X1. Loss of ALL of tho following oncito communication mIothods:*v(sito spocific_ list of coemmunications mcthed+-6^ f4o-_s--IMonth 20XXTMI 3-80EP-AA-1009 (Revision XX) | |||
Exelon NuclearThree Mile Island Station Annex Exellon NuceIarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS(cito spocific list Of communUi~cations mcthodG)3. Loss of ALL o tho foloi the NRC comuic. ations methods'(site spocif ic list. of coammunications methods)Basis:I This IC addresses a significant loss of on-site-, offsite, or NRC OFeffskecommunications capabilities. While not a direct challenge to plant or personnel safety,I this event warrants prompt notifications to Offsite Response Organizations (OROs. andthe NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 BasisaAddresses a total loss of the communications methods used in support of routine plantoperations.EAL #2 BasisaAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in procedure EP-MA-1 14-1 00-F-01, State / Local Event Notification Form. (coo EAL #3 basisaAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, SU62. 1105-12 Communications System3. FSAR Section 7.4.4, CommunicationMonth 20XXTMI 3-81EP-AA-1009 (Revision XX) | |||
Throm Uila Wa6nd Qtatinn AnnovI=Yalnn TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSU87Initiating Condition:Failure to isolate containment or loss of containment pressure control.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):1. a. Failure of containment to isolate when required by an actuation signal.ANDb. ANY required penetration remains open > 15 minutes of the actuationsignaL.ALL required penetrations aro not Glosod within 15 minutes ofthaGuaten signal.OR2. a. Reactor Buildina pressure > 30 DSiaANDb. Reactor Building Emergency cooling is less than ANY one of the followingconditions > 15 minutes:SPRAY COOLERS2 00 31 1a. Gontainment wersesr grcater man (Site S~eGITIG wroccurci.lANDL- I I-W.. ...utit. I.~I _R"~ -ui; -w.U-1 1-0.i VI! tbi.,,,b 't-iPH ~~V Id UttK1iW~t 1b~;~u~ IddIK1t V..,A ai~r f ir, I + i~ ~rI~i~IIUzi birl %7r m Hxx quo %7r x7ritit7r.Basis:This IC addresses a failure of one Or any containment penetrations toautomatically isolate (close) when required by an actuation signal. It also addresses anevent that results in high containment pressure with a concurrent failure of containmentpressure control systems. Absent challenges to another fission product barrier, eithercondition represents potential degradation of the level of safety of the plant.Month 20XXTMI 3-82EP-AA-1009 (Revision XX) | |||
Tkriags Uild li@Innr Qfc*irtun AuingvIP:v-alfn NimdlachTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSFer-EAL #1 Basis,-The containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); afailure resulting from testing or maintenance does not warrant classification. Thedetermination of containment and penetration status -isolated or not isolated -shouldbe made in accordance with the appropriate criteria contained in the plant AOPs andEOPs. The 15-minute criterion is included to allow operators time to manually isolatethe required penetrations, if possible.EAL #2 BasisaAddresses a condition where containment pressure is greater than the setpoint atwhich containment energy (heat) removal systems are designed to automaticallyactuate, and less than one full train of equipment is capable of operating per design.The 15-minute criterion is included to allow operators time to manually start equipmentthat may not have automatically started, if possible. The inability to start the requiredequipment indicates that containment heat removal/depressurization systems (e.g.,containment sprays or ice condenser fans) are either lost or performing in a degradedmanner.This event would escalate to a Site Area Emergency in accordance with IC FS1 if therewere a concurrent loss or potential loss of either the Fuel Clad or RCS fission productbarriers.Basis Reference(s):1. NEI 99-01 Rev 6, SU72. FSAR Section 6.6 Reactor Building Pressure-Time Response3. Technical Specifications 3.5.3, Engineered Safeguards Protection SystemActuation Setpoints4. FSAR Section 6.3.3, Actuation5. FSAR Section 6.5.3, Hydrogen Generation6. OP-TM-EOP-006, LOCA Cooldown7. 1302-5.25 Reactor Building Sump Level8. FSAR Section 5.2 Reactor Building9. FSAR Section 9.2, Chemical Addition and Sampling System10. OP-TM-EOP-002, Loss of 250F Subcooling Margin11. OP-TM-EOP-006, LOCA Cooldown12. OP-TM-EOP-01 0, Emergency Procedure Rules, Guides and Graphs13. OP-TM-MAP-D0301, High Make-up FlowMonth 20XXTMI 3-83EP-AA-1 009 (Revision XX) hrgo Uila lalzonel Qtafietn AnnovI:vallnn KI%: : arh rTkraa Mum 1e6nr4 ~tmtir~n Annmv Fvmlnn M..ri.mrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA12Initiating Condition:Loss of all offsite and all onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:5,6, DEmergency Action Level (EAL):Note: The Emergency Director should declare the promptly upondetermining that the applicable time 15 minutec time has been exceeded, or willlikely be exceeded.1. Loss of ALL offsite AC power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-11B Emergency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutesfrom the time of loss of both offsite and onsite AC power.Loes of ALL offsite and ALL onsite AC Powor to (site specific emergency buses) for 15minuto Or Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-relatedThis IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergencycore cooling, containment heat removal/pressure control, spent fuel heat removal andthe ultimate heat sink.When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas a Site Area Emergency because of the increased time available to restore anemergency bus to service. Additional time is available due to the reduced core decayheat load, and the lower temperatures and pressures in various plant systems. Thus,Month 20XXTMI 3-84EP-AA-1009 (Revision XX) | |||
Thrdaim Uilgh lalanri -Qfnfifn AnnovI::gslnn hle ar~l~Tkrna MiI~ IeI~nrI Qt~tir~n Annn~w Fv.inn NI. .i-I~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSwhen in these modes, this condition represents an actual or potential substantialdegradation of the level of safety of the plant.I Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via IC CS6 or RASI.Basis Reference(s):1. NEI 99-01 Rev 6, CA22. FSAR Section 8.2.2, Unit Distribution System3. FSAR Section 8.2.3, Sources of Auxiliary Power4. Technical Specification Section 3.7, Unit Electric Power System5. 1107-1 Normal Electrical System6. 11 07-2A Emergency Electrical -4KV and 480 Volt7. OP-TM-AOP-020 Loss Of Station Power8. 1107-3 Diesel Generator9. 1107-9 SBO Diesel Generator10. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-85EP-AA-1009 (Revision XX) | |||
ExAIon NuclearIhri Win Is landl Station Annex EIxelln Nu!leIsarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU12Initiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:5,6, DEmergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Eivontevent promptly upondetermining that the applicable time 5--minute6-has been exceeded, or will likelybe exceeded.1. AC power capability to Emergency 4KV buses reduced to only one of thefollowing power sources for > 15 minutes.* Auxiliary Transformer 1A* Auxiliarv Transformer 1 B* Emergency Diesel Generator EG-Y-1A" Emergency Diesel Generator EG-Y-1 B* SBO Diesel Generator EG-Y-4AND2. Any additional single power source failure will result in a loss of ALL AC powerto SAFETY SYSTEMS.plwer courco for 15 minut cI Ior Inge.ANDb. Any additional singlo power source failuro will result in leos of all AG power toSAFETY SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or Dlacina it in the cold shutdown condition. includina the EGCS.These aretypically systems classified as safety-related.This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS. In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment.Month 20XXTMI 3-86EP-AA-1009 (Revision XX) | |||
ExAIon NuclearThrpa Mill IslandI Rtation Annexr Exelon NuclanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSI When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas an Alert because of the increased time available to restore another power source toservice. Additional time is available due to the reduced core decay heat load, and thelower temperatures and pressures in various plant systems. Thus, when in thesemodes, this condition is considered to be a potential degradation of the level of safety ofthe plant.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below.I | |||
* A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).I | |||
* A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator.* A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.The subsequent loss of the remaining single power source would escalate the event toan Alert in accordance with IC CA1_.Basis Reference(s):1. NEI 99-01 Rev 6 CU22. FSAR Section 8.2.2, Unit Distribution System3. FSAR Section 8.2.3, Sources of Auxiliary Power4. Technical Specification Section 3.7, Unit Electric Power System5. 1107-1 Normal Electrical System6. 11 07-2A Emergency Electrical -4KV and 480 Volt7. OP-TM-AOP-020 Loss Of Station Power8. 1107-3 Diesel Generator9. 1107-9 SBO Diesel Generator10. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-87EP-AA-1009 (Revision XX) | |||
Tknaft RA16% lalonA totinn AnndavI::valnn N"AaarlTkr~a Ilila lalauiri ~*a*kirm Ann~v Fvm Inn F'Juuir~Ia~v U III~~ 1U5h1 *OUE 1 tSSuu U UE SE 1fl ~ * * ~TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCA26Initiating Condition:Hazardous event affecting SAFETY SYSTEM needed-required for the current operatingmode.Operating Mode Applicability:5,6Emergency Action Level (EAL):1. a, The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)" Internal or external flooding event" High winds or tornado strike" FIRE" EXPLOSION" (site sepocfic hazar~ds)" Other events with similar hazard characteristics as determined by theShift ManagerAND2.b. EITHER of the following:a.__,. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM needed-required byTechnical Specifications for the current operating mode.ORThe event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure Reeded-required by TechnicalSpecifications for the current operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization. A release of steam (from highenergy lines or components) or an electrical component failure (caused by short circuits,grounding, arcing, etc.) should not automatically be considered an explosion. SuchMonth 20XXTMI 3-88EP-AA-1009 (Revision XX) hrom Uila Wand Qtafinn AnnoyF:yalnn haPl"AarThree Mile l@kanrl Qtntinn Anney Fvelnn Mm .r~learTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSevents may require a post-event inspection to determine if the attributes of an explosionare present.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placinq it in the cold shutdown condition, includinq the ECOS. These aretypically systems classified as safety-related.VISIBLE DAMAGE: Damage to a component or structure that is readily observablewithout measurements, testing, or analysis. The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components,- neededrequired for the currentoperating mode, "required", i.e. required to be operable by Technical Specifications forthe current operating mode. This condition significantly reduces the margin to a loss orpotential loss of a fission product barrier, and therefore represents an actual or potentialsubstantial degradation of the level of safety of the plant. Manual or automatic electricalisolation of safety equipment due to flooding, in and of itself, does not constitutedegraded performance and is classified under HU6.EAL 1-b42.a Basis-aAddresses damage to a SAFETY SYSTEM train that is- required to be operable byTechnical Specifications for the current operating mode, and is in 6e:VGe/operationsince indications for it will be readily available. The indications of degradedperformance should be significant enough to cause concern regarding the operability orreliability of the SAFETY SYSTEM train.EAL 4-b-22.b Basis-aAddresses damage to a SAFETY SYSTEM component that is -required to beoperable by Technical Specifications for the current operating mode, and is not inewe peration or readily apparent through indications alone, or to a structurecontaining SAFETY SYSTEM components. Operators will make this determinationbased on the totality of available event and damage report information. This is intendedto be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC CS6 or RAS1.If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):1. NEI 99-01 Rev 6, CA6Month 20XXTMI 3-89EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU34Initiating Condition:Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Eventevent promptly upondetermining that the applicable time 15 m..utcs time has been exceeded, or willlikely be exceeded.Voltage is < 105 VDC on required 125 VDC Distribution Systems 1 A and 1 B for > 15minutes.Indicated v,,oltage is loss than (site specific bus voltage v.. alue) On required Vita! DGh15buses forF 16 min*utes Or !onger.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a loss of Vital DC power which compromises the ability to monitorand control operable SAFETY SYSTEMS when the plant is in the cold shutdown orrefueling mode. In these modes, the core decay heat load has been significantlyreduced, and coolant system temperatures and pressures are lower; these conditionsIi, Feaseraise the time available to restore a vital DC bus to service. Thus, thiscondition is considered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to supportoperation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.For example, if Train A is out-of-service (inoperable) for scheduled outage maintenancework and Train B is in-service (operable), then a loss of Vital DC power affecting Train Bwould require the declaration of an Unusual Event. A loss of Vital DC power to Train Awould not warrant an emergency classification.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Depending upon the event, escalation of the emergency classification level would be viaIC CA6 or CA5_, or an IC in Recognition Category BA.Month 20XXTMI 3-90EP-AA-1 009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSBasis Reference(s):1. NEI 99-01 Rev 6, CU42. FSAR Section 8.2.2.6, 250/125 VDC System3. 1107-2C Vital DC Electrical System4. OP-TM-AOP-023, A DC System Failure5. OP-TM-AOP-024, B DC System FailureMonth 20XXTMI 3-91EP-AA-1 009 (Revision XX) | |||
Fxelon NuclearThree Mile Isla~nd Station Annex ExeIon NuclanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU4"Initiating Condition:Loss of all onsite or offsite communications capabilities.Operating Mode Applicability:5,6, DEmergency Action Level (EAL):1. Loss of ALL Table C1 Onsite communications capability affecting the ability toperform routine operations.OR2. Loss of ALL Table C1 Offsite communication capability affecting the ability toperform offsite notifications.OR3. Loss of ALL Table Cl NRC communication capability affecting the ability toperform NRC notifications.Table Cl Communications CapabilitvSystem Onsite Offsite NRCRadios XPlant pagqe XPlant Telephone System XSound Powered Phones XCommercial Telephones X X XNARS XENS X XHPN X XSatellite phones X X1. Loss of ALL ofth f10 ollowing GAsito communication motnode:(site 6pocific list Of communications moethods)2. Loess of ALL of tho following ORO comAmunications moethods:;(r.ite snnfoifi list of Gammus acat a nS mo~thnds\ .... -If............ IMonth 20XXTMI 3-92EP-AA-1009 (Revision XX) | |||
ExAIon NuclearThree Mile Islsand Stamtion Annex ExeIon NucleasrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS3. Loss of ALL of the following NRC communications mr.thods:(site -specific list of communications mnethods)Basis:I This IC addresses a significant loss of on-site-, offsite, or NRC --ffeiecommunications capabilities. While not a direct challenge to plant or personnel safety,I this event warrants prompt notifications to Offsite Response Organizations (OROs. andthe NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 BasisaAddresses a total loss of the communications methods used in support of routine plantoperations.EAL #2 BasisaAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in Procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form._(see Developer Notes).EAL #3 BasisaAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, CU52. 1105-12 Communications System3. FSAR Section 7.4.4, CommunicationMonth 20XXTMI 3-93EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearThree Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSInitiating Condition:Inability to maintain the plant in cold shutdown.Operating Mode Applicability:5,6CA53Emergency Action Level (EAL):Note: The Emergency Director should declare the Ale---event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.1. UNPLANNED rise in RCS temDerature > 200°F due to lossof decay heatremoval for > Table C2 duration.Table C2 RCS Heat-up Duration ThresholdsRCS Containment Closure Heat-upStatus Status DurationIntact Not Applicable 60 minutes*Not IntactEstablished 20 minutes*ORReduced Not Established 0 minutesInventory* If an RCS heat removal system is in operation withinthis time frame and RCS temperature is being reduced,then EAL #1 is not applicable.OR2. UNPLANNED RCS pressure rise > 10 osia as a result of temperature rise dueto loss of decay heat removal. (This EAL does not apply in solid plantconditions.)S I I M, f1 r 1 A 0,10 1I-r% ! ..I~If~ * .~..----.. .L.. 1¶L.ffffffffffffffffffffffffffff~-~-- ~r'~I I IF~II-I -¶r~P~t-I I trwrr~z1r.r1 In I-¶1 = Tflmr1f~r1TIIrC~ T~ f1rf~ITf4r rrIn IFITf~ Vhlr-NIIIULe....l c d rI------- ----- --- -------an ll,duration pepcifiod in the fo-lloing table.JVI Month 20XXTMI 3-94EP-AA-1009 (Revision XX) | |||
Tkrmm Uilia lalanri Qfatinn AnniavFIsYlnn Nn rlhuarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSTable: RCS He-at up Duration ThoeshodRCS Staus Containment Clocuro Heat-up DurationStatushAtaet (but not at.reduod i nentoiI applia 6u iinuteifP444;1)Not intacst (Or at rouedGN7= Establoshe2d M-nt~es-*Inwente~y [Pl4q~) Not Ectabliched 0 F~inutes* if an RCS hoat removal system is in oncration with:in this time fr-ameand RCS tcmperaturo is boing reduced, the EAL. is not applmicablo-.i l&li--tl Ali, lklr"r't .-&I- /_.u -!.C!-' S ft Sr,. A ft ft ,rr% I-,IE.% .-. ~~V~T' 1~1 FT'~ f~r1rN~TIr* rirrwi~i rf~h-. ' -~ ~-- r'rt4wTT~;. ~ S SIS 1 RU.. ~%~4j I *%t A~ASS.IPWADII ULUIr.. ~Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchanae or event mav be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, etc.).This IC addresses conditions involving a loss of decay heat removal capability or anaddition of heat to the RCS in excess of that which can currently be removed. Eithercondition represents an actual or potential substantial degradation of the level of safetyof the plant.A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.The RCS Heat-up Duration Thresholds table addresses ao i6,reaserise in RCStemperature when CONTAINMENT CLOSURE is established but the RCS is not intact,or RCS inventory is reduced (e.g., mid-loop operation in PWRs). The 20-minutecriterion was included to allow time for operator action to address the temperatureMonth 20XXTMI 3-95EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSI The RCS Heat-up Duration Thresholds table also addresses an inereaserise in RCStemperature with the RCS intact. The status of CONTAINMENT CLOSURE is notcrucial in this condition since the intact RCS is providing a high pressure barrier to afission product release. The 60-minute time frame should allow sufficient time toaddress the temperature inereaserise without a substantial degradation in plant safety.Finally, in the case where there is an inereaserise in RCS temperature, the RCS is notintact or is at reduced inventory-[P-RJ, and CONTAINMENT CLOSURE is notestablished, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) theevaporated reactor coolant may be released directly into the Containment atmosphereand subsequently to the environment, and 2) there is reduced reactor coolant inventoryabove the top of irradiated fuel.EAL #2 BasispProvides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS61- or RAS1.Basis Reference(s):1. NEI 99-01 Rev 6, CA32. Technical Specifications sections: 1.2.1, 1.7.a and c3. Technical Specifications sections: 3.6.12.a4. Technical Specifications sections: 3.6.55. Technical Specifications sections: 3.8.66. Technical Specifications sections: 1.2.1, 1.7.a and c, 3.6.12.a, 3.6.5, 3.8.67. 1101-3 Containment Integrity and Access Limits8. OP-TM-EOP-030, Loss of Decay Heat Removal9. Outage Fuel Protection Criteria DocumentMonth 20XXTMI 3-96EP-AA-1009 (Revision XX) | |||
Throm Wha lalanri Qtafinn AnnavI=Yalnn N, ii , nnilp nleaTBleniE l i 3-2n: EVIn lechnIcITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCU53Initiating Condition:UNPLANNED iArGease-rise in RCS temperatureOperating Mode Applicability:5,6Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual E'-ntovent promptly upondetermining that the applicable time -1.-miFites-has been exceeded, or will likelybe exceeded.1. UNPLANNED rise in RCS temDerature > 200°F due to loss ofdecay heatremoval.OR2. Loss of the followinq* for > 15 minutes.* ALL RCS temperature indicationsAND* ALL RCS level indications1 WWIPI NEDf InrrGMpp in 5Z~ tcF~r~nPtiir tG nrr"ateF than 1ritre 6nterifir ---r Gg *-r~..,..%..a,..fI ~ nairi ni... .*rjn.Ar. *nrv.r..n rr'.*. awn I;.'.'. ;*'I............. r..... rf% I m A I I -'Cn a----.. Ui niLiL Iv ~IIIl,J'vf.JA,.UIU ,1IU IU..ULI~v vv vi , v, v,.vBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.This IC addresses an UNPLANNED i*Reeaserise in RCS temperature above theTechnical Specification cold shutdown temperature limit, or the inability to determineMonth 20XXTMI 3-97EP-AA-1009 (Revision XX) | |||
Thre Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSRCS temperature and level, represents a potential degradation of the level of safety ofthe plant. If the RCS is not intact and CONTAINMENT CLOSURE is not establishedduring this event, the Emergency Director should also refer to IC CA53.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.I EAL #1 involves a loss of decay heat removal capability, or an addition of heat to theRCS in excess of that which can currently be removed, such that reactor coolanttemperature cannot be maintained below the cold shutdown temperature limit specifiedin Technical Specifications. During this condition, there is no immediate threat of fueldamage because the core decay heat load has been reduced since the cessation ofpower operation.During an outage, the level in the reactor vessel will normally be maintained above thereactor vessel flange. Refueling evolutions that lower water level below the reactorvessel flange are carefully planned and controlled. A loss of forced decay heat removalat reduced inventory may result in a rapid iniereaserise in reactor coolant temperaturedepending on the time after shutdown.EAL #2 reflects a condition where there has been a significant loss of instrumentationcapability necessary to monitor RCS conditions and operators would be unable tomonitor key parameters necessary to assure core decay heat removal. During thiscondition, there is no immediate threat of fuel damage because the core decay heatload has been reduced since the cessation of power operation.I Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.I Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA53 basedon exceeding plant configuration-specific time criteria.Basis Reference(s):Month 20XXTMI 3-98EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS1. NEI 99-01 Rev 6, CU32. 1103-11 RCS Water Level Control3. FSAR Section 7.3.2, Non-Nuclear Instrumentation4. 1302-6.6 RCS Temp/Press, TSAT Monitor, ATWS and DSS Calibration5. NEI 99-01 Rev 5, CU46. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-99EP-AA-1009 (Revision XX) | |||
Throm Uilds lalanel tatinn AnnovP~valnn NltrhlarThro~ Mila IcI~nr4 ~t~tinn Annv ~v~Inn NiuiI.mrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCG6-4Initiating Condition:Loss of reactor vessel/RCS inventory affecting fuel clad integrity with containmentchallenged.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note: The Emergency Director should declare the G-noral ElinergencycLvent promptlyupon determining that the applicable time 30-minutes-has been exceeded, or willlikely be exceeded.1. Reactor vessel level unknown for > 30 minutes.AND2. Core uncovery is indicated by ANY of the following:" Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Erratic Source Range Neutron Monitor indication.OR" Radiation monitors RM-G-6 or RM-G-7 reading > 3 RPhr.AND3. Any Containment Challenge Indication (Table Q4)Table C3 Indications of RCS Leakaqe" UNPLANNED Reactor BIdg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise** UNPLANNED RCDT level rise*" UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.Month 20XXTMI 13-100EP-AA-1 009 (Revision XX) | |||
Thrdada Uilin lainnel Qfafinn AnngvFIaYlenn MN,,rluarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSTable C4 Containment Challenge Indications* Hydrogen Concentration in Containment > 4%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established** if CONTAINMENT CLOSURE is re-established prior to exceeding the30-minute core uncovery time limit, then escalation to a GeneralEmergency is not required.1 a. (Reactor S level less than (site specific level) for 30 minutes oFANDb. ANY indication from the Containment Ghallongce Table (see below).2. a. Reactor vesseV/RGS level cannot be moenitored- for 30 mninutes Or longor.Alki lr'k i ;~ A f A k, AK fV +k~ f H~IA~i¶A:IV. A: A: I-:4!: -1e Erratic sour-ee range moenitor- indication-- J10 4 +4XIW4ý AP;*IAQP, A I-q +Fk, q;RP.P. A V.14Mn AR--. Ar. M-A P,4ALQ, IQ Q P-14 92 6but.mna-nitude to inateute core uneoverwANDtner- site speelcifle atcattlons)AKIV irA;^ft+a^r% ;r^rv, +kft tr-.+ ; + t-%k H -r k! k-0 lllU *U S w *l cciw Kl * *1t* *i *ClntainmInt Challenge Tablo89 CONT.AINMENT CLOSURE not established*45 (Explosive mixture) exists inside eontainmentIs UNPLANNED increase in ntainment pressureMonth 20XXTMI 13-101EP-AA-1 009 (Revision XX) | |||
Throm Uilm lalanrl Qtatinn AnnovF:v-alnn M* r-loarTkrea Mile lelenel ~tetiw~n Annay ~v.Inn M.u~l.erTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS* If CONTAINMENT CLOSURE is re establiehd PrGir to eXcoding the 30 minute timelimit, then d-larMati-n of a General Emer t reqUired.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.IMMINENT: The traiectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.This IC addresses the inability to restore and maintain reactor vessel level above thetop of active fuel with containment challenged. This condition represents actual orIMMINENT substantial core degradation or melting with potential for loss of containmentintegrity. Releases can be reasonably expected to exceed EPA Protective ActionGuidelines (PAG. exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a directand unmonitored release of radioactivity to the environment. If CONTAINMENTCLOSURE is re-established prior to exceeding the 30-minute time limit, then declarationof a General Emergency is not required.The existence of an explosive mixture means, at a minimum, that the containmentatmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity. Ittherefore represents a challenge to Containment integrity.In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to acore uncovery could result in an explosive gas mixture in containment. If all installedhydrogen gas monitors are out-of-service during an event leading to fuel claddingdamage, it may not be possible to obtain a containment hydrogen gas concentrationreading as ambient conditions within the containment will preclude personnel access.During periods when installed containment hydrogen gas monitors are out-of-service,operators may use the other listed indications to assess whether or not containment ischallenged.Month 20XXTMI 3-102EP-AA-1 009 (Revision XX) | |||
ThrAma Milo lalanfi Qtafinn AnnovIFvalnn hlir-laarThrna Mila I@kanel ~t~tinn Ann~v Fv.Inn Muuri~~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSIn EAL-2-b, Tthe 30-minute criterion is tied to a readily recognizable event start time(i.e., the total loss of ability to monitor level), and allows sufficient time to monitor,assess and correlate reactor and plant conditions to determine if core uncovery hasactually occurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor reactor vessel/RCS level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the reactor vessel/RCS.These EALs address concems raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Basis Reference(s):1. NEI 99-01 Rev 6, CG12. 1103-11 RCS Water Level Control3. 1101-3 Containment Integrity and Access Limits4. OP-TM-EOP-030, Loss of Decay Heat Removal5. FSAR Sections 5.2, Reactor Building6. FSAR Sections 6.5.2, Hydrogen Monitoring7. FSAR Sections 6.5.3, Hydrogen Generation8. Technical Specifications 3.5.5, Accident Monitoring Instrumentation9. EP-AEL-0501, Estimation of Radiation Monitor Readings Indicating CoreUncovery During Refuel10. 1301-1 Shift and Daily Checks, Data Sheet 3Month 20XXTMI 3-103EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCS6-1Initiating Condition:Loss of reactor vessel/RCS inventory affecting core decay heat removal capability.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note: The Emergency Director should declare the Site Ara EmergencGye.ent promptlyupon determining that the applicable time 30-*miRutes-has been exceeded, or willlikely be exceeded.1. a. Reactor vessel/RCS level unknown for >30 minutes.ANDb. Core uncovery is indicated by ANY of the following:" Table C3 indications of a sufficient magnitude to indicate core uncoverY.OR* Erratic Source Range Neutron Monitor indication.OR" Radiation Monitors RM-G-6 or RM-G-7 reading > 3 R/hr.Table C3 Indications of RCS Leakaqe" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise*" UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.Month 20XXTMI 3-104EP-AA-1 009 (Revision XX) | |||
Fxelon NuclearThree Mile Island tation Annex Exelon Nulea. rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS1 a. CONT.AI NMENT CLOS'U' nrm o.,t | |||
* l.v .w u i 4zrI1MfrND PALN1%P1Ic^f~Lo w w"-"JLý ..... JI%-.--. r-2 a. CONITAINMEArMNlT ostablished.-ANDIP. t elactOr V98seVRG8[-jt. V -'vvn Or i-irv ["Mv-ff level less ihan tienospe~ii eve+yb db dfA 3. a. t oacmor voesscv "b. [#dW-Hvt Or Kidw MVVi-hf ieVo1 c-annot DOP monnorca-e for 30mFinuto or I9ngre.b. Core Uncovery is indicated by ANY of the followina:.. ............ j ....--j ...........0 (Site spccitic r-actiation moenitor-) reactin ereater- tflan (site speeciei value)* ,rratic souree r-ane montotr n IP PWRNIJ1 1 P eLJ" 1UNPLAPNP4L increase int kstte speeciuc sump anwaor tanK) levels of Sufficefemmagnitude to intdicate cor-e uncoever-y" (Other- site specific indieations)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurallv defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.Thi" IC addresses a "ignificant and p,.l.ng.d loss of r.actOF. ...s-eVRCS in..ntor;control and makeup capability loading to IMMINENT fuel damage. .The lost inventorymay be due to a RCS component failure, a loss of configuration control or prolongedboiling of reactor coolant. These conditions entail major failures of plant functionsneeded for protection of the public and thus warrant a Site Area Emergency declaration.Month 20XXTMI 3-105EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSI Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.I Outage/shutdown contingency plans typically provide for re-establishing or verifyingCONTAINMENT CLOSURE following a loss of heat removal or RCS inventory controlfunctions. The differenc e. in the speifi.ed RC5,,'roqact9r Veol levels of EAL" 1 .b and 2.,rolo,-t the fact that with CLOSURE tr- thero ;s a la1probability of a fission pro9duct roloaco to the enyironmont.kin AL-&a1-,tThe 30-minute criterion is tied to a readily recognizable event start time(i.e., the total loss of ability to monitor level), and allows sufficient time to monitor,assess and correlate reactor and plant conditions to determine if core uncovery hasactually occurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor reactor vessel/RCS level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. SumpI and/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the reactor vessel/RCS.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Escalation of the emergency classification level would be via IC CG-16 or ARG1.Basis Reference(s):1. NEI 99-01 Rev 6, CS12. OP-TM-PRF1-0405 RB Sump Level Hi3. 1101-3 Containment Integrity and Access LimitsMonth 20XXTMI 3-106EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS4. 1301-1 Shift and Daily Checks, Data Sheet 35. 1103-11 RCS Water Level Control6. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-107EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA6I-Initiating Condition:Loss of reactor vessel/RCS inventory.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note: The Emergency Director should declare the event Ale--promptly upondetermining that the applicable time 4 6 minutes-has been exceeded, or will likelybe exceeded.1. Loss of reactor vessel / RCS inventory as indicated by RCS level < 0 inches onDraindown Level indicator.OR2. a. Reactor vessel / RCS level unknown for > 15 minutes.ANDb. Loss of reactor vessel / RCS inventory per Table C3 indications.Table C3 Indications of RCS Leakage" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary BId-g. Sump level rise*" UNPLANNED BWST level rise*" UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vesseVRCS inventory.1. Less of reactor invento, y as indicated by level less than (,ite- spcifi,level)2. a. Reactor vosA.ol'RCS_ level cannot be monitored for 15 minutes or longerMonth 20XXTMI 13-108EP-AA-1009 (Revision XX) | |||
Fyplnn NunlAnrThratz Miis 11-r-lnd Rtatinn Annox ExAInn Nunipjr~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSANDb. UNPLANNED increaso in (site cpecific sump and/or tank) levels due toless. Of roactor vocccl/RCS ivno''Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.--This IC addresses conditions that are precursors to a loss of the ability toadequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier).This condition represents a potential substantial reduction in the level of plant safety.EAL #1 BasisF=G: EAL aA lowering of water level below 0 inches on Draindown Level indicator (site-speGifiG. indicates that operator actions have not been successful in restoring andmaintaining reactor vessel/RCS water level. The heat-up rate of the coolant williWiearserise as the available water inventory is reduced. A continuing desiease-drop inwater level will lead to core uncovery.Although related, EAL #1 is concerned with the loss of RCS inventory and not thepotential concurrent effects on systems needed for decay heat removal (e.g., loss of aResidual Heat Removal suction point). An inIreaeerise in RCS temperature caused bya loss of decay heat removal capability is evaluated under IC CA53.EAL #2 Basis,- AI-v,, tThe inability to monitor reactor vessel/RCS level may be caused byinstrumentation and/or power failures, or water level dropping below the range ofavailable instrumentation. If water level cannot be monitored, operators may determinethat an inventory loss is occurring by observing changes in sump and/or tank levels.Sump and/or tank level changes must be evaluated against other potential sources ofwater flow to ensure they are indicative of leakage from the reactor vessel/RCS.The 15-minute duration for the loss of level indication was chosen because it is half ofthe EAL duration specified in IC CS61-If the reactor vessel/RCS inventory level continues to lower, then escalation to Site AreaEmergency would be via IC CS64-.Month 20XXTMI 3-109EP-AA-1009 (Revision XX) | |||
Thraso Mfiilg la@6ne1 Qttinn AnnoyIFyalnn TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSBasis Reference(s):1. NEI 99-01 Rev 6, CA12. OP-TM-PRF1-0405 RB Sump Level Hi3. 1301 -1 Shift and Daily Checks, Data Sheet 34. 1103-11 RCS Water Level Control5. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-110EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCU6-Initiating Condition:UNPLANNED loss of reactor vessel/RCS inventory for 15 minutes or longer.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note: The Emergency Director should declare the Unucual Eventevent promptly upondetermining that the applicable time 45-inutes-has been exceeded, or will likelybe exceeded.1. UNPLANNED loss of reactor coolant results in the inability to restore andmaintain reactor vessel / RCS level to > procedurally established lower limitfor > 15 minutes.OR2. a. Reactor vessel / RCS level unknownANDb. Loss of reactor vessel / RCS inventory per Table 03 indications.Table C3 Indications of RCS Leakage" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise*" UNPLANNED RCDT level rise*" UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.I l_ _ I l= =- II .... .1. ,;io-R W 99 roaorA cooiant rIu-it In reactor ves,-v-68 level IeSeMan areauired lowor limfit for 15 mninutoc Or loG~er.2~. a. ReiacROr vessew:u Ica lve GannoI he manmotau.Month 20XXTMI 3-111EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearThree Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSh. UNPL ANNEDinrocoi (lit-p epoific sump andio tank) leveols.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses the inability to restore and maintain water level to a requiredminimum level (or the lower limit of a level band), or a loss of the ability to monitorreactor vessel/RCS level concurrent with indications of coolant leakage. Either of theseconditions is considered to be a potential degradation of the level of safety of the plant.The procedurally established lower limit is not an operational band established abovethe procedural limit to allow for operator action prior to exceeding the procedural limit,but it is the procedurally established lower limit.Refueling evolutions that deerease-lower RCS water inventory are carefully planned andcontrolled. An UNPLANNED event that results in water level decreasing below aprocedurally required limit warrants the declaration of an Unusual Event due to thereduced water inventory that is available to keep the core covered.EAL #1 Basis-rfecognizes that the minimum required reactor vessel/RCS level can change severaltimes during the course of a refueling outage as different plant configurations andsystem lineups are implemented. This EAL is met if the minimum level, specified for thecurrent plant conditions, cannot be maintained for 15 minutes or longer. The minimumlevel is typically specified in the applicable operating procedure but may be specified inanother controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions torestore and maintain the expected water level. This criterion excludes transientconditions causing a brief lowering of water level.EAL #2 Basis-aAddresses a condition where all means to determine reactor vessel/RCS level havebeen lost. In this condition, operators may determine that an inventory loss is occurringby observing changes in sump and/or tank levels. Sump and/or tank level changesmust be evaluated against other potential sources of water flow to ensure they areindicative of leakage from the reactor vessel/RCS.Continued loss of RCS inventory may result in escalation to the Alert emergencyclassification level via either IC CA6-- or CA53.Month 20XXTMI 3-112EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSBasis Reference(s):1. NEI 99-01, Rev. 6 CUi2. Technical Specification 3.1.6. Leakage3. OP-TM-220-251 RCS Leak Rate Determination Using PPC4. OP-TM-220-252, Primary -To -Secondary Leakrate Determination (OTSGLeakage): Normal Operations5. OP-TM-MAP-C0105 RCS Draindown LVL HI/LO6. OP-TM-PRF1-0405 RB Sump Level HI7. UFSAR 6.4.3, Bases of Leakage Estimate8. 1103-11 RCS Water Level Control9. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-113EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1Initiating Condition:HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:1,2,3,4,5,6, DEmergency Action Level (EAL):1. A notification from the Security Force that a HOSTILE ACTION is occurring orhas occurred within the PROTECTED AREA.AND2. a. ANY Table H1 safety function cannot be controlled or maintained.ORb. Damaae to spent fuel has occurred or is IMMINENTTable H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)" Core Cooling (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)1 A HOS9T" R ACTION in, ennuFiring n has nnnrcmrd w~ithin thN PRQTFCGT-EAD~A ..nna.4a~'4k~. 4kn In4nrsaa;4n nan. *nhi t.k;~ ~.W mV m mYA 13 CANDlk EITuED ,ý*af II'amrik nir,4-. .a--"--I ----!UIV m TVl mOIIOW fflO -ýA&DT TEiCIfe iS~~ar-ar CTflflO .. aoiTo Zo ormaitied." Reaetivity eontroel" Coe e-eealifg" RCS heat remoevalOP.a * .~+/-x~* L.-----a"A I amage to onn Tipin i nla ourrotU oer OFTMI 3-114!MMHN1M1N+.EP-AA-1009 (Revision XX)Month 20XX hrgag% Rfiilg% lainnei tatinn AnndavI::aleln Thr~ MiI~ lolanri Qt~tir~n Ann~v Fv~Inn hi. maI.arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.IMMINENT: The traiectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.This IC addresses an event in which a HOSTILE FORCE has taken physical control ofthe facility to the extent that the plant staff can no longer operate equipment necessaryto maintain key safety functions. It also addresses a HOSTILE ACTION leading to aloss of physical control that results in actual or IMMINENT damage to spent fuel due to1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls,etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot bemaintained.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].Emorgoncy plans and implementing pr.,,durc thorefore, EALS,should not inceororate S-ecurity sensitive information. This includoes infomation thaMonth 20XXTMI 3-115EP-AA-1009 (Revision XX) | |||
Throa Uila Wand qtntinn AnnowFYmlnn | |||
* r MII~a~lkwIIii¥ IQHIIt tim AIII'vA IFvpInn NmItnisarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYmay be adyantagopu6 to a potential advercar,', Such as the padiculaFGRG cocrinaspecific throat Or threat location. Security sensitive infeo~mation should becontained in non public documon9te cuch as the Security Plan.Basis Reference(s):1. NEI 99-01, Rev. 6 HG12. Security and Safeguards Contingency Plan Station Security Plan -Appendix CMonth 20XXTMI 3-116EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS1Initiating Condition:HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:1,2,3,4,5,6, DEmergency Action Level (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.1. A HOSTILEr" ACTION.M is occurr.ing or has ..cur..d within the PROTECTEDAREA as roportod by the (sito cpocific cocurity shift suporvision).Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An obiect directed toward a NPP that could cause concem for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTEDAREA. This event will require rapid response and assistance due to the possibility fordamage to plant equipment.Month 20XXTMI 3-117EP-AA-1009 (Revision XX) | |||
I=yAInn Thrat Milua haIand Rtiation Annax Exellnn Nuclei~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYTimely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Site Area Emergency declaration will mobilize OROresources and have them available to develop and implement public protective actionsin the unlikely event that the attack is successful in impairing multiple safety functions.This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTEDAREA located outside the plant PROTECTED AREA; such an attack should beassessed using IC HAl. It also does not apply to incidents that are accidental events,acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by aHOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters,physical disputes between employees, etc. Reporting of these types of events isadequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR§ 50.72.Emer-gency plans and implementing procoduros aro public documonts; thoreforo, EALsshould not incorporato Sccurity sensitive information. This includes information thatmay be advantageous to a poential andvxers-ary, SUch as, the particulars OA cneig aspecific threat or threat loation. sensitiv. e information should be conta"ined innon public dOcumoents such as the Security Plan.Escalation of the emergency classification level would be via IC HG1.Basis Reference(s):1. NEI 99-01 Rev 6, HS12. Security and Safeguards Contingency Plan Station Security Plan -Appendix CMonth 20XXTMI 3-118EP-AA-1009 (Revision XX) | |||
Thrisi Mfiil Ihunind Station Annex ExeInn NuclazrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA1Initiating Condition:HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threatwithin 30 minutes.Operating Mode Applicability:1,2,3,4,5,6, DEmergency Action Level (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutes fromthe site.1. A HO1STILE ACTION is ....ring or- has o.....ed wit.hn the OWNEROR2. Notification by the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the OWNER CONTROLED AREA.-A validated notification from NRC of an afircraft attack throat within 30 mninutoc ofBasis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An obiect directed toward a NPP that could cause concem for itscontinued operability, reliability, or personnel safety.OWNER CONTROLLED AREA (OCA): The property associated with the station andowned by the company. Access is normally limited to persons entering for officialbusiness.Month 20XXTMI 3-119EP-AA-1009 (Revision XX) | |||
Thriam Uila lalanel Qtafinn AnnovPv--Ionn M ilAg~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYPROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.This IC addresses the occurrence of a HOSTILE ACTION within the OWNERCONTROLLED AREA or notification of an aircraft attack threat. This event will requirerapid response and assistance due to the possibility of the attack progressing to thePROTECTED AREA, or the need to prepare the plant and staff for a potential aircraftimpact.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Alert declaration will also heighten the awareness ofOffsite Response Organizations, allowing them to be better prepared should it benecessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience,or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputesbetween employees, etc. Reporting of these types of events is adequately addressedby other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL #1 addresses the threat from the impact of an aircraft on the plant, and theanticipated arrival time is within 30 minutes. The intent of this EAL is to ensure thatthreat-related notifications are made in a timely manner so that plant Personnel andOROs are in a heightened state of readiness. This EAL is met when the threat-relatedinformation has been validated in accordance with OP-TM-AOP-008, Security Threat /Intrusion.EAL #24 is applicable for any HOSTILE ACTION occurring, or that has occurred, in theOWNER CONTROLLED AREA. This includes any action directed against an ISFSI thatis located outside the plant PROTECTED AREA.Month 20XXTMI 3-120EP-AA-1009 (Revision XX) | |||
Throgs Uila laicknei Qfzbfinn AnniavIFvalnn Mid-as:r~lTkree Mile le6nrI ~totirn Annoy ~velnn hi. .,iorTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYEAL #2 addresses the throat from the impact of an arcraft. an the plant, and theanticipatod arri'.al time is within 30 mninutes. Tho intent of this EAL is to cnsure thtthrAt+_relatAd ification; eare mnade in a timely maRennr so that plant andOR~s are in a heightened State Of readiness. This EAL is mnet w~hen the threat reelattedinformation has boon validated in accordancc with (Site Specific procedure).The NRC Headquarters Operations Officer (HOO) will communicate to the licensee ifthe threat involves an aircraft. The status and size of the plane may be provided byNORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNERCONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected,although not certain, that notification by an appropriate Federal agency to the site wouldclarify this point. In this case, the appropriate federal agency is intended to be NORAD,FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs,should not be unduly delayed while awaiting notification by a Federal agency.EmergencY plans and implementing procedures are public documents; therefore, EiALsshould not incorporate Security sensitive information. This includ-e-s inforFmation thatmay be advantageous to a potential adver-sar;, such as the particul..ars cncming aspecific thre-.at r t~hrea-t lctin Security sensitive information should be contained inon-public- doc-numents such as the Securfity Plan.Escalation of the emergency classification level would be via IC HS1.Basis Reference(s):1. NEI 99-01 Rev 6, HA12. Security and Safeguards Contingency Plan Station Security Plan -Appendix C3. OP-TM-AOP-008, Security Threat / IntrusionMonth 20XXTMI 3-121EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU1Initiating Condition:Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:1,2,3,4,5,6, DEmergency Action Level (EAL):1. Notification of a credible security threat directed at the site as determined PerSY-AA-1 01-132, Security Assessment and Response to Unusual Activities.1 .A SECURITY CONDITION that does not involve a HOSTILE ACT-ION as r-eperted bythe (site specific secur-ity shift superyisioni).OR2. A validated notification from the NRC providing information of an aircraft threat.2. Notification of a cr-edible security threat direeted at the sitcOR3. Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.3. A validatod frm tho NRC proeviding information of an aircraf throat.Basis:SECURITY CONDITION: Any Security Event as listed in the approved securitycontingency plan that constitutes a threat/compromise to site security, threat/risk to sitepersonnel, or a potential degradation to the level of safety of the plant. A SECURITYCONDITION does not involve a HOSTILE ACTIONSAFETY SYSTEM: A system reguired for safe plant operation, cooling down the Plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).Month 20XXTMI 3-122EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEMequipment, and thus represent a potential degradation in the level of plant safety.Security events which do not meet one of these EALs are adequately addressed by therequirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed asHOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Classification of these events will initiate appropriate threat-related notifications to plantpersonnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 addresses the receipt of a credible security threat. The credibility of the threatis assessed in accordance with SY-AA-101-132. rcforone-' (ct .p... securit. chi.toccurringohaocred Traiin onsouri' ont oonfirmation and casciafigoation imaontrollodl duo to the naturo Mof Saegurds and 10 CFr- & 2.Q inoainEAL #2 addresses the threat from the impact of an aircraft on the plant. The NRCHeadquarters Operations Officer (HOO) will communicate to the licensee if the threatinvolves an aircraft. The status and size of the plane may also be provided by NORADthrough the NRC. Validation of the threat is performed in accordance with OP-TM-AOP-008, Security Threat / Intrusion. (sl-'+ .... ". -" ... .th. r"..'+-ofa credible secuity throat. The credibility of tho thre.at. s assessed in aoredance with(site specific procedure).EAL #3 references Security Force.s.. t spe.. fi. secu ftuýrit. h .....4 .... -becausethese are the individuals trained to confirm that a security event is occurring or hasoccurred. Training on security event confirmation and classification is controlled due tothe nature of Safeguards and 10 CFR § 2.39 information.addrossc thb thr-oat from theo pla-t The d-arters Operatio-n ; Offier. )'.,;llplane mayl alson be pro'.'j- iso by NORAM throughli ti-hejr HRO.0aldation0 of the- threat iEmFergency plans and implementing procedu wre are p-ublic documents; therefore, EALsMonth I 2OX.. ....... .... TM.. ..... 3-.. .12 EP.... A -..... 00 (Revision .. .X)...Month 20XXTMI 3-123EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYSFGUuIu iu nGI~upiL RGPFdeeUFiny eurWy~ iintorwtten. -t-HI AGIu-iuuu IinuIAWME"iu twmay be advantageous to a potential advorsar.., cUch a. the c. .ing aSepoiGctra rtra oain Socurity sensitive information should bo containod inno public documonts cuch as tho Socurity Plan.Escalation of the emergency classification level would be via IC HA1.Basis Reference(s):1. NEI 99-01 Rev 6, HU12. SY-AA-101 -132, Security Assessment and Response to Unusual Activities3. Security And Safeguards Contingency Plan Station Security Plan -Appendix CMonth 20XXTMI 3-124EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS26Initiating Condition:Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:1,2,3, 4,5,6, DEmergency Action Level (EAL):Note: The Emergency Director should declare the Sit-e Area Em,, promptlyupon determining that (Site .p.ific nb---. '-the applicable hasbeen exceeded, or will likely be exceeded.1. A Control Room evacuation has resulted in olant control beina transferred from theControl Room to the Remote Shutdown (RSD) stations.AND2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.Table H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* Core Cooling (ability to cool the core)" RCS Heat Removal (ability to maintain heat sink)1. a. An event has resulted in plant control being tra;ns~forre-d- panels andloacontro stations). from the Control Room to (Sit Specifi remote ShutdonANDb. Control of ANY of the following key Safety fUnctienrs is not reostablishedwithin (sto specific number of mninutes)." Reactivity controlA r'.r -;1" rDIACam / iD\ MIA= I201 E IA/0I* RCS heat remov~al..... L ..... JMonth 20XXTMI 3-125EP-AA-1009 (Revision XX) | |||
Thrgg% RAilim lalonrl Qfatinn AnnmvPI=alrn N,,-Ilmar.... -- .w... ..s4. .ts4t.. a -n U. .n s.. .aTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:The time Period to establish control of the plant starts when either:a. Control of the plant is no longer maintained in the Main Control RoomORb. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations, and the control of a key safety function cannot bereestablished in a timely manner. The failure to gain control of a key safety functionfollowing a transfer of plan control to alternate locations is a precursor to a challenge toone Or moreajy fission product barriers within a relatively short period of time.The determination of whether or not "control" is established at the remote safeshutdown location(s) is based on Emergency Director judgment. The EmergencyDirector is expected to make a reasonable, informed judgment within (the site-spe-i-f*time f-. .a.sfeo 15 minutes whether or not the operating staff has control of key safetyfunctions from the remote safe shutdown location(s).Escalation of the emergency classification level would be via IC FG1 or CG64-.Basis Reference(s):1. NEI 99-01, Rev 6 HS62. OP-TM-EOP-020, Cooldown from Outside the Control RoomMonth 20XXTMI 3-126EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA26Initiating Condition:Control Room evacuation resulting in transfer of plant control to alternate locations.Operating Mode Applicability:1, 2,3,4,5,6, DEmergency Action Level (EAL):An-eyentA Control Room evacuation has resulted in plant control being transferredfrom the Control Room to the Remote Shutdown (RSD) stations. '.(.ite-.peGi...remote shutdown pano lhand- control stations).Basis:This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations outside the Control Room. The loss of the ability to controlthe plant from the Control Room is considered to be a potential substantial degradationin the level of plant safety.Following a Control Room evacuation, control of the plant will be transferred to alternateshutdown locations. The necessity to control a plant shutdown from outside the ControlRoom, in addition to responding to the event that required the evacuation of the ControlRoom, will present challenges to plant operators and other on-shift personnel.Activation of the ERO and emergency response facilities will assist in responding tothese challenges.Escalation of the emergency classification level would be via IC HS26.Basis Reference(s):1. NEI 99-01, Rev 6 HA62. OP-TM-EOP-020, Cooldown from Outside the Control RoomMonth 20XXTMI 3-127EP-AA-1009 (Revision XX) | |||
Three Mile IAsland Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU34Initiating Condition:FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:1,2,3,4,5,6, DEmergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Eventevent promptlyupon determining that the applicable time has been exceeded, or will likelybe exceeded.1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of thefollowing FIRE detection indications:" Report from the field (i.e., visual observation)" Receipt of multiple (more than 1) fire alarms or indications" Field verification of a single fire alarmOR2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indicationsof a FIRE).ANDb. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.OR3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes ofthe initial report, alarm or indication.OR4 A FIRE within the plant PROTECTED AREA that requires firefighting support byan offsite fire response agency to extinguish.Month 20XXTMI 3-128EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYTable H2 Vital Areas* Reactor Building* Intake Building0 Intermediate Building* Control Tower* Auxiliary and Fuel Handling Buildings* 1 A and 1 B Diesel Generator Buildings* BWST* CST* ILBIB t .I | |||
* Il "(1) a. A & Imit- us P1444 emtinaulshed witnin 113-minutoS Of AP* of the TollewingFR-iit aetection iAG1cGAuons:0 ý f~rf t f *k~t f ,h^ Col b~ a~. v .cua ah-raonwA* 55 .S S S tfl St. S .S ~S .V S- ---S V LASS%~* 5/vAA SI34LJt:XSS USAPS S/SStJ UA SLin nweRem vu ...ILIUI elt a3 singleu 1111 aIlaANDl.w-zrv(site-spocifi list of plant rooms or arcas)AJE __ \;.I a. eODDIO or a single Tra naram i.e.. no Gfmer inoucamon of a ri-1~i9.......... I"ANDb. Th- FIRE is locAted Within ANY of thA fo.lloinn ,lant ro omsFo areas.(6itc spocific li6t of plant rooms Or areas)AiNDG. The e;stcno of -a FIRE is not Yrificd wA~ithin 30 minutes of alarm (3) A FIRE within the plant ,r -pnt with an ISFS. outside the plant;rottedAfera l PROTECTED AREA not etinguished within 60minutes ofti nitial report, alarm Or indication.* AIm I | |||
* al l *C41 1'- HI-IH AAIRfllf tfA flIflt or 1541i-Si Un Pl nantr. mw!T an ii-Sif ni imrin MRl~ WantfI "!Dv ... .-',*i A ..- w-¶ DD 1 ýwT f ADýA *k.w '.I~i~ -5 *rmkVLI NUr~,S w-h R wý c ,offsiot- fire response to ..v;-,a ui;hil--IMonth 20XXTMI 3-129EP-AA-1009 (Revision XX) | |||
ThrimAm Wig& laltanei Qfnfirn AnnimvWL~v,'Innn kNilr-ImorTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippinqdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of apotential degradation of the level of safety of the plant.EAL #1 BasisThe intent of the 15-minute duration is to size the FIRE and to discriminate againstsmall FIRES that are readily extinguished (e.g., smoldering waste paper basket). Inaddition to alarms, other indications of a FIRE could be a drop in fire main pressure,automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial firealarm, indication, or report. For EAL assessment purposes, the emergency declarationclock starts at the time that the initial alarm, indication, or report was received, and notthe time that a subsequent verification action was performed. Similarly, the fire durationclock also starts at the time of receipt of the initial alarms, indication or report.EAL #2 BasisThis-EAL-aAddresses receipt of a single fire alarm, and the existence of a FIRE is notverified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt,operators will take prompt actions to confirm the validity of a single fire alarm. For EALassessment purposes, the 30-minute clock starts at the time that the initial alarm wasreceived, and not the time that a subsequent verification action was performed.A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipmentfailure or a spurious activation, and not an actual FIRE. For this reason, additional timeis allowed to verify the validity of the alarm. The 30-minute period is a reasonableamount of time to determine if an actual FIRE exists; however, after that time, andabsent information to the contrary, it is assumed that an actual FIRE is in progress.If an actual FIRE is verified by a report from the field, then EAL #1 is immediatelyapplicable, and the emergency must be declared if the FIRE is not extinguished within15-minutes of the report. If the alarm is verified to be due to an equipment failure or aMonth 20XXTMI 3-130EP-AA-1009 (Revision XX) | |||
NuclearThreIeI MilIe IVsland Station Annex FI n NucIeasrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYspurious activation, and this verification occurs within 30-minutes of the receipt of thealarm, then this EAL is not applicable and no emergency declaration is warranted.EAL #3 BasisIn addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plantPROTECTED AREA not extinguished within 60-minutes may also potentially degradethe level of plant safety. This basis extends to a FIRE ccurr'ing within thcPROTECTED AREA -ofn SFSI lo,,,,,,,ated ,.,id.-,,e the plant PROTECTED AREA.[Sentence for plants with an ISESI outside the plant P-roterted AnreaEAL #4 BasisIf a FIRE within the plant or ISFS, [forplants with an ISFSI the plant PrtoctodAr-ea]-PROTECTED AREA is of sufficient size to require a response by an offsitefirefighting agency (e.g., a local town Fire Department), then the level of plant safety ispotentially degraded. The dispatch of an offsite firefighting agency to the site requiresan emergency declaration only if it is needed to actively support firefighting effortsbecause the fire is beyond the capability of the Fire Brigade to extinguish. Declarationis not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix RAppendix R to 10 CFR 50, states in part:Criterion 3 of Appendix A to this part specifies that "Structures, systems, andcomponents important to safety shall be designed and located to minimize,consistent with other safety requirements, the probability and effect of fires andexplosions."When considering the effects of fire, those systems associated with achievingand maintaining safe shutdown conditions assume major importance to safetybecause damage to them can lead to core damage resulting from loss of coolantthrough boil-off.Because fire may affect safe shutdown systems and because the loss of functionof systems used to mitigate the consequences of design basis accidents underpost-fire conditions does not per se impact public safety, the need to limit firedamage to systems required to achieve and maintain safe shutdown conditions isgreater than the need to limit fire damage to those systems required to mitigatethe consequences of design basis accidents.In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of1-hour fire barriers for the enclosure of cable and equipment and associated non-safetycircuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify asingle alarm is well within this worst-case 1-hour time period.Month 20XXTMI 3-131EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYDepending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA26 or MA5SA9.Basis Reference(s):1. NEI 99-01, Rev 6 HU42. FSAR Figure 2.1-3, Extended Plot Plan TMINS3. FSAR Section 5.1, Class I Structures, Components, and Systems4. OP-TM-AOP-001, Fire5. OP-TM-EOP-020, Cooldown Outside of Control RoomMonth 20XXTMI 3-132EP-AA-1009 (Revision XX) | |||
Throm Uila lalanri Qfafinn AnnovI::alnn NnMalrTham. Mum IoImnrI Qtmtir~n Annmv Fvmlnn i~ImirIm~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU42Initiating Condition:Seismic event greater than OBE levels.Operating Mode Applicability:1,2,3,4,5,6, DEmergency Action Level (EAL):Seismic event > Operating Basis Earthquake (OBE) as indicated by seismic AlarmsPRF-1-3 Operating Basis Earthquake and PRF-1-2 Threshold Seismic Condition.Siw;n-m eveont groatcr than Oporating Basis Earthquak, (,BE) as indicatod by:.a. (cito- sepoific indic-ation that.asii ovent met Or oxcooedod 0OBE limits)Basis:This IC addresses a seismic event that results in accelerations at the plant site greaterthan those specified for an Operating Basis Earthquake (OBE)'. An earthquake greaterthan an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have nosignificant impact on safety-related systems, structures and components; however,some time may be required for the plant staff to ascertain the actual post-eventcondition of the plant (e.g., performs walk-downs and post-event inspections). Giventhe time necessary to perform walk-downs and inspections, and fully understand anyimpacts, this event represents a potential degradation of the level of safety of the plant.Event verification with external sources should not be necessary during or following anOBE. Earthquakes of this magnitude should be readily felt by on-site personnel andrecognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).The Shift Manager or Emergency Director may seek external verification if deemedappropriate (e.g., a call to the USGS, check internet news sources, etc.); however, theverification action must not preclude a timely emergency declaration.Depending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA26 or HA5SA".An OBE is vibratory ground motion for which those features of a nuclear power plantnecessary for continued operation without undue risk to the health and safety of thepublic will remain functional.An SSE is vibratory ground motion for which certain (generally, safety-related)structures, systems, and components must be designed to remain functional.Month 20XXTMI 3-133EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis Reference(s):1. NEI 99-01, Rev 6 HU22. OP-TM-AOP-003, Earthquake3. PRF 1-3 Operating Bases Earthquake4. PRF 1-2 Threshold Seismic EventMonth 20XXTMI 3-134EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5Initiating Condition:Gaseous release impeding access to equipment necessary for normal plant operations,cooldown or shutdown.Operating Mode Applicability:1,2,3,4,5,6, DEmergency Action Level (EAL):Note: If the eauipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emeraencv classification iswarranted.1. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area.Table H3Areas with Entry Related Mode ApplicabilityArea Entry Related ModeApplicabilityReactor Building* Modes 4. 5. and 6Intermediate Building* Modes 4, 5, and 6Auxiliary Building* Modes 4, 5, and 6Fuel Handling Building* Modes 4, 5, and 6*Areas required to establish shutdown coolingAND2. Entrv into the room or area is prohibited or impededNote: It the equipment In the listed oom or arca was areadyinoperable Or out1e e thc event occurred, then no- omergency classification isWa~rated.-(1) a. Release of a toxiccroie asphyxiant or: flammable gas into any of thefollowin pln-ooSo riasOR!.' ...-10-J --J - --........... ;J.L ----X .... I=,IL--J =--J--ýWTYZTZ ýým ý'&' ZI.r, ., IMonth 20XXTMI 3-135EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYb. intry into the rFOom O area is prohibited or impeded.Basis:This IC addresses an event involving a release of a hazardous gas that precludes orimpedes access to equipment necessary to transition the plant from normal plantoperation to cooldown and shutdown as specified in normal plant proceduresma.itai.no.mal plant operamtio o requed for a no.mal plant coodown and chutd -- ..n... Thiscondition represents an actual or potential substantial degradation of the level of safetyof the plant.Table H3 is a list of plant rooms or areas with entry-related mode applicability thatcontain equipment which require a manual/local action necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal operatingprocedures (establish shutdown cooling), where if this action is not completed the plantwould not be able to attain and maintain cold shutdown.This Table does not include rooms or areas for which entry is required solely to performactions of an administrative or record keeping nature (e.g., normal rounds or routineinspections).This Table does not include the Control Room since adequate engineered safety/designfeatures are in place to preclude a Control Room evacuation due to the release of ahazardous gas.An Alert declaration is warranted if entry into the affected room/area is, or may be,procedurally required during the plant operating mode in effect and the gaseous releasepreclude the ability to place shutdown cooling in serviceat the time of the gaseousrelease. The emergency classification is not contingent upon whether entry is actuallynecessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires theEmergency Director's judgment that the gas concentration in the affected room/area issufficient to preclude or significantly impede procedurally required access. Thisjudgment may be based on a variety of factors including an existing job hazard analysis,report of ill effects on personnel, advice from a subject matter expert or operatingexperience with the same or similar hazards. Access should be considered as impededif extraordinary measures are necessary to facilitate entry of personnel into the affectedroom/area (e.g., requiring use of protective equipment, such as SCBAs, that is notroutinely employed).An emergency declaration is not warranted if any of the following conditions apply.The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the timeof the gaseous release). For example, the plant is in Mode 1 when the gaseousMonth 20XXTMI 3-136EP-AA-1 009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYrelease occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4." The gas release is a planned activity that includes compensatory measures whichaddress the temporary inaccessibility of a room or area (e.g., fire suppressionsystem testing)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerouslevels. Most commonly, asphyxiants work by merely displacing air in an enclosedenvironment. This reduces the concentration of oxygen below the normal level ofaround 19%, which can lead to breathing difficulties, unconsciousness or even death.I This EAL does not apply to firefighting activities that generate smoke or thatautomatically or manually activate a fire suppression system in an area.I Escalation of the emergency classification level would be via Recognition Category BA,C or F ICs.Basis Reference(s):1. NEI 99-01, Rev 6 HA52. FSAR Figure 2.1-3, Extended Plot Plan TMINS3. FSAR Section 5.1, Class I Structures, Components, and Systems4. NEI 99-01, Rev. 5 HA35. OP-TM-406-901, Hazardous Material Release6. AR-660892, Station Halon and IDLH Evaluations7. 29CFR1910.134(b) and 29CFR1910.134(d)(2)(iii)Month 20XXTMI 3-137EP-AA-1009 (Revision XX) | |||
Throm Uila Wand Qtatinn AnnovFvl=eml Kbitl-harTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU63Initiating Condition:Hazardous EventOperating Mode Applicability:1, 2,3,4,5,6, DEmergency Action Level (EAL):Note: EAL #4 does not applv to routine traffic impediments such as foq. snow, ice, orvehicle breakdowns or accidents.1. Tornado strike within the PROTECTED AREA.OR2. Internal room or area floodinq of a magnitude sufficient to require manual orautomatic electrical isolation of a SAFETY SYSTEM component required byTechnical Specifications for the current operating mode.OR3. Movement of personnel within the PROTECTED AREA is impeded due to an offsiteevent involvina hazardous materials (e.a., an offsite chemical spill or toxic aasrelease).OR4. A hazardous event that results in on-site conditions sufficient to prohibit the plantstaff from accessina the site via Dersonal vehicles.OR5. Abnormal river water level at the intake Pump and Screen House. as indicated byEITHER:a. > 300 ft. el. (high level)ORb. < 274 ft. el. (low level)KI M AI 4J'Url nA r4n nrnt nrm 1rn*.4;n ; A; ml- 1 4- -. ma .to UM "me% " K----I- "- -" " M e " p " r tf~, rf t----I--:--I-- L --- --I-Jav a narln ate.I----- --~-------%.Ii III^ ^/ ^ pt Ir^^ A ti IPll14IA ~ .....Z..~...L.. 4L.. M^ r1r-r-*r~rý A Mr-~ Ak -Li iU i ru .uii i M1 tWHIM, btHMI W~tH, t iuMonth 20XXTMI 3-138EP-AA-1009 (Revision XX) hroo Uila halsand Rtntinn AnnoyThi. MIuli Iv v Vt~n A Exn NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY(2) Irt-,.,.-- re mOrT, ar; -... e-,,-,,.;,,g of a magntud ; ,I ..ft,,;n-, to ..... e ....I,,automatic A-elotrical isoelation of a SAFETYý SYSTEM Gompnn neded for thOcurrent operating moede-.(3) Movement o-f personnel within the PROTECTED AREA is impeded duo to anoffeito eyent in.oighzardous materials (e.g., an offeito chemical spill Or toxiG_(4) A hazardouc event that results in on-site conditions suffic-ient to prohibit the plantstaff frome _accessing the site via personal vehicles.(5) (Site-specific of natural Or thngical hazard events)Basis:PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.SAFETY SYSTEM: A system required for safe plant ogeration. cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretygically systems classified as safety-related.This IC addresses hazardous events that are considered to represent a potentialdegradation of the level of safety of the plant.EAL #1 -Basis-aAddresses a tornado striking (touching down) within the Protected Area.EAL #2 BasisaAddresses flooding of a building room or area that results in operators isolating powerto a SAFETY SYSTEM component due to water level or other wetting concerns.Classification is also required if the water level or related wetting causes an automaticisolation of a SAFETY SYSTEM component from its power source (e.g., a breaker orrelay trip). To warrant classification, operability of the affected component must berequired by Technical Specifications for the current operating mode. Manual isolation ofpower to a SAFETY SYSTEM component as a result of leakage is an event of lesserimpact and would be expected to cause small and localized damage. The consequenceof this type of event is adequately assessed and addressed in accordance withTechnical Specifications.EAL #3 BasisaAddresses a hazardous materials event originating at an offsite location and ofsufficient magnitude to impede the movement of personnel within the PROTECTEDAREA.Month 20XXTMI 3-139EP-AA-1009 (Revision XX) | |||
Three Mile IRsland Station Annex Exelon NuceIarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYEAL #4 BasisaAddresses a hazardous event that causes an on-site impediment to vehicle movementand significant enough to prohibit the plant staff from accessing the site using personalvehicles. Examples of such an event include site flooding caused by a hurricane, heavyrains, up-river water releases, dam failure, etc., or an on-site train derailment blockingthe access road.This EAL is not intended to apply to routine impediments such as fog, snow, ice, orvehicle breakdowns or accidents, but rather to more significant conditions such as theHurricane Andrew strike on Turkey Point in 1992, the flooding around the CooperStation during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in2011.EAL #5 Basis:The level of the Susquehanna River is approaching flood stage; flood stage is definedas 302 ft el. at the Intake Pump and Screen House.A low river water condition below 274 ft el. requires a Technical Specification 3.0.1 plantshutdown per OP-TM-AOP-005 and is a precursor to a more serious condition.EAL= #5 addroccec (site spccific descriptiGPn).Escalation of the emergency classification level would be based on ICs in RecognitionCategories RA, F, MSj H or C.Basis Reference(s):1. NEI 99-01, Rev 6 HU32. OP-TM-AOP-005 River Water System Failures3. OP-TM-AOP-002, Flood4. OP-TM-AOP-004, Tornado / High WindsMonth 20XXTMI 3-140EP-AA-1 009 (Revision XX) | |||
Thrmn~ M.ild li@Inni Q*fafinnu AnngavI=v-mlnn M"rAmarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a GENERAL EMERGENCY.Operating Mode Applicability:1,2,3, 4,5,6, DEmergency Action Level (EAL):(44 Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or IMMINENTsubstantial core degradation or melting with potential for loss of containment integrity orHOSTILE ACTION that results in an actual loss of physical control of the facility.Releases can be reasonably expected to exceed EPA Protective Action Guidelineexposure levels offsite for more than the immediate site area.Basis:IMMINENT: The traiectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy eguipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for aGeneral Emergency.Basis Reference(s):1. NEI 99-01, Rev 6 HG7Month 20XXTMI 3-141EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a SITE AREA EMERGENCY.Operating Mode Applicability:1,2,3, 4,5,6, DEmergency Action Level (EAL):M( Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or likely major failuresof plant functions needed for protection of the public or HOSTILE ACTION that results inintentional damage or malicious acts, (1) toward site personnel or equipment that couldlead to the likely failure of or, (2) that prevent effective access to equipment needed forthe protection of the public. Any releases are not expected to result in exposure levelswhich exceed EPA Protective Action Guideline exposure levels beyond the siteboundary.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for a SiteArea Emergency.Basis Reference(s):1. NEI 99-01, Rev 6 HS7Month 20XXTMI 3-142EP-AA-1 009 (Revision XX) | |||
Throm Milts Weandi Qtatinn Anno~vFwi::nl N, MplarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an ALERT Operating Mode Applicability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):(-1) Other conditions exist which, in the judgment of the Emergency Director, indicatethat events are in progress or have occurred which involve an actual or potentialsubstantial degradation of the level of safety of the plant or a security event thatinvolves probable life threatening risk to site personnel or damage to site equipmentbecause of HOSTILE ACTION. Any releases are expected to be limited to smallfractions of the EPA Protective Action Guideline exposure levels.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anAlert.Basis Reference(s):1. NEI 99-01, Rev 6 HA7Month 20XXTMI 3-143EP-AA-1009 (Revision XX) | |||
Thnag Migla Ieanei Qtntiv~n AnnovI:valenn Mir-loarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an (NO),UNUSUAL EVENT.Operating Mode Applicability:1,2,3, 4,5,6, DEmergency Action Level (EAL):I (-M1 Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which indicate a potential degradation ofthe level of safety of the plant or indicate a security threat to facility protection has beeninitiated. No releases of radioactive material requiring offsite response or monitoring areexpected unless further degradation of safety systems occurs.Basis:This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anEVENT.Basis Reference(s):1. NEI 99-01, Rev 6 HU7Month 20XXTMI 3-144EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisEmergency Action Level Technical Basis Page IndexGeneral Site Area Alert Unusual EventEAL Pg. EAL Pg. EAL Pg. EAL Pg.RG1 3-32 RS1 3-34 RA1 3-36 RU1 3-39RA2 3-42 RU2 3-44RA3 3-46 RU3 3-49FG1 3-50 FS1 3-51 FA1 3-52 1Fuel Clad RCS ContainmentFC1 3-53 RC1 3-59 CT1 3-64FC2 3-54 RC2 3-61 CT2 3-67FC3 3-56 RC3 3-62 CT3 3-68CT4 3-69FC5 3-58 RC5 3-63 CT5 3-75MG1 3-76 MS1 3-78 MA1 3-80 MUW 3-82MG2 3-83 MS2 3-85MS3 3-86 MA3 3-88 MU3 3-90MA4 3-93 MU4 3-95MA5 3-97MU6 3-99MU7 3-101MU8 3-103CA1 3-105 CU1 3-107C A 2 3 -10 9 _ _ _ _-1 1____ _ _ ____ __ ___ CU3 3-111CU4 3-113CA5 3-115 CU5 3-118CG6 3-120 CS6 3-124 CA6 3-127 CU6 3-129HG1 3-131 HS1 3-133 HA1 3-135 HU1 3-138HS2 3-140 HA2 3-142HU3 3-143HU4 3-147HA5 3-148HU6 3-151HG7 3-154 HS7 3-155 HA7 3-156 HU7 3-157Month 20XXTMI 3-31EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRGIInitiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRem TEDEor 5000 mRem thyroid CDE.Operating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.OR2. Dose assessment Using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected to continuefor > 60 minutes.ORb. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for60 minutes of inhalation.Month 20XXTMI 3-32EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRG1 (cont)Emergency Action Level (EAL) (cont):Table R1 Effluent Monitor ThresholdsEffluent Monitor General EmergencyRM-G-25 (Cond Offgas) 9.53 E+06 mR/hrRM-A-8GH (Station Vent) 3.09 E+05 cpmRM-G-24 (RB Purge) 5.55 E+05 mRlhrRM-A-14 (ESF Vent) 6.66 E+02 uCi/ccBasis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to the EPA Protective Action Guides (PAGs). Itincludes both monitored and un-monitored releases. Releases of this magnitude willrequire implementation of protective actions for the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at the EPA PAG of 1000 mRem while the 5000 mRem thyroid CDEwas established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroidCDE.Basis Reference(s):1. NEI 99-01 Rev 6, AG12. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile Island3. EP-AA-112-500 Emergency Environmental Monitoring4. FSAR Section 11.4 Radiation Monitoring System5. EP-AA-1 10-200 Dose Assessment6. EP-AA-1 10-201 On Shift Dose AssessmentMonth 20XXTMI 3-33EP-AA-1 009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRS1Initiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDEor 500 mRem thyroid CDE.Operating Mode Applicability:1, 2,3, 4,5,6, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.1. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 15 minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 100 mRem TEDEORb. > 500 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >100 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for60 minutes of inhalation.Month 20XXTMI 3-34EP-AA-1009 (Revision XX) | |||
N rThree MileIs land Station Annex FvAinn NuleIAarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRS1 (cont)Emergency Action Level (EAL) (cont):Table RI Effluent Monitor ThresholdsEffluent Monitor Site Area EmergencyRM-G-25 (Cond Offgas) 9.53 E+05 mR/hrRM-A-8GH (Station Vent) 3.09 E+04 cpmRM-G-24 (RB Purge) 5.55 E+04 mR/hrRM-A-14 (ESF Vent) 6.66 E+01 uCi/ccBasis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).It includes both monitored and un-monitored releases. Releases of this magnitude areassociated with the failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at 10% of the EPA PAG of 1000 mRem while the 500 mRemthyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDEand thyroid CDE.Escalation of the emergency classification level would be via IC RG1.Basis Reference(s):1. NEI 99-01 Rev 6, AS12. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile Island3. EP-AA-1 12-500 Emergency Environmental Monitoring4. FSAR Section 11.4 Radiation Monitoring System5. EP-AA-1 10-200 Dose Assessment6. EP-AA-1 10-201 On Shift Dose AssessmentMonth 20XXTMI 3-35EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA1Initiating Condition:Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRemTEDE or 50 mRem thyroid CDE.Operating Mode Applicability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 50 mRem CDE ThyroidOR3. Analysis of a liquid effluent sample indicates a concentration or release rate thatwould result in doses greater than EITHER of the following at or beyond the siteboundarya. 10 mRem TEDE for 60 minutes of exposureORb. 50 mRem CDE Thyroid for 60 minutes of exposureORMonth 20XXTMI 3-36EP-AA-1009 (Revision XX) | |||
Thran Win hmhanrl -Qfnfien AnnoyI:vnlrn KI"t-InmrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA1 (cont)Emergency Action Level (EAL) (cont):4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate > 50 mRem CDEThyroid for 60 minutes of inhalation.Table R1 Effluent Monitor ThresholdsEffluent Monitor AlertRM-G-25 (Cond Offgas) 9.53 E+04 mR/hrRM-A-8GH (Station Vent) 3.09 E+03 cpmRM-G-24 (RB Purge) 5.55 E+03 mR/hrRM-A-14 (ESF Vent) 6.66 E+00 uCi/ccBasis:This IC addresses a release of gaseous or liquid radioactivity that results in projected oractual offsite doses greater than or equal to 1% of the EPA Protective Action Guides(PAGs). It includes both monitored and un-monitored releases. Releases of thismagnitude represent an actual or potential substantial degradation of the level of safety ofthe plant as indicated by a radiological release that significantly exceeds regulatory limits(e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at 1% of the EPA PAG of 1000 mRem while the 50 mRem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Escalation of the emergency classification level would be via IC RS1.Month 20XXTMI 3-37EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA1 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, AA12. OP 1101-2.1 Radiation Monitoring System Setpoints3. FSAR Section 11.4 Radiation Monitoring System4. OP-TM-MAP-CO101, Radiation Level HI5. EP-EAL-0609, Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile Island6. EP-EAL-0616, Revision 0, Three Mile Island Criteria for Choosing RadiologicalLiquid Effluent EAL Threshold Values7. EP-EAL-0622, Revision 0, Three Mile Island Criteria for Choosing RadiologicalGaseous Effluent EAL Threshold Values for Waste Gas Decay TanksMonth 20XXTMI 3-38EP-AA-1 009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU1Initiating Condition:Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60minutes or longer.Operating Mode Applicability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.1. Reading on ANY of the following effluent monitors > 2 times alarm setpointestablished by a current radioactive release discharge permit for > 60 minutes." RM-L-6, Radwaste Discharge" RM-L-12, IWTS / IWFS Discharge" RM-A-7, Waste Gas Decay Tank Discharge" Discharge Permit specified monitorOR2. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 60 minutes.OR3. Confirmed sample analyses for gaseous or liquid releases indicate concentrationsor release rates > 2 times ODCM Limit with a release duration of > 60 minutes.Month 20XXTMI 3-39EP-AA-1009 (Revision XX) rThree Mile~ Island Staition Annex ExalInn NuclerIArTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRUI (cont)Emergency Action Level (EAL) (cont):Table R1 Effluent Monitor ThresholdsEffluent Monitor Unusual EvetRM-G-25 (Cond Offgas) 1.09 E+03 mR/hrRM-A-8GH (Station Vent) 7.03 E+01 cpmRM-G-24 (RB Purge) 6.34 E+01 mR/hrRM-A-14 (ESF Vent) 7.60 E-02 uCi/ccBasis:This IC addresses a potential decrease in the level of safety of the plant as indicated by alow-level radiological release that exceeds regulatory commitments for an extendedperiod of time (e.g., an uncontrolled release). It includes any gaseous or liquidradiological release, monitored or un-monitored, including those for which a radioactivitydischarge permit is normally prepared.Nuclear power plants incorporate design features intended to control the release ofradioactive effluents to the environment. Further, there are administrative controlsestablished to prevent unintentional releases, and to control and monitor intentionalreleases. The occurrence of an extended, uncontrolled radioactive release to theenvironment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.Releases should not be prorated or averaged. For example, a release exceeding 4 timesrelease limits for 30 minutes does not meet the EAL.EAL #1 BasisThis EAL addresses radioactivity releases that cause effluent radiation monitor readingsto exceed 2 times the limit established by a radioactivity discharge permit. This EAL willtypically be associated with planned batch releases from non-continuous releasepathways (e.g., radwaste, waste gas).The effluent monitors listed are those normally used for planned discharges. If adischarge is performed using a different flowpath or effluent monitor other than thoselisted (e.g., a portable or temporary effluent monitor), then the declaration criteria will bebased on the monitor specified in the Discharge Permit.EAL #2 BasisThis EAL addresses normally occurring continuous radioactivity releases from monitoredgaseous effluent pathways.Month 20XXTMI 3-40EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRUl (cont)Basis (cont):EAL #3 BasisThis 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 RAI.Basis Reference(s):1. NEI 99-01 Rev 6, AU12. OP 1101-2.1 Radiation Monitoring System Setpoints3. FSAR Section 11.4 Radiation Monitoring System4. Offsite Dose Calculation (ODCM)5. OP-TM-MAP-CO101, Radiation Level HI6. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile IslandMonth 20XXTMI 3-41EP-AA-1009 (Revision XX) | |||
Three Mile kIslnd Station Annexv ExaInn Miiu-lpagrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA2Initiating Condition:Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel asindicated by ANY Table R2 Radiation Monitor reading >1000 mRem/hrTable R2Radiation MonitorsRMS Area Monitored ModeRM-G-9 FHB Bridge Rad Monitor ALLRM-G-6 RB Auxiliary Bridge Rad Monitor 5, 6RM-G-7 RB Main Bridge Rad Monitor 5, 6Basis:REFUELING PATHWAY: all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.IMMINENT: The trajectory of events or conditions is such that an EAL will be met within arelatively short period of time regardless of mitigation or corrective actions.This IC addresses events that have caused IMMINENT or actual damage to an irradiatedfuel assembly. These events present radiological safety challenges to plant personneland are precursors to a release of radioactivity to the environment. As such, theyrepresent an actual or potential substantial degradation of the level of safety of the plant.Month 20XXTMI 3-42EP-AA-1009 (Revision XX) | |||
Thran Milo lalnnrl Qfnfinn AnnoyIPvln~n Thr~a MiI~ I@6nv4 ~t2*inn Ann~v Fvalnn Nuu-I~~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA2 (cont)Basis (cont):EAL #1 Basis:This EAL escalates from RU2 in that the loss of level, in the affected portion of theREFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery ofirradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visualobservation (e.g., reports from personnel or camera images), as well as significantchanges in water and radiation levels, or other plant parameters. Computational aidsmay also be used (e.g., a boil-off curve). Classification of an event using this EAL shouldbe based on the totality of available indications, reports and observations.While an area radiation monitor could detect a rise in a dose rate due to a lowering ofwater level in some portion of the REFUELING PATHWAY, the reading may not be areliable indication of whether or not the fuel is actually uncovered. To the degreepossible, readings should be considered in combination with other available indications ofinventory loss.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.EAL #2 Basis:This EAL addresses a release of radioactive material caused by mechanical damage toirradiated fuel. Damaging events may include the dropping, bumping or binding of anassembly, or dropping a heavy load onto an assembly. A rise in readings on radiationmonitors should be considered in conjunction with in-plant reports or observations of apotential fuel damaging event (e.g., a fuel handling accident).Escalation of the emergency would be based on either Recognition Category R or C ICs.Basis Reference(s):1. NEI 99-01 Rev 6, AA22. Operating Procedure OP-TM-MAP-C0105 RCS Draindown LVL HI/LO3. OP-TM-MAP-CO101, Radiation Level HI4. UFSAR, Section 14.2.2.1 -"Fuel Handling Accident"5 Technical Specification 3.8.11 (Reactor Cavity Level)6. Operating Procedure OP 1101-2.1 Radiation Monitoring System SetpointsMonth 20XXTMI 3-43EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU2Initiating Condition:UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):1. a. UNPLANNED water level drop in the REFUELING PATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable R2.Table R2Radiation MonitorsRMS Area Monitored ModeRM-G-9 FHB Bridge Rad Monitor ALLRM-G-6 RB Auxiliary Bridge Rad Monitor 5,6RM-G-7 RB Main Bridge Rad Monitor 5, 6Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.REFUELING PATHWAY: all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.This IC addresses a loss in water level above irradiated fuel sufficient to cause elevatedradiation levels. This condition could be a precursor to a more serious event and is alsoindicative of a minor loss in the ability to control radiation levels within the plant. It istherefore a potential degradation in the level of safety of the plant.A water level loss will be primarily determined by indications from available levelinstrumentation. Other sources of level indications may include reports from plantpersonnel (e.g., from a refueling crew) or video camera observations (if available) or fromany other temporarily installed monitoring instrumentation. A significant drop in the waterlevel may also cause a rise in the radiation levels of adjacent areas that can be detectedby monitors in those locations.Month 20XXTMI 3-44EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU2 (cont)Basis (cont):The effects of planned evolutions should be considered. For example, a refueling bridgearea radiation monitor reading may rise due to planned evolutions such as lifting of thereactor vessel head or movement of a fuel assembly. Note that this EAL is applicableonly in cases where 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.Basis Reference(s):1. NEI 99-01 Rev 6, AU22. UFSAR, Section 14.2.2.1 -"Fuel Handling Accident"3. OP-TM-MAP-CO105 RCS Draindown4. OP 1202-12, Excessive Radiation Levels5. OP 1101-2.1 Radiation Monitoring System Setpoints6. Technical Specification 3.8.11 (Reactor Cavity Level)Month 20XXTMI 3-45EP-AA-1009 (Revision XX) | |||
Three Mile kIslnd Stamtion Annex FYAlnn Mana-I0nrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA3Initiating Condition:Radiation levels that impede access to equipment necessary for normal plant operations,cooldown or shutdown.Operating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):Note:* If the equipment in the room or area listed in Table R4 was already inoperable, orout of service, before the event occurred, then no emergency classification iswarranted.1. Dose rate > 15 mR/hr in ANY of the areas contained in Table R3:Table R3Areas Requiring Continuous Occupancy* Main Control Room* Central Alarm Station -(by survey)OR2. UNPLANNED event results in radiation levels that prohibit or significantly impedeaccess to ANY of the following Table R4 plant rooms or areas:Table R4Areas with Entry Related Mode ApplicabilityArea Entry Related ModeApplicabilityReactor Building* Modes 4, 5, and 6Intermediate Building* Modes 4, 5, and 6Auxiliary Building* Modes 4, 5, and 6Fuel Handling Building* Modes 4, 5, and 6*Areas required to establish shutdown coolingMonth 20XXTMI 3-46EP-AA-1009 (Revision XX) rThree MileIs land Stamtion Annex Fyelnn NuclaInrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA3 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient topreclude or impede personnel from performing actions necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal plantprocedures. As such, it represents an actual or potential substantial degradation of thelevel of safety of the plant. The Emergency Director should consider the cause of theincreased radiation levels and determine if another IC may be applicable.Table R4 is a list of plant rooms or areas with entry-related mode applicability that containequipment which require a manual/local action necessary to transition the plant fromnormal plant operation to cooldown and shutdown as specified in normal operatingprocedures (establish shutdown cooling), where if this action is not completed the plantwould not be able to attain and maintain cold shutdown. This Table does not includerooms or areas for which entry is required solely to perform actions of an administrative orrecord keeping nature (e.g., normal rounds or routine inspections).Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including theControl Room.For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, ormay be, procedurally required during the plant operating mode in effect and the elevatedradiation levels preclude the ability to place shutdown cooling in service. The emergencyclassification is not contingent upon whether entry is actually necessary at the time of theincreased radiation levels. Access should be considered as impeded if extraordinarymeasures are necessary to facilitate entry of personnel into the affected room/area (e.g.,installing temporary shielding beyond that required by procedures, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normaladministrative 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 radiationrise occurs, and the procedures used for normal operation, cooldown and shutdowndo not require entry into the affected room until Mode 4." The increased radiation levels are a result of a planned activity that includescompensatory measures which address the temporary inaccessibility of a room orarea (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections).Month 20XXTMI 3-47EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA3 (cont)Basis (cont):* The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category R, Cor F ICs.Basis Reference(s):1. NEI 99-01 Rev 6, AA32. FSAR Section 5.01 Class I Structures, Components, and Systems3. OP-TM-MAP-CO101, Radiation Level HIMonth 20XXTMI 3-48EP-AA-1 009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU3Initiating Condition:Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):1. Letdown Monitor RM-L-1 alert alarm (high or low channel).OR2. Sample analysis indicates that:a. Dose Equivalent 1-131 specific coolant activity > 60.0 uCi/gm.ORb. Dose Equivalent XE-133 specific coolant activity> 797.0 uCi/gm.Basis:This IC addresses a reactor coolant activity value that exceeds an allowable limitspecified in Technical Specifications. This condition is a precursor to a more significantevent and represents a potential degradation of the level of safety of the plant.Conditions that cause the specified monitor to alarm that are not related to fuel claddegradation should not result in the declaration of an Unusual Event.This EAL addresses site-specific radiation monitor readings that provide indication of adegradation of fuel clad integrity.An Unusual Event is only warranted when actual fuel clad damage is the cause of theelevated coolant sample activity (as determined by laboratory confirmation). Fuel claddamage should be assumed to be the cause of elevated Reactor Coolant activity unlessanother cause is known.Escalation of the emergency classification level would be via ICs FAl or the RecognitionCategory R ICs.Basis Reference(s):1. NEI 99-01 Rev 6, SU32. Operating Procedure 1101-2.1 Radiation Monitoring System Setpoints3. FSAR Section 11.4.4, Liquid Monitoring Subsystem4. OP-TM-MAP-CO101, Radiation Level HI5. Technical Specifications 3.1.4, Reactor Coolant System ActivityMonth 20XXTMI 3-49EP-AA-1 009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFG1Initiating Condition:Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-50EP-AA-1 009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFS1Initiating Condition:Loss or Potential Loss of ANY two barriers.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-51EP-AA-1009 (Revision XX) | |||
Nur.legrThree Mile Island Sftation Annex FveInn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFA1Initiating Condition:ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Alert classification level, Fuel Cladding and RCS barriers are weighted moreheavily than the Containment barrier. Unlike the Containment barrier, loss or potentialloss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactivematerials or degradation of core cooling capability. Note that the loss or potential loss ofContainment barrier in combination with loss or potential loss of either Fuel Cladding orRCS barrier results in declaration of a Site Area Emergency under EAL FSI.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-52EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC1Initiating Condition:RCS or SG Tube LeakageOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:POTENTIAL LOSS1. RCITS hot leg instruments indicate 0 inches after lowering trend.AND2. In-core thermocouples are unavailable.AND3. ALL RCP's are secured.Basis:There is no Loss threshold associated with RCS or SG Tube Leakage.Potential Loss Threshold #1 Basis:This reading indicates a reduction in reactor vessel water level sufficient to allow theonset of heat-induced cladding damage.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. FSAR 7.3.2.2.c.10.d3. OP-TM-EOP-008, RCS Superheated4. OP-TM-EOP-010, Emergency Procedure Rules Guides and GraphsMonth 20XXTMI 3-53EP-AA-1009 (Revision XX) | |||
FxpInn Three Mile kIsland Staition Annex FvAlnn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC2Initiating Condition:Inadequate Heat RemovalOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. Tclad > 1400°FPOTENTIAL LOSS2. > 25°F SuperheatOR3. HPI-PORV Cooling in effect.Basis:Loss Threshold #1 BasisThis reading indicates temperatures within the core are sufficient to cause significantsuperheating of reactor coolant.Potential Loss Threshold #2 BasisThis reading indicates temperatures within the core are sufficient to allow the onset ofheat-induced cladding damage.Potential Loss Threshold #3 BasisThis condition indicates an extreme challenge to the ability to remove RCS heat usingthe steam generators (i.e., loss of an effective secondary-side heat sink). This conditionrepresents a potential loss of the Fuel Clad Barrier. In accordance with EOPs, theremay be unusual accident conditions during which operators intentionally reduce theheat removal capability of the steam generators; during these conditions, classificationusing threshold is not warranted.Meeting this threshold results in a Site Area Emergency because this threshold isidentical to RCS Barrier RC2 Potential Loss threshold; both will be met. This conditionwarrants a Site Area Emergency declaration because inadequate RCS heat removalmay result in fuel heat-up sufficient to damage the cladding and raise RCS pressure tothe point where mass will be lost from the system.Month 20XXTMI 3-54EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC2 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. OS-24 Attachment D3. OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer4. OP-TM-EOP-008, RCS Superheated5. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs6. OS-24, Conduct of Operations during Abnormal and Emergency EventsMonth 20XXTMI 3-55EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC3Initiating Condition:Containment Radiation / RCS ActivityOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. Containment radiation monitor (RM-G-22 or RM-G-23) reading > 1.95E+03 R/hr.OR2. Coolant activity > 300uCi/gm Dose Equivalent 1-131Basis:Loss Threshold #1 Basis:The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the containment, assuming that reactor coolant activity equals300pCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greaterthan that expected for iodine spikes and corresponds to an approximate range of 2% to5% fuel clad damage. Since this condition indicates that a significant amount of fuelclad damage has occurred, it represents a loss of the Fuel Clad Barrier.The radiation monitor reading in this threshold is higher than that specified for RCSBarrier RC3 Loss Threshold since it indicates a loss of both the Fuel Clad Barrier andthe RCS Barrier. Note that a combination of the two monitor readings appropriatelyescalates the emergency classification level to a Site Area Emergency.Loss Threshold #2 Basis:This threshold indicates that RCS radioactivity concentration is greater than 300 pCi/gmdose equivalent 1-131. Reactor coolant activity above this level is greater than thatexpected for iodine spikes and corresponds to an approximate range of 2% to 5% fuelclad damage. Since this condition indicates that a significant amount of fuel claddamage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highlyelevated activity levels could require several hours to complete. Nonetheless, asample-related threshold is included as a backup to other indicationsThere is no Fuel Clad Barrier Potential Loss threshold associated with RCS Activity /Containment Radiation.Month 20XXTMI 3-56EP-AA-1009 (Revision XX) | |||
Kh Throp Milo~ 1--Ind Station Annex Pvalnn NmuuulanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC3 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-MAP-CO101, Radiation Level HI3. FSAR Section 11.4.4, Liquid Monitoring System Description4. Calculation C3640-98-034, Prediction of the Response of RM-G-6 and 7 to FuelDamage5. Core Damage Assessment Methodology (CDAM)Month 20XXTMI 3-57EP-AA-1 009 (Revision XX) | |||
Pvalnn kl"AanrThree Mila kIslnd Rtnatinn AnnqxF~n .1 vgiTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC5Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. Any condition in the opinion of the Emergency Director that indicates Loss of the FuelClad Barrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergency Director that indicates Potential Lossof the Fuel Clad Barrier.Basis:Loss Threshold #1 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold #2 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-58EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC1Initiating Condition:RCS or SG Tube LeakageOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. Automatic or manual ESAS actuation is required by EITHER of the following:a. UNISOLABLE RCS leakageORb. Steam Generator tube RUPTURE.POTENTIAL LOSS2. UNISOLABLE RCS leakage > 150gpm.OR3. HPI-PORV Cooling in effect.OR4. a. RCS Pressure > 2450 psig.ANDb. RCS Pressure not lowering.Basis:UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.RUPTURE(D): The condition of a steam generator in which primary-to-secondaryleakage is of sufficient magnitude to require a safety injection.FAULTED: The term applied to a steam generator that has a steam leak on thesecondary side of sufficient size to cause an uncontrolled drop in steam generatorpressure or the steam generator to become completely depressurized.Loss Threshold #1 BasisThis threshold is based on an UNISOLABLE RCS leak of sufficient size to require anautomatic or manual actuation of the Emergency Core Cooling System (ECCS). Thiscondition clearly represents a loss of the RCS Barrier.Month 20XXTMI 3-59EP-AA-1009 (Revision XX) | |||
Three Milo Islandl Station Annex Fvalnn INJ~rlanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRCl (cont)Basis (cont):This threshold is applicable to unidentified and pressure boundary leakage, as well asidentified leakage. It is also applicable to UNISOLABLE RCS leakage through aninterfacing system. The mass loss may be into any location -inside containment, to thesecondary-side (i.e., steam generator tube leakage) or outside of containment.A steam generator with primary-to-secondary leakage of sufficient magnitude to requirea safety injection is considered to be RUPTURED. If a RUPTURED steam generator isalso FAULTED outside of containment, the declaration escalates to a Site AreaEmergency since the Containment Barrier CT1 Loss threshold will also be met.Potential Loss Threshold #2 BasisThis threshold is based on an UNISOLABLE RCS leak that results in the inability tomaintain pressurizer level within specified limits by operation of a normally usedcharging (makeup) pump, but an ECCS (SI) actuation has not occurred. The thresholdis met when an operating procedure, or operating crew supervision, directs that astandby charging (makeup) pump be placed in service to restore and maintainpressurizer level.This threshold is applicable to unidentified and pressure boundary leakage, as well asidentified leakage. It is also applicable to UNISOLABLE RCS leakage through aninterfacing system. The mass loss may be into any location -inside containment, to thesecondary-side (i.e., steam generator tube leakage) or outside of containment.If a leaking steam generator is also FAULTED outside of containment, the declarationescalates to a Site Area Emergency since the Containment Barrier CT1 Loss Threshold#1 will also be met.Potential Loss Threshold #3 BasisThis condition indicates an extreme challenge to the integrity of the RCS pressureboundary due to pressurized thermal shock -a transient that causes rapid RCScooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized).Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-010 Emergency Procedure Rules, Guides And Graphs3. OP-TM-EOP-002 Loss of 25°F Subcooled Margin4. OP-TM-MAP-D031, MU Flow HI5. OP-TM-EOP-005, OTSG Tube LeakageMonth 20XXTMI 3-60EP-AA-1009 (Revision XX) | |||
Thra~ MiIA% liennr -4fnfiv~n Anng~vP~v-ltln Ik1, ,-ImrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC2Initiating Condition:Inadequate Heat RemovalOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:POTENTIAL LOSSHPI-PORV Cooling in effect.Basis:There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold BasisHPI-PORV Cooling in effect indicates a Lack of Primary to Secondary Heat Transfercapability.This condition indicates an extreme challenge to the ability to remove RCS heat usingthe steam generators (i.e., loss of an effective secondary-side heat sink). This conditionrepresents a potential loss of the RCS Barrier. In accordance with EOPs, there may beunusual accident conditions during which operators intentionally reduce the heatremoval capability of the steam generators; during these conditions, classification usingthreshold is not warranted.Meeting this threshold results in a Site Area Emergency because this threshold isidentical to Fuel Clad Barrier FC2 Potential Loss Threshold #3; both will be met. Thiscondition warrants a Site Area Emergency declaration because inadequate RCS heatremoval may result in fuel heat-up sufficient to damage the cladding and raise RCSpressure to the point where mass will be lost from the system.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-004, Lack of Primary to Secondary Heat TransferMonth 20XXTMI 3-61EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC3Initiating Condition:Containment Radiation / RCS ActivityOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSSContainment radiation monitor (RM-G-22 or RM-G-23) reading > 25 R/hr.Basis:Loss Threshold BasisThe radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the containment, assuming that reactor coolant activity equalsTechnical Specification allowable limits. This value is lower than that specified for FuelClad Barrier FC3 Loss threshold #1 since it indicates a loss of the RCS Barrier only.There is no RCS Potential Loss threshold associated with RCS Activity / ContainmentRadiation.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. EP-EAL-061 1, Criteria for Choosing Containment Radiation Monitor ReadingIndicative of Loss of RCS BarrierMonth 20XXTMI 3-62EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC5Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. Any condition in the opinion of the Emergency Director that indicates Loss of the RCSBarrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergency Director that indicates Potential Lossof the RCS Barrier.Basis:Loss Threshold #1 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the RCS Barrier is lost.Potential Loss Threshold #2 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the RCS Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored..Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-63EP-AA-1 009 (Revision XX) | |||
Thraga Milo kinnei -Qfnfie-.n AnnoyP:valnn Klir-lnrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT1Initiating Condition:RCS or SG Tube LeakageOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. SG tube leakage > 150gpmAND2. SG is FAULTED outside of containment.Basis:FAULTED: The term applied to a steam generator that has a steam leak on thesecondary side of sufficient size to cause an uncontrolled drop in steam generatorpressure or the steam generator to become completely depressurized.RUPTURE(D): The condition of a steam generator in which primary-to-secondaryleakage is of sufficient magnitude to require a safety injection.Loss Threshold BasisThis threshold addresses a leaking or RUPTURED Steam Generator (SG) that is alsoFAULTED outside of containment. The condition of the SG, whether leaking orRUPTURED, is determined in accordance with the thresholds for RCS Barrier RC1Potential Loss Threshold 2 and Loss Threshold 1.b, respectively. This conditionrepresents a bypass of the containment barrier.FAULTED is a defined term within the NEI 99-01 methodology; this determination is notnecessarily dependent upon entry into, or diagnostic steps within, an EOP. Forexample, if the pressure in a steam generator is decreasing uncontrollably [part of theFAULTED definition] and the faulted steam generator isolation procedure is not enteredbecause EOP user rules are dictating implementation of another procedure to address ahigher priority condition, the steam generator is still considered FAULTED foremergency classification purposes.The FAULTED criterion establishes an appropriate lower bound on the size of a steamrelease that may require an emergency classification. Steam releases of this size arereadily observable with normal Control Room indications. The lower bound for thisaspect of the containment barrier is analogous to the lower bound criteria specified in ICRU3 for the fuel clad barrier (i.e., RCS activity values) and IC MU6 for the RCS barrier(i.e., RCS leak rate values).This threshold also applies to prolonged steam releases necessitated by operationalconsiderations such as the forced steaming of a leaking or RUPTURED steamgenerator directly to atmosphere to cooldown the plant, or to drive an auxiliary(emergency) feed water pump. These types of conditions will result in a significant andMonth 20XXTMI 3-64EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCTI (cont)Basis (cont):sustained release of radioactive steam to the environment (and are thus similar to aFAULTED condition). The inability to isolate the steam flow without an adverse effecton plant cooldown meets the intent of a loss of containment.Steam releases associated with the expected operation of a SG power operated reliefvalve or safety relief valve do not meet the intent of this threshold. Such releases mayoccur intermittently for a short period of time following a reactor trip as operatorsprocess through emergency operating procedures to bring the plant to a stablecondition and prepare to initiate a plant cooldown. Steam releases associated with theunexpected operation of a valve (e.g., a stuck-open safety valve) meets this threshold.Following an SG tube leak or rupture, there may be minor radiological releases througha secondary-side system component (e.g., air ejectors, glad seal exhausters, valvepacking, etc.). These types of releases do not constitute a loss or potential loss ofcontainment but should be evaluated using the Recognition Category R ICs.The emergency classification levels resulting from primary-to-secondary leakage, withor without a steam release from the FAULTED SG, are summarized below.Affected SG is FAULTEDOutside of Containment?Yes NoPrimary to SecondaryLeak RateLess than or equal to 25gpmGreater than 25 gpmGreater than 150 gpm.The capacity of one makeuppump in the normalcharging mode is exceeded(RCS Barrier PotentialLoss)Requires an automatic ormanual ESAS actuation(RCS Barrier Loss)No classificationUnusual Event perMU6Site Area Emergencyper FS1Site Area Emergencyper FS1No classificationUnusual Event perMU6Alert per FA1Alert per FAIThere is no Potential Loss threshold associated with RCS or SG Tube Leakage.Month 20XXTMI 3-65EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT1 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs3. OP-TM-EOP-005, OTSG Tube Leakage4. OP-TM-EOP-001, Reactor TripMonth 20XXTMI 3-66EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearThre Mil Isand taton AnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT2Initiating Condition:Inadequate Heat RemovalOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:POTENTIAL LOSS1. Tclad > 1800°F.AND2. EOP Restoration procedures not effective in < 15 minutes.Basis:IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold BasisThis condition represents an IMMINENT core melt sequence which, if not corrected,could lead to vessel failure and an increased potential for containment failure. For thiscondition to occur, there must already have been a loss of the RCS Barrier and the FuelClad Barrier. If implementation of a procedure(s) to restore adequate core cooling is noteffective (successful) within 15 minutes, it is assumed that the event trajectory will likelylead to core melting and a subsequent challenge of the Containment Barrier.The restoration procedure is considered "effective" if core exit thermocouple readingsare decreasing and/or if reactor vessel level is increasing. Whether or not theprocedure(s) will be effective should be apparent within 15 minutes. The EmergencyDirector should escalate the emergency classification level as soon as it is determinedthat the procedure(s) will not be effective.Severe accident analyses (e.g., NUREG-1 150) have concluded that function restorationprocedures can arrest core degradation in a significant fraction of core damagescenarios, and that the likelihood of containment failure is very small in these events.Given this, it is appropriate to provide 15 minutes beyond the required entry point todetermine if procedural actions can reverse the core melt sequence.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-008, RCS Superheated3. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs4. OP-TM-EOP-006, LOCA CooldownMonth 20XXTMI 3-67EP-AA-1009 (Revision XX) | |||
Three MileIs land Staition Annex Fvnlnn NmirlIg:arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT3Initiating Condition:Containment Radiation / RCS ActivityOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:POTENTIAL LOSSContainment radiation monitor (RM-G-22 or RM-G-23) reading > 4.40E+03 R/hr.Basis:There is no Loss threshold associated with RCS Activity / Containment Radiation.Potential Loss Threshold BasisThe radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the containment, assuming that 20% of the fuel cladding has failed.This level of fuel clad failure is well above that used to determine the analogous FuelClad Barrier Loss and RCS Barrier Loss thresholds.NUREG-1 228, Source Estimations During Incident Response to Severe Nuclear PowerPlant Accidents, indicates the fuel clad failure must be greater than approximately 20%in order for there to be a major release of radioactivity requiring offsite protectiveactions. For this condition to exist, there must already have been a loss of the RCSBarrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as apotential loss of containment which would then escalate the emergency classificationlevel to a General Emergency.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. Core Damage Assessment Methodology (CDAM)Month 20XXTMI 3-68EP-AA-1 009 (Revision XX) | |||
Throa RAila kinnd Atntinn AnnoyIP=Ylnn NMtlor, ~Thr~ MiI~ IQI2nrI ~t~*inn Ann~iw Fv~Ir~n NmmvIc~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT4Initiating Condition:Containment Integrity or BypassOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. Containment isolation is required and EITHER of the following:a. UNPLANNED lowering in containment pressure or rise in radiation monitorreadings outside of containment in the Emergency Directors judgment indicatea loss of containment integrity.ORb. UNISOLABLE pathway from containment to the environment exists.OR2. Indication of RCS leakage outside of containmentPOTENTIAL LOSS3. Reactor Building Pressure > 55 psig and rising.OR4. Hydrogen Concentration in Containment > 4%.OR5. a. Reactor Building pressure > 30 psigANDb. Reactor Building Emergency cooling is less than ANY one of the followingconditions:SPRAY COOLERS2 00 31 1Basis:FAULTED: The term applied to a steam generator that has a steam leak on thesecondary side of sufficient size to cause an uncontrolled drop in steam generatorpressure or the steam generator to become completely depressurized.UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.Month 20XXTMI 3-69EP-AA-1 009 (Revision XX) | |||
Thrao Milo lainnd _Qfnfirn AnnoyI~v-g- In n Thrc&c MiIg~ Ie6nd ~t2tinn Anng~w Fv~inn tJm.pIa~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT4 (cont)Basis (cont):UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.Loss Threshold #1 BasisThese thresholds address a situation where containment isolation is required and one oftwo conditions exists as discussed below. Users are reminded that there may beaccident and release conditions that simultaneously meet both loss thresholds 1.a and1.b.l.a -Containment integrity has been lost, i.e., the actual containment atmospheric leakrate likely exceeds that associated with allowable leakage (or sometimes referred to asdesign leakage). Following the release of RCS mass into containment, containmentpressure will fluctuate based on a variety of factors; a loss of containment integritycondition may (or may not) be accompanied by a noticeable drop in containmentpressure. Recognizing the inherent difficulties in determining a containment leak rateduring accident conditions, it is expected that the Emergency Director will assess thisthreshold using judgment, and with due consideration given to current plant conditions,and available operational and radiological data (e.g., containment pressure, readings onradiation monitors outside containment, operating status of containment pressurecontrol equipment, etc.).Refer to the middle piping run of Figure 3-F-1. Two simplified examples are provided.One is leakage from a penetration and the other is leakage from an in-service systemvalve. Depending upon radiation monitor locations and sensitivities, the leakage couldbe detected by any of the four monitors depicted in the figure.Another example would be a loss or potential loss of the RCS barrier, and thesimultaneous occurrence of two FAULTED locations on a steam generator where onefault is located inside containment (e.g., on a steam or feedwater line) and the otheroutside of containment. In this case, the associated steam line provides a pathway forthe containment atmosphere to escape to an area outside the containment.Following the leakage of RCS mass into containment and a rise in containmentpressure, there may be minor radiological releases associated with allowable (design)containment leakage through various penetrations or system components. Thesereleases do not constitute a loss or potential loss of containment but should beevaluated using the Recognition Category R ICs.1.b -Conditions are such that there is an UNISOLABLE pathway for the migration ofradioactive material from the containment atmosphere to the environment. As usedhere, the term "environment" includes the atmosphere of a room or area, outside thecontainment, that may, in turn, communicate with the outside-the-plant atmosphere(e.g., through discharge of a ventilation system or atmospheric leakage). Dependingupon a variety of factors, this condition may or may not be accompanied by a noticeabledrop in containment pressure.Month 20XXTMI 3-70EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT4 (cont)Basis (cont):Refer to the top piping run of Figure 3-F-1. In this simplified example, the inboard andoutboard isolation valves remained open after a containment isolation was required (i.e.,containment isolation was not successful). There is now an UNISOLABLE pathwayfrom the containment to the environment.The existence of a filter is not considered in the threshold assessment. Filters do notremove fission product noble gases. In addition, a filter could become ineffective due toiodine and/or particulate loading beyond design limits (i.e., retention ability has beenexceeded) or water saturation from steam/high humidity in the release stream.Leakage between two interfacing liquid systems, by itself, does not meet this threshold.Refer to the bottom piping run of Figure 3-F-1. In this simplified example, leakage in anRCP seal cooler is allowing radioactive material to enter the Auxiliary Building. Theradioactivity would be detected by the Process Monitor. If there is no leakage from theclosed water cooling system to the Auxiliary Building, then no threshold has been met.If the pump or system piping developed a leak that allowed steam/water to enter theAuxiliary Building, then loss threshold 2 would be met. Depending upon radiationmonitor locations and sensitivities, this leakage could be detected by any of the fourmonitors depicted in the figure and cause threshold 1.a to be met as well.Following the leakage of RCS mass into containment and a rise in containmentpressure, there may be minor radiological releases associated with allowable (design)containment leakage through various penetrations or system components. Minorreleases may also occur if a containment isolation valve(s) fails to close but thecontainment atmosphere escapes to a closed system. These releases do not constitutea loss or potential loss of containment but should be evaluated using the RecognitionCategory R ICs.The status of the containment barrier during an event involving steam generator tubeleakage is assessed using Containment Barrier CT1 Loss threshold.Loss Threshold #2 BasisContainment sump, temperature, pressure and/or radiation levels will rise if reactorcoolant mass is leaking into the containment. If these parameters have not increased,then the reactor coolant mass may be leaking outside of containment (i.e., acontainment bypass sequence). Raises in sump, temperature, pressure, flow and/orradiation level readings outside of the containment may indicate that the RCS mass isbeing lost outside of containment.Unexpected elevated readings and alarms on radiation monitors with detectors outsidecontainment should be corroborated with other available indications to confirm that thesource is a loss of RCS mass outside of containment. If the fuel clad barrier has notbeen lost, radiation monitor readings outside of containment may not rise significantly;however, other unexpected changes in sump levels, area temperatures or pressures,flow rates, etc. should be sufficient to determine if RCS mass is being lost outside of thecontainment.Month 20XXTMI 3-71EP-AA-1009 (Revision XX) | |||
Throp Mila IslandI Station Annex PvaInn NiirlanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT4 (cont)Basis (cont):Refer to the middle piping run of Figure 3-F-1. In this simplified example, a leak hasoccurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building.Depending upon radiation monitor locations and sensitivities, the leakage could bedetected by any of the four monitors depicted in the figure and cause loss threshold I.ato be met as well. To ensure proper escalation of the emergency classification, the RCSleakage outside of containment must be related to the mass loss that is causing theRCS Barrier RC1 Loss Threshold l.a and/or Potential Loss threshold 2.a to be met.Potential Loss Threshold #3 BasisIf containment pressure exceeds the design pressure, there exists a potential to lose theContainment Barrier. To reach this level, there must be an inadequate core coolingcondition for an extended period of time; therefore, the RCS and Fuel Clad barrierswould already be lost. Thus, this threshold is a discriminator between a Site AreaEmergency and General Emergency since there is now a potential to lose the thirdbarrier.Potential Loss Threshold #4 BasisThe existence of an explosive mixture means, at a minimum, that the containmentatmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity. Ittherefore represents a potential loss of the Containment Barrier.Potential Loss Threshold #5 BasisThis threshold describes a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed toautomatically actuate, and less than one full train of equipment is capable of operatingper design. The 15-minute criterion is included to allow operators time to manually startequipment that may not have automatically started, if possible. This thresholdrepresents a potential loss of containment in that containment heatremoval/depressurization systems (e.g., containment sprays, ice condenser fans, etc.,but not including containment venting strategies) are either lost or performing in adegraded manner.Month 20XXTMI 3-72EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT4 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. FSAR Section 6.6 Reactor Building Pressure-Time Response3. Technical Specifications 3.5.3, Engineered Safeguards Protection SystemActuation Setpoints4. FSAR Section 6.3.3, Actuation5. FSAR Section 6.5.3, Hydrogen Generation6. OP-TM-EOP-006, LOCA Cooldown7. 1302-5.25 Reactor Building Sump Level8. FSAR Section 5.2 Reactor Building9. FSAR Section 9.2, Chemical Addition and Sampling System10. OP-TM-EOP-002, Loss of 250F Subcooling Margin11. OP-TM-EOP-006, LOCA Cooldown12. OP-TM-EOP-010, Emergency Procedure Rules, Guides and Graphs13. OP-TM-MAP-D0301, High Make-up FlowMonth 20XXTMI 3-73EP-AA-1009 (Revision XX) | |||
Throciaf lalanrd .tnfinn AnnoyaEwarIn& ^Im~RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONPinni irn 24.1:.l" PWR Ce.nntninmont Infonrift nr QunMae Fvomnl,0W W I* 1.b-- Airbornerelease from *pathwayVentCoolingMonth 20XXTMI 3-74EP-AA-1009 (Revision XX) | |||
Fxelnn Three Mile Island Station Annex FeInIn NuIcIeIarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT5Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. Any condition in the opinion of the Emergency Director that indicates Loss of theContainment Barrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergency Director that indicates Potential Lossof the Containment Barrier.Basis:Loss Threshold #1 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is lost.Potential Loss Threshold #2 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is potentially lost. The EmergencyDirector should also consider whether or not to declare the barrier potentially lost in theevent that barrier status cannot be monitored.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-75EP-AA-1009 (Revision XX) rThree MileIsa ind Station Annex Fxelnn N~uclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG1Initiating Condition:Prolonged loss of all offsite and all onsite AC power to emergency busses.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1 B Emergency Diesel Generators and EG-Y-4 SBO DieselGenerator to supply power to Emergency 4KV buses.AND3. EITHER of the following:a. Restoration of at least one Emergency 4KV bus in < 4 hours is not likely.ORb. > 25°F superheatBasis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a prolonged loss of all power sources to AC emergency buses. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiringelectric power including those necessary for emergency core cooling, containment heatremoval/pressure control, spent fuel heat removal and the ultimate heat sink. Aprolonged loss of these buses will lead to a loss of any fission product barriers. Inaddition, fission product barrier monitoring capabilities may be degraded under theseconditions.The EAL should require declaration of a General Emergency prior to meeting thethresholds for IC FG1. This will allow additional time for implementation of offsiteprotective actions.Escalation of the emergency classification from Site Area Emergency will occur if it isprojected that power cannot be restored to at least one AC emergency bus by the endof the analyzed station blackout coping period. Beyond this time, plant responses andMonth 20XXTMI 3-76EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG1 (cont).Basis (cont):event trajectory are subject to greater uncertainty, and there is an increased likelihoodof challenges to multiple fission product barriers.The estimate for restoring at least one emergency bus should be based on a realisticappraisal of the situation. Mitigation actions with a low probability of success should notbe used as a basis for delaying a classification upgrade. The goal is to maximize thetime available to prepare for, and implement, protective actions for the public.The EAL will also require a General Emergency declaration if the loss of AC powerresults in parameters that indicate an inability to adequately remove decay heat fromthe core.Basis Reference(s):1. NEI 99-01 Rev 6, SG12. OP-TM-EOP-010 Emergency Procedure Rules, Guides And Graphs3. FSAR Section 8.2.2 Unit Distribution System4. FSAR Section 8.2.3 Sources of Auxiliary Power5. FSAR Section 8.5 Station Blackout6. Technical Specification Section 3.7, Unit Electric Power System7. 1107-1 Normal Electrical System8. 11 07-2A Emergency Electrical -4KV and 480 Volt9. OP-TM-AOP-020 Loss Of Station Power10. 1107-3 Diesel Generator11. 1107-9 SBO Diesel Generator12. OP-TM-EOP-008 RCS Superheated13. OS-24, Conduct of. Operation during Abnormal and Emergency EventsMonth 20XXTMI 3-77EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS1Initiating Condition:Loss of all offsite and all onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC Power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1 B Emergency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutes from thetime of loss of both offsite and onsite AC powerBasis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergencycore cooling, containment heat removal/pressure control, spent fuel heat removal andthe ultimate heat sink. In addition, fission product barrier monitoring capabilities may bedegraded under these conditions. This IC represents a condition that involves actual orlikely major failures of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RG1, FG1, MG1, orMG2.Month 20XXTMI 3-78EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS1 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, SS12. FSAR Section 8.2.3, Sources of Auxiliary Power3. Technical Specification Section 3.7, Unit Electric Power System4. 1107-1 Normal Electrical System5. 11 07-2A Emergency Electrical -4KV and 480 Volt6. OP-TM-AOP-020 Loss Of Station Power7. 1107-3 Diesel Generator8. 1107-9 SBO Diesel Generator9. FSAR Section 8.2.2, Unit Distribution System10. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-79EP-AA-1009 (Revision XX) | |||
F=Yplnn Nw-lonrThree MileIsl~andl Station AnnexF~n Ni~aaTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMAIInitiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. AC power capability to Emergency 4KV buses reduced to only one of the followingpower sources for > 15 minutes.* Auxiliary Transformer 1A* Auxiliary Transformer 1 B* Emergency Diesel Generator EG-Y-1A* Emergency Diesel Generator EG-Y-1 B* SBO Diesel Generator EG-Y-4AND2. Any additional single power source failure will result in a loss of ALL AC power toSAFETY SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS. In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment. This IC provides an escalation path from ICMUl.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below.* A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).Month 20XXTMI 3-80EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMAI (cont)Basis (cont):" A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator.* A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.Escalation of the emergency classification level would be via IC MS1.Basis Reference(s):1. NEI 99-01 Rev 6, SA12. FSAR Section 8.2.3, Sources of Auxiliary Power3. FSAR Section 8.5, Station Blackout4. Technical Specification Section 3.7, Unit Electric Power System5. 1107-1 Normal Electrical System6. 11 07-2A Emergency Electrical -4KV and 480 Volt7. OP-TM-AOP-020 Loss Of Station Power8. 1107-3 Diesel Generator9. .1107-9 SBO Diesel Generator10. FSAR Section 8.2.2, Unit Distribution SystemMonth 20XXTMI 3-81EP-AA-1 009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU1Initiating Condition:Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:e The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Loss of ALL offsite AC power capability to Emergency 4KV busses for > 15 minutes.Basis:This IC addresses a prolonged loss of offsite power. The loss of offsite power sourcesrenders the plant more vulnerable to a complete loss of power to AC emergency buses.This condition represents a potential reduction in the level of safety of the plant.For emergency classification purposes, "capability" means that an offsite AC powersource(s) is available to the emergency buses, whether or not the buses are poweredfrom it.The emergency busses of the affected unit can be powered from the unaffected unitthrough the crosstie breakers. Unit crosstie is considered an adequate source of offsitepower when evaluating this EAL.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof offsite power.Escalation of the emergency classification level would be via IC MAl.Basis Reference(s):1. NEI 99-01 Rev 6, SU12. FSAR Section 8.2.3, Sources of Auxiliary Power3. Technical Specification Section 3.7, Unit Electric Power System4. 1107-1 Normal Electrical System5. 11 07-2A Emergency Electrical -4KV and 480 Volt6. OP-TM-AOP-020 Loss Of Station Power7. 1107-3 Diesel Generator8. 1107-9 SBO Diesel Generator9. FSAR Section 8.2.2, Unit Distribution SystemMonth 20XXTMI 13-82EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG2Initiating Condition:Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBO DieselGenerator to supply power to Emergency 4KV buses.AND3. Voltage is < 105 VDC on 125 VDC Distribution System 1A and lB.AND4. ALL AC and Vital DC power sources have been lost for >15 minutes.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiringelectric power including those necessary for emergency core cooling, containment heatremoval/pressure control, spent fuel heat removal and the ultimate heat sink. A loss ofVital DC power compromises the ability to monitor and control SAFETY SYSTEMS. Asustained loss of both AC and DC power will lead to multiple challenges to fissionproduct barriers.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses. The 15-minute emergency declaration clock begins at the point when all EALsare met.Month 20XXTMI 3-83EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG2 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, SG82. FSAR Section 8.2.2.6, 250/125 VDC System3. 11 07-2C Vital DC Electrical System4. OP-TM-AOP-023, A DC System Failure5. OP-TM-AOP-024, B DC System Failure6. FSAR Section 8.2.2, Unit Distribution System7. FSAR Section 8.2.3, Sources of Auxiliary Power8. Technical Specification Section 3.7, Unit Electric Power System9. 1107-1 Normal Electrical System10. 1107-2A Emergency Electrical -4KV and 480 Volt11. OP-TM-AOP-020 Loss Of Station Power12. 1107-3 Diesel Generator13. 1107-9 SBO Diesel Generator14. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-84EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS2Initiating Condition:Loss of all vital DC power for 15 minutes or longer.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Voltage is < 105 VDC on 125 VDC Distribution System 1A and 1B for>15 minutes.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a loss of Vital DC power which compromises the ability to monitorand control SAFETY SYSTEMS. In modes above Cold Shutdown, this conditioninvolves a major failure of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RG1, FG1 or MG3.Basis Reference(s):1. NEI 99-01 Rev 6, SS82. FSAR Section 8.2.2.6, 250/125 VDC System3. 1107-2C Vital DC Electrical System4. OP-TM-AOP-023, A DC System Failure5. OP-TM-AOP-024, B DC System FailureMonth 20XXTMI 3-85EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS3Initiating Condition:Inability to shutdown the reactor causing a challenge to core cooling or RCS heatremoval.Operating Mode Applicability:1,2Emergency Action Level (EAL):1. Automatic or Manual Trip did not shutdown the reactor as indicated by ReactorPower > 5%.AND2. ALL manual actions to shutdown the reactor have been unsuccessful as indicatedby Reactor Power > 5%.AND3. EITHER of the following conditions exist:a. Tclad > 14000F.ORb. HPI-PORV Cooling in effect.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor trip that results in a reactor shutdown, all subsequent operator manual actions,both inside and outside the Control Room including driving in control rods and boroninjection, are unsuccessful, and continued power generation is challenging thecapability to adequately remove heat from the core and/or the RCS. This condition willlead to fuel damage if additional mitigation actions are unsuccessful and thus warrantsthe declaration of a Site Area Emergency.In some instances, the emergency classification resulting from this IC/EAL may behigher than that resulting from an assessment of the plant responses and symptomsagainst the Recognition Category F ICs/EALs. This is appropriate in that theRecognition Category F ICs/EALs do not address the additional threat posed by afailure to shutdown the reactor. The inclusion of this IC and EAL ensures the timelydeclaration of a Site Area Emergency in response to prolonged failure to shutdown thereactor.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Escalation of the emergency classification level would be via IC RG1 or FGI.Month 20XXTMI 3-86EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS3 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, SS52. OP-TM-EOP-004, Lack of Primary-to-Secondary Heat Transfer3. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs4. OP-TM-EOP-001, Reactor Trip5. 1102-4 Power Operation6. OP-TM-641-000- Reactor Protection System (RPS/DSS)Month 20XXTMI 3-87EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA3Initiating Condition:Automatic or manual trip fails to shutdown the reactor, and subsequent manual actionstaken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note:* A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.1. Automatic Trip did not shutdown the reactor as indicated by Reactor Power > 5%.AND2. Manual actions taken at the Console Center are not successful in shutting down thereactor as indicated by Reactor Power > 5%.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic reactor tripthat results in a reactor shutdown, and subsequent operator manual actions taken at theConsole Center to shutdown the reactor are also unsuccessful. This conditionrepresents an actual or potential substantial degradation of the level of safety of theplant. An emergency declaration is required even if the reactor is subsequentlyshutdown by an action taken away from the Console Center since this event entails asignificant failure of the RPS.A manual action at the Console Center is any operator action, or set of actions, whichcauses the control rods to be rapidly inserted into the core (e.g., initiating a manualreactor trip. This action does not include manually driving in control rods orimplementation of boron injection strategies. If this action(s) is unsuccessful, operatorswould immediately pursue additional manual actions at locations away from the ConsoleCenter (e.g., locally opening breakers). Actions taken at back-panels or other locationswithin the Control Room, or any location outside the Control Room, are not consideredto be "at the Console Center".The plant response to the failure of an automatic reactor trip will vary based uponseveral factors including the reactor power level prior to the event, availability of thecondenser, performance of mitigation equipment and actions, other concurrent plantconditions, etc. If the failure to shutdown the reactor is prolonged enough to cause achallenge to the core cooling or RCS heat removal safety functions, the emergencyMonth 20XXTMI 3-88EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA3 (cont)Basis (cont):classification level will escalate to a Site Area Emergency via IC MS3. Depending uponplant responses and symptoms, escalation is also possible via IC FS1. Absent the plantconditions needed to meet either IC MS3 or FS1, an Alert declaration is appropriate forthis event.It is recognized that plant responses or symptoms may also require an Alert declarationin accordance with the Recognition Category F ICs; however, this IC and EAL areincluded to ensure a timely emergency declaration.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Basis Reference(s):1. NEI 99-01 Rev 6, SA52. OP-TM-EOP-004, Lack of Primary-to-Secondary Heat Transfer3. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs4. OP-TM-EOP-001, Reactor Trip5. 1102-4 Power Operation6. OP-TM-641-000- Reactor Protection System (RPS/DSS)Month 20XXTMI 3-89EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU3Initiating Condition:Automatic or manual trip fails to shutdown the reactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note:A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.1. a. Automatic Trip did not shutdown the reactor as indicated by Reactor Power> 5%.ANDb. Subsequent manual action taken at the Console Center is successful inshutting down the reactor.OR2. a. Manual Trip did not shutdown the reactor as indicated by Reactor Power > 5%.ANDb. Subsequent automatic Trip is successful in shutting down the reactor.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor trip that results in a reactor shutdown, and either a subsequent operator manualaction taken at the Console Center or an automatic trip is successful in shutting downthe reactor. This event is a precursor to a more significant condition and thus representsa potential degradation of the level of safety of the plant.EAL #1 BasisFollowing the failure on an automatic reactor trip, operators will promptly initiate manualactions at the Console Center to shutdown the reactor (e.g., initiate a manual reactortrip). If these manual actions are successful in shutting down the reactor, core heatgeneration will quickly fall to a level within the capabilities of the plant's decay heatremoval systems.Month 20XXTMI 3-90EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU3 (cont)Basis (cont):EAL #2 BasisIf an initial manual reactor trip is unsuccessful, a concurrent plant condition, may leadto the generation of an automatic reactor trip signal. If a subsequent automatic trip issuccessful in shutting down the reactor, core heat generation will quickly fall to a levelwithin the capabilities of the plant's decay heat removal systems.A manual action at the Console Center is any operator action, or set of actions, whichcauses the control rods to be rapidly inserted into the core (e.g., initiating a manualreactor trip). This action does not include manually driving in control rods orimplementation of boron injection strategies. Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the Console Center".The plant response to the failure of an automatic or manual reactor trip will vary basedupon several factors including the reactor power level prior to the event, availability ofthe condenser, performance of mitigation equipment and actions, other concurrent plantconditions, etc. If subsequent operator manual actions taken at the Console Center arealso unsuccessful in shutting down the reactor, then the emergency classification levelwill escalate to an Alert via IC MA3. Depending upon the plant response, escalation isalso possible via IC FAI. Absent the plant conditions needed to meet either IC MA3 orFAI, an Unusual Event declaration is appropriate for this event.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Should a reactor trip signal be generated as a result of plant work (e.g., RPS setpointtesting), the following classification guidance should be applied." If the signal generated as a result of plant work causes a plant transient that createsa real condition that should have included an automatic reactor trip and the RPS failsto automatically shutdown the reactor, then this IC and the EALs are applicable, andshould be evaluated." If the signal generated as a result of plant work does not cause a plant transient butshould have generated an RPS trip signal and the trip failure is determined throughother means (e.g., assessment of test results), then this IC and the EALs are notapplicable and no classification is warranted.Month 20XXTMI 13-91EP-AA-1 009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU3 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, SU52. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs3. OP-TM-EOP-001, Reactor Trip4. 1102-4 Power Operation5. OP-TM-641-000- Reactor Protection System (RPS/DSS)Month 20XXTMI 3-92EP-AA-1009 (Revision XX) | |||
Three Mile kIslnd Station Annex FxeInn Nule~I~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA4Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. a. UNPLANNED event results in the inability to monitor ANY Table M1 parametersfrom within the Control Room for > 15 minutes.Table M1 Control Room Parameters" Reactor Power" PZR Level, RCS Pressure" In Core/Core Exit Temperature" Level in at least one OTSG.* OTSG Emergency Feed Water FlowANDb. ANY Table M2 transient in progress.Table M2 Significant Transients" Automatic Turbine Runback >25% thermal reactor power" Electrical Load Rejection >25% full electrical load" Reactor Trip* ESAS Actuationa Thermal Power oscillations > 10%Month 20XXTMI 3-93EP-AA-1009 (Revision XX) | |||
Three Mih- Islamnd Staution Annex Fvninn Niir~icprTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA4 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses the difficulty associated with monitoring rapidly changing plantconditions during a transient without the ability to obtain SAFETY SYSTEM parametersfrom within the Control Room. During this condition, the margin to a potential fissionproduct barrier challenge is reduced. It thus represents a potential substantialdegradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for any of the listedparameters cannot be determined from within the Control Room. This situation wouldrequire a loss of all of the Control Room sources for the given parameter(s). Forexample, the reactor power level cannot be determined from any analog, computerpoint, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022)to determine if an NRC event report is required. The event would be reported if itsignificantly impaired the capability to perform emergency assessments. In particular,emergency assessments necessary to implement abnormal operating procedures,emergency operating procedures, and emergency plan implementing proceduresaddressing emergency classification, accident assessment, or protective actiondecision-making.This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity control, core cooling and RCS heat removal. The loss ofthe ability to determine any of these parameters from within the Control Room isconsidered to be more significant than simply a reportable condition. In addition, if allindication sources for any of the listed parameters are lost, then the ability to determinethe values of other SAFETY SYSTEM parameters may be impacted as well. Forexample, if the value for reactor vessel level cannot be determined from the indicationsand recorders on a main control board, the SPDS or the plant computer, the availabilityof other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation of the emergency classification level would be via ICs FS1 or IC RSI.Basis Reference(s):1. NEI 99-01 Rev 6, SA2Month 20XXTMI 3-94EP-AA-1009 (Revision XX) rThree Mile kIslnd Station Annex FvAinn NucleI~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU4Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.UNPLANNED event results in the inability to monitor ANY Table M1 parameters fromwithin the Control Room for > 15 minutes.Table M1 Control Room Parametersa Reactor Power* PZR Level* RCS Pressure* In Core/Core Exit Temperature* Level in at least one OTSG.e OTSG Emergency Feed Water FlowBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses the difficulty associated with monitoring normal plant conditionswithout the ability to obtain SAFETY SYSTEM parameters from within the ControlRoom. This condition is a precursor to a more significant event and represents apotential degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for any of the listedparameters cannot be determined from within the Control Room. This situation wouldrequire a loss of all of the Control Room sources for the given parameter(s). Forexample, the reactor power level cannot be determined from any analog, digital andrecorder source within the Control Room. An event involving a loss of plant indications,Month 20XXTMI 3-95EP-AA-1009 (Revision XX) | |||
PyPinn Mid-lonrThree~ Mile Islmnd Stt~ion Anne~x FAn ~~~TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU4 (cont)Basis (cont):annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72(and associated guidance in NUREG-1022) to determine if an NRC event report isrequired. The event would be reported if it significantly impaired the capability toperform emergency assessments. In particular, emergency assessments necessary toimplement abnormal operating procedures, emergency operating procedures, andemergency plan implementing procedures addressing emergency classification,accident assessment, or protective action decision-making.This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity control, core cooling and RCS heat removal. The loss ofthe ability to determine any of these parameters from within the Control Room isconsidered to be more significant than simply a reportable condition. In addition, if allindication sources for any of the listed parameters are lost, then the ability to determinethe values of other SAFETY SYSTEM parameters may be impacted as well. Forexample, if the value for reactor vessel level cannot be determined from the indicationsand recorders on a main control board, the SPDS or the plant computer, the availabilityof other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation of the emergency classification level would be via IC MA4.Basis Reference(s):1. NEI 99-01 Rev 6, SU2Month 20XXTMI 3-96EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearThre Mil Isand taton AnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA5Initiating Condition:Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):1. The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)" Internal or external flooding event" High winds or tornado strike" FIRE* EXPLOSION" Other events with similar hazard characteristics as determined by theShift ManagerAND2. EITHER of the following:a. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM required by TechnicalSpecifications for the current operating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure required by Technical Specifications for thecurrent operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization. A release of steam (from highenergy lines or components) or an electrical component failure (caused by short circuits,grounding, arcing, etc.) should not automatically be considered an explosion. Suchevents may require a post-event inspection to determine if the attributes of an explosionare present.Month 20XXTMI 3-97EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA5 (cont)Basis (cont):SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.VISIBLE DAMAGE: Damage to a component or structure that is readily observablewithout measurements, testing, or analysis. The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components, required for the current operatingmode, "required", i.e. required to be operable by Technical Specifications for the currentoperating mode. This condition significantly reduces the margin to a loss or potentialloss of a fission product barrier, and therefore represents an actual or potentialsubstantial degradation of the level of safety of the plant. Manual or automatic electricalisolation of safety equipment due to flooding, in and of itself, does not constitutedegraded performance and is classified under HU6.EAL #2.a BasisThis EAL addresses damage to a SAFETY SYSTEM train that is required to beoperable by Technical Specifications for the current operating mode, and is in operationsince indications for it will be readily available. The indications of degradedperformance should be significant enough to cause concern regarding the operability orreliability of the SAFETY SYSTEM train.EAL #2.b BasisThis EAL addresses damage to a SAFETY SYSTEM component that is required to beoperable by Technical Specifications for the current operating mode, and is not inoperation or readily apparent through indications alone, as well as damage to astructure containing SAFETY SYSTEM components. Operators will make thisdetermination based on the totality of available event and damage report information.This is intended to be a brief assessment not requiring lengthy analysis or quantificationof the damage.Escalation of the emergency classification level would be via IC FS1 or RS1.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.*Basis Reference(s):1. NEI 99-01, Rev 6 SA9Month 20XXTMI 3-98EP-AA-1009 (Revision XX) | |||
Three Mile Islandl Station Annexv Fwalfnn NIlanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU6Initiating Condition:RCS leakage for 15 minutes or longer.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage > 10 gpm for > 15 minutes.OR2. RCS identified leakage >25 gpm for > 15 minutes.OR3. Leakage from the RCS to a location outside containment >25 gpm for > 15 minutes.Basis:UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.This IC addresses RCS leakage which may be a precursor to a more significant event.In this case, RCS leakage has been detected and operators, following applicableprocedures, have been unable to promptly isolate the leak. This condition is consideredto be a potential degradation of the level of safety of the plant.EAL #1 and EAL #2 BasisThese EALs are focused on a loss of mass from the RCS due to "unidentified leakage","pressure boundary leakage" or "identified leakage" (as these leakage types are definedin the plant Technical Specifications).EAL #3 BasisThis EAL addresses a RCS mass loss caused by an UNISOLABLE leak through aninterfacing system. These EALs thus apply to leakage into the containment, asecondary-side system (e.g., steam generator tube leakage) or a location outside ofcontainment.The leak rate values for each EAL were selected because they are usually observablewith normal Control Room indications. Lesser values typically require time-consumingcalculations to determine (e.g., a mass balance calculation). EAL #1 uses a lower valuethat reflects the greater significance of unidentified or pressure boundary leakage.Month 20XXTMI 3-99EP-AA-1009 (Revision XX) | |||
ThrAn MiIA kI~nd St~tinn Annn~rThree Mile Island Station Annex Exellon N"d-h-arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU6 (cont)Basis (cont):The release of mass from the RCS due to the as-designed/expected operation of arelief valve does not warrant an emergency classification. An emergency classificationwould be required if a mass loss is caused by a relief valve that is not functioning asdesigned/expected (e.g., a relief valve sticks open and the line flow cannot be isolated).The 15-minute threshold duration allows sufficient time for prompt operator actions toisolate the leakage, if possible.Escalation of the emergency classification level would be via ICs of RecognitionCategory R or F.Basis Reference(s):1. NEI 99-01 Rev 6, SU42. OP-TM-220-251 RCS Leak Rate Determination3. OP-TM-220-252, Primary -To -Secondary Leakrate Determination4. OP-TM-PRFl-0405 RB Sump Level HI5. UFSAR 6.4.3, Bases of Leakage Estimate6. UFSAR 6.4.4, Design Basis Leakage7. OP-TM-AOP-050, Reactor Coolant Leakage8. Technical Specification 3.1.6, Leakage and Table 4.1-2, Minimum EquipmentTest FrequencyMonth 20XXTMI 3-100EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU7Initiating Condition:Loss of all On-site or Off-site communications capabilities.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):1. Loss of ALL Table M3 Onsite communications capability affecting the ability toperform routine operations.OR2. Loss of ALL Table M3 Offsite communication capability affecting the ability toperform offsite notifications.OR3. Loss of ALL Table M3 NRC communication capability affecting the ability toperform NRC notifications.Table M3 Communications CaoabilitvSystem Onsite Offsite NRCRadios XPlant page XPlant Telephone System XSound Powered Phones XCommercial Telephones X X XNARS XENS X XHPN X XSatellite phones X XBasis:This IC addresses a significant loss of on-site, offsite, or NRC communicationscapabilities. While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).Month 20XXTMI 3-101EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU7 (cont)Basis (cont):EAL #1 BasisAddresses a total loss of the communications methods used in support of routine plantoperations.EAL #2 BasisAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form.EAL #3 BasisAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, SU62. 1105-12 Communications System3. FSAR Section 7.4.4, CommunicationMonth 20XXTMI 3-102EP-AA-1009 (Revision XX) | |||
Thrain Milo laitanri -Q+mfinn AnnavIzv--Ir^n kh,,-li-,rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU8Initiating Condition:Failure to isolate containment or loss of containment pressure control.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):1. a. Failure of containment to isolate when required by an actuation signal.ANDb. ANY required penetration remains open > 15 minutes of the actuationsignal.OR2. a. Reactor Building pressure > 30 psigANDb. Reactor Building Emergency cooling is less than ANY one of the followingconditions for > 15 minutes:SPRAY COOLERS2 00 31 1Basis:This IC addresses a failure of any containment penetrations to automatically isolate(close) when required by an actuation signal. It also addresses an event that results inhigh containment pressure with a concurrent failure of containment pressure controlsystems. Absent challenges to another fission product barrier, either conditionrepresents potential degradation of the level of safety of the plant.EAL #1 BasisThe containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); afailure resulting from testing or maintenance does not warrant classification. Thedetermination of containment and penetration status -isolated or not isolated -shouldbe made in accordance with the appropriate criteria contained in the plant AOPs andEOPs. The 15-minute criterion is included to allow operators time to manually isolatethe required penetrations, if possible.Month 20XXTMI 3-103EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annexmmlvmvl m i ThreeMileIslan Staion Anex xelnn NuclerIzrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU8 (cont)Basis (cont):EAL #2 BasisAddresses a condition where containment pressure is greater than the setpoint at whichcontainment energy (heat) removal systems are designed to automatically actuate, andless than one full train of equipment is capable of operating per design. The 15-minutecriterion is included to allow operators time to manually start equipment that may nothave automatically started, if possible. The inability to start the required equipmentindicates that containment heat removal/depressurization systems (e.g., containmentsprays or ice condenser fans) are either lost or performing in a degraded manner.This event would escalate to a Site Area Emergency in accordance with IC FS1 if therewere a concurrent loss or potential loss of either the Fuel Clad or RCS fission productbarriers.Basis Reference(s):1. NEI 99-01 Rev 6, SU72. FSAR Section 6.6 Reactor Building Pressure-Time Response3. Technical Specifications 3.5.3, Engineered Safeguards Protection SystemActuation Setpoints4. FSAR Section 6.3.3, Actuation5. FSAR Section 6.5.3, Hydrogen Generation6. OP-TM-EOP-006, LOCA Cooldown7. 1302-5.25 Reactor Building Sump Level8. FSAR Section 5.2 Reactor Building9. FSAR Section 9.2, Chemical Addition and Sampling System10. OP-TM-EOP-002, Loss of 250F Subcooling Margin11. OP-TM-EOP-006, LOCA Cooldown12. OP-TM-EOP-010, Emergency Procedure Rules, Guides and Graphs13. OP-TM-MAP-D0301, High Make-up FlowMonth 20XXTMI 3-104EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA1Initiating Condition:Loss of all offsite and all onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:5,6, DEmergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1 B Emergency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutesfrom the time of loss of both offsite and onsite AC power.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-relatedThis IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergencycore cooling, containment heat removal/pressure control, spent fuel heat removal andthe ultimate heat sink.When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas a Site Area Emergency because of the increased time available to restore anemergency bus to service. Additional time is available due to the reduced core decayheat load, and the lower temperatures and pressures in various plant systems. Thus,when in these modes, this condition represents an actual or potential substantialdegradation of the level of safety of the plant.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via IC CS6 or RS1.Month 20XXTMI 3-105EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCAI (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CA22. FSAR Section 8.2.2, Unit Distribution System3. FSAR Section 8.2.3, Sources of Auxiliary Power4. Technical Specification Section 3.7, Unit Electric Power System5. 1107-1 Normal Electrical System6. 11 07-2A Emergency Electrical -4KV and 480 Volt7. OP-TM-AOP-020 Loss Of Station Power8. 1107-3 Diesel Generator9. 1107-9 SBO Diesel Generator10. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-106EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annexm B Thre Mil Islnd tatin Anex xelnn NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSculInitiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:5,6, DEmergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. AC power capability to Emergency 4KV buses reduced to only one of thefollowing power sources for > 15 minutes." Auxiliary Transformer 1A" Auxiliary Transformer 1 B" Emergency Diesel Generator EG-Y-1A" Emergency Diesel Generator EG-Y-1 B" SBO Diesel Generator EG-Y-4AND2. ANY additional single power source failure will result in a loss of ALLAC powerto SAFETY SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS. In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment.When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas an Alert because of the increased time available to restore another power source toservice. Additional time is available due to the reduced core decay heat load, and thelower temperatures and pressures in various plant systems. Thus, when in thesemodes, this condition is considered to be a potential degradation of the level of safety ofthe plant.Month 20XXTMI 3-107EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCUl (cont)Basis (cont):An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below." A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).* A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator.* A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.The subsequent loss of the remaining single power source would escalate the event toan Alert in accordance with IC CA1.Basis Reference(s):1. NEI 99-01 Rev 6 CU22. FSAR Section 8.2.2, Unit Distribution System3. FSAR Section 8.2.3, Sources of Auxiliary Power4. Technical Specification Section 3.7, Unit Electric Power System5. 1107-1 Normal Electrical System6. 11 07-2A Emergency Electrical -4KV and 480 Volt7. OP-TM-AOP-020 Loss Of Station Power8. 1107-3 Diesel Generator9. 1107-9 SBO Diesel Generator10. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-108EP-AA-1009 (Revision XX) rThree Mile~ kIslnd Station Annex Fvalnn Myt-lon&~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA2Initiating Condition:Hazardous event affecting SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:5,6Emergency Action Level (EAL):1. The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)* Internal or external flooding event" High winds or tornado strike" FIRE" EXPLOSION" Other events with similar hazard characteristics as determined by theShift ManagerAND2. EITHER of the following:a. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM required by TechnicalSpecifications for the current operating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure required by Technical Specifications for thecurrent operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization. A release of steam (from highenergy lines or components) or an electrical component failure (caused by short circuits,grounding, arcing, etc.) should not automatically be considered an explosion. Suchevents may require a post-event inspection to determine if the attributes of an explosionare present.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.Month 20XXTMI 3-109EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearThre Mil Isand taton AnexExelnn NucilearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA2 (cont)Basis (cont):VISIBLE DAMAGE: Damage to a component or structure that is readily observablewithout measurements, testing, or analysis. The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components, required for the current operatingmode, "required", i.e. required to be operable by Technical Specifications for the currentoperating mode. This condition significantly reduces the margin to a loss or potentialloss of a fission product barrier, and therefore represents an actual or potentialsubstantial degradation of the level of safety of the plant. Manual or automatic electricalisolation of safety equipment due to flooding, in and of itself, does not constitutedegraded performance and is classified under HU6.EAL #2.a BasisAddresses damage to a SAFETY SYSTEM train that is required to be operable byTechnical Specifications for the current operating mode, and is in operation sinceindications for it will be readily available. The indications of degraded performanceshould be significant enough to cause concern regarding the operability or reliability ofthe SAFETY SYSTEM train.EAL #2.b BasisAddresses damage to a SAFETY SYSTEM component that is required to be operableby Technical Specifications for the current operating mode, and is not in operation orreadily apparent through indications alone, or to a structure containing SAFETYSYSTEM components. Operators will make this determination based on the totality ofavailable event and damage report information. This is intended to be a briefassessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC CS6 or RS1.If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):1. NEI 99-01 Rev 6, CA6Month 20XXTMI 3-110EP-AA-1009 (Revision XX) | |||
N Three MileIsa dnd St~ation Annex Fvialnn N~im-lonrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCU3Initiating Condition:Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Indicated voltage is < 105 VDC on required 125 VDC Distribution System 1A and 1Bfor> 15 minutes.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a loss of Vital DC power which compromises the ability to monitorand control operable SAFETY SYSTEMS when the plant is in the cold shutdown orrefueling mode. In these modes, the core decay heat load has been significantlyreduced, and coolant system temperatures and pressures are lower; these conditionsraise the time available to restore a vital DC bus to service. Thus, this condition isconsidered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to supportoperation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.For example, if Train A is out-of-service (inoperable) for scheduled outage maintenancework and Train B is in-service (operable), then a loss of Vital DC power affecting Train Bwould require the declaration of an Unusual Event. A loss of Vital DC power to Train Awould not warrant an emergency classification.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Depending upon the event, escalation of the emergency classification level would be viaIC CA6 or CA5, or an IC in Recognition Category R.Month 20XXTMI 3-111EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU3 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CU42. FSAR Section 8.2.2.6, 250/125 VDC System3. 1107-2C Vital DC Electrical System4. OP-TM-AOP-023, A DC System Failure5. OP-TM-AOP-024, B DC System FailureMonth 20XXTMI 3-112EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex 3x:lTn NuchnricTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU4Initiating Condition:Loss of all onsite or offsite communications capabilities.Operating Mode Applicability:5,6, DEmergency Action Level (EAL):1. Loss of ALL Table C1 Onsite communications capability affecting the ability toperform routine operations.OR2. Loss of ALL Table C1 Offsite communication capability affecting the ability toperform offsite notifications.OR3. Loss of ALL Table C1 NRC communication capability affectingperform NRC notifications.the ability toTable Cl Communications CapabilitySystem Onsite Offsite NRCRadios XPlant page XPlant Telephone System XSound Powered Phones XCommercial Telephones X X XNARS XENS X XHPN X XSatellite phones I X XBasis:This IC addresses a significant loss of on-site, offsite, or NRC communicationscapabilities. While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 addresses a total loss of the communications methods used in support ofroutine plant operations.Month 20XXTMI 3-113EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU4 (cont)Basis (cont):EAL #2 BasisAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form.EAL #3 BasisAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, CU52. 1105-12 Communications System3. FSAR Section 7.4.4, CommunicationMonth 20XXTMI 3-114EP-AA-1009 (Revision XX) | |||
Throo Milo lainnd Rfnfinn AnnavI:v,%1lnn Km,,-I--,rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA5Initiating Condition:Inability to maintain the plant in cold shutdown.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature > 2001F due to loss of decay heatremoval for > Table C2 duration.OR2. UNPLANNED RCS pressure rise > 10 psig as a result of temperature rise dueto loss of decay heat removal. (This EAL does not apply in solid plantconditions.)Table C2 RCS Heat-up Duration ThresholdsRCS Status Containment Closure Heat-upStatus DurationIntact Not Applicable 60 minutes*Not Intact Established 20 minutes*ORReduced Inventory Not Established 0 minutes* If an RCS heat removal system is in operation within this timeframe and RCS temperature is being reduced, then EAL #1 is notapplicable.Month 20XXTMI 3-115EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA5 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, etc.).This IC addresses conditions involving a loss of decay heat removal capability or anaddition of heat to the RCS in excess of that which can currently be removed. Eithercondition represents an actual or potential substantial degradation of the level of safetyof the plant.A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperaturewhen CONTAINMENT CLOSURE is established but the RCS is not intact, or RCSinventory is reduced (e.g., mid-loop operation in PWRs). The 20-minute criterion wasincluded to allow time for operator action to address the temperature rise.The RCS Heat-up Duration Thresholds table also addresses a rise in RCS temperaturewith the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in thiscondition since the intact RCS is providing a high pressure barrier to a fission productrelease. The 60-minute time frame should allow sufficient time to address thetemperature rise without a substantial degradation in plant safety.Finally, in the case where there is a rise in RCS temperature, the RCS is not intact or isat reduced inventory, and CONTAINMENT CLOSURE is not established, no heat-upduration is allowed (i.e., 0 minutes). This is because 1) the evaporated reactor coolantmay be released directly into the Containment atmosphere and subsequently to theenvironment, and 2) there is reduced reactor coolant inventory above the top ofirradiated fuel.EAL #2 BasisProvides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS6 or RS1.Month 20XXTMI 3-116EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA5 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CA32. Technical Specifications sections: 1.2.1, 1.7.a and c3. Technical Specifications sections: 3.6.12.a4. Technical Specifications sections: 3.6.55. Technical Specifications sections: 3.8.66. Technical Specifications sections: 1.2.1, 1.7.a and c, 3.6.12.a, 3.6.5, 3.8.67. 1101-3 Containment Integrity and Access Limits8. OP-TM-EOP-030, Loss of Decay Heat Removal9. Outage Fuel Protection Criteria DocumentMonth 20XXTMI 3-117EP-AA-1009 (Revision XX) | |||
Three MileIs land Staition Annex FYAlnn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU5Initiating Condition:UNPLANNED rise in RCS temperatureOperating Mode Applicability:5,6Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature > 200OF due to loss of decay heatremoval.OR2. Loss of the following for >15 minutes.* ALL RCS temperature indicationsAND* ALL RCS level indicationsBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.This IC addresses an UNPLANNED rise in RCS temperature above the TechnicalSpecification cold shutdown temperature limit, or the inability to determine RCStemperature and level, represents a potential degradation of the level of safety of theplant. If the RCS is not intact and CONTAINMENT CLOSURE is not established duringthis event, the Emergency Director should also refer to IC CA5.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.Month 20XXTMI 3-118EP-AA-1009 (Revision XX) | |||
N, Thra.o Mila~ IslandI Station Annex Fwainn NiirIanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU5 (cont)Basis (cont):EAL #1 involves a loss of decay heat removal capability, or an addition of heat to theRCS in excess of that which can currently be removed, such that reactor coolanttemperature cannot be maintained below the cold shutdown temperature limit specifiedin Technical Specifications. During this condition, there is no immediate threat of fueldamage because the core decay heat load has been reduced since the cessation ofpower operation.During an outage, the level in the reactor vessel will normally be maintained above thereactor vessel flange. Refueling evolutions that lower water level below the reactorvessel flange are carefully planned and controlled. A loss of forced decay heat removalat reduced inventory may result in a rapid rise in reactor coolant temperature dependingon the time after shutdown.EAL #2 reflects a condition where there has been a significant loss of instrumentationcapability necessary to monitor RCS conditions and operators would be unable tomonitor key parameters necessary to assure core decay heat removal. During thiscondition, there is no immediate threat of fuel damage because the core decay heatload has been reduced since the cessation of power operation.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA5 based onexceeding plant configuration-specific time criteria.Basis Reference(s):1. NEI 99-01 Rev 6, CU32. 1103-11 RCS Water Level Control3. FSAR Section 7.3.2, Non-Nuclear Instrumentation4. 1302-6.6 RCS Temp/Press, TSAT Monitor, ATWS and DSS Calibration5. NEI 99-01 Rev 5, CU46. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-119EP-AA-1009 (Revision XX) | |||
Three Mile kIslnd Station Annex FwAlnn NucleItarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCG6Initiating Condition:Loss of reactor vessel/RCS inventory affecting fuel clad integrity with containmentchallenged.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Reactor Vessel / RCS level unknown for > 30 minutes.AND2. Core uncovery is indicated by ANY of the following:" Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Erratic Source Range Neutron Monitor indication.OR* Radiation Monitor RM-G-6 or RM-G-7 reading > 3 R/hr.AND3. ANY Containment Challenge Indication (Table C4)Table C3 Indications of RCS Leakage* UNPLANNED Reactor Bldg Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise*" UNPLANNED BWST level rise** UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.Month 20XXTMI 3-120EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCG6 (cont)Emergency Action Level (EAL) (cont):Table C4 Containment Challenge Indications* Hydrogen Concentration in Containment > 4%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established** if CONTAINMENT CLOSURE is re-established prior to exceeding the30-minute core uncovery time limit, then escalation to a GeneralEmergency is not required.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.This IC addresses the inability to restore and maintain reactor vessel level above thetop of active fuel with containment challenged. This condition represents actual orIMMINENT substantial core degradation or melting with potential for loss of containmentintegrity. Releases can be reasonably expected to exceed EPA Protective ActionGuidelines (PAG) exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a directand unmonitored release of radioactivity to the environment. If CONTAINMENTCLOSURE is re-established prior to exceeding the 30-minute time limit, then declarationof a General Emergency is not required.Month 20XXTMI 3-121EP-AA-1009 (Revision XX) | |||
Thran RAilda lainnei -Q+n+irn AnnovI~v-Inlrn K, ,ig----rThra~~ MiI~ Ic6nrI ~*~h$inn Annav ~v~Ii~n hi I *f~ I ~ rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCG6 (cont)Basis (cont):The existence of an explosive mixture means, at a minimum, that the containmentatmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity. Ittherefore represents a challenge to Containment integrity.In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to acore uncovery could result in an explosive gas mixture in containment. If all installedhydrogen gas monitors are out-of-service during an event leading to fuel claddingdamage, it may not be possible to obtain a containment hydrogen gas concentrationreading as ambient conditions within the containment will preclude personnel access.During periods when installed containment hydrogen gas monitors are out-of-service,operators may use the other listed indications to assess whether or not containment ischallenged.The 30-minute criterion is tied to a readily recognizable event start time (i.e., the totalloss of ability to monitor level), and allows sufficient time to monitor, assess andcorrelate reactor and plant conditions to determine if core uncovery has actuallyoccurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor reactor vessel/RCS level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the reactor vessel/RCS.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Month 20XXTMI 3-122EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCG6 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CG12. 1103-11 RCS Water Level Control3. 1101-3 Containment Integrity and Access Limits4. OP-TM-EOP-030, Loss of Decay Heat Removal5. FSAR Sections 5.2, Reactor Building6. FSAR Sections 6.5.2, Hydrogen Monitoring7. FSAR Sections 6.5.3, Hydrogen Generation8. Technical Specifications 3.5.5, Accident Monitoring Instrumentation9. EP-AEL-0501, Estimation of Radiation Monitor Readings Indicating CoreUncovery During Refuel10. 1301-1 Shift and Daily Checks, Data Sheet 3Month 20XXTMI 3-123EP-AA-1009 (Revision XX) | |||
Three Mile kIslnd Sta~tion Annex FvAinn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCS6Initiating Condition:Loss of reactor vessel/RCS inventory affecting core decay heat removal capability.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. Reactor Vessel / RCS level unknown for >30 minutes.AND2. Core uncovery is indicated by ANY of the following:" Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Erratic Source Range Neutron Monitor indication.OR* Radiation Monitors RM-G-6 or RM-G-7 reading > 3 R/hr.Table C3 Indications of RCS Leakage* UNPLANNED Reactor Bldg Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise** UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.Month 20XXTMI 3-124EP-AA-1009 (Revision XX) | |||
Three MileIsa mnd Station Annex FvAinn N~uclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCS6 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.The lost inventory may be due to a RCS component failure, a loss of configurationcontrol or prolonged boiling of reactor coolant. These conditions entail major failures ofplant functions needed for protection of the public and thus warrant a Site AreaEmergency declaration.Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.Outage/shutdown contingency plans typically provide for re-establishing or verifyingCONTAINMENT CLOSURE following a loss of heat removal or RCS inventory controlfunctions.The 30-minute criterion is tied to a readily recognizable event start time (i.e., the totalloss of ability to monitor level), and allows sufficient time to monitor, assess andcorrelate reactor and plant conditions to determine if core uncovery has actuallyoccurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor reactor vessel/RCS level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the reactor vessel/RCS.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Escalation of the emergency classification level would be via IC CG6 or RG1.Month 20XXTMI 3-125EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCS6 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CS12. OP-TM-PRF1-0405 RB Sump Level Hi3. 1101-3 Containment Integrity and Access Limits4. 1301-1 Shift and Daily Checks, Data Sheet 35. 1103-11 RCS Water Level Control6. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-126EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA6Initiating Condition:Loss of reactor vessel/RCS inventory.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of Reactor Vessel / RCS inventory as indicated by RCS level< 0 inches on Draindown Level indicator.OR2. a. Reactor Vessel / RCS level unknown for > 15 minutes.ANDb. Loss of Reactor Vessel / RCS inventory per Table C3 indications.Table C3 Indications of RCS Leakage" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise*" UNPLANNED BWST level rise*" UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.Month 20XXTMI 3-127EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearThre Mil Isand taton AnexExelon Nuclea~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA6 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses conditions that are precursors to a loss of the ability to adequatelycool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). Thiscondition represents a potential substantial reduction in the level of plant safety.EAL #1 BasisA lowering of water level below 0 inches on Draindown Level indicator indicates thatoperator actions have not been successful in restoring and maintaining reactorvessel/RCS water level. The heat-up rate of the coolant will rise as the available waterinventory is reduced. A continuing drop in water level will lead to core uncovery.Although related, EAL #1 is concerned with the loss of RCS inventory and not thepotential concurrent effects on systems needed for decay heat removal (e.g., loss of aResidual Heat Removal suction point). A rise in RCS temperature caused by a loss ofdecay heat removal capability is evaluated under IC CA5.EAL #2 BasisThe inability to monitor reactor vessel/RCS level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the reactor vessel/RCS.The 15-minute duration for the loss of level indication was chosen because it is half ofthe EAL duration specified in IC CS6If the reactor vessel/RCS inventory level continues to lower, then escalation to Site AreaEmergency would be via IC CS6.Basis Reference(s):1. NEI 99-01 Rev 6, CA12. OP-TM-PRF1-0405 RB Sump Level Hi3. 1301-1 Shift and Daily Checks, Data Sheet 34. 1103-11 RCS Water Level Control5. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-128EP-AA-1009 (Revision XX) l:xmlnn Three Mile Island Station Annex Fvl:n Nucha srisTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU6Initiating Condition:UNPLANNED loss of reactor vessel/RCS inventory for 15 minutes or longer.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED loss of reactor coolant results in the inability to restore andmaintain Reactor Vessel / RCS level to > procedurally established lower limitfor > 15 minutes.OR2. a. Reactor Vessel / RCS level unknown.ANDb. Loss of Reactor Vessel / RCS inventory per Table C3 indications.Table C3 Indications of RCS Leakage" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise*" UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses the inability to restore and maintain water level to a requiredminimum level (or the lower limit of a level band), or a loss of the ability to monitorreactor vessel/RCS level concurrent with indications of coolant leakage. Either of theseconditions is considered to be a potential degradation of the level of safety of the plant.Month 20XXTMI 3-129EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU6 (cont)Basis (cont):The procedurally established lower limit is not an operational band established abovethe procedural limit to allow for operator action prior to exceeding the procedural limit,but it is the procedurally established lower limit.Refueling evolutions that lower RCS water inventory are carefully planned andcontrolled. An UNPLANNED event that results in water level decreasing below aprocedurally required limit warrants the declaration of an Unusual Event due to thereduced water inventory that is available to keep the core covered.EAL #1 BasisRecognizes that the minimum required reactor vessel/RCS level can change severaltimes during the course of a refueling outage as different plant configurations andsystem lineups are implemented. This EAL is met if the minimum level, specified for thecurrent plant conditions, cannot be maintained for 15 minutes or longer. The minimumlevel is typically specified in the applicable operating procedure but may be specified inanother controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions torestore and maintain the expected water level. This criterion excludes transientconditions causing a brief lowering of water level.EAL #2 BasisAddresses a condition where all means to determine reactor vessel/RCS level havebeen lost. In this condition, operators may determine that an inventory loss is occurringby observing changes in sump and/or tank levels. Sump and/or tank level changesmust be evaluated against other potential sources of water flow to ensure they areindicative of leakage from the reactor vessel/RCS.Continued loss of RCS inventory may result in escalation to the Alert emergencyclassification level via either IC CA6 or CA5.Basis Reference(s):1. NEI 99-01, Rev. 6 CU12. Technical Specification 3.1.6. Leakage3. OP-TM-220-251 RCS Leak Rate Determination Using PPC4. OP-TM-220-252, Primary -To -Secondary Leakrate Determination (OTSGLeakage): Normal Operations5. OP-TM-MAP-C0105 RCS Draindown LVL HI/LO6. OP-TM-PRF1-0405 RB Sump Level HI7. UFSAR 6.4.3, Bases of Leakage Estimate8. 1103-11 RCS Water Level Control9. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-130EP-AA-1009 (Revision XX) | |||
Three Mile Islamnd Stt~ion Annex~ Fvalnn NwirlonrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1Initiating Condition:HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):1. A notification from the Security Force that a HOSTILE ACTION is occurring orhas occurred within the PROTECTED AREA.AND2. a. ANY Table H1 safety function cannot be controlled or maintained.ORb. Damage to spent fuel has occurred or is IMMINENTTable H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* Core Cooling (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.Month 20XXTMI 13-131EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annexm m ThreeMileIslad Staion nnexFvAon Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1 (cont)Basis (cont):HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.This IC addresses an event in which a HOSTILE FORCE has taken physical control ofthe facility to the extent that the plant staff can no longer operate equipment necessaryto maintain key safety functions. It also addresses a HOSTILE ACTION leading to aloss of physical control that results in actual or IMMINENT damage to spent fuel due to1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls,etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot bemaintained.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].contained in non-public documents such as the Security Plan.Basis Reference(s):1. NEI 99-01, Rev. 6 HG12. Security and Safeguards Contingency Plan Station Security Plan -Appendix CMonth 20XXTMI 3-132EP-AA-1009 (Revision XX) | |||
Thrina RAHAm lalnnrl -Qfnfirn AnnavPimyglrnn N, gl-nerThr~ MiIg& Ie6nrI Q*~t.vhn Ann~v Fv~Ir~n hi. ir~Ic~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS1.Initiating Condition:HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:1, 2,3,4,5,6, DEmergency Action Level (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTEDAREA. This event will require rapid response and assistance due to the possibility fordamage to plant equipment.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Month 20XXTMI 3-133EP-AA-1 009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS1 (cont)Basis (cont):Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Site Area Emergency declaration will mobilize OROresources and have them available to develop and implement public protective actionsin the unlikely event that the attack is successful in impairing multiple safety functions.This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTEDAREA located outside the plant PROTECTED AREA; such an attack should beassessed using IC HAl. It also does not apply to incidents that are accidental events,acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by aHOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters,physical disputes between employees, etc. Reporting of these types of events isadequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR§ 50.72.Escalation of the emergency classification level would be via IC HG1.Basis Reference(s):1. NEI 99-01 Rev 6, HS12. Security and Safeguards Contingency Plan Station Security Plan -Appendix CMonth 20XXTMI 3-134EP-AA-1009 (Revision XX) | |||
Three Mile kIslnd S~tation Annex FvPInn NucleIarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHAIInitiating Condition:HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threatwithin 30 minutes.Operating Mode Applicability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutes fromthe site.OR2. Notification by the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the OWNER CONTROLED AREA.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.OWNER CONTROLLED AREA (OCA): The property associated with the station andowned by the company. Access is normally limited to persons entering for officialbusiness.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.This IC addresses the occurrence of a HOSTILE ACTION within the OWNERCONTROLLED AREA or notification of an aircraft attack threat. This event will requirerapid response and assistance due to the possibility of the attack progressing to theMonth 20XXTMI 3-135EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHAI (cont)Basis (cont):This IC addresses the occurrence of a HOSTILE ACTION within the OWNERCONTROLLED AREA or notification of an aircraft attack threat. This event will requirerapid response and assistance due to the possibility of the attack progressing to thePROTECTED AREA, or the need to prepare the plant and staff for a potential aircraftimpact. Timely and accurate communications between Security Shift Supervision andthe Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Alert declaration will also heighten the awareness ofOffsite Response Organizations, allowing them to be better prepared should it benecessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience,or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputesbetween employees, etc. Reporting of these types of events is adequately addressedby other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL #1 addresses the threat from the impact of an aircraft on the plant, and theanticipated arrival time is within 30 minutes. The intent of this EAL is to ensure thatthreat-related notifications are made in a timely manner so that plant personnel andOROs are in a heightened state of readiness. This EAL is met when the threat-relatedinformation has been validated in accordance with OP-TM-AOP-008, Security Threat /Intrusion.EAL #2 is applicable for any HOSTILE ACTION occurring, or that has occurred, in theOWNER CONTROLLED AREA. This includes any action directed against an ISFSI thatis located outside the plant PROTECTED AREA.The NRC Headquarters Operations Officer (HOO) will communicate to the licensee ifthe threat involves an aircraft. The status and size of the plane may be provided byNORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNERCONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected,although not certain, that notification by an appropriate Federal agency to the site wouldclarify this point. In this case, the appropriate federal agency is intended to be NORAD,FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs,should not be unduly delayed while awaiting notification by a Federal agency.Escalation of the emergency classification level would be via IC HS1.Month 20XXTMI 3-136EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHAI (cont)Basis Reference(s):1. NEI 99-01 Rev 6, HA12. Security and Safeguards Contingency Plan Station Security Plan -Appendix C3. OP-TM-AOP-008, Security Threat / IntrusionMonth 20XXTMI 3-137EP-AA-1009 (Revision XX) | |||
Fxelnn Three Mile~ kIslnd Station Annex FvAlnn NuclekarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU1Initiating Condition:Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:1, 2,3,4,5,6, DEmergency Action Level (EAL):1. Notification of a credible security threat directed at the site as determined perSY-AA-101-132, Security Assessment and Response to Unusual Activities.OR2. A validated notification from the NRC providing information of an aircraft threat.OR3. Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.Basis:SECURITY CONDITION: Any Security Event as listed in the approved securitycontingency plan that constitutes a threat/compromise to site security, threat/risk to sitepersonnel, or a potential degradation to the level of safety of the plant. A SECURITYCONDITION does not involve a HOSTILE ACTIONSAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.Month 20XXTMI 3-138EP-AA-1009 (Revision XX) | |||
Thran Win IQ12nri Q+!m+irn AnnavC%-d%1#%n Khir-ldmýrThr~ MiIc, IeI~anrI ~*~*.r~n Annav *5 .. | |||
* w* .*. ...... --.... .r.. ...n fl~I %.1 I I~ L 1 ~OITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHUl (cont)Basis (cont):This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEMequipment, and thus represent a potential degradation in the level of plant safety.Security events which do not meet one of these EALs are adequately addressed by therequirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed asHOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Classification of these events will initiate appropriate threat-related notifications to plantpersonnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 addresses the receipt of a credible security threat. The credibility of the threatis assessed in accordance with SY-AA-101-132.EAL #2 addresses the threat from the impact of an aircraft on the plant. The NRCHeadquarters Operations Officer (HOO) will communicate to the licensee if the threatinvolves an aircraft. The status and size of the plane may also be provided by NORADthrough the NRC. Validation of the threat is performed in accordance with OP-TM-AOP-008, Security Threat / Intrusion.EAL #3 references Security Force because these are the individuals trained to confirmthat a security event is occurring or has occurred. Training on security eventconfirmation and classification is controlled due to the nature of Safeguards and 10 CFR§ 2.39 information.Escalation of the emergency classification level would be via IC HAl.Basis Reference(s):1. NEI 99-01 Rev 6, HU12. SY-AA-101-132, Security Assessment and Response to Unusual Activities3. Security And Safeguards Contingency Plan Station Security Plan -Appendix CMonth 20XXTMI 3-139EP-AA-1009 (Revision XX) | |||
Throa RAila lainnd Rtnfinn AnnovIPvg'lrnn KIuorlimrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS2Initiating Condition:Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per OP-TM-EOP-020, Cooldown from Outsidethe Control Room.AND2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.Table H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* Core Cooling (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Basis:The time period to establish control of the plant starts when either:a. Control of the plant is no longer maintained in the Main Control RoomORb. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations, and the control of a key safety function cannot bereestablished in a timely manner. The failure to gain control of a key safety functionfollowing a transfer of plan control to alternate locations is a precursor to a challenge toany fission product barriers within a relatively short period of time.Month 20XXTMI 3-140EP-AA-1009 (Revision XX) | |||
I=-zpinn Niie.IprThree Mile Island Station AnnexFYnnNIAaTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS2 (cont)Basis (cont):The determination of whether or not "control" is established at the remote safeshutdown location(s) is based on Emergency Director judgment. The EmergencyDirector is expected to make a reasonable, informed judgment within 15 minuteswhether or not the operating staff has control of key safety functions from the remotesafe shutdown location(s).Escalation of the emergency classification level would be via IC FG1 or CG6.Basis Reference(s):1. NEI 99-01, Rev 6 HS62. OP-TM-EOP-020, Cooldown from Outside the Control RoomMonth 20XXTMI 3-141EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA2Initiating Condition:Control Room evacuation resulting in transfer of plant control to alternate locations.Operating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per OP-TM-EOP-020, Cooldown from Outside theControl Room.Basis:This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations outside the Control Room. The loss of the ability to controlthe plant from the Control Room is considered to be a potential substantial degradationin the level of plant safety.Following a Control Room evacuation, control of the plant will be transferred to alternateshutdown locations. The necessity to control a plant shutdown from outside the ControlRoom, in addition to responding to the event that required the evacuation of the ControlRoom, will present challenges to plant operators and other on-shift personnel.Activation of the ERO and emergency response facilities will assist in responding tothese challenges.Escalation of the emergency classification level would be via IC HS2.Basis Reference(s):1. NEI 99-01, Rev 6 HA62. OP-TM-EOP-020, Cooldown from Outside the Control RoomMonth 20XXTMI 3-142EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3Initiating Condition:FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of thefollowing FIRE detection indications:" Report from the field (i.e., visual observation)" Receipt of multiple (more than 1) fire alarms or indications* Field verification of a single fire alarmOR2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indicationsof a FIRE).ANDb. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.OR3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes ofthe initial report, alarm or indication.OR4 A FIRE within the plant PROTECTED AREA that requires firefighting support byan offsite fire response agency to extinguish.Month 20XXTMI 3-143EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexNuclearThre Mil Isand taton AnexExelnn NucilearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)Emergency Action Level (EAL) (cont):Table H2 Vital Areas* Reactor Building* Intake Building* Intermediate Building0 Control Tower0 Auxiliary and Fuel Handling Buildings0 1A and 1B Diesel Generator Buildings* BWSTo CSTBasis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of apotential degradation of the level of safety of the plant.EAL #1 BasisThe intent of the 15-minute duration is to size the FIRE and to discriminate againstsmall FIRES that are readily extinguished (e.g., smoldering waste paper basket). Inaddition to alarms, other indications of a FIRE could be a drop in fire main pressure,automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial firealarm, indication, or report. For EAL assessment purposes, the emergency declarationclock starts at the time that the initial alarm, indication, or report was received, and notthe time that a subsequent verification action was performed. Similarly, the fire durationclock also starts at the time of receipt of the initial alarms, indication or report.EAL #2 BasisAddresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e.,proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will takeprompt actions to confirm the validity of a single fire alarm. For EAL assessmentpurposes, the 30-minute clock starts at the time that the initial alarm was received, andnot the time that a subsequent verification action was performed.Month 20XXTMI 3-144EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)Basis (cont):A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipmentfailure or a spurious activation, and not an actual FIRE. For this reason, additional timeis allowed to verify the validity of the alarm. The 30-minute period is a reasonableamount of time to determine if an actual FIRE exists; however, after that time, andabsent information to the contrary, it is assumed that an actual FIRE is in progress.If an actual FIRE is verified by a report from the field, then EAL #1 is immediatelyapplicable, and the emergency must be declared if the FIRE is not extinguished within15-minutes of the report. If the alarm is verified to be due to an equipment failure or aspurious activation, and this verification occurs within 30-minutes of the receipt of thealarm, then this EAL is not applicable and no emergency declaration is warranted.EAL #3 BasisIn addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plantPROTECTED AREA not extinguished within 60-minutes may also potentially degradethe level of plant safety.EAL #4 BasisIf a FIRE within the plant PROTECTED AREA is of sufficient size to require a responseby an offsite firefighting agency (e.g., a local town Fire Department), then the level ofplant safety is potentially degraded. The dispatch of an offsite firefighting agency to thesite requires an emergency declaration only if it is needed to actively support firefightingefforts because the fire is beyond the capability of the Fire Brigade to extinguish.Declaration is not necessary if the agency resources are placed on stand-by, orsupporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix RAppendix R to 10 CFR 50, states in part:Criterion 3 of Appendix A to this part specifies that "Structures, systems, andcomponents important to safety shall be designed and located to minimize,consistent with other safety requirements, the probability and effect of fires andexplosions."When considering the effects of fire, those systems associated with achievingand maintaining safe shutdown conditions assume major importance to safetybecause damage to them can lead to core damage resulting from loss of coolantthrough boil-off.Month 20XXTMI 37145EP-AA-1009 (Revision XX) | |||
Three Mile Isla~nd Station Annex FvieInn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)Basis (cont):Because fire may affect safe shutdown systems and because the loss of functionof systems used to mitigate the consequences of design basis accidents underpost-fire conditions does not per se impact public safety, the need to limit firedamage to systems required to achieve and maintain safe shutdown conditions isgreater than the need to limit fire damage to those systems required to mitigatethe consequences of design basis accidents.In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of1-hour fire barriers for the enclosure of cable and equipment and associated non-safetycircuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify asingle alarm is well within this worst-case 1-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA2 or MA5.Basis Reference(s):1. NEI 99-01, Rev 6 HU42. FSAR Figure 2.1-3, Extended Plot Plan TMINS3. FSAR Section 5.1, Class I Structures, Components, and Systems4. OP-TM-AOP-001, Fire5. OP-TM-EOP-020, Cooldown Outside of Control RoomMonth 20XXTMI 13-146EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU4Initiating Condition:Seismic event greater than OBE levels.Operating Mode Applicability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):Seismic event > Operating Basis Earthquake (OBE) as indicated by seismic AlarmsPRF-1-3 Operating Basis earthquake and PRF-1-2 Threshold Seismic Condition.Basis:This IC addresses a seismic event that results in accelerations at the plant site greaterthan those specified for an Operating Basis Earthquake (OBE)1.An earthquake greaterthan an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have nosignificant impact on safety-related systems, structures and components; however,some time may be required for the plant staff to ascertain the actual post-eventcondition of the plant (e.g., performs walk-downs and post-event inspections). Giventhe time necessary to perform walk-downs and inspections, and fully understand anyimpacts, this event represents a potential degradation of the level of safety of the plant.Event verification with external sources should not be necessary during or following anOBE. Earthquakes of this magnitude should be readily felt by on-site personnel andrecognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).The Shift Manager or Emergency Director may seek external verification if deemedappropriate (e.g., a call to the USGS, check internet news sources, etc.); however, theverification action must not preclude a timely emergency declaration.Depending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA2 or MA5.Basis Reference(s):1. NEI 99-01, Rev 6 HU22. OP-TM-AOP-003, Earthquake3. PRF 1-3 Operating Bases Earthquake4. PRF 1-2 Threshold Seismic Event1 An OBE is vibratory ground motion for which those features of a nuclear power plantnecessary for continued operation without undue risk to the health and safety of thepublic will remain functional.An SSE is vibratory ground motion for which certain (generally, safety-related)structures, systems, and components must be designed to remain functional.Month 20XXTMI 3-147EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5Initiating Condition:Gaseous release impeding access to equipment necessary for normal plant operations,cooldown or shutdown.Operating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):Note:If the equipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emergency classification is warranted.1. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area.Table H3Areas with Entry Related Mode ApplicabilityArea Entry Related ModeApplicabilityReactor Building* Modes 4, 5, and 6Intermediate Building* Modes 4, 5, and 6Auxiliary Building* Modes 4, 5, and 6Fuel Handling Building* Modes 4, 5, and 6*Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impededBasis:This IC addresses an event involving a release of a hazardous gas that precludes orimpedes access to equipment necessary to transition the plant from normal plantoperation to cooldown and shutdown as specified in normal plant procedures. Thiscondition represents an actual or potential substantial degradation of the level of safetyof the plant.Month 20XXTMI 3-148EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5 (cont)Basis (cont):Table H3 is a list of plant rooms or areas with entry-related mode applicability thatcontain equipment which require a manual/local action necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal operatingprocedures (establish shutdown cooling), where if this action is not completed the plantwould not be able to attain and maintain cold shutdown. This Table does not includerooms or areas for which entry is required solely to perform actions of an administrativeor record keeping nature (e.g., normal rounds or routine inspections).This Table does not include the Control Room since adequate engineered safety/designfeatures are in place to preclude a Control Room evacuation due to the release of ahazardous gas.An Alert declaration is warranted if entry into the affected room/area is, or may be,procedurally required during the plant operating mode in effect and the gaseous releasepreclude the ability to place shutdown cooling in service. The emergency classificationis not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires theEmergency Director's judgment that the gas concentration in the affected room/area issufficient to preclude or significantly impede procedurally required access. Thisjudgment may be based on a variety of factors including an existing job hazard analysis,report of ill effects on personnel, advice from a subject matter expert or operatingexperience with the same or similar hazards. Access should be considered as impededif extraordinary measures are necessary to facilitate entry of personnel into the affectedroom/area (e.g., requiring use of protective equipment, such as SCBAs, that is notroutinely employed).An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the timeof the gaseous release). For example, the plant is in Mode 1 when the gaseousrelease occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4." The gas release is a planned activity that includes compensatory measures whichaddress the temporary inaccessibility of a room or area (e.g., fire suppressionsystem testing)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.Month 20XXTMI 3-149EP-AA-1009 (Revision XX) | |||
NtislAirThree MileIsa dnd Station Annex FvAlnn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5 (cont)Basis (cont):An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerouslevels. Most commonly, asphyxiants work by merely displacing air in an enclosedenvironment. This reduces the concentration of oxygen below the normal level ofaround 19%, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that generate smoke or thatautomatically or manually activate a fire suppression system in an area.Escalation of the emergency classification level would be via Recognition Category R, Cor F ICs.Basis Reference(s):1. NEI 99-01, Rev 6 HA52. FSAR Figure 2.1-3, Extended Plot Plan TMINS3. FSAR Section 5.1, Class I Structures, Components, and Systems4. NEI 99-01, Rev. 5 HA35. OP-TM-406-901, Hazardous Material Release6. AR-660892, Station Halon and IDLH Evaluations7. 29CFR1910.134(b) and 29CFR1910.134(d)(2)(iii)Month 20XXTMI 3-150EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU6Initiating Condition:Hazardous EventOperating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):Note:EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, orvehicle breakdowns or accidents.1. Tornado strike within the PROTECTED AREA.OR2. Internal room or area flooding of a magnitude sufficient to require manual orautomatic electrical isolation of a SAFETY SYSTEM component required byTechnical Specifications for the current operating mode.OR3. Movement of personnel within the PROTECTED AREA is impeded due to an offsiteevent involving hazardous materials (e.g., an offsite chemical spill or toxic gasrelease).OR4. A hazardous event that results in on-site conditions sufficient to prohibit the plantstaff from accessing the site via personal vehicles.OR5. Abnormal river water level at the intake Pump and Screen House, as indicated byEITHER:a. > 300 ft. el. (high level)ORb. < 274 ft. el. (low level)Basis:PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.Month 20XXTMI 3-151EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU6 (cont)Basis (cont):This IC addresses hazardous events that are considered to represent a potentialdegradation of the level of safety of the plant.EAL I BasisAddresses a tornado striking (touching down) within the Protected Area.EAL #2 BasisAddresses flooding of a building room or area that results in operators isolating power toa SAFETY SYSTEM component due to water level or other wetting concerns.Classification is also required if the water level or related wetting causes an automaticisolation of a SAFETY SYSTEM component from its power source (e.g., a breaker orrelay trip). To warrant classification, operability of the affected component must berequired by Technical Specifications for the current operating mode. Manual isolation ofpower to a SAFETY SYSTEM component as a result of is an event of lesser impact andwould be expected to cause small and localized damage. The consequence of this typeof event is adequately assessed and addressed in accordance with TechnicalSpecifications.EAL #3 BasisAddresses a hazardous materials event originating at an offsite location and of sufficientmagnitude to impede the movement of personnel within the PROTECTED AREA.EAL #4 BasisAddresses a hazardous event that causes an on-site impediment to vehicle movementand significant enough to prohibit the plant staff from accessing the site using personalvehicles. Examples of such an event include site flooding caused by a hurricane, heavyrains, up-river water releases, dam failure, etc., or an on-site train derailment blockingthe access road.This EAL is not intended to apply to routine impediments such as fog, snow, ice, orvehicle breakdowns or accidents, but rather to more significant conditions such as theHurricane Andrew strike on Turkey Point in 1992, the flooding around the CooperStation during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in2011.Escalation of the emergency classification level would be based on ICs in RecognitionCategories R, F, M, H or C.Basis Reference(s):1. NEI 99-01, Rev 6 HU32. OP-TM-AOP-005 River Water System Failures3. OP-TM-AOP-002, Flood4. OP-TM-AOP-004, Tornado / High WindsMonth 20XXTMI 3-152EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU6 (cont)B asis .(co~nt): .i .,.'~ ii..i .!. '.. ...... ... ...... .... ..... .. .. .. ..... .. ....EAL #5 Basis:The level of the Susquehanna River is approaching flood stage; flood stage is definedas 302 ft el. at the Intake Pump and Screen House.A low river water condition below 274 ft el. requires a Technical Specification 3.0.1 plantshutdown per OP-TM-AOP-005 and is a precursor to a more serious condition.Escalation of the emergency classification level would be based on ICs in RecognitionCategories R, F, M, H or C.Basis Reference(s):,,1. NEI 99-01, Rev 6 HU32. OP-TM-AOP-005 River Water System Failures3. OP-TM-AOP-002, Flood4. OP-TM-AOP-004, Tornado / High WindsMonth 20XXTMI 3-153EP-AA-1009 (Revision XX) | |||
Three Mile Island Station Annex Exelnn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a GENERAL EMERGENCY.Operating Mode Applicability:1,2, 3, 4, 5, 6, DEimergencyi Action LevelE(EAL):Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which involve actual or IMMINENT substantialcore degradation or melting with potential for loss of containment integrity or HOSTILEACTION that results in an actual loss of physical control of the facility. Releases can bereasonably expected to exceed EPA Protective Action Guideline exposure levels offsitefor more than the immediate site area.IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for aGeneral Emergency.Basis Refere.ce():1.. ........ ....e1 -O 1 ,..ev 6 H ................. ..... ... .....G..... .... ...1. NEI 99-01, Rev 6 HG7Month 20XXTMI 3-154EP-AA-1009 (Revision XX) | |||
Throp Milo 14miand Qfafinn AnnoyI:valnn Ikl, AaharThr~ MiIu~ IQI~nrI ~t~tinn Ann~y Fv~Inn NI. .r~I~~irTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS7!n~itiatir~gl | |||
* ondition~ i:"i ....... ..i. .............. ... i. .". ... ........ .... ....... ........... ...... ....Initiating Condition::Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a SITE AREA EMERGENCY.Operating ModeAppihcability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):..Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which involve actual or likely major failures ofplant functions needed for protection of the public or HOSTILE ACTION that results inintentional damage or malicious acts, (1) toward site personnel or equipment that couldlead to the likely failure of or, (2) that prevent effective access to equipment needed forthe protection of the public. Any releases are not expected to result in exposure levelswhich exceed EPA Protective Action Guideline exposure levels beyond the siteboundary.B a s is : .. ..:. ." ......HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for a SiteArea Emergency..- ... ... ..* ..... .. ..Basis 9Reference(s):1. NEI 99-01, Rev 6HS7Month 20XXTMI 3-155EP-AA-1009 (Revision XX) | |||
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA7Initiating Condition:.,:,Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an ALERT.operating Mode Applicability. .. r.tin. ....Appl i..l....i1,2,3, 4,5,6, DEmergency Action Level (EAL): -Other conditions exist which, in the judgment of the Emergency Director, indicate thatevents are in progress or have occurred which involve an actual or potential substantialdegradation of the level of safety of the plant or a security event that involves probablelife threatening risk to site personnel or damage to site equipment because of HOSTILEACTION. Any releases are expected to be limited to small fractions of the EPAProtective Action Guideline exposure levels.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anAlert.Basis Reference(s)-:.... ....................................1 .. ... ...... ....1 .NEI 99-01, Rev 6 HA7Month 20XXTMI 3-156EP-AA-1009 (Revision XX) | |||
Thragm Win lalanrl Qfatien AnngvPvgslrn KI"r-IghinrTkr~ MiI~ lelanri Qtat.r~n Annav ~veIii~ Mm ~ S S 55~~ *W* 55 **S.* 5 tUt*** 155 I. 1 fl~ I 5.11 I EU La 5 *~C ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU7Initiating Condition:..Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an UNUSUAL EVENT.Ope~rating Mode'..Applicability:..:,.., .1,2,3, 4,5,6, DEmergency Action Level (EAL):.Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which indicate a potential degradation of thelevel of safety of the plant or indicate a security threat to facility protection has beeninitiated. No releases of radioactive material requiring offsite response or monitoring areexpected unless further degradation of safety systems occurs.Basis:This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anUNUSUAL EVENT.Basis Reference(s):1. NEI 99-01, Rev 6HU7Month 20XXTMI 3-157EP-AA-1009 (Revision XX)}} | |||
Revision as of 04:44, 28 June 2018
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Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSU76Initiating Condition:Loss of all On-site or Off-site communications capabilities.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):1. Loss of ALL Table M3 Onsite communications capability affecting the ability toperform routine operations.OR2. Loss of ALL Table M3 Offsite communication capability affectina the abilitv toperform offsite notifications.OR3. Loss of ALL Table M3 NRC communication capability affecting the ability toperform NRC notifications.Table M3 Communications CaDabilitvSystem Onsite Offsite NRCRadios XPlant page XPlant Telephone System XSound Powered Phones XCommercial Telephones X X XNARS XENS X XHPN X XSatellite phones _ X X1. Loss of ALL of tho following oncito communication mIothods:*v(sito spocific_ list of coemmunications mcthed+-6^ f4o-_s--IMonth 20XXTMI 3-80EP-AA-1009 (Revision XX)
Exelon NuclearThree Mile Island Station Annex Exellon NuceIarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONS(cito spocific list Of communUi~cations mcthodG)3. Loss of ALL o tho foloi the NRC comuic. ations methods'(site spocif ic list. of coammunications methods)Basis:I This IC addresses a significant loss of on-site-, offsite, or NRC OFeffskecommunications capabilities. While not a direct challenge to plant or personnel safety,I this event warrants prompt notifications to Offsite Response Organizations (OROs. andthe NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 BasisaAddresses a total loss of the communications methods used in support of routine plantoperations.EAL #2 BasisaAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in procedure EP-MA-1 14-1 00-F-01, State / Local Event Notification Form. (coo EAL #3 basisaAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, SU62. 1105-12 Communications System3. FSAR Section 7.4.4, CommunicationMonth 20XXTMI 3-81EP-AA-1009 (Revision XX)
Throm Uila Wa6nd Qtatinn AnnovI=Yalnn TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSU87Initiating Condition:Failure to isolate containment or loss of containment pressure control.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):1. a. Failure of containment to isolate when required by an actuation signal.ANDb. ANY required penetration remains open > 15 minutes of the actuationsignaL.ALL required penetrations aro not Glosod within 15 minutes ofthaGuaten signal.OR2. a. Reactor Buildina pressure > 30 DSiaANDb. Reactor Building Emergency cooling is less than ANY one of the followingconditions > 15 minutes:SPRAY COOLERS2 00 31 1a. Gontainment wersesr grcater man (Site S~eGITIG wroccurci.lANDL- I I-W.. ...utit. I.~I _R"~ -ui; -w.U-1 1-0.i VI! tbi.,,,b 't-iPH ~~V Id UttK1iW~t 1b~;~u~ IddIK1t V..,A ai~r f ir, I + i~ ~rI~i~IIUzi birl %7r m Hxx quo %7r x7ritit7r.Basis:This IC addresses a failure of one Or any containment penetrations toautomatically isolate (close) when required by an actuation signal. It also addresses anevent that results in high containment pressure with a concurrent failure of containmentpressure control systems. Absent challenges to another fission product barrier, eithercondition represents potential degradation of the level of safety of the plant.Month 20XXTMI 3-82EP-AA-1009 (Revision XX)
Tkriags Uild li@Innr Qfc*irtun AuingvIP:v-alfn NimdlachTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSFer-EAL #1 Basis,-The containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); afailure resulting from testing or maintenance does not warrant classification. Thedetermination of containment and penetration status -isolated or not isolated -shouldbe made in accordance with the appropriate criteria contained in the plant AOPs andEOPs. The 15-minute criterion is included to allow operators time to manually isolatethe required penetrations, if possible.EAL #2 BasisaAddresses a condition where containment pressure is greater than the setpoint atwhich containment energy (heat) removal systems are designed to automaticallyactuate, and less than one full train of equipment is capable of operating per design.The 15-minute criterion is included to allow operators time to manually start equipmentthat may not have automatically started, if possible. The inability to start the requiredequipment indicates that containment heat removal/depressurization systems (e.g.,containment sprays or ice condenser fans) are either lost or performing in a degradedmanner.This event would escalate to a Site Area Emergency in accordance with IC FS1 if therewere a concurrent loss or potential loss of either the Fuel Clad or RCS fission productbarriers.Basis Reference(s):1. NEI 99-01 Rev 6, SU72. FSAR Section 6.6 Reactor Building Pressure-Time Response3. Technical Specifications 3.5.3, Engineered Safeguards Protection SystemActuation Setpoints4. FSAR Section 6.3.3, Actuation5. FSAR Section 6.5.3, Hydrogen Generation6. OP-TM-EOP-006, LOCA Cooldown7. 1302-5.25 Reactor Building Sump Level8. FSAR Section 5.2 Reactor Building9. FSAR Section 9.2, Chemical Addition and Sampling System10. OP-TM-EOP-002, Loss of 250F Subcooling Margin11. OP-TM-EOP-006, LOCA Cooldown12. OP-TM-EOP-01 0, Emergency Procedure Rules, Guides and Graphs13. OP-TM-MAP-D0301, High Make-up FlowMonth 20XXTMI 3-83EP-AA-1 009 (Revision XX) hrgo Uila lalzonel Qtafietn AnnovI:vallnn KI%: : arh rTkraa Mum 1e6nr4 ~tmtir~n Annmv Fvmlnn M..ri.mrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA12Initiating Condition:Loss of all offsite and all onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:5,6, DEmergency Action Level (EAL):Note: The Emergency Director should declare the promptly upondetermining that the applicable time 15 minutec time has been exceeded, or willlikely be exceeded.1. Loss of ALL offsite AC power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-11B Emergency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutesfrom the time of loss of both offsite and onsite AC power.Loes of ALL offsite and ALL onsite AC Powor to (site specific emergency buses) for 15minuto Or Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-relatedThis IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergencycore cooling, containment heat removal/pressure control, spent fuel heat removal andthe ultimate heat sink.When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas a Site Area Emergency because of the increased time available to restore anemergency bus to service. Additional time is available due to the reduced core decayheat load, and the lower temperatures and pressures in various plant systems. Thus,Month 20XXTMI 3-84EP-AA-1009 (Revision XX)
Thrdaim Uilgh lalanri -Qfnfifn AnnovI::gslnn hle ar~l~Tkrna MiI~ IeI~nrI Qt~tir~n Annn~w Fv.inn NI. .i-I~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSwhen in these modes, this condition represents an actual or potential substantialdegradation of the level of safety of the plant.I Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via IC CS6 or RASI.Basis Reference(s):1. NEI 99-01 Rev 6, CA22. FSAR Section 8.2.2, Unit Distribution System3. FSAR Section 8.2.3, Sources of Auxiliary Power4. Technical Specification Section 3.7, Unit Electric Power System5. 1107-1 Normal Electrical System6. 11 07-2A Emergency Electrical -4KV and 480 Volt7. OP-TM-AOP-020 Loss Of Station Power8. 1107-3 Diesel Generator9. 1107-9 SBO Diesel Generator10. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-85EP-AA-1009 (Revision XX)
ExAIon NuclearIhri Win Is landl Station Annex EIxelln Nu!leIsarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU12Initiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:5,6, DEmergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Eivontevent promptly upondetermining that the applicable time 5--minute6-has been exceeded, or will likelybe exceeded.1. AC power capability to Emergency 4KV buses reduced to only one of thefollowing power sources for > 15 minutes.* Auxiliary Transformer 1A* Auxiliarv Transformer 1 B* Emergency Diesel Generator EG-Y-1A" Emergency Diesel Generator EG-Y-1 B* SBO Diesel Generator EG-Y-4AND2. Any additional single power source failure will result in a loss of ALL AC powerto SAFETY SYSTEMS.plwer courco for 15 minut cI Ior Inge.ANDb. Any additional singlo power source failuro will result in leos of all AG power toSAFETY SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or Dlacina it in the cold shutdown condition. includina the EGCS.These aretypically systems classified as safety-related.This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS. In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment.Month 20XXTMI 3-86EP-AA-1009 (Revision XX)
ExAIon NuclearThrpa Mill IslandI Rtation Annexr Exelon NuclanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSI When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas an Alert because of the increased time available to restore another power source toservice. Additional time is available due to the reduced core decay heat load, and thelower temperatures and pressures in various plant systems. Thus, when in thesemodes, this condition is considered to be a potential degradation of the level of safety ofthe plant.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below.I
- A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).I
- A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator.* A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.The subsequent loss of the remaining single power source would escalate the event toan Alert in accordance with IC CA1_.Basis Reference(s):1. NEI 99-01 Rev 6 CU22. FSAR Section 8.2.2, Unit Distribution System3. FSAR Section 8.2.3, Sources of Auxiliary Power4. Technical Specification Section 3.7, Unit Electric Power System5. 1107-1 Normal Electrical System6. 11 07-2A Emergency Electrical -4KV and 480 Volt7. OP-TM-AOP-020 Loss Of Station Power8. 1107-3 Diesel Generator9. 1107-9 SBO Diesel Generator10. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-87EP-AA-1009 (Revision XX)
Tknaft RA16% lalonA totinn AnndavI::valnn N"AaarlTkr~a Ilila lalauiri ~*a*kirm Ann~v Fvm Inn F'Juuir~Ia~v U III~~ 1U5h1 *OUE 1 tSSuu U UE SE 1fl ~ * * ~TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCA26Initiating Condition:Hazardous event affecting SAFETY SYSTEM needed-required for the current operatingmode.Operating Mode Applicability:5,6Emergency Action Level (EAL):1. a, The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)" Internal or external flooding event" High winds or tornado strike" FIRE" EXPLOSION" (site sepocfic hazar~ds)" Other events with similar hazard characteristics as determined by theShift ManagerAND2.b. EITHER of the following:a.__,. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM needed-required byTechnical Specifications for the current operating mode.ORThe event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure Reeded-required by TechnicalSpecifications for the current operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization. A release of steam (from highenergy lines or components) or an electrical component failure (caused by short circuits,grounding, arcing, etc.) should not automatically be considered an explosion. SuchMonth 20XXTMI 3-88EP-AA-1009 (Revision XX) hrom Uila Wand Qtafinn AnnoyF:yalnn haPl"AarThree Mile l@kanrl Qtntinn Anney Fvelnn Mm .r~learTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSevents may require a post-event inspection to determine if the attributes of an explosionare present.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placinq it in the cold shutdown condition, includinq the ECOS. These aretypically systems classified as safety-related.VISIBLE DAMAGE: Damage to a component or structure that is readily observablewithout measurements, testing, or analysis. The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components,- neededrequired for the currentoperating mode, "required", i.e. required to be operable by Technical Specifications forthe current operating mode. This condition significantly reduces the margin to a loss orpotential loss of a fission product barrier, and therefore represents an actual or potentialsubstantial degradation of the level of safety of the plant. Manual or automatic electricalisolation of safety equipment due to flooding, in and of itself, does not constitutedegraded performance and is classified under HU6.EAL 1-b42.a Basis-aAddresses damage to a SAFETY SYSTEM train that is- required to be operable byTechnical Specifications for the current operating mode, and is in 6e:VGe/operationsince indications for it will be readily available. The indications of degradedperformance should be significant enough to cause concern regarding the operability orreliability of the SAFETY SYSTEM train.EAL 4-b-22.b Basis-aAddresses damage to a SAFETY SYSTEM component that is -required to beoperable by Technical Specifications for the current operating mode, and is not inewe peration or readily apparent through indications alone, or to a structurecontaining SAFETY SYSTEM components. Operators will make this determinationbased on the totality of available event and damage report information. This is intendedto be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC CS6 or RAS1.If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):1. NEI 99-01 Rev 6, CA6Month 20XXTMI 3-89EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU34Initiating Condition:Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Eventevent promptly upondetermining that the applicable time 15 m..utcs time has been exceeded, or willlikely be exceeded.Voltage is < 105 VDC on required 125 VDC Distribution Systems 1 A and 1 B for > 15minutes.Indicated v,,oltage is loss than (site specific bus voltage v.. alue) On required Vita! DGh15buses forF 16 min*utes Or !onger.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a loss of Vital DC power which compromises the ability to monitorand control operable SAFETY SYSTEMS when the plant is in the cold shutdown orrefueling mode. In these modes, the core decay heat load has been significantlyreduced, and coolant system temperatures and pressures are lower; these conditionsIi, Feaseraise the time available to restore a vital DC bus to service. Thus, thiscondition is considered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to supportoperation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.For example, if Train A is out-of-service (inoperable) for scheduled outage maintenancework and Train B is in-service (operable), then a loss of Vital DC power affecting Train Bwould require the declaration of an Unusual Event. A loss of Vital DC power to Train Awould not warrant an emergency classification.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Depending upon the event, escalation of the emergency classification level would be viaIC CA6 or CA5_, or an IC in Recognition Category BA.Month 20XXTMI 3-90EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSBasis Reference(s):1. NEI 99-01 Rev 6, CU42. FSAR Section 8.2.2.6, 250/125 VDC System3. 1107-2C Vital DC Electrical System4. OP-TM-AOP-023, A DC System Failure5. OP-TM-AOP-024, B DC System FailureMonth 20XXTMI 3-91EP-AA-1 009 (Revision XX)
Fxelon NuclearThree Mile Isla~nd Station Annex ExeIon NuclanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU4"Initiating Condition:Loss of all onsite or offsite communications capabilities.Operating Mode Applicability:5,6, DEmergency Action Level (EAL):1. Loss of ALL Table C1 Onsite communications capability affecting the ability toperform routine operations.OR2. Loss of ALL Table C1 Offsite communication capability affecting the ability toperform offsite notifications.OR3. Loss of ALL Table Cl NRC communication capability affecting the ability toperform NRC notifications.Table Cl Communications CapabilitvSystem Onsite Offsite NRCRadios XPlant pagqe XPlant Telephone System XSound Powered Phones XCommercial Telephones X X XNARS XENS X XHPN X XSatellite phones X X1. Loss of ALL ofth f10 ollowing GAsito communication motnode:(site 6pocific list Of communications moethods)2. Loess of ALL of tho following ORO comAmunications moethods:;(r.ite snnfoifi list of Gammus acat a nS mo~thnds\ .... -If............ IMonth 20XXTMI 3-92EP-AA-1009 (Revision XX)
ExAIon NuclearThree Mile Islsand Stamtion Annex ExeIon NucleasrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS3. Loss of ALL of the following NRC communications mr.thods:(site -specific list of communications mnethods)Basis:I This IC addresses a significant loss of on-site-, offsite, or NRC --ffeiecommunications capabilities. While not a direct challenge to plant or personnel safety,I this event warrants prompt notifications to Offsite Response Organizations (OROs. andthe NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 BasisaAddresses a total loss of the communications methods used in support of routine plantoperations.EAL #2 BasisaAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in Procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form._(see Developer Notes).EAL #3 BasisaAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, CU52. 1105-12 Communications System3. FSAR Section 7.4.4, CommunicationMonth 20XXTMI 3-93EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearThree Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSInitiating Condition:Inability to maintain the plant in cold shutdown.Operating Mode Applicability:5,6CA53Emergency Action Level (EAL):Note: The Emergency Director should declare the Ale---event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.1. UNPLANNED rise in RCS temDerature > 200°F due to lossof decay heatremoval for > Table C2 duration.Table C2 RCS Heat-up Duration ThresholdsRCS Containment Closure Heat-upStatus Status DurationIntact Not Applicable 60 minutes*Not IntactEstablished 20 minutes*ORReduced Not Established 0 minutesInventory* If an RCS heat removal system is in operation withinthis time frame and RCS temperature is being reduced,then EAL #1 is not applicable.OR2. UNPLANNED RCS pressure rise > 10 osia as a result of temperature rise dueto loss of decay heat removal. (This EAL does not apply in solid plantconditions.)S I I M, f1 r 1 A 0,10 1I-r% ! ..I~If~ * .~..----.. .L.. 1¶L.ffffffffffffffffffffffffffff~-~-- ~r'~I I IF~II-I -¶r~P~t-I I trwrr~z1r.r1 In I-¶1 = Tflmr1f~r1TIIrC~ T~ f1rf~ITf4r rrIn IFITf~ Vhlr-NIIIULe....l c d rI------- ----- --- -------an ll,duration pepcifiod in the fo-lloing table.JVI Month 20XXTMI 3-94EP-AA-1009 (Revision XX)
Tkrmm Uilia lalanri Qfatinn AnniavFIsYlnn Nn rlhuarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSTable: RCS He-at up Duration ThoeshodRCS Staus Containment Clocuro Heat-up DurationStatushAtaet (but not at.reduod i nentoiI applia 6u iinuteifP444;1)Not intacst (Or at rouedGN7= Establoshe2d M-nt~es-*Inwente~y [Pl4q~) Not Ectabliched 0 F~inutes* if an RCS hoat removal system is in oncration with:in this time fr-ameand RCS tcmperaturo is boing reduced, the EAL. is not applmicablo-.i l&li--tl Ali, lklr"r't .-&I- /_.u -!.C!-' S ft Sr,. A ft ft ,rr% I-,IE.% .-. ~~V~T' 1~1 FT'~ f~r1rN~TIr* rirrwi~i rf~h-. ' -~ ~-- r'rt4wTT~;. ~ S SIS 1 RU.. ~%~4j I *%t A~ASS.IPWADII ULUIr.. ~Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchanae or event mav be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, etc.).This IC addresses conditions involving a loss of decay heat removal capability or anaddition of heat to the RCS in excess of that which can currently be removed. Eithercondition represents an actual or potential substantial degradation of the level of safetyof the plant.A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.The RCS Heat-up Duration Thresholds table addresses ao i6,reaserise in RCStemperature when CONTAINMENT CLOSURE is established but the RCS is not intact,or RCS inventory is reduced (e.g., mid-loop operation in PWRs). The 20-minutecriterion was included to allow time for operator action to address the temperatureMonth 20XXTMI 3-95EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSI The RCS Heat-up Duration Thresholds table also addresses an inereaserise in RCStemperature with the RCS intact. The status of CONTAINMENT CLOSURE is notcrucial in this condition since the intact RCS is providing a high pressure barrier to afission product release. The 60-minute time frame should allow sufficient time toaddress the temperature inereaserise without a substantial degradation in plant safety.Finally, in the case where there is an inereaserise in RCS temperature, the RCS is notintact or is at reduced inventory-[P-RJ, and CONTAINMENT CLOSURE is notestablished, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) theevaporated reactor coolant may be released directly into the Containment atmosphereand subsequently to the environment, and 2) there is reduced reactor coolant inventoryabove the top of irradiated fuel.EAL #2 BasispProvides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS61- or RAS1.Basis Reference(s):1. NEI 99-01 Rev 6, CA32. Technical Specifications sections: 1.2.1, 1.7.a and c3. Technical Specifications sections: 3.6.12.a4. Technical Specifications sections: 3.6.55. Technical Specifications sections: 3.8.66. Technical Specifications sections: 1.2.1, 1.7.a and c, 3.6.12.a, 3.6.5, 3.8.67. 1101-3 Containment Integrity and Access Limits8. OP-TM-EOP-030, Loss of Decay Heat Removal9. Outage Fuel Protection Criteria DocumentMonth 20XXTMI 3-96EP-AA-1009 (Revision XX)
Throm Wha lalanri Qtafinn AnnavI=Yalnn N, ii , nnilp nleaTBleniE l i 3-2n: EVIn lechnIcITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCU53Initiating Condition:UNPLANNED iArGease-rise in RCS temperatureOperating Mode Applicability:5,6Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual E'-ntovent promptly upondetermining that the applicable time -1.-miFites-has been exceeded, or will likelybe exceeded.1. UNPLANNED rise in RCS temDerature > 200°F due to loss ofdecay heatremoval.OR2. Loss of the followinq* for > 15 minutes.* ALL RCS temperature indicationsAND* ALL RCS level indications1 WWIPI NEDf InrrGMpp in 5Z~ tcF~r~nPtiir tG nrr"ateF than 1ritre 6nterifir ---r Gg *-r~..,..%..a,..fI ~ nairi ni... .*rjn.Ar. *nrv.r..n rr'.*. awn I;.'.'. ;*'I............. r..... rf% I m A I I -'Cn a----.. Ui niLiL Iv ~IIIl,J'vf.JA,.UIU ,1IU IU..ULI~v vv vi , v, v,.vBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.This IC addresses an UNPLANNED i*Reeaserise in RCS temperature above theTechnical Specification cold shutdown temperature limit, or the inability to determineMonth 20XXTMI 3-97EP-AA-1009 (Revision XX)
Thre Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSRCS temperature and level, represents a potential degradation of the level of safety ofthe plant. If the RCS is not intact and CONTAINMENT CLOSURE is not establishedduring this event, the Emergency Director should also refer to IC CA53.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.I EAL #1 involves a loss of decay heat removal capability, or an addition of heat to theRCS in excess of that which can currently be removed, such that reactor coolanttemperature cannot be maintained below the cold shutdown temperature limit specifiedin Technical Specifications. During this condition, there is no immediate threat of fueldamage because the core decay heat load has been reduced since the cessation ofpower operation.During an outage, the level in the reactor vessel will normally be maintained above thereactor vessel flange. Refueling evolutions that lower water level below the reactorvessel flange are carefully planned and controlled. A loss of forced decay heat removalat reduced inventory may result in a rapid iniereaserise in reactor coolant temperaturedepending on the time after shutdown.EAL #2 reflects a condition where there has been a significant loss of instrumentationcapability necessary to monitor RCS conditions and operators would be unable tomonitor key parameters necessary to assure core decay heat removal. During thiscondition, there is no immediate threat of fuel damage because the core decay heatload has been reduced since the cessation of power operation.I Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.I Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA53 basedon exceeding plant configuration-specific time criteria.Basis Reference(s):Month 20XXTMI 3-98EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS1. NEI 99-01 Rev 6, CU32. 1103-11 RCS Water Level Control3. FSAR Section 7.3.2, Non-Nuclear Instrumentation4. 1302-6.6 RCS Temp/Press, TSAT Monitor, ATWS and DSS Calibration5. NEI 99-01 Rev 5, CU46. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-99EP-AA-1009 (Revision XX)
Throm Uilds lalanel tatinn AnnovP~valnn NltrhlarThro~ Mila IcI~nr4 ~t~tinn Annv ~v~Inn NiuiI.mrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCG6-4Initiating Condition:Loss of reactor vessel/RCS inventory affecting fuel clad integrity with containmentchallenged.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note: The Emergency Director should declare the G-noral ElinergencycLvent promptlyupon determining that the applicable time 30-minutes-has been exceeded, or willlikely be exceeded.1. Reactor vessel level unknown for > 30 minutes.AND2. Core uncovery is indicated by ANY of the following:" Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Erratic Source Range Neutron Monitor indication.OR" Radiation monitors RM-G-6 or RM-G-7 reading > 3 RPhr.AND3. Any Containment Challenge Indication (Table Q4)Table C3 Indications of RCS Leakaqe" UNPLANNED Reactor BIdg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise** UNPLANNED RCDT level rise*" UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.Month 20XXTMI 13-100EP-AA-1 009 (Revision XX)
Thrdada Uilin lainnel Qfafinn AnngvFIaYlenn MN,,rluarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSTable C4 Containment Challenge Indications* Hydrogen Concentration in Containment > 4%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established** if CONTAINMENT CLOSURE is re-established prior to exceeding the30-minute core uncovery time limit, then escalation to a GeneralEmergency is not required.1 a. (Reactor S level less than (site specific level) for 30 minutes oFANDb. ANY indication from the Containment Ghallongce Table (see below).2. a. Reactor vesseV/RGS level cannot be moenitored- for 30 mninutes Or longor.Alki lr'k i ;~ A f A k, AK fV +k~ f H~IA~i¶A:IV. A: A: I-:4!: -1e Erratic sour-ee range moenitor- indication-- J10 4 +4XIW4ý AP;*IAQP, A I-q +Fk, q;RP.P. A V.14Mn AR--. Ar. M-A P,4ALQ, IQ Q P-14 92 6but.mna-nitude to inateute core uneoverwANDtner- site speelcifle atcattlons)AKIV irA;^ft+a^r% ;r^rv, +kft tr-.+ ; + t-%k H -r k! k-0 lllU *U S w *l cciw Kl * *1t* *i *ClntainmInt Challenge Tablo89 CONT.AINMENT CLOSURE not established*45 (Explosive mixture) exists inside eontainmentIs UNPLANNED increase in ntainment pressureMonth 20XXTMI 13-101EP-AA-1 009 (Revision XX)
Throm Uilm lalanrl Qtatinn AnnovF:v-alnn M* r-loarTkrea Mile lelenel ~tetiw~n Annay ~v.Inn M.u~l.erTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS* If CONTAINMENT CLOSURE is re establiehd PrGir to eXcoding the 30 minute timelimit, then d-larMati-n of a General Emer t reqUired.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.IMMINENT: The traiectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.This IC addresses the inability to restore and maintain reactor vessel level above thetop of active fuel with containment challenged. This condition represents actual orIMMINENT substantial core degradation or melting with potential for loss of containmentintegrity. Releases can be reasonably expected to exceed EPA Protective ActionGuidelines (PAG. exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a directand unmonitored release of radioactivity to the environment. If CONTAINMENTCLOSURE is re-established prior to exceeding the 30-minute time limit, then declarationof a General Emergency is not required.The existence of an explosive mixture means, at a minimum, that the containmentatmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity. Ittherefore represents a challenge to Containment integrity.In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to acore uncovery could result in an explosive gas mixture in containment. If all installedhydrogen gas monitors are out-of-service during an event leading to fuel claddingdamage, it may not be possible to obtain a containment hydrogen gas concentrationreading as ambient conditions within the containment will preclude personnel access.During periods when installed containment hydrogen gas monitors are out-of-service,operators may use the other listed indications to assess whether or not containment ischallenged.Month 20XXTMI 3-102EP-AA-1 009 (Revision XX)
ThrAma Milo lalanfi Qtafinn AnnovIFvalnn hlir-laarThrna Mila I@kanel ~t~tinn Ann~v Fv.Inn Muuri~~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSIn EAL-2-b, Tthe 30-minute criterion is tied to a readily recognizable event start time(i.e., the total loss of ability to monitor level), and allows sufficient time to monitor,assess and correlate reactor and plant conditions to determine if core uncovery hasactually occurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor reactor vessel/RCS level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the reactor vessel/RCS.These EALs address concems raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Basis Reference(s):1. NEI 99-01 Rev 6, CG12. 1103-11 RCS Water Level Control3. 1101-3 Containment Integrity and Access Limits4. OP-TM-EOP-030, Loss of Decay Heat Removal5. FSAR Sections 5.2, Reactor Building6. FSAR Sections 6.5.2, Hydrogen Monitoring7. FSAR Sections 6.5.3, Hydrogen Generation8. Technical Specifications 3.5.5, Accident Monitoring Instrumentation9. EP-AEL-0501, Estimation of Radiation Monitor Readings Indicating CoreUncovery During Refuel10. 1301-1 Shift and Daily Checks, Data Sheet 3Month 20XXTMI 3-103EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCS6-1Initiating Condition:Loss of reactor vessel/RCS inventory affecting core decay heat removal capability.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note: The Emergency Director should declare the Site Ara EmergencGye.ent promptlyupon determining that the applicable time 30-*miRutes-has been exceeded, or willlikely be exceeded.1. a. Reactor vessel/RCS level unknown for >30 minutes.ANDb. Core uncovery is indicated by ANY of the following:" Table C3 indications of a sufficient magnitude to indicate core uncoverY.OR* Erratic Source Range Neutron Monitor indication.OR" Radiation Monitors RM-G-6 or RM-G-7 reading > 3 R/hr.Table C3 Indications of RCS Leakaqe" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise*" UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.Month 20XXTMI 3-104EP-AA-1 009 (Revision XX)
Fxelon NuclearThree Mile Island tation Annex Exelon Nulea. rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS1 a. CONT.AI NMENT CLOS'U' nrm o.,t
- l.v .w u i 4zrI1MfrND PALN1%P1Ic^f~Lo w w"-"JLý ..... JI%-.--. r-2 a. CONITAINMEArMNlT ostablished.-ANDIP. t elactOr V98seVRG8[-jt. V -'vvn Or i-irv ["Mv-ff level less ihan tienospe~ii eve+yb db dfA 3. a. t oacmor voesscv "b. [#dW-Hvt Or Kidw MVVi-hf ieVo1 c-annot DOP monnorca-e for 30mFinuto or I9ngre.b. Core Uncovery is indicated by ANY of the followina:.. ............ j ....--j ...........0 (Site spccitic r-actiation moenitor-) reactin ereater- tflan (site speeciei value)* ,rratic souree r-ane montotr n IP PWRNIJ1 1 P eLJ" 1UNPLAPNP4L increase int kstte speeciuc sump anwaor tanK) levels of Sufficefemmagnitude to intdicate cor-e uncoever-y" (Other- site specific indieations)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurallv defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.Thi" IC addresses a "ignificant and p,.l.ng.d loss of r.actOF. ...s-eVRCS in..ntor;control and makeup capability loading to IMMINENT fuel damage. .The lost inventorymay be due to a RCS component failure, a loss of configuration control or prolongedboiling of reactor coolant. These conditions entail major failures of plant functionsneeded for protection of the public and thus warrant a Site Area Emergency declaration.Month 20XXTMI 3-105EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSI Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.I Outage/shutdown contingency plans typically provide for re-establishing or verifyingCONTAINMENT CLOSURE following a loss of heat removal or RCS inventory controlfunctions. The differenc e. in the speifi.ed RC5,,'roqact9r Veol levels of EAL" 1 .b and 2.,rolo,-t the fact that with CLOSURE tr- thero ;s a la1probability of a fission pro9duct roloaco to the enyironmont.kin AL-&a1-,tThe 30-minute criterion is tied to a readily recognizable event start time(i.e., the total loss of ability to monitor level), and allows sufficient time to monitor,assess and correlate reactor and plant conditions to determine if core uncovery hasactually occurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor reactor vessel/RCS level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. SumpI and/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the reactor vessel/RCS.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Escalation of the emergency classification level would be via IC CG-16 or ARG1.Basis Reference(s):1. NEI 99-01 Rev 6, CS12. OP-TM-PRF1-0405 RB Sump Level Hi3. 1101-3 Containment Integrity and Access LimitsMonth 20XXTMI 3-106EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS4. 1301-1 Shift and Daily Checks, Data Sheet 35. 1103-11 RCS Water Level Control6. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-107EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA6I-Initiating Condition:Loss of reactor vessel/RCS inventory.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note: The Emergency Director should declare the event Ale--promptly upondetermining that the applicable time 4 6 minutes-has been exceeded, or will likelybe exceeded.1. Loss of reactor vessel / RCS inventory as indicated by RCS level < 0 inches onDraindown Level indicator.OR2. a. Reactor vessel / RCS level unknown for > 15 minutes.ANDb. Loss of reactor vessel / RCS inventory per Table C3 indications.Table C3 Indications of RCS Leakage" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary BId-g. Sump level rise*" UNPLANNED BWST level rise*" UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vesseVRCS inventory.1. Less of reactor invento, y as indicated by level less than (,ite- spcifi,level)2. a. Reactor vosA.ol'RCS_ level cannot be monitored for 15 minutes or longerMonth 20XXTMI 13-108EP-AA-1009 (Revision XX)
Fyplnn NunlAnrThratz Miis 11-r-lnd Rtatinn Annox ExAInn Nunipjr~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSANDb. UNPLANNED increaso in (site cpecific sump and/or tank) levels due toless. Of roactor vocccl/RCS ivnoBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.--This IC addresses conditions that are precursors to a loss of the ability toadequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier).This condition represents a potential substantial reduction in the level of plant safety.EAL #1 BasisF=G: EAL aA lowering of water level below 0 inches on Draindown Level indicator (site-speGifiG. indicates that operator actions have not been successful in restoring andmaintaining reactor vessel/RCS water level. The heat-up rate of the coolant williWiearserise as the available water inventory is reduced. A continuing desiease-drop inwater level will lead to core uncovery.Although related, EAL #1 is concerned with the loss of RCS inventory and not thepotential concurrent effects on systems needed for decay heat removal (e.g., loss of aResidual Heat Removal suction point). An inIreaeerise in RCS temperature caused bya loss of decay heat removal capability is evaluated under IC CA53.EAL #2 Basis,- AI-v,, tThe inability to monitor reactor vessel/RCS level may be caused byinstrumentation and/or power failures, or water level dropping below the range ofavailable instrumentation. If water level cannot be monitored, operators may determinethat an inventory loss is occurring by observing changes in sump and/or tank levels.Sump and/or tank level changes must be evaluated against other potential sources ofwater flow to ensure they are indicative of leakage from the reactor vessel/RCS.The 15-minute duration for the loss of level indication was chosen because it is half ofthe EAL duration specified in IC CS61-If the reactor vessel/RCS inventory level continues to lower, then escalation to Site AreaEmergency would be via IC CS64-.Month 20XXTMI 3-109EP-AA-1009 (Revision XX)
Thraso Mfiilg la@6ne1 Qttinn AnnoyIFyalnn TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSBasis Reference(s):1. NEI 99-01 Rev 6, CA12. OP-TM-PRF1-0405 RB Sump Level Hi3. 1301 -1 Shift and Daily Checks, Data Sheet 34. 1103-11 RCS Water Level Control5. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-110EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCU6-Initiating Condition:UNPLANNED loss of reactor vessel/RCS inventory for 15 minutes or longer.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note: The Emergency Director should declare the Unucual Eventevent promptly upondetermining that the applicable time 45-inutes-has been exceeded, or will likelybe exceeded.1. UNPLANNED loss of reactor coolant results in the inability to restore andmaintain reactor vessel / RCS level to > procedurally established lower limitfor > 15 minutes.OR2. a. Reactor vessel / RCS level unknownANDb. Loss of reactor vessel / RCS inventory per Table 03 indications.Table C3 Indications of RCS Leakage" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise*" UNPLANNED RCDT level rise*" UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.I l_ _ I l= =- II .... .1. ,;io-R W 99 roaorA cooiant rIu-it In reactor ves,-v-68 level IeSeMan areauired lowor limfit for 15 mninutoc Or loG~er.2~. a. ReiacROr vessew:u Ica lve GannoI he manmotau.Month 20XXTMI 3-111EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearThree Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSh. UNPL ANNEDinrocoi (lit-p epoific sump andio tank) leveols.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses the inability to restore and maintain water level to a requiredminimum level (or the lower limit of a level band), or a loss of the ability to monitorreactor vessel/RCS level concurrent with indications of coolant leakage. Either of theseconditions is considered to be a potential degradation of the level of safety of the plant.The procedurally established lower limit is not an operational band established abovethe procedural limit to allow for operator action prior to exceeding the procedural limit,but it is the procedurally established lower limit.Refueling evolutions that deerease-lower RCS water inventory are carefully planned andcontrolled. An UNPLANNED event that results in water level decreasing below aprocedurally required limit warrants the declaration of an Unusual Event due to thereduced water inventory that is available to keep the core covered.EAL #1 Basis-rfecognizes that the minimum required reactor vessel/RCS level can change severaltimes during the course of a refueling outage as different plant configurations andsystem lineups are implemented. This EAL is met if the minimum level, specified for thecurrent plant conditions, cannot be maintained for 15 minutes or longer. The minimumlevel is typically specified in the applicable operating procedure but may be specified inanother controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions torestore and maintain the expected water level. This criterion excludes transientconditions causing a brief lowering of water level.EAL #2 Basis-aAddresses a condition where all means to determine reactor vessel/RCS level havebeen lost. In this condition, operators may determine that an inventory loss is occurringby observing changes in sump and/or tank levels. Sump and/or tank level changesmust be evaluated against other potential sources of water flow to ensure they areindicative of leakage from the reactor vessel/RCS.Continued loss of RCS inventory may result in escalation to the Alert emergencyclassification level via either IC CA6-- or CA53.Month 20XXTMI 3-112EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSBasis Reference(s):1. NEI 99-01, Rev. 6 CUi2. Technical Specification 3.1.6. Leakage3. OP-TM-220-251 RCS Leak Rate Determination Using PPC4. OP-TM-220-252, Primary -To -Secondary Leakrate Determination (OTSGLeakage): Normal Operations5. OP-TM-MAP-C0105 RCS Draindown LVL HI/LO6. OP-TM-PRF1-0405 RB Sump Level HI7. UFSAR 6.4.3, Bases of Leakage Estimate8. 1103-11 RCS Water Level Control9. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-113EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1Initiating Condition:HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:1,2,3,4,5,6, DEmergency Action Level (EAL):1. A notification from the Security Force that a HOSTILE ACTION is occurring orhas occurred within the PROTECTED AREA.AND2. a. ANY Table H1 safety function cannot be controlled or maintained.ORb. Damaae to spent fuel has occurred or is IMMINENTTable H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)" Core Cooling (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)1 A HOS9T" R ACTION in, ennuFiring n has nnnrcmrd w~ithin thN PRQTFCGT-EAD~A ..nna.4a~'4k~. 4kn In4nrsaa;4n nan. *nhi t.k;~ ~.W mV m mYA 13 CANDlk EITuED ,ý*af II'amrik nir,4-. .a--"--I ----!UIV m TVl mOIIOW fflO -ýA&DT TEiCIfe iS~~ar-ar CTflflO .. aoiTo Zo ormaitied." Reaetivity eontroel" Coe e-eealifg" RCS heat remoevalOP.a * .~+/-x~* L.-----a"A I amage to onn Tipin i nla ourrotU oer OFTMI 3-114!MMHN1M1N+.EP-AA-1009 (Revision XX)Month 20XX hrgag% Rfiilg% lainnei tatinn AnndavI::aleln Thr~ MiI~ lolanri Qt~tir~n Ann~v Fv~Inn hi. maI.arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.IMMINENT: The traiectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.This IC addresses an event in which a HOSTILE FORCE has taken physical control ofthe facility to the extent that the plant staff can no longer operate equipment necessaryto maintain key safety functions. It also addresses a HOSTILE ACTION leading to aloss of physical control that results in actual or IMMINENT damage to spent fuel due to1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls,etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot bemaintained.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].Emorgoncy plans and implementing pr.,,durc thorefore, EALS,should not inceororate S-ecurity sensitive information. This includoes infomation thaMonth 20XXTMI 3-115EP-AA-1009 (Revision XX)
Throa Uila Wand qtntinn AnnowFYmlnn
- r MII~a~lkwIIii¥ IQHIIt tim AIII'vA IFvpInn NmItnisarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYmay be adyantagopu6 to a potential advercar,', Such as the padiculaFGRG cocrinaspecific throat Or threat location. Security sensitive infeo~mation should becontained in non public documon9te cuch as the Security Plan.Basis Reference(s):1. NEI 99-01, Rev. 6 HG12. Security and Safeguards Contingency Plan Station Security Plan -Appendix CMonth 20XXTMI 3-116EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS1Initiating Condition:HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:1,2,3,4,5,6, DEmergency Action Level (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.1. A HOSTILEr" ACTION.M is occurr.ing or has ..cur..d within the PROTECTEDAREA as roportod by the (sito cpocific cocurity shift suporvision).Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An obiect directed toward a NPP that could cause concem for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTEDAREA. This event will require rapid response and assistance due to the possibility fordamage to plant equipment.Month 20XXTMI 3-117EP-AA-1009 (Revision XX)
I=yAInn Thrat Milua haIand Rtiation Annax Exellnn Nuclei~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYTimely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Site Area Emergency declaration will mobilize OROresources and have them available to develop and implement public protective actionsin the unlikely event that the attack is successful in impairing multiple safety functions.This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTEDAREA located outside the plant PROTECTED AREA; such an attack should beassessed using IC HAl. It also does not apply to incidents that are accidental events,acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by aHOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters,physical disputes between employees, etc. Reporting of these types of events isadequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR§ 50.72.Emer-gency plans and implementing procoduros aro public documonts; thoreforo, EALsshould not incorporato Sccurity sensitive information. This includes information thatmay be advantageous to a poential andvxers-ary, SUch as, the particulars OA cneig aspecific threat or threat loation. sensitiv. e information should be conta"ined innon public dOcumoents such as the Security Plan.Escalation of the emergency classification level would be via IC HG1.Basis Reference(s):1. NEI 99-01 Rev 6, HS12. Security and Safeguards Contingency Plan Station Security Plan -Appendix CMonth 20XXTMI 3-118EP-AA-1009 (Revision XX)
Thrisi Mfiil Ihunind Station Annex ExeInn NuclazrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA1Initiating Condition:HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threatwithin 30 minutes.Operating Mode Applicability:1,2,3,4,5,6, DEmergency Action Level (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutes fromthe site.1. A HO1STILE ACTION is ....ring or- has o.....ed wit.hn the OWNEROR2. Notification by the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the OWNER CONTROLED AREA.-A validated notification from NRC of an afircraft attack throat within 30 mninutoc ofBasis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An obiect directed toward a NPP that could cause concem for itscontinued operability, reliability, or personnel safety.OWNER CONTROLLED AREA (OCA): The property associated with the station andowned by the company. Access is normally limited to persons entering for officialbusiness.Month 20XXTMI 3-119EP-AA-1009 (Revision XX)
Thriam Uila lalanel Qtafinn AnnovPv--Ionn M ilAg~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYPROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.This IC addresses the occurrence of a HOSTILE ACTION within the OWNERCONTROLLED AREA or notification of an aircraft attack threat. This event will requirerapid response and assistance due to the possibility of the attack progressing to thePROTECTED AREA, or the need to prepare the plant and staff for a potential aircraftimpact.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Alert declaration will also heighten the awareness ofOffsite Response Organizations, allowing them to be better prepared should it benecessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience,or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputesbetween employees, etc. Reporting of these types of events is adequately addressedby other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL #1 addresses the threat from the impact of an aircraft on the plant, and theanticipated arrival time is within 30 minutes. The intent of this EAL is to ensure thatthreat-related notifications are made in a timely manner so that plant Personnel andOROs are in a heightened state of readiness. This EAL is met when the threat-relatedinformation has been validated in accordance with OP-TM-AOP-008, Security Threat /Intrusion.EAL #24 is applicable for any HOSTILE ACTION occurring, or that has occurred, in theOWNER CONTROLLED AREA. This includes any action directed against an ISFSI thatis located outside the plant PROTECTED AREA.Month 20XXTMI 3-120EP-AA-1009 (Revision XX)
Throgs Uila laicknei Qfzbfinn AnniavIFvalnn Mid-as:r~lTkree Mile le6nrI ~totirn Annoy ~velnn hi. .,iorTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYEAL #2 addresses the throat from the impact of an arcraft. an the plant, and theanticipatod arri'.al time is within 30 mninutes. Tho intent of this EAL is to cnsure thtthrAt+_relatAd ification; eare mnade in a timely maRennr so that plant andOR~s are in a heightened State Of readiness. This EAL is mnet w~hen the threat reelattedinformation has boon validated in accordancc with (Site Specific procedure).The NRC Headquarters Operations Officer (HOO) will communicate to the licensee ifthe threat involves an aircraft. The status and size of the plane may be provided byNORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNERCONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected,although not certain, that notification by an appropriate Federal agency to the site wouldclarify this point. In this case, the appropriate federal agency is intended to be NORAD,FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs,should not be unduly delayed while awaiting notification by a Federal agency.EmergencY plans and implementing procedures are public documents; therefore, EiALsshould not incorporate Security sensitive information. This includ-e-s inforFmation thatmay be advantageous to a potential adver-sar;, such as the particul..ars cncming aspecific thre-.at r t~hrea-t lctin Security sensitive information should be contained inon-public- doc-numents such as the Securfity Plan.Escalation of the emergency classification level would be via IC HS1.Basis Reference(s):1. NEI 99-01 Rev 6, HA12. Security and Safeguards Contingency Plan Station Security Plan -Appendix C3. OP-TM-AOP-008, Security Threat / IntrusionMonth 20XXTMI 3-121EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU1Initiating Condition:Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:1,2,3,4,5,6, DEmergency Action Level (EAL):1. Notification of a credible security threat directed at the site as determined PerSY-AA-1 01-132, Security Assessment and Response to Unusual Activities.1 .A SECURITY CONDITION that does not involve a HOSTILE ACT-ION as r-eperted bythe (site specific secur-ity shift superyisioni).OR2. A validated notification from the NRC providing information of an aircraft threat.2. Notification of a cr-edible security threat direeted at the sitcOR3. Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.3. A validatod frm tho NRC proeviding information of an aircraf throat.Basis:SECURITY CONDITION: Any Security Event as listed in the approved securitycontingency plan that constitutes a threat/compromise to site security, threat/risk to sitepersonnel, or a potential degradation to the level of safety of the plant. A SECURITYCONDITION does not involve a HOSTILE ACTIONSAFETY SYSTEM: A system reguired for safe plant operation, cooling down the Plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).Month 20XXTMI 3-122EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEMequipment, and thus represent a potential degradation in the level of plant safety.Security events which do not meet one of these EALs are adequately addressed by therequirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed asHOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Classification of these events will initiate appropriate threat-related notifications to plantpersonnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 addresses the receipt of a credible security threat. The credibility of the threatis assessed in accordance with SY-AA-101-132. rcforone-' (ct .p... securit. chi.toccurringohaocred Traiin onsouri' ont oonfirmation and casciafigoation imaontrollodl duo to the naturo Mof Saegurds and 10 CFr- & 2.Q inoainEAL #2 addresses the threat from the impact of an aircraft on the plant. The NRCHeadquarters Operations Officer (HOO) will communicate to the licensee if the threatinvolves an aircraft. The status and size of the plane may also be provided by NORADthrough the NRC. Validation of the threat is performed in accordance with OP-TM-AOP-008, Security Threat / Intrusion. (sl-'+ .... ". -" ... .th. r"..'+-ofa credible secuity throat. The credibility of tho thre.at. s assessed in aoredance with(site specific procedure).EAL #3 references Security Force.s.. t spe.. fi. secu ftuýrit. h .....4 .... -becausethese are the individuals trained to confirm that a security event is occurring or hasoccurred. Training on security event confirmation and classification is controlled due tothe nature of Safeguards and 10 CFR § 2.39 information.addrossc thb thr-oat from theo pla-t The d-arters Operatio-n ; Offier. )'.,;llplane mayl alson be pro'.'j- iso by NORAM throughli ti-hejr HRO.0aldation0 of the- threat iEmFergency plans and implementing procedu wre are p-ublic documents; therefore, EALsMonth I 2OX.. ....... .... TM.. ..... 3-.. .12 EP.... A -..... 00 (Revision .. .X)...Month 20XXTMI 3-123EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYSFGUuIu iu nGI~upiL RGPFdeeUFiny eurWy~ iintorwtten. -t-HI AGIu-iuuu IinuIAWME"iu twmay be advantageous to a potential advorsar.., cUch a. the c. .ing aSepoiGctra rtra oain Socurity sensitive information should bo containod inno public documonts cuch as tho Socurity Plan.Escalation of the emergency classification level would be via IC HA1.Basis Reference(s):1. NEI 99-01 Rev 6, HU12. SY-AA-101 -132, Security Assessment and Response to Unusual Activities3. Security And Safeguards Contingency Plan Station Security Plan -Appendix CMonth 20XXTMI 3-124EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS26Initiating Condition:Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:1,2,3, 4,5,6, DEmergency Action Level (EAL):Note: The Emergency Director should declare the Sit-e Area Em,, promptlyupon determining that (Site .p.ific nb---. '-the applicable hasbeen exceeded, or will likely be exceeded.1. A Control Room evacuation has resulted in olant control beina transferred from theControl Room to the Remote Shutdown (RSD) stations.AND2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.Table H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* Core Cooling (ability to cool the core)" RCS Heat Removal (ability to maintain heat sink)1. a. An event has resulted in plant control being tra;ns~forre-d- panels andloacontro stations). from the Control Room to (Sit Specifi remote ShutdonANDb. Control of ANY of the following key Safety fUnctienrs is not reostablishedwithin (sto specific number of mninutes)." Reactivity controlA r'.r -;1" rDIACam / iD\ MIA= I201 E IA/0I* RCS heat remov~al..... L ..... JMonth 20XXTMI 3-125EP-AA-1009 (Revision XX)
Thrgg% RAilim lalonrl Qfatinn AnnmvPI=alrn N,,-Ilmar.... -- .w... ..s4. .ts4t.. a -n U. .n s.. .aTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:The time Period to establish control of the plant starts when either:a. Control of the plant is no longer maintained in the Main Control RoomORb. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations, and the control of a key safety function cannot bereestablished in a timely manner. The failure to gain control of a key safety functionfollowing a transfer of plan control to alternate locations is a precursor to a challenge toone Or moreajy fission product barriers within a relatively short period of time.The determination of whether or not "control" is established at the remote safeshutdown location(s) is based on Emergency Director judgment. The EmergencyDirector is expected to make a reasonable, informed judgment within (the site-spe-i-f*time f-. .a.sfeo 15 minutes whether or not the operating staff has control of key safetyfunctions from the remote safe shutdown location(s).Escalation of the emergency classification level would be via IC FG1 or CG64-.Basis Reference(s):1. NEI 99-01, Rev 6 HS62. OP-TM-EOP-020, Cooldown from Outside the Control RoomMonth 20XXTMI 3-126EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA26Initiating Condition:Control Room evacuation resulting in transfer of plant control to alternate locations.Operating Mode Applicability:1, 2,3,4,5,6, DEmergency Action Level (EAL):An-eyentA Control Room evacuation has resulted in plant control being transferredfrom the Control Room to the Remote Shutdown (RSD) stations. '.(.ite-.peGi...remote shutdown pano lhand- control stations).Basis:This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations outside the Control Room. The loss of the ability to controlthe plant from the Control Room is considered to be a potential substantial degradationin the level of plant safety.Following a Control Room evacuation, control of the plant will be transferred to alternateshutdown locations. The necessity to control a plant shutdown from outside the ControlRoom, in addition to responding to the event that required the evacuation of the ControlRoom, will present challenges to plant operators and other on-shift personnel.Activation of the ERO and emergency response facilities will assist in responding tothese challenges.Escalation of the emergency classification level would be via IC HS26.Basis Reference(s):1. NEI 99-01, Rev 6 HA62. OP-TM-EOP-020, Cooldown from Outside the Control RoomMonth 20XXTMI 3-127EP-AA-1009 (Revision XX)
Three Mile IAsland Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU34Initiating Condition:FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:1,2,3,4,5,6, DEmergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Eventevent promptlyupon determining that the applicable time has been exceeded, or will likelybe exceeded.1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of thefollowing FIRE detection indications:" Report from the field (i.e., visual observation)" Receipt of multiple (more than 1) fire alarms or indications" Field verification of a single fire alarmOR2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indicationsof a FIRE).ANDb. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.OR3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes ofthe initial report, alarm or indication.OR4 A FIRE within the plant PROTECTED AREA that requires firefighting support byan offsite fire response agency to extinguish.Month 20XXTMI 3-128EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYTable H2 Vital Areas* Reactor Building* Intake Building0 Intermediate Building* Control Tower* Auxiliary and Fuel Handling Buildings* 1 A and 1 B Diesel Generator Buildings* BWST* CST* ILBIB t .I
- Il "(1) a. A & Imit- us P1444 emtinaulshed witnin 113-minutoS Of AP* of the TollewingFR-iit aetection iAG1cGAuons:0 ý f~rf t f *k~t f ,h^ Col b~ a~. v .cua ah-raonwA* 55 .S S S tfl St. S .S ~S .V S- ---S V LASS%~* 5/vAA SI34LJt:XSS USAPS S/SStJ UA SLin nweRem vu ...ILIUI elt a3 singleu 1111 aIlaANDl.w-zrv(site-spocifi list of plant rooms or arcas)AJE __ \;.I a. eODDIO or a single Tra naram i.e.. no Gfmer inoucamon of a ri-1~i9.......... I"ANDb. Th- FIRE is locAted Within ANY of thA fo.lloinn ,lant ro omsFo areas.(6itc spocific li6t of plant rooms Or areas)AiNDG. The e;stcno of -a FIRE is not Yrificd wA~ithin 30 minutes of alarm (3) A FIRE within the plant ,r -pnt with an ISFS. outside the plant;rottedAfera l PROTECTED AREA not etinguished within 60minutes ofti nitial report, alarm Or indication.* AIm I
- al l *C41 1'- HI-IH AAIRfllf tfA flIflt or 1541i-Si Un Pl nantr. mw!T an ii-Sif ni imrin MRl~ WantfI "!Dv ... .-',*i A ..- w-¶ DD 1 ýwT f ADýA *k.w '.I~i~ -5 *rmkVLI NUr~,S w-h R wý c ,offsiot- fire response to ..v;-,a ui;hil--IMonth 20XXTMI 3-129EP-AA-1009 (Revision XX)
ThrimAm Wig& laltanei Qfnfirn AnnimvWL~v,'Innn kNilr-ImorTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippinqdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of apotential degradation of the level of safety of the plant.EAL #1 BasisThe intent of the 15-minute duration is to size the FIRE and to discriminate againstsmall FIRES that are readily extinguished (e.g., smoldering waste paper basket). Inaddition to alarms, other indications of a FIRE could be a drop in fire main pressure,automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial firealarm, indication, or report. For EAL assessment purposes, the emergency declarationclock starts at the time that the initial alarm, indication, or report was received, and notthe time that a subsequent verification action was performed. Similarly, the fire durationclock also starts at the time of receipt of the initial alarms, indication or report.EAL #2 BasisThis-EAL-aAddresses receipt of a single fire alarm, and the existence of a FIRE is notverified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt,operators will take prompt actions to confirm the validity of a single fire alarm. For EALassessment purposes, the 30-minute clock starts at the time that the initial alarm wasreceived, and not the time that a subsequent verification action was performed.A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipmentfailure or a spurious activation, and not an actual FIRE. For this reason, additional timeis allowed to verify the validity of the alarm. The 30-minute period is a reasonableamount of time to determine if an actual FIRE exists; however, after that time, andabsent information to the contrary, it is assumed that an actual FIRE is in progress.If an actual FIRE is verified by a report from the field, then EAL #1 is immediatelyapplicable, and the emergency must be declared if the FIRE is not extinguished within15-minutes of the report. If the alarm is verified to be due to an equipment failure or aMonth 20XXTMI 3-130EP-AA-1009 (Revision XX)
NuclearThreIeI MilIe IVsland Station Annex FI n NucIeasrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYspurious activation, and this verification occurs within 30-minutes of the receipt of thealarm, then this EAL is not applicable and no emergency declaration is warranted.EAL #3 BasisIn addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plantPROTECTED AREA not extinguished within 60-minutes may also potentially degradethe level of plant safety. This basis extends to a FIRE ccurr'ing within thcPROTECTED AREA -ofn SFSI lo,,,,,,,ated ,.,id.-,,e the plant PROTECTED AREA.[Sentence for plants with an ISESI outside the plant P-roterted AnreaEAL #4 BasisIf a FIRE within the plant or ISFS, [forplants with an ISFSI the plant PrtoctodAr-ea]-PROTECTED AREA is of sufficient size to require a response by an offsitefirefighting agency (e.g., a local town Fire Department), then the level of plant safety ispotentially degraded. The dispatch of an offsite firefighting agency to the site requiresan emergency declaration only if it is needed to actively support firefighting effortsbecause the fire is beyond the capability of the Fire Brigade to extinguish. Declarationis not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix RAppendix R to 10 CFR 50, states in part:Criterion 3 of Appendix A to this part specifies that "Structures, systems, andcomponents important to safety shall be designed and located to minimize,consistent with other safety requirements, the probability and effect of fires andexplosions."When considering the effects of fire, those systems associated with achievingand maintaining safe shutdown conditions assume major importance to safetybecause damage to them can lead to core damage resulting from loss of coolantthrough boil-off.Because fire may affect safe shutdown systems and because the loss of functionof systems used to mitigate the consequences of design basis accidents underpost-fire conditions does not per se impact public safety, the need to limit firedamage to systems required to achieve and maintain safe shutdown conditions isgreater than the need to limit fire damage to those systems required to mitigatethe consequences of design basis accidents.In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of1-hour fire barriers for the enclosure of cable and equipment and associated non-safetycircuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify asingle alarm is well within this worst-case 1-hour time period.Month 20XXTMI 3-131EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYDepending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA26 or MA5SA9.Basis Reference(s):1. NEI 99-01, Rev 6 HU42. FSAR Figure 2.1-3, Extended Plot Plan TMINS3. FSAR Section 5.1, Class I Structures, Components, and Systems4. OP-TM-AOP-001, Fire5. OP-TM-EOP-020, Cooldown Outside of Control RoomMonth 20XXTMI 3-132EP-AA-1009 (Revision XX)
Throm Uila lalanri Qfafinn AnnovI::alnn NnMalrTham. Mum IoImnrI Qtmtir~n Annmv Fvmlnn i~ImirIm~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU42Initiating Condition:Seismic event greater than OBE levels.Operating Mode Applicability:1,2,3,4,5,6, DEmergency Action Level (EAL):Seismic event > Operating Basis Earthquake (OBE) as indicated by seismic AlarmsPRF-1-3 Operating Basis Earthquake and PRF-1-2 Threshold Seismic Condition.Siw;n-m eveont groatcr than Oporating Basis Earthquak, (,BE) as indicatod by:.a. (cito- sepoific indic-ation that.asii ovent met Or oxcooedod 0OBE limits)Basis:This IC addresses a seismic event that results in accelerations at the plant site greaterthan those specified for an Operating Basis Earthquake (OBE)'. An earthquake greaterthan an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have nosignificant impact on safety-related systems, structures and components; however,some time may be required for the plant staff to ascertain the actual post-eventcondition of the plant (e.g., performs walk-downs and post-event inspections). Giventhe time necessary to perform walk-downs and inspections, and fully understand anyimpacts, this event represents a potential degradation of the level of safety of the plant.Event verification with external sources should not be necessary during or following anOBE. Earthquakes of this magnitude should be readily felt by on-site personnel andrecognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).The Shift Manager or Emergency Director may seek external verification if deemedappropriate (e.g., a call to the USGS, check internet news sources, etc.); however, theverification action must not preclude a timely emergency declaration.Depending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA26 or HA5SA".An OBE is vibratory ground motion for which those features of a nuclear power plantnecessary for continued operation without undue risk to the health and safety of thepublic will remain functional.An SSE is vibratory ground motion for which certain (generally, safety-related)structures, systems, and components must be designed to remain functional.Month 20XXTMI 3-133EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis Reference(s):1. NEI 99-01, Rev 6 HU22. OP-TM-AOP-003, Earthquake3. PRF 1-3 Operating Bases Earthquake4. PRF 1-2 Threshold Seismic EventMonth 20XXTMI 3-134EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5Initiating Condition:Gaseous release impeding access to equipment necessary for normal plant operations,cooldown or shutdown.Operating Mode Applicability:1,2,3,4,5,6, DEmergency Action Level (EAL):Note: If the eauipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emeraencv classification iswarranted.1. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area.Table H3Areas with Entry Related Mode ApplicabilityArea Entry Related ModeApplicabilityReactor Building* Modes 4. 5. and 6Intermediate Building* Modes 4, 5, and 6Auxiliary Building* Modes 4, 5, and 6Fuel Handling Building* Modes 4, 5, and 6*Areas required to establish shutdown coolingAND2. Entrv into the room or area is prohibited or impededNote: It the equipment In the listed oom or arca was areadyinoperable Or out1e e thc event occurred, then no- omergency classification isWa~rated.-(1) a. Release of a toxiccroie asphyxiant or: flammable gas into any of thefollowin pln-ooSo riasOR!.' ...-10-J --J - --........... ;J.L ----X .... I=,IL--J =--J--ýWTYZTZ ýým ý'&' ZI.r, ., IMonth 20XXTMI 3-135EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYb. intry into the rFOom O area is prohibited or impeded.Basis:This IC addresses an event involving a release of a hazardous gas that precludes orimpedes access to equipment necessary to transition the plant from normal plantoperation to cooldown and shutdown as specified in normal plant proceduresma.itai.no.mal plant operamtio o requed for a no.mal plant coodown and chutd -- ..n... Thiscondition represents an actual or potential substantial degradation of the level of safetyof the plant.Table H3 is a list of plant rooms or areas with entry-related mode applicability thatcontain equipment which require a manual/local action necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal operatingprocedures (establish shutdown cooling), where if this action is not completed the plantwould not be able to attain and maintain cold shutdown.This Table does not include rooms or areas for which entry is required solely to performactions of an administrative or record keeping nature (e.g., normal rounds or routineinspections).This Table does not include the Control Room since adequate engineered safety/designfeatures are in place to preclude a Control Room evacuation due to the release of ahazardous gas.An Alert declaration is warranted if entry into the affected room/area is, or may be,procedurally required during the plant operating mode in effect and the gaseous releasepreclude the ability to place shutdown cooling in serviceat the time of the gaseousrelease. The emergency classification is not contingent upon whether entry is actuallynecessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires theEmergency Director's judgment that the gas concentration in the affected room/area issufficient to preclude or significantly impede procedurally required access. Thisjudgment may be based on a variety of factors including an existing job hazard analysis,report of ill effects on personnel, advice from a subject matter expert or operatingexperience with the same or similar hazards. Access should be considered as impededif extraordinary measures are necessary to facilitate entry of personnel into the affectedroom/area (e.g., requiring use of protective equipment, such as SCBAs, that is notroutinely employed).An emergency declaration is not warranted if any of the following conditions apply.The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the timeof the gaseous release). For example, the plant is in Mode 1 when the gaseousMonth 20XXTMI 3-136EP-AA-1 009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYrelease occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4." The gas release is a planned activity that includes compensatory measures whichaddress the temporary inaccessibility of a room or area (e.g., fire suppressionsystem testing)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerouslevels. Most commonly, asphyxiants work by merely displacing air in an enclosedenvironment. This reduces the concentration of oxygen below the normal level ofaround 19%, which can lead to breathing difficulties, unconsciousness or even death.I This EAL does not apply to firefighting activities that generate smoke or thatautomatically or manually activate a fire suppression system in an area.I Escalation of the emergency classification level would be via Recognition Category BA,C or F ICs.Basis Reference(s):1. NEI 99-01, Rev 6 HA52. FSAR Figure 2.1-3, Extended Plot Plan TMINS3. FSAR Section 5.1, Class I Structures, Components, and Systems4. NEI 99-01, Rev. 5 HA35. OP-TM-406-901, Hazardous Material Release6. AR-660892660892 Station Halon and IDLH Evaluations7. 29CFR1910.134(b) and 29CFR1910.134(d)(2)(iii)Month 20XXTMI 3-137EP-AA-1009 (Revision XX)
Throm Uila Wand Qtatinn AnnovFvl=eml Kbitl-harTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU63Initiating Condition:Hazardous EventOperating Mode Applicability:1, 2,3,4,5,6, DEmergency Action Level (EAL):Note: EAL #4 does not applv to routine traffic impediments such as foq. snow, ice, orvehicle breakdowns or accidents.1. Tornado strike within the PROTECTED AREA.OR2. Internal room or area floodinq of a magnitude sufficient to require manual orautomatic electrical isolation of a SAFETY SYSTEM component required byTechnical Specifications for the current operating mode.OR3. Movement of personnel within the PROTECTED AREA is impeded due to an offsiteevent involvina hazardous materials (e.a., an offsite chemical spill or toxic aasrelease).OR4. A hazardous event that results in on-site conditions sufficient to prohibit the plantstaff from accessina the site via Dersonal vehicles.OR5. Abnormal river water level at the intake Pump and Screen House. as indicated byEITHER:a. > 300 ft. el. (high level)ORb. < 274 ft. el. (low level)KI M AI 4J'Url nA r4n nrnt nrm 1rn*.4;n ; A; ml- 1 4- -. ma .to UM "me% " K----I- "- -" " M e " p " r tf~, rf t----I--:--I-- L --- --I-Jav a narln ate.I----- --~-------%.Ii III^ ^/ ^ pt Ir^^ A ti IPll14IA ~ .....Z..~...L.. 4L.. M^ r1r-r-*r~rý A Mr-~ Ak -Li iU i ru .uii i M1 tWHIM, btHMI W~tH, t iuMonth 20XXTMI 3-138EP-AA-1009 (Revision XX) hroo Uila halsand Rtntinn AnnoyThi. MIuli Iv v Vt~n A Exn NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY(2) Irt-,.,.-- re mOrT, ar; -... e-,,-,,.;,,g of a magntud ; ,I ..ft,,;n-, to ..... e ....I,,automatic A-elotrical isoelation of a SAFETYý SYSTEM Gompnn neded for thOcurrent operating moede-.(3) Movement o-f personnel within the PROTECTED AREA is impeded duo to anoffeito eyent in.oighzardous materials (e.g., an offeito chemical spill Or toxiG_(4) A hazardouc event that results in on-site conditions suffic-ient to prohibit the plantstaff frome _accessing the site via personal vehicles.(5) (Site-specific of natural Or thngical hazard events)Basis:PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.SAFETY SYSTEM: A system required for safe plant ogeration. cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretygically systems classified as safety-related.This IC addresses hazardous events that are considered to represent a potentialdegradation of the level of safety of the plant.EAL #1 -Basis-aAddresses a tornado striking (touching down) within the Protected Area.EAL #2 BasisaAddresses flooding of a building room or area that results in operators isolating powerto a SAFETY SYSTEM component due to water level or other wetting concerns.Classification is also required if the water level or related wetting causes an automaticisolation of a SAFETY SYSTEM component from its power source (e.g., a breaker orrelay trip). To warrant classification, operability of the affected component must berequired by Technical Specifications for the current operating mode. Manual isolation ofpower to a SAFETY SYSTEM component as a result of leakage is an event of lesserimpact and would be expected to cause small and localized damage. The consequenceof this type of event is adequately assessed and addressed in accordance withTechnical Specifications.EAL #3 BasisaAddresses a hazardous materials event originating at an offsite location and ofsufficient magnitude to impede the movement of personnel within the PROTECTEDAREA.Month 20XXTMI 3-139EP-AA-1009 (Revision XX)
Three Mile IRsland Station Annex Exelon NuceIarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYEAL #4 BasisaAddresses a hazardous event that causes an on-site impediment to vehicle movementand significant enough to prohibit the plant staff from accessing the site using personalvehicles. Examples of such an event include site flooding caused by a hurricane, heavyrains, up-river water releases, dam failure, etc., or an on-site train derailment blockingthe access road.This EAL is not intended to apply to routine impediments such as fog, snow, ice, orvehicle breakdowns or accidents, but rather to more significant conditions such as theHurricane Andrew strike on Turkey Point in 1992, the flooding around the CooperStation during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in2011.EAL #5 Basis:The level of the Susquehanna River is approaching flood stage; flood stage is definedas 302 ft el. at the Intake Pump and Screen House.A low river water condition below 274 ft el. requires a Technical Specification 3.0.1 plantshutdown per OP-TM-AOP-005 and is a precursor to a more serious condition.EAL= #5 addroccec (site spccific descriptiGPn).Escalation of the emergency classification level would be based on ICs in RecognitionCategories RA, F, MSj H or C.Basis Reference(s):1. NEI 99-01, Rev 6 HU32. OP-TM-AOP-005 River Water System Failures3. OP-TM-AOP-002, Flood4. OP-TM-AOP-004, Tornado / High WindsMonth 20XXTMI 3-140EP-AA-1 009 (Revision XX)
Thrmn~ M.ild li@Inni Q*fafinnu AnngavI=v-mlnn M"rAmarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a GENERAL EMERGENCY.Operating Mode Applicability:1,2,3, 4,5,6, DEmergency Action Level (EAL):(44 Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or IMMINENTsubstantial core degradation or melting with potential for loss of containment integrity orHOSTILE ACTION that results in an actual loss of physical control of the facility.Releases can be reasonably expected to exceed EPA Protective Action Guidelineexposure levels offsite for more than the immediate site area.Basis:IMMINENT: The traiectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy eguipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for aGeneral Emergency.Basis Reference(s):1. NEI 99-01, Rev 6 HG7Month 20XXTMI 3-141EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a SITE AREA EMERGENCY.Operating Mode Applicability:1,2,3, 4,5,6, DEmergency Action Level (EAL):M( Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or likely major failuresof plant functions needed for protection of the public or HOSTILE ACTION that results inintentional damage or malicious acts, (1) toward site personnel or equipment that couldlead to the likely failure of or, (2) that prevent effective access to equipment needed forthe protection of the public. Any releases are not expected to result in exposure levelswhich exceed EPA Protective Action Guideline exposure levels beyond the siteboundary.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An obiect directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for a SiteArea Emergency.Basis Reference(s):1. NEI 99-01, Rev 6 HS7Month 20XXTMI 3-142EP-AA-1 009 (Revision XX)
Throm Milts Weandi Qtatinn Anno~vFwi::nl N, MplarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an ALERT Operating Mode Applicability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):(-1) Other conditions exist which, in the judgment of the Emergency Director, indicatethat events are in progress or have occurred which involve an actual or potentialsubstantial degradation of the level of safety of the plant or a security event thatinvolves probable life threatening risk to site personnel or damage to site equipmentbecause of HOSTILE ACTION. Any releases are expected to be limited to smallfractions of the EPA Protective Action Guideline exposure levels.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anAlert.Basis Reference(s):1. NEI 99-01, Rev 6 HA7Month 20XXTMI 3-143EP-AA-1009 (Revision XX)
Thnag Migla Ieanei Qtntiv~n AnnovI:valenn Mir-loarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an (NO),UNUSUAL EVENT.Operating Mode Applicability:1,2,3, 4,5,6, DEmergency Action Level (EAL):I (-M1 Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which indicate a potential degradation ofthe level of safety of the plant or indicate a security threat to facility protection has beeninitiated. No releases of radioactive material requiring offsite response or monitoring areexpected unless further degradation of safety systems occurs.Basis:This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anEVENT.Basis Reference(s):1. NEI 99-01, Rev 6 HU7Month 20XXTMI 3-144EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisEmergency Action Level Technical Basis Page IndexGeneral Site Area Alert Unusual EventEAL Pg. EAL Pg. EAL Pg. EAL Pg.RG1 3-32 RS1 3-34 RA1 3-36 RU1 3-39RA2 3-42 RU2 3-44RA3 3-46 RU3 3-49FG1 3-50 FS1 3-51 FA1 3-52 1Fuel Clad RCS ContainmentFC1 3-53 RC1 3-59 CT1 3-64FC2 3-54 RC2 3-61 CT2 3-67FC3 3-56 RC3 3-62 CT3 3-68CT4 3-69FC5 3-58 RC5 3-63 CT5 3-75MG1 3-76 MS1 3-78 MA1 3-80 MUW 3-82MG2 3-83 MS2 3-85MS3 3-86 MA3 3-88 MU3 3-90MA4 3-93 MU4 3-95MA5 3-97MU6 3-99MU7 3-101MU8 3-103CA1 3-105 CU1 3-107C A 2 3 -10 9 _ _ _ _-1 1____ _ _ ____ __ ___ CU3 3-111CU4 3-113CA5 3-115 CU5 3-118CG6 3-120 CS6 3-124 CA6 3-127 CU6 3-129HG1 3-131 HS1 3-133 HA1 3-135 HU1 3-138HS2 3-140 HA2 3-142HU3 3-143HU4 3-147HA5 3-148HU6 3-151HG7 3-154 HS7 3-155 HA7 3-156 HU7 3-157Month 20XXTMI 3-31EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRGIInitiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRem TEDEor 5000 mRem thyroid CDE.Operating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.OR2. Dose assessment Using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected to continuefor > 60 minutes.ORb. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for60 minutes of inhalation.Month 20XXTMI 3-32EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRG1 (cont)Emergency Action Level (EAL) (cont):Table R1 Effluent Monitor ThresholdsEffluent Monitor General EmergencyRM-G-25 (Cond Offgas) 9.53 E+06 mR/hrRM-A-8GH (Station Vent) 3.09 E+05 cpmRM-G-24 (RB Purge) 5.55 E+05 mRlhrRM-A-14 (ESF Vent) 6.66 E+02 uCi/ccBasis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to the EPA Protective Action Guides (PAGs). Itincludes both monitored and un-monitored releases. Releases of this magnitude willrequire implementation of protective actions for the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at the EPA PAG of 1000 mRem while the 5000 mRem thyroid CDEwas established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroidCDE.Basis Reference(s):1. NEI 99-01 Rev 6, AG12. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile Island3. EP-AA-112-500 Emergency Environmental Monitoring4. FSAR Section 11.4 Radiation Monitoring System5. EP-AA-1 10-200 Dose Assessment6. EP-AA-1 10-201 On Shift Dose AssessmentMonth 20XXTMI 3-33EP-AA-1 009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRS1Initiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDEor 500 mRem thyroid CDE.Operating Mode Applicability:1, 2,3, 4,5,6, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.1. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 15 minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 100 mRem TEDEORb. > 500 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >100 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for60 minutes of inhalation.Month 20XXTMI 3-34EP-AA-1009 (Revision XX)
N rThree MileIs land Station Annex FvAinn NuleIAarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRS1 (cont)Emergency Action Level (EAL) (cont):Table RI Effluent Monitor ThresholdsEffluent Monitor Site Area EmergencyRM-G-25 (Cond Offgas) 9.53 E+05 mR/hrRM-A-8GH (Station Vent) 3.09 E+04 cpmRM-G-24 (RB Purge) 5.55 E+04 mR/hrRM-A-14 (ESF Vent) 6.66 E+01 uCi/ccBasis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).It includes both monitored and un-monitored releases. Releases of this magnitude areassociated with the failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at 10% of the EPA PAG of 1000 mRem while the 500 mRemthyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDEand thyroid CDE.Escalation of the emergency classification level would be via IC RG1.Basis Reference(s):1. NEI 99-01 Rev 6, AS12. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile Island3. EP-AA-1 12-500 Emergency Environmental Monitoring4. FSAR Section 11.4 Radiation Monitoring System5. EP-AA-1 10-200 Dose Assessment6. EP-AA-1 10-201 On Shift Dose AssessmentMonth 20XXTMI 3-35EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA1Initiating Condition:Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRemTEDE or 50 mRem thyroid CDE.Operating Mode Applicability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 50 mRem CDE ThyroidOR3. Analysis of a liquid effluent sample indicates a concentration or release rate thatwould result in doses greater than EITHER of the following at or beyond the siteboundarya. 10 mRem TEDE for 60 minutes of exposureORb. 50 mRem CDE Thyroid for 60 minutes of exposureORMonth 20XXTMI 3-36EP-AA-1009 (Revision XX)
Thran Win hmhanrl -Qfnfien AnnoyI:vnlrn KI"t-InmrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA1 (cont)Emergency Action Level (EAL) (cont):4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate > 50 mRem CDEThyroid for 60 minutes of inhalation.Table R1 Effluent Monitor ThresholdsEffluent Monitor AlertRM-G-25 (Cond Offgas) 9.53 E+04 mR/hrRM-A-8GH (Station Vent) 3.09 E+03 cpmRM-G-24 (RB Purge) 5.55 E+03 mR/hrRM-A-14 (ESF Vent) 6.66 E+00 uCi/ccBasis:This IC addresses a release of gaseous or liquid radioactivity that results in projected oractual offsite doses greater than or equal to 1% of the EPA Protective Action Guides(PAGs). It includes both monitored and un-monitored releases. Releases of thismagnitude represent an actual or potential substantial degradation of the level of safety ofthe plant as indicated by a radiological release that significantly exceeds regulatory limits(e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at 1% of the EPA PAG of 1000 mRem while the 50 mRem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Escalation of the emergency classification level would be via IC RS1.Month 20XXTMI 3-37EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA1 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, AA12. OP 1101-2.1 Radiation Monitoring System Setpoints3. FSAR Section 11.4 Radiation Monitoring System4. OP-TM-MAP-CO101, Radiation Level HI5. EP-EAL-0609, Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile Island6. EP-EAL-0616, Revision 0, Three Mile Island Criteria for Choosing RadiologicalLiquid Effluent EAL Threshold Values7. EP-EAL-0622, Revision 0, Three Mile Island Criteria for Choosing RadiologicalGaseous Effluent EAL Threshold Values for Waste Gas Decay TanksMonth 20XXTMI 3-38EP-AA-1 009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU1Initiating Condition:Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60minutes or longer.Operating Mode Applicability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.1. Reading on ANY of the following effluent monitors > 2 times alarm setpointestablished by a current radioactive release discharge permit for > 60 minutes." RM-L-6, Radwaste Discharge" RM-L-12, IWTS / IWFS Discharge" RM-A-7, Waste Gas Decay Tank Discharge" Discharge Permit specified monitorOR2. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 60 minutes.OR3. Confirmed sample analyses for gaseous or liquid releases indicate concentrationsor release rates > 2 times ODCM Limit with a release duration of > 60 minutes.Month 20XXTMI 3-39EP-AA-1009 (Revision XX) rThree Mile~ Island Staition Annex ExalInn NuclerIArTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRUI (cont)Emergency Action Level (EAL) (cont):Table R1 Effluent Monitor ThresholdsEffluent Monitor Unusual EvetRM-G-25 (Cond Offgas) 1.09 E+03 mR/hrRM-A-8GH (Station Vent) 7.03 E+01 cpmRM-G-24 (RB Purge) 6.34 E+01 mR/hrRM-A-14 (ESF Vent) 7.60 E-02 uCi/ccBasis:This IC addresses a potential decrease in the level of safety of the plant as indicated by alow-level radiological release that exceeds regulatory commitments for an extendedperiod of time (e.g., an uncontrolled release). It includes any gaseous or liquidradiological release, monitored or un-monitored, including those for which a radioactivitydischarge permit is normally prepared.Nuclear power plants incorporate design features intended to control the release ofradioactive effluents to the environment. Further, there are administrative controlsestablished to prevent unintentional releases, and to control and monitor intentionalreleases. The occurrence of an extended, uncontrolled radioactive release to theenvironment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.Releases should not be prorated or averaged. For example, a release exceeding 4 timesrelease limits for 30 minutes does not meet the EAL.EAL #1 BasisThis EAL addresses radioactivity releases that cause effluent radiation monitor readingsto exceed 2 times the limit established by a radioactivity discharge permit. This EAL willtypically be associated with planned batch releases from non-continuous releasepathways (e.g., radwaste, waste gas).The effluent monitors listed are those normally used for planned discharges. If adischarge is performed using a different flowpath or effluent monitor other than thoselisted (e.g., a portable or temporary effluent monitor), then the declaration criteria will bebased on the monitor specified in the Discharge Permit.EAL #2 BasisThis EAL addresses normally occurring continuous radioactivity releases from monitoredgaseous effluent pathways.Month 20XXTMI 3-40EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRUl (cont)Basis (cont):EAL #3 BasisThis 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 RAI.Basis Reference(s):1. NEI 99-01 Rev 6, AU12. OP 1101-2.1 Radiation Monitoring System Setpoints3. FSAR Section 11.4 Radiation Monitoring System4. Offsite Dose Calculation (ODCM)5. OP-TM-MAP-CO101, Radiation Level HI6. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values, Three Mile IslandMonth 20XXTMI 3-41EP-AA-1009 (Revision XX)
Three Mile kIslnd Station Annexv ExaInn Miiu-lpagrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA2Initiating Condition:Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel asindicated by ANY Table R2 Radiation Monitor reading >1000 mRem/hrTable R2Radiation MonitorsRMS Area Monitored ModeRM-G-9 FHB Bridge Rad Monitor ALLRM-G-6 RB Auxiliary Bridge Rad Monitor 5, 6RM-G-7 RB Main Bridge Rad Monitor 5, 6Basis:REFUELING PATHWAY: all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.IMMINENT: The trajectory of events or conditions is such that an EAL will be met within arelatively short period of time regardless of mitigation or corrective actions.This IC addresses events that have caused IMMINENT or actual damage to an irradiatedfuel assembly. These events present radiological safety challenges to plant personneland are precursors to a release of radioactivity to the environment. As such, theyrepresent an actual or potential substantial degradation of the level of safety of the plant.Month 20XXTMI 3-42EP-AA-1009 (Revision XX)
Thran Milo lalnnrl Qfnfinn AnnoyIPvln~n Thr~a MiI~ I@6nv4 ~t2*inn Ann~v Fvalnn Nuu-I~~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA2 (cont)Basis (cont):EAL #1 Basis:This EAL escalates from RU2 in that the loss of level, in the affected portion of theREFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery ofirradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visualobservation (e.g., reports from personnel or camera images), as well as significantchanges in water and radiation levels, or other plant parameters. Computational aidsmay also be used (e.g., a boil-off curve). Classification of an event using this EAL shouldbe based on the totality of available indications, reports and observations.While an area radiation monitor could detect a rise in a dose rate due to a lowering ofwater level in some portion of the REFUELING PATHWAY, the reading may not be areliable indication of whether or not the fuel is actually uncovered. To the degreepossible, readings should be considered in combination with other available indications ofinventory loss.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.EAL #2 Basis:This EAL addresses a release of radioactive material caused by mechanical damage toirradiated fuel. Damaging events may include the dropping, bumping or binding of anassembly, or dropping a heavy load onto an assembly. A rise in readings on radiationmonitors should be considered in conjunction with in-plant reports or observations of apotential fuel damaging event (e.g., a fuel handling accident).Escalation of the emergency would be based on either Recognition Category R or C ICs.Basis Reference(s):1. NEI 99-01 Rev 6, AA22. Operating Procedure OP-TM-MAP-C0105 RCS Draindown LVL HI/LO3. OP-TM-MAP-CO101, Radiation Level HI4. UFSAR, Section 14.2.2.1 -"Fuel Handling Accident"5 Technical Specification 3.8.11 (Reactor Cavity Level)6. Operating Procedure OP 1101-2.1 Radiation Monitoring System SetpointsMonth 20XXTMI 3-43EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU2Initiating Condition:UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):1. a. UNPLANNED water level drop in the REFUELING PATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable R2.Table R2Radiation MonitorsRMS Area Monitored ModeRM-G-9 FHB Bridge Rad Monitor ALLRM-G-6 RB Auxiliary Bridge Rad Monitor 5,6RM-G-7 RB Main Bridge Rad Monitor 5, 6Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.REFUELING PATHWAY: all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.This IC addresses a loss in water level above irradiated fuel sufficient to cause elevatedradiation levels. This condition could be a precursor to a more serious event and is alsoindicative of a minor loss in the ability to control radiation levels within the plant. It istherefore a potential degradation in the level of safety of the plant.A water level loss will be primarily determined by indications from available levelinstrumentation. Other sources of level indications may include reports from plantpersonnel (e.g., from a refueling crew) or video camera observations (if available) or fromany other temporarily installed monitoring instrumentation. A significant drop in the waterlevel may also cause a rise in the radiation levels of adjacent areas that can be detectedby monitors in those locations.Month 20XXTMI 3-44EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU2 (cont)Basis (cont):The effects of planned evolutions should be considered. For example, a refueling bridgearea radiation monitor reading may rise due to planned evolutions such as lifting of thereactor vessel head or movement of a fuel assembly. Note that this EAL is applicableonly in cases where 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.Basis Reference(s):1. NEI 99-01 Rev 6, AU22. UFSAR, Section 14.2.2.1 -"Fuel Handling Accident"3. OP-TM-MAP-CO105 RCS Draindown4. OP 1202-12, Excessive Radiation Levels5. OP 1101-2.1 Radiation Monitoring System Setpoints6. Technical Specification 3.8.11 (Reactor Cavity Level)Month 20XXTMI 3-45EP-AA-1009 (Revision XX)
Three Mile kIslnd Stamtion Annex FYAlnn Mana-I0nrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA3Initiating Condition:Radiation levels that impede access to equipment necessary for normal plant operations,cooldown or shutdown.Operating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):Note:* If the equipment in the room or area listed in Table R4 was already inoperable, orout of service, before the event occurred, then no emergency classification iswarranted.1. Dose rate > 15 mR/hr in ANY of the areas contained in Table R3:Table R3Areas Requiring Continuous Occupancy* Main Control Room* Central Alarm Station -(by survey)OR2. UNPLANNED event results in radiation levels that prohibit or significantly impedeaccess to ANY of the following Table R4 plant rooms or areas:Table R4Areas with Entry Related Mode ApplicabilityArea Entry Related ModeApplicabilityReactor Building* Modes 4, 5, and 6Intermediate Building* Modes 4, 5, and 6Auxiliary Building* Modes 4, 5, and 6Fuel Handling Building* Modes 4, 5, and 6*Areas required to establish shutdown coolingMonth 20XXTMI 3-46EP-AA-1009 (Revision XX) rThree MileIs land Stamtion Annex Fyelnn NuclaInrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA3 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient topreclude or impede personnel from performing actions necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal plantprocedures. As such, it represents an actual or potential substantial degradation of thelevel of safety of the plant. The Emergency Director should consider the cause of theincreased radiation levels and determine if another IC may be applicable.Table R4 is a list of plant rooms or areas with entry-related mode applicability that containequipment which require a manual/local action necessary to transition the plant fromnormal plant operation to cooldown and shutdown as specified in normal operatingprocedures (establish shutdown cooling), where if this action is not completed the plantwould not be able to attain and maintain cold shutdown. This Table does not includerooms or areas for which entry is required solely to perform actions of an administrative orrecord keeping nature (e.g., normal rounds or routine inspections).Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including theControl Room.For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, ormay be, procedurally required during the plant operating mode in effect and the elevatedradiation levels preclude the ability to place shutdown cooling in service. The emergencyclassification is not contingent upon whether entry is actually necessary at the time of theincreased radiation levels. Access should be considered as impeded if extraordinarymeasures are necessary to facilitate entry of personnel into the affected room/area (e.g.,installing temporary shielding beyond that required by procedures, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normaladministrative 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 radiationrise occurs, and the procedures used for normal operation, cooldown and shutdowndo not require entry into the affected room until Mode 4." The increased radiation levels are a result of a planned activity that includescompensatory measures which address the temporary inaccessibility of a room orarea (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections).Month 20XXTMI 3-47EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRA3 (cont)Basis (cont):* The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category R, Cor F ICs.Basis Reference(s):1. NEI 99-01 Rev 6, AA32. FSAR Section 5.01 Class I Structures, Components, and Systems3. OP-TM-MAP-CO101, Radiation Level HIMonth 20XXTMI 3-48EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSRU3Initiating Condition:Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):1. Letdown Monitor RM-L-1 alert alarm (high or low channel).OR2. Sample analysis indicates that:a. Dose Equivalent 1-131 specific coolant activity > 60.0 uCi/gm.ORb. Dose Equivalent XE-133 specific coolant activity> 797.0 uCi/gm.Basis:This IC addresses a reactor coolant activity value that exceeds an allowable limitspecified in Technical Specifications. This condition is a precursor to a more significantevent and represents a potential degradation of the level of safety of the plant.Conditions that cause the specified monitor to alarm that are not related to fuel claddegradation should not result in the declaration of an Unusual Event.This EAL addresses site-specific radiation monitor readings that provide indication of adegradation of fuel clad integrity.An Unusual Event is only warranted when actual fuel clad damage is the cause of theelevated coolant sample activity (as determined by laboratory confirmation). Fuel claddamage should be assumed to be the cause of elevated Reactor Coolant activity unlessanother cause is known.Escalation of the emergency classification level would be via ICs FAl or the RecognitionCategory R ICs.Basis Reference(s):1. NEI 99-01 Rev 6, SU32. Operating Procedure 1101-2.1 Radiation Monitoring System Setpoints3. FSAR Section 11.4.4, Liquid Monitoring Subsystem4. OP-TM-MAP-CO101, Radiation Level HI5. Technical Specifications 3.1.4, Reactor Coolant System ActivityMonth 20XXTMI 3-49EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFG1Initiating Condition:Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-50EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFS1Initiating Condition:Loss or Potential Loss of ANY two barriers.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-51EP-AA-1009 (Revision XX)
Nur.legrThree Mile Island Sftation Annex FveInn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFA1Initiating Condition:ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Alert classification level, Fuel Cladding and RCS barriers are weighted moreheavily than the Containment barrier. Unlike the Containment barrier, loss or potentialloss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactivematerials or degradation of core cooling capability. Note that the loss or potential loss ofContainment barrier in combination with loss or potential loss of either Fuel Cladding orRCS barrier results in declaration of a Site Area Emergency under EAL FSI.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-52EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC1Initiating Condition:RCS or SG Tube LeakageOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:POTENTIAL LOSS1. RCITS hot leg instruments indicate 0 inches after lowering trend.AND2. In-core thermocouples are unavailable.AND3. ALL RCP's are secured.Basis:There is no Loss threshold associated with RCS or SG Tube Leakage.Potential Loss Threshold #1 Basis:This reading indicates a reduction in reactor vessel water level sufficient to allow theonset of heat-induced cladding damage.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. FSAR 7.3.2.2.c.10.d3. OP-TM-EOP-008, RCS Superheated4. OP-TM-EOP-010, Emergency Procedure Rules Guides and GraphsMonth 20XXTMI 3-53EP-AA-1009 (Revision XX)
FxpInn Three Mile kIsland Staition Annex FvAlnn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC2Initiating Condition:Inadequate Heat RemovalOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. Tclad > 1400°FPOTENTIAL LOSS2. > 25°F SuperheatOR3. HPI-PORV Cooling in effect.Basis:Loss Threshold #1 BasisThis reading indicates temperatures within the core are sufficient to cause significantsuperheating of reactor coolant.Potential Loss Threshold #2 BasisThis reading indicates temperatures within the core are sufficient to allow the onset ofheat-induced cladding damage.Potential Loss Threshold #3 BasisThis condition indicates an extreme challenge to the ability to remove RCS heat usingthe steam generators (i.e., loss of an effective secondary-side heat sink). This conditionrepresents a potential loss of the Fuel Clad Barrier. In accordance with EOPs, theremay be unusual accident conditions during which operators intentionally reduce theheat removal capability of the steam generators; during these conditions, classificationusing threshold is not warranted.Meeting this threshold results in a Site Area Emergency because this threshold isidentical to RCS Barrier RC2 Potential Loss threshold; both will be met. This conditionwarrants a Site Area Emergency declaration because inadequate RCS heat removalmay result in fuel heat-up sufficient to damage the cladding and raise RCS pressure tothe point where mass will be lost from the system.Month 20XXTMI 3-54EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC2 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. OS-24 Attachment D3. OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer4. OP-TM-EOP-008, RCS Superheated5. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs6. OS-24, Conduct of Operations during Abnormal and Emergency EventsMonth 20XXTMI 3-55EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC3Initiating Condition:Containment Radiation / RCS ActivityOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. Containment radiation monitor (RM-G-22 or RM-G-23) reading > 1.95E+03 R/hr.OR2. Coolant activity > 300uCi/gm Dose Equivalent 1-131Basis:Loss Threshold #1 Basis:The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the containment, assuming that reactor coolant activity equals300pCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greaterthan that expected for iodine spikes and corresponds to an approximate range of 2% to5% fuel clad damage. Since this condition indicates that a significant amount of fuelclad damage has occurred, it represents a loss of the Fuel Clad Barrier.The radiation monitor reading in this threshold is higher than that specified for RCSBarrier RC3 Loss Threshold since it indicates a loss of both the Fuel Clad Barrier andthe RCS Barrier. Note that a combination of the two monitor readings appropriatelyescalates the emergency classification level to a Site Area Emergency.Loss Threshold #2 Basis:This threshold indicates that RCS radioactivity concentration is greater than 300 pCi/gmdose equivalent 1-131. Reactor coolant activity above this level is greater than thatexpected for iodine spikes and corresponds to an approximate range of 2% to 5% fuelclad damage. Since this condition indicates that a significant amount of fuel claddamage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highlyelevated activity levels could require several hours to complete. Nonetheless, asample-related threshold is included as a backup to other indicationsThere is no Fuel Clad Barrier Potential Loss threshold associated with RCS Activity /Containment Radiation.Month 20XXTMI 3-56EP-AA-1009 (Revision XX)
Kh Throp Milo~ 1--Ind Station Annex Pvalnn NmuuulanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC3 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-MAP-CO101, Radiation Level HI3. FSAR Section 11.4.4, Liquid Monitoring System Description4. Calculation C3640-98-034, Prediction of the Response of RM-G-6 and 7 to FuelDamage5. Core Damage Assessment Methodology (CDAM)Month 20XXTMI 3-57EP-AA-1 009 (Revision XX)
Pvalnn kl"AanrThree Mila kIslnd Rtnatinn AnnqxF~n .1 vgiTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC5Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. Any condition in the opinion of the Emergency Director that indicates Loss of the FuelClad Barrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergency Director that indicates Potential Lossof the Fuel Clad Barrier.Basis:Loss Threshold #1 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold #2 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-58EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC1Initiating Condition:RCS or SG Tube LeakageOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. Automatic or manual ESAS actuation is required by EITHER of the following:a. UNISOLABLE RCS leakageORb. Steam Generator tube RUPTURE.POTENTIAL LOSS2. UNISOLABLE RCS leakage > 150gpm.OR3. HPI-PORV Cooling in effect.OR4. a. RCS Pressure > 2450 psig.ANDb. RCS Pressure not lowering.Basis:UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.RUPTURE(D): The condition of a steam generator in which primary-to-secondaryleakage is of sufficient magnitude to require a safety injection.FAULTED: The term applied to a steam generator that has a steam leak on thesecondary side of sufficient size to cause an uncontrolled drop in steam generatorpressure or the steam generator to become completely depressurized.Loss Threshold #1 BasisThis threshold is based on an UNISOLABLE RCS leak of sufficient size to require anautomatic or manual actuation of the Emergency Core Cooling System (ECCS). Thiscondition clearly represents a loss of the RCS Barrier.Month 20XXTMI 3-59EP-AA-1009 (Revision XX)
Three Milo Islandl Station Annex Fvalnn INJ~rlanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRCl (cont)Basis (cont):This threshold is applicable to unidentified and pressure boundary leakage, as well asidentified leakage. It is also applicable to UNISOLABLE RCS leakage through aninterfacing system. The mass loss may be into any location -inside containment, to thesecondary-side (i.e., steam generator tube leakage) or outside of containment.A steam generator with primary-to-secondary leakage of sufficient magnitude to requirea safety injection is considered to be RUPTURED. If a RUPTURED steam generator isalso FAULTED outside of containment, the declaration escalates to a Site AreaEmergency since the Containment Barrier CT1 Loss threshold will also be met.Potential Loss Threshold #2 BasisThis threshold is based on an UNISOLABLE RCS leak that results in the inability tomaintain pressurizer level within specified limits by operation of a normally usedcharging (makeup) pump, but an ECCS (SI) actuation has not occurred. The thresholdis met when an operating procedure, or operating crew supervision, directs that astandby charging (makeup) pump be placed in service to restore and maintainpressurizer level.This threshold is applicable to unidentified and pressure boundary leakage, as well asidentified leakage. It is also applicable to UNISOLABLE RCS leakage through aninterfacing system. The mass loss may be into any location -inside containment, to thesecondary-side (i.e., steam generator tube leakage) or outside of containment.If a leaking steam generator is also FAULTED outside of containment, the declarationescalates to a Site Area Emergency since the Containment Barrier CT1 Loss Threshold#1 will also be met.Potential Loss Threshold #3 BasisThis condition indicates an extreme challenge to the integrity of the RCS pressureboundary due to pressurized thermal shock -a transient that causes rapid RCScooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized).Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-010 Emergency Procedure Rules, Guides And Graphs3. OP-TM-EOP-002 Loss of 25°F Subcooled Margin4. OP-TM-MAP-D031, MU Flow HI5. OP-TM-EOP-005, OTSG Tube LeakageMonth 20XXTMI 3-60EP-AA-1009 (Revision XX)
Thra~ MiIA% liennr -4fnfiv~n Anng~vP~v-ltln Ik1, ,-ImrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC2Initiating Condition:Inadequate Heat RemovalOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:POTENTIAL LOSSHPI-PORV Cooling in effect.Basis:There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold BasisHPI-PORV Cooling in effect indicates a Lack of Primary to Secondary Heat Transfercapability.This condition indicates an extreme challenge to the ability to remove RCS heat usingthe steam generators (i.e., loss of an effective secondary-side heat sink). This conditionrepresents a potential loss of the RCS Barrier. In accordance with EOPs, there may beunusual accident conditions during which operators intentionally reduce the heatremoval capability of the steam generators; during these conditions, classification usingthreshold is not warranted.Meeting this threshold results in a Site Area Emergency because this threshold isidentical to Fuel Clad Barrier FC2 Potential Loss Threshold #3; both will be met. Thiscondition warrants a Site Area Emergency declaration because inadequate RCS heatremoval may result in fuel heat-up sufficient to damage the cladding and raise RCSpressure to the point where mass will be lost from the system.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-004, Lack of Primary to Secondary Heat TransferMonth 20XXTMI 3-61EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC3Initiating Condition:Containment Radiation / RCS ActivityOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSSContainment radiation monitor (RM-G-22 or RM-G-23) reading > 25 R/hr.Basis:Loss Threshold BasisThe radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the containment, assuming that reactor coolant activity equalsTechnical Specification allowable limits. This value is lower than that specified for FuelClad Barrier FC3 Loss threshold #1 since it indicates a loss of the RCS Barrier only.There is no RCS Potential Loss threshold associated with RCS Activity / ContainmentRadiation.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. EP-EAL-061 1, Criteria for Choosing Containment Radiation Monitor ReadingIndicative of Loss of RCS BarrierMonth 20XXTMI 3-62EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC5Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. Any condition in the opinion of the Emergency Director that indicates Loss of the RCSBarrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergency Director that indicates Potential Lossof the RCS Barrier.Basis:Loss Threshold #1 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the RCS Barrier is lost.Potential Loss Threshold #2 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the RCS Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored..Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-63EP-AA-1 009 (Revision XX)
Thraga Milo kinnei -Qfnfie-.n AnnoyP:valnn Klir-lnrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT1Initiating Condition:RCS or SG Tube LeakageOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. SG tube leakage > 150gpmAND2. SG is FAULTED outside of containment.Basis:FAULTED: The term applied to a steam generator that has a steam leak on thesecondary side of sufficient size to cause an uncontrolled drop in steam generatorpressure or the steam generator to become completely depressurized.RUPTURE(D): The condition of a steam generator in which primary-to-secondaryleakage is of sufficient magnitude to require a safety injection.Loss Threshold BasisThis threshold addresses a leaking or RUPTURED Steam Generator (SG) that is alsoFAULTED outside of containment. The condition of the SG, whether leaking orRUPTURED, is determined in accordance with the thresholds for RCS Barrier RC1Potential Loss Threshold 2 and Loss Threshold 1.b, respectively. This conditionrepresents a bypass of the containment barrier.FAULTED is a defined term within the NEI 99-01 methodology; this determination is notnecessarily dependent upon entry into, or diagnostic steps within, an EOP. Forexample, if the pressure in a steam generator is decreasing uncontrollably [part of theFAULTED definition] and the faulted steam generator isolation procedure is not enteredbecause EOP user rules are dictating implementation of another procedure to address ahigher priority condition, the steam generator is still considered FAULTED foremergency classification purposes.The FAULTED criterion establishes an appropriate lower bound on the size of a steamrelease that may require an emergency classification. Steam releases of this size arereadily observable with normal Control Room indications. The lower bound for thisaspect of the containment barrier is analogous to the lower bound criteria specified in ICRU3 for the fuel clad barrier (i.e., RCS activity values) and IC MU6 for the RCS barrier(i.e., RCS leak rate values).This threshold also applies to prolonged steam releases necessitated by operationalconsiderations such as the forced steaming of a leaking or RUPTURED steamgenerator directly to atmosphere to cooldown the plant, or to drive an auxiliary(emergency) feed water pump. These types of conditions will result in a significant andMonth 20XXTMI 3-64EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCTI (cont)Basis (cont):sustained release of radioactive steam to the environment (and are thus similar to aFAULTED condition). The inability to isolate the steam flow without an adverse effecton plant cooldown meets the intent of a loss of containment.Steam releases associated with the expected operation of a SG power operated reliefvalve or safety relief valve do not meet the intent of this threshold. Such releases mayoccur intermittently for a short period of time following a reactor trip as operatorsprocess through emergency operating procedures to bring the plant to a stablecondition and prepare to initiate a plant cooldown. Steam releases associated with theunexpected operation of a valve (e.g., a stuck-open safety valve) meets this threshold.Following an SG tube leak or rupture, there may be minor radiological releases througha secondary-side system component (e.g., air ejectors, glad seal exhausters, valvepacking, etc.). These types of releases do not constitute a loss or potential loss ofcontainment but should be evaluated using the Recognition Category R ICs.The emergency classification levels resulting from primary-to-secondary leakage, withor without a steam release from the FAULTED SG, are summarized below.Affected SG is FAULTEDOutside of Containment?Yes NoPrimary to SecondaryLeak RateLess than or equal to 25gpmGreater than 25 gpmGreater than 150 gpm.The capacity of one makeuppump in the normalcharging mode is exceeded(RCS Barrier PotentialLoss)Requires an automatic ormanual ESAS actuation(RCS Barrier Loss)No classificationUnusual Event perMU6Site Area Emergencyper FS1Site Area Emergencyper FS1No classificationUnusual Event perMU6Alert per FA1Alert per FAIThere is no Potential Loss threshold associated with RCS or SG Tube Leakage.Month 20XXTMI 3-65EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT1 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs3. OP-TM-EOP-005, OTSG Tube Leakage4. OP-TM-EOP-001, Reactor TripMonth 20XXTMI 3-66EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearThre Mil Isand taton AnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT2Initiating Condition:Inadequate Heat RemovalOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:POTENTIAL LOSS1. Tclad > 1800°F.AND2. EOP Restoration procedures not effective in < 15 minutes.Basis:IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold BasisThis condition represents an IMMINENT core melt sequence which, if not corrected,could lead to vessel failure and an increased potential for containment failure. For thiscondition to occur, there must already have been a loss of the RCS Barrier and the FuelClad Barrier. If implementation of a procedure(s) to restore adequate core cooling is noteffective (successful) within 15 minutes, it is assumed that the event trajectory will likelylead to core melting and a subsequent challenge of the Containment Barrier.The restoration procedure is considered "effective" if core exit thermocouple readingsare decreasing and/or if reactor vessel level is increasing. Whether or not theprocedure(s) will be effective should be apparent within 15 minutes. The EmergencyDirector should escalate the emergency classification level as soon as it is determinedthat the procedure(s) will not be effective.Severe accident analyses (e.g., NUREG-1 150) have concluded that function restorationprocedures can arrest core degradation in a significant fraction of core damagescenarios, and that the likelihood of containment failure is very small in these events.Given this, it is appropriate to provide 15 minutes beyond the required entry point todetermine if procedural actions can reverse the core melt sequence.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. OP-TM-EOP-008, RCS Superheated3. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs4. OP-TM-EOP-006, LOCA CooldownMonth 20XXTMI 3-67EP-AA-1009 (Revision XX)
Three MileIs land Staition Annex Fvnlnn NmirlIg:arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT3Initiating Condition:Containment Radiation / RCS ActivityOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:POTENTIAL LOSSContainment radiation monitor (RM-G-22 or RM-G-23) reading > 4.40E+03 R/hr.Basis:There is no Loss threshold associated with RCS Activity / Containment Radiation.Potential Loss Threshold BasisThe radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the containment, assuming that 20% of the fuel cladding has failed.This level of fuel clad failure is well above that used to determine the analogous FuelClad Barrier Loss and RCS Barrier Loss thresholds.NUREG-1 228, Source Estimations During Incident Response to Severe Nuclear PowerPlant Accidents, indicates the fuel clad failure must be greater than approximately 20%in order for there to be a major release of radioactivity requiring offsite protectiveactions. For this condition to exist, there must already have been a loss of the RCSBarrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as apotential loss of containment which would then escalate the emergency classificationlevel to a General Emergency.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. Core Damage Assessment Methodology (CDAM)Month 20XXTMI 3-68EP-AA-1 009 (Revision XX)
Throa RAila kinnd Atntinn AnnoyIP=Ylnn NMtlor, ~Thr~ MiI~ IQI2nrI ~t~*inn Ann~iw Fv~Ir~n NmmvIc~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT4Initiating Condition:Containment Integrity or BypassOperating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. Containment isolation is required and EITHER of the following:a. UNPLANNED lowering in containment pressure or rise in radiation monitorreadings outside of containment in the Emergency Directors judgment indicatea loss of containment integrity.ORb. UNISOLABLE pathway from containment to the environment exists.OR2. Indication of RCS leakage outside of containmentPOTENTIAL LOSS3. Reactor Building Pressure > 55 psig and rising.OR4. Hydrogen Concentration in Containment > 4%.OR5. a. Reactor Building pressure > 30 psigANDb. Reactor Building Emergency cooling is less than ANY one of the followingconditions:SPRAY COOLERS2 00 31 1Basis:FAULTED: The term applied to a steam generator that has a steam leak on thesecondary side of sufficient size to cause an uncontrolled drop in steam generatorpressure or the steam generator to become completely depressurized.UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.Month 20XXTMI 3-69EP-AA-1 009 (Revision XX)
Thrao Milo lainnd _Qfnfirn AnnoyI~v-g- In n Thrc&c MiIg~ Ie6nd ~t2tinn Anng~w Fv~inn tJm.pIa~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT4 (cont)Basis (cont):UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.Loss Threshold #1 BasisThese thresholds address a situation where containment isolation is required and one oftwo conditions exists as discussed below. Users are reminded that there may beaccident and release conditions that simultaneously meet both loss thresholds 1.a and1.b.l.a -Containment integrity has been lost, i.e., the actual containment atmospheric leakrate likely exceeds that associated with allowable leakage (or sometimes referred to asdesign leakage). Following the release of RCS mass into containment, containmentpressure will fluctuate based on a variety of factors; a loss of containment integritycondition may (or may not) be accompanied by a noticeable drop in containmentpressure. Recognizing the inherent difficulties in determining a containment leak rateduring accident conditions, it is expected that the Emergency Director will assess thisthreshold using judgment, and with due consideration given to current plant conditions,and available operational and radiological data (e.g., containment pressure, readings onradiation monitors outside containment, operating status of containment pressurecontrol equipment, etc.).Refer to the middle piping run of Figure 3-F-1. Two simplified examples are provided.One is leakage from a penetration and the other is leakage from an in-service systemvalve. Depending upon radiation monitor locations and sensitivities, the leakage couldbe detected by any of the four monitors depicted in the figure.Another example would be a loss or potential loss of the RCS barrier, and thesimultaneous occurrence of two FAULTED locations on a steam generator where onefault is located inside containment (e.g., on a steam or feedwater line) and the otheroutside of containment. In this case, the associated steam line provides a pathway forthe containment atmosphere to escape to an area outside the containment.Following the leakage of RCS mass into containment and a rise in containmentpressure, there may be minor radiological releases associated with allowable (design)containment leakage through various penetrations or system components. Thesereleases do not constitute a loss or potential loss of containment but should beevaluated using the Recognition Category R ICs.1.b -Conditions are such that there is an UNISOLABLE pathway for the migration ofradioactive material from the containment atmosphere to the environment. As usedhere, the term "environment" includes the atmosphere of a room or area, outside thecontainment, that may, in turn, communicate with the outside-the-plant atmosphere(e.g., through discharge of a ventilation system or atmospheric leakage). Dependingupon a variety of factors, this condition may or may not be accompanied by a noticeabledrop in containment pressure.Month 20XXTMI 3-70EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT4 (cont)Basis (cont):Refer to the top piping run of Figure 3-F-1. In this simplified example, the inboard andoutboard isolation valves remained open after a containment isolation was required (i.e.,containment isolation was not successful). There is now an UNISOLABLE pathwayfrom the containment to the environment.The existence of a filter is not considered in the threshold assessment. Filters do notremove fission product noble gases. In addition, a filter could become ineffective due toiodine and/or particulate loading beyond design limits (i.e., retention ability has beenexceeded) or water saturation from steam/high humidity in the release stream.Leakage between two interfacing liquid systems, by itself, does not meet this threshold.Refer to the bottom piping run of Figure 3-F-1. In this simplified example, leakage in anRCP seal cooler is allowing radioactive material to enter the Auxiliary Building. Theradioactivity would be detected by the Process Monitor. If there is no leakage from theclosed water cooling system to the Auxiliary Building, then no threshold has been met.If the pump or system piping developed a leak that allowed steam/water to enter theAuxiliary Building, then loss threshold 2 would be met. Depending upon radiationmonitor locations and sensitivities, this leakage could be detected by any of the fourmonitors depicted in the figure and cause threshold 1.a to be met as well.Following the leakage of RCS mass into containment and a rise in containmentpressure, there may be minor radiological releases associated with allowable (design)containment leakage through various penetrations or system components. Minorreleases may also occur if a containment isolation valve(s) fails to close but thecontainment atmosphere escapes to a closed system. These releases do not constitutea loss or potential loss of containment but should be evaluated using the RecognitionCategory R ICs.The status of the containment barrier during an event involving steam generator tubeleakage is assessed using Containment Barrier CT1 Loss threshold.Loss Threshold #2 BasisContainment sump, temperature, pressure and/or radiation levels will rise if reactorcoolant mass is leaking into the containment. If these parameters have not increased,then the reactor coolant mass may be leaking outside of containment (i.e., acontainment bypass sequence). Raises in sump, temperature, pressure, flow and/orradiation level readings outside of the containment may indicate that the RCS mass isbeing lost outside of containment.Unexpected elevated readings and alarms on radiation monitors with detectors outsidecontainment should be corroborated with other available indications to confirm that thesource is a loss of RCS mass outside of containment. If the fuel clad barrier has notbeen lost, radiation monitor readings outside of containment may not rise significantly;however, other unexpected changes in sump levels, area temperatures or pressures,flow rates, etc. should be sufficient to determine if RCS mass is being lost outside of thecontainment.Month 20XXTMI 3-71EP-AA-1009 (Revision XX)
Throp Mila IslandI Station Annex PvaInn NiirlanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT4 (cont)Basis (cont):Refer to the middle piping run of Figure 3-F-1. In this simplified example, a leak hasoccurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building.Depending upon radiation monitor locations and sensitivities, the leakage could bedetected by any of the four monitors depicted in the figure and cause loss threshold I.ato be met as well. To ensure proper escalation of the emergency classification, the RCSleakage outside of containment must be related to the mass loss that is causing theRCS Barrier RC1 Loss Threshold l.a and/or Potential Loss threshold 2.a to be met.Potential Loss Threshold #3 BasisIf containment pressure exceeds the design pressure, there exists a potential to lose theContainment Barrier. To reach this level, there must be an inadequate core coolingcondition for an extended period of time; therefore, the RCS and Fuel Clad barrierswould already be lost. Thus, this threshold is a discriminator between a Site AreaEmergency and General Emergency since there is now a potential to lose the thirdbarrier.Potential Loss Threshold #4 BasisThe existence of an explosive mixture means, at a minimum, that the containmentatmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity. Ittherefore represents a potential loss of the Containment Barrier.Potential Loss Threshold #5 BasisThis threshold describes a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed toautomatically actuate, and less than one full train of equipment is capable of operatingper design. The 15-minute criterion is included to allow operators time to manually startequipment that may not have automatically started, if possible. This thresholdrepresents a potential loss of containment in that containment heatremoval/depressurization systems (e.g., containment sprays, ice condenser fans, etc.,but not including containment venting strategies) are either lost or performing in adegraded manner.Month 20XXTMI 3-72EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT4 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-32. FSAR Section 6.6 Reactor Building Pressure-Time Response3. Technical Specifications 3.5.3, Engineered Safeguards Protection SystemActuation Setpoints4. FSAR Section 6.3.3, Actuation5. FSAR Section 6.5.3, Hydrogen Generation6. OP-TM-EOP-006, LOCA Cooldown7. 1302-5.25 Reactor Building Sump Level8. FSAR Section 5.2 Reactor Building9. FSAR Section 9.2, Chemical Addition and Sampling System10. OP-TM-EOP-002, Loss of 250F Subcooling Margin11. OP-TM-EOP-006, LOCA Cooldown12. OP-TM-EOP-010, Emergency Procedure Rules, Guides and Graphs13. OP-TM-MAP-D0301, High Make-up FlowMonth 20XXTMI 3-73EP-AA-1009 (Revision XX)
Throciaf lalanrd .tnfinn AnnoyaEwarIn& ^Im~RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONPinni irn 24.1:.l" PWR Ce.nntninmont Infonrift nr QunMae Fvomnl,0W W I* 1.b-- Airbornerelease from *pathwayVentCoolingMonth 20XXTMI 3-74EP-AA-1009 (Revision XX)
Fxelnn Three Mile Island Station Annex FeInIn NuIcIeIarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT5Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3,4Fission Product Barrier (FPB) Threshold:LOSS1. Any condition in the opinion of the Emergency Director that indicates Loss of theContainment Barrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergency Director that indicates Potential Lossof the Containment Barrier.Basis:Loss Threshold #1 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is lost.Potential Loss Threshold #2 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is potentially lost. The EmergencyDirector should also consider whether or not to declare the barrier potentially lost in theevent that barrier status cannot be monitored.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-3Month 20XXTMI 3-75EP-AA-1009 (Revision XX) rThree MileIsa ind Station Annex Fxelnn N~uclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG1Initiating Condition:Prolonged loss of all offsite and all onsite AC power to emergency busses.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1 B Emergency Diesel Generators and EG-Y-4 SBO DieselGenerator to supply power to Emergency 4KV buses.AND3. EITHER of the following:a. Restoration of at least one Emergency 4KV bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely.ORb. > 25°F superheatBasis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a prolonged loss of all power sources to AC emergency buses. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiringelectric power including those necessary for emergency core cooling, containment heatremoval/pressure control, spent fuel heat removal and the ultimate heat sink. Aprolonged loss of these buses will lead to a loss of any fission product barriers. Inaddition, fission product barrier monitoring capabilities may be degraded under theseconditions.The EAL should require declaration of a General Emergency prior to meeting thethresholds for IC FG1. This will allow additional time for implementation of offsiteprotective actions.Escalation of the emergency classification from Site Area Emergency will occur if it isprojected that power cannot be restored to at least one AC emergency bus by the endof the analyzed station blackout coping period. Beyond this time, plant responses andMonth 20XXTMI 3-76EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG1 (cont).Basis (cont):event trajectory are subject to greater uncertainty, and there is an increased likelihoodof challenges to multiple fission product barriers.The estimate for restoring at least one emergency bus should be based on a realisticappraisal of the situation. Mitigation actions with a low probability of success should notbe used as a basis for delaying a classification upgrade. The goal is to maximize thetime available to prepare for, and implement, protective actions for the public.The EAL will also require a General Emergency declaration if the loss of AC powerresults in parameters that indicate an inability to adequately remove decay heat fromthe core.Basis Reference(s):1. NEI 99-01 Rev 6, SG12. OP-TM-EOP-010 Emergency Procedure Rules, Guides And Graphs3. FSAR Section 8.2.2 Unit Distribution System4. FSAR Section 8.2.3 Sources of Auxiliary Power5. FSAR Section 8.5 Station Blackout6. Technical Specification Section 3.7, Unit Electric Power System7. 1107-1 Normal Electrical System8. 11 07-2A Emergency Electrical -4KV and 480 Volt9. OP-TM-AOP-020 Loss Of Station Power10. 1107-3 Diesel Generator11. 1107-9 SBO Diesel Generator12. OP-TM-EOP-008 RCS Superheated13. OS-24, Conduct of. Operation during Abnormal and Emergency EventsMonth 20XXTMI 3-77EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS1Initiating Condition:Loss of all offsite and all onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC Power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1 B Emergency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutes from thetime of loss of both offsite and onsite AC powerBasis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergencycore cooling, containment heat removal/pressure control, spent fuel heat removal andthe ultimate heat sink. In addition, fission product barrier monitoring capabilities may bedegraded under these conditions. This IC represents a condition that involves actual orlikely major failures of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RG1, FG1, MG1, orMG2.Month 20XXTMI 3-78EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS1 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, SS12. FSAR Section 8.2.3, Sources of Auxiliary Power3. Technical Specification Section 3.7, Unit Electric Power System4. 1107-1 Normal Electrical System5. 11 07-2A Emergency Electrical -4KV and 480 Volt6. OP-TM-AOP-020 Loss Of Station Power7. 1107-3 Diesel Generator8. 1107-9 SBO Diesel Generator9. FSAR Section 8.2.2, Unit Distribution System10. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-79EP-AA-1009 (Revision XX)
F=Yplnn Nw-lonrThree MileIsl~andl Station AnnexF~n Ni~aaTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMAIInitiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. AC power capability to Emergency 4KV buses reduced to only one of the followingpower sources for > 15 minutes.* Auxiliary Transformer 1A* Auxiliary Transformer 1 B* Emergency Diesel Generator EG-Y-1A* Emergency Diesel Generator EG-Y-1 B* SBO Diesel Generator EG-Y-4AND2. Any additional single power source failure will result in a loss of ALL AC power toSAFETY SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS. In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment. This IC provides an escalation path from ICMUl.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below.* A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).Month 20XXTMI 3-80EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMAI (cont)Basis (cont):" A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator.* A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.Escalation of the emergency classification level would be via IC MS1.Basis Reference(s):1. NEI 99-01 Rev 6, SA12. FSAR Section 8.2.3, Sources of Auxiliary Power3. FSAR Section 8.5, Station Blackout4. Technical Specification Section 3.7, Unit Electric Power System5. 1107-1 Normal Electrical System6. 11 07-2A Emergency Electrical -4KV and 480 Volt7. OP-TM-AOP-020 Loss Of Station Power8. 1107-3 Diesel Generator9. .1107-9 SBO Diesel Generator10. FSAR Section 8.2.2, Unit Distribution SystemMonth 20XXTMI 3-81EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU1Initiating Condition:Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:e The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Loss of ALL offsite AC power capability to Emergency 4KV busses for > 15 minutes.Basis:This IC addresses a prolonged loss of offsite power. The loss of offsite power sourcesrenders the plant more vulnerable to a complete loss of power to AC emergency buses.This condition represents a potential reduction in the level of safety of the plant.For emergency classification purposes, "capability" means that an offsite AC powersource(s) is available to the emergency buses, whether or not the buses are poweredfrom it.The emergency busses of the affected unit can be powered from the unaffected unitthrough the crosstie breakers. Unit crosstie is considered an adequate source of offsitepower when evaluating this EAL.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof offsite power.Escalation of the emergency classification level would be via IC MAl.Basis Reference(s):1. NEI 99-01 Rev 6, SU12. FSAR Section 8.2.3, Sources of Auxiliary Power3. Technical Specification Section 3.7, Unit Electric Power System4. 1107-1 Normal Electrical System5. 11 07-2A Emergency Electrical -4KV and 480 Volt6. OP-TM-AOP-020 Loss Of Station Power7. 1107-3 Diesel Generator8. 1107-9 SBO Diesel Generator9. FSAR Section 8.2.2, Unit Distribution SystemMonth 20XXTMI 13-82EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG2Initiating Condition:Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBO DieselGenerator to supply power to Emergency 4KV buses.AND3. Voltage is < 105 VDC on 125 VDC Distribution System 1A and lB.AND4. ALL AC and Vital DC power sources have been lost for >15 minutes.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiringelectric power including those necessary for emergency core cooling, containment heatremoval/pressure control, spent fuel heat removal and the ultimate heat sink. A loss ofVital DC power compromises the ability to monitor and control SAFETY SYSTEMS. Asustained loss of both AC and DC power will lead to multiple challenges to fissionproduct barriers.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses. The 15-minute emergency declaration clock begins at the point when all EALsare met.Month 20XXTMI 3-83EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMG2 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, SG82. FSAR Section 8.2.2.6, 250/125 VDC System3. 11 07-2C Vital DC Electrical System4. OP-TM-AOP-023, A DC System Failure5. OP-TM-AOP-024, B DC System Failure6. FSAR Section 8.2.2, Unit Distribution System7. FSAR Section 8.2.3, Sources of Auxiliary Power8. Technical Specification Section 3.7, Unit Electric Power System9. 1107-1 Normal Electrical System10. 1107-2A Emergency Electrical -4KV and 480 Volt11. OP-TM-AOP-020 Loss Of Station Power12. 1107-3 Diesel Generator13. 1107-9 SBO Diesel Generator14. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-84EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS2Initiating Condition:Loss of all vital DC power for 15 minutes or longer.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Voltage is < 105 VDC on 125 VDC Distribution System 1A and 1B for>15 minutes.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a loss of Vital DC power which compromises the ability to monitorand control SAFETY SYSTEMS. In modes above Cold Shutdown, this conditioninvolves a major failure of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RG1, FG1 or MG3.Basis Reference(s):1. NEI 99-01 Rev 6, SS82. FSAR Section 8.2.2.6, 250/125 VDC System3. 1107-2C Vital DC Electrical System4. OP-TM-AOP-023, A DC System Failure5. OP-TM-AOP-024, B DC System FailureMonth 20XXTMI 3-85EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS3Initiating Condition:Inability to shutdown the reactor causing a challenge to core cooling or RCS heatremoval.Operating Mode Applicability:1,2Emergency Action Level (EAL):1. Automatic or Manual Trip did not shutdown the reactor as indicated by ReactorPower > 5%.AND2. ALL manual actions to shutdown the reactor have been unsuccessful as indicatedby Reactor Power > 5%.AND3. EITHER of the following conditions exist:a. Tclad > 14000F.ORb. HPI-PORV Cooling in effect.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor trip that results in a reactor shutdown, all subsequent operator manual actions,both inside and outside the Control Room including driving in control rods and boroninjection, are unsuccessful, and continued power generation is challenging thecapability to adequately remove heat from the core and/or the RCS. This condition willlead to fuel damage if additional mitigation actions are unsuccessful and thus warrantsthe declaration of a Site Area Emergency.In some instances, the emergency classification resulting from this IC/EAL may behigher than that resulting from an assessment of the plant responses and symptomsagainst the Recognition Category F ICs/EALs. This is appropriate in that theRecognition Category F ICs/EALs do not address the additional threat posed by afailure to shutdown the reactor. The inclusion of this IC and EAL ensures the timelydeclaration of a Site Area Emergency in response to prolonged failure to shutdown thereactor.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Escalation of the emergency classification level would be via IC RG1 or FGI.Month 20XXTMI 3-86EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMS3 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, SS52. OP-TM-EOP-004, Lack of Primary-to-Secondary Heat Transfer3. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs4. OP-TM-EOP-001, Reactor Trip5. 1102-4 Power Operation6. OP-TM-641-000- Reactor Protection System (RPS/DSS)Month 20XXTMI 3-87EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA3Initiating Condition:Automatic or manual trip fails to shutdown the reactor, and subsequent manual actionstaken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note:* A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.1. Automatic Trip did not shutdown the reactor as indicated by Reactor Power > 5%.AND2. Manual actions taken at the Console Center are not successful in shutting down thereactor as indicated by Reactor Power > 5%.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic reactor tripthat results in a reactor shutdown, and subsequent operator manual actions taken at theConsole Center to shutdown the reactor are also unsuccessful. This conditionrepresents an actual or potential substantial degradation of the level of safety of theplant. An emergency declaration is required even if the reactor is subsequentlyshutdown by an action taken away from the Console Center since this event entails asignificant failure of the RPS.A manual action at the Console Center is any operator action, or set of actions, whichcauses the control rods to be rapidly inserted into the core (e.g., initiating a manualreactor trip. This action does not include manually driving in control rods orimplementation of boron injection strategies. If this action(s) is unsuccessful, operatorswould immediately pursue additional manual actions at locations away from the ConsoleCenter (e.g., locally opening breakers). Actions taken at back-panels or other locationswithin the Control Room, or any location outside the Control Room, are not consideredto be "at the Console Center".The plant response to the failure of an automatic reactor trip will vary based uponseveral factors including the reactor power level prior to the event, availability of thecondenser, performance of mitigation equipment and actions, other concurrent plantconditions, etc. If the failure to shutdown the reactor is prolonged enough to cause achallenge to the core cooling or RCS heat removal safety functions, the emergencyMonth 20XXTMI 3-88EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA3 (cont)Basis (cont):classification level will escalate to a Site Area Emergency via IC MS3. Depending uponplant responses and symptoms, escalation is also possible via IC FS1. Absent the plantconditions needed to meet either IC MS3 or FS1, an Alert declaration is appropriate forthis event.It is recognized that plant responses or symptoms may also require an Alert declarationin accordance with the Recognition Category F ICs; however, this IC and EAL areincluded to ensure a timely emergency declaration.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Basis Reference(s):1. NEI 99-01 Rev 6, SA52. OP-TM-EOP-004, Lack of Primary-to-Secondary Heat Transfer3. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs4. OP-TM-EOP-001, Reactor Trip5. 1102-4 Power Operation6. OP-TM-641-000- Reactor Protection System (RPS/DSS)Month 20XXTMI 3-89EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU3Initiating Condition:Automatic or manual trip fails to shutdown the reactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note:A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.1. a. Automatic Trip did not shutdown the reactor as indicated by Reactor Power> 5%.ANDb. Subsequent manual action taken at the Console Center is successful inshutting down the reactor.OR2. a. Manual Trip did not shutdown the reactor as indicated by Reactor Power > 5%.ANDb. Subsequent automatic Trip is successful in shutting down the reactor.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor trip that results in a reactor shutdown, and either a subsequent operator manualaction taken at the Console Center or an automatic trip is successful in shutting downthe reactor. This event is a precursor to a more significant condition and thus representsa potential degradation of the level of safety of the plant.EAL #1 BasisFollowing the failure on an automatic reactor trip, operators will promptly initiate manualactions at the Console Center to shutdown the reactor (e.g., initiate a manual reactortrip). If these manual actions are successful in shutting down the reactor, core heatgeneration will quickly fall to a level within the capabilities of the plant's decay heatremoval systems.Month 20XXTMI 3-90EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU3 (cont)Basis (cont):EAL #2 BasisIf an initial manual reactor trip is unsuccessful, a concurrent plant condition, may leadto the generation of an automatic reactor trip signal. If a subsequent automatic trip issuccessful in shutting down the reactor, core heat generation will quickly fall to a levelwithin the capabilities of the plant's decay heat removal systems.A manual action at the Console Center is any operator action, or set of actions, whichcauses the control rods to be rapidly inserted into the core (e.g., initiating a manualreactor trip). This action does not include manually driving in control rods orimplementation of boron injection strategies. Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the Console Center".The plant response to the failure of an automatic or manual reactor trip will vary basedupon several factors including the reactor power level prior to the event, availability ofthe condenser, performance of mitigation equipment and actions, other concurrent plantconditions, etc. If subsequent operator manual actions taken at the Console Center arealso unsuccessful in shutting down the reactor, then the emergency classification levelwill escalate to an Alert via IC MA3. Depending upon the plant response, escalation isalso possible via IC FAI. Absent the plant conditions needed to meet either IC MA3 orFAI, an Unusual Event declaration is appropriate for this event.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Should a reactor trip signal be generated as a result of plant work (e.g., RPS setpointtesting), the following classification guidance should be applied." If the signal generated as a result of plant work causes a plant transient that createsa real condition that should have included an automatic reactor trip and the RPS failsto automatically shutdown the reactor, then this IC and the EALs are applicable, andshould be evaluated." If the signal generated as a result of plant work does not cause a plant transient butshould have generated an RPS trip signal and the trip failure is determined throughother means (e.g., assessment of test results), then this IC and the EALs are notapplicable and no classification is warranted.Month 20XXTMI 13-91EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU3 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, SU52. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs3. OP-TM-EOP-001, Reactor Trip4. 1102-4 Power Operation5. OP-TM-641-000- Reactor Protection System (RPS/DSS)Month 20XXTMI 3-92EP-AA-1009 (Revision XX)
Three Mile kIslnd Station Annex FxeInn Nule~I~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA4Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. a. UNPLANNED event results in the inability to monitor ANY Table M1 parametersfrom within the Control Room for > 15 minutes.Table M1 Control Room Parameters" Reactor Power" PZR Level, RCS Pressure" In Core/Core Exit Temperature" Level in at least one OTSG.* OTSG Emergency Feed Water FlowANDb. ANY Table M2 transient in progress.Table M2 Significant Transients" Automatic Turbine Runback >25% thermal reactor power" Electrical Load Rejection >25% full electrical load" Reactor Trip* ESAS Actuationa Thermal Power oscillations > 10%Month 20XXTMI 3-93EP-AA-1009 (Revision XX)
Three Mih- Islamnd Staution Annex Fvninn Niir~icprTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA4 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses the difficulty associated with monitoring rapidly changing plantconditions during a transient without the ability to obtain SAFETY SYSTEM parametersfrom within the Control Room. During this condition, the margin to a potential fissionproduct barrier challenge is reduced. It thus represents a potential substantialdegradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for any of the listedparameters cannot be determined from within the Control Room. This situation wouldrequire a loss of all of the Control Room sources for the given parameter(s). Forexample, the reactor power level cannot be determined from any analog, computerpoint, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022)to determine if an NRC event report is required. The event would be reported if itsignificantly impaired the capability to perform emergency assessments. In particular,emergency assessments necessary to implement abnormal operating procedures,emergency operating procedures, and emergency plan implementing proceduresaddressing emergency classification, accident assessment, or protective actiondecision-making.This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity control, core cooling and RCS heat removal. The loss ofthe ability to determine any of these parameters from within the Control Room isconsidered to be more significant than simply a reportable condition. In addition, if allindication sources for any of the listed parameters are lost, then the ability to determinethe values of other SAFETY SYSTEM parameters may be impacted as well. Forexample, if the value for reactor vessel level cannot be determined from the indicationsand recorders on a main control board, the SPDS or the plant computer, the availabilityof other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation of the emergency classification level would be via ICs FS1 or IC RSI.Basis Reference(s):1. NEI 99-01 Rev 6, SA2Month 20XXTMI 3-94EP-AA-1009 (Revision XX) rThree Mile kIslnd Station Annex FvAinn NucleI~arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU4Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.UNPLANNED event results in the inability to monitor ANY Table M1 parameters fromwithin the Control Room for > 15 minutes.Table M1 Control Room Parametersa Reactor Power* PZR Level* RCS Pressure* In Core/Core Exit Temperature* Level in at least one OTSG.e OTSG Emergency Feed Water FlowBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses the difficulty associated with monitoring normal plant conditionswithout the ability to obtain SAFETY SYSTEM parameters from within the ControlRoom. This condition is a precursor to a more significant event and represents apotential degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for any of the listedparameters cannot be determined from within the Control Room. This situation wouldrequire a loss of all of the Control Room sources for the given parameter(s). Forexample, the reactor power level cannot be determined from any analog, digital andrecorder source within the Control Room. An event involving a loss of plant indications,Month 20XXTMI 3-95EP-AA-1009 (Revision XX)
PyPinn Mid-lonrThree~ Mile Islmnd Stt~ion Anne~x FAn ~~~TABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU4 (cont)Basis (cont):annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72(and associated guidance in NUREG-1022) to determine if an NRC event report isrequired. The event would be reported if it significantly impaired the capability toperform emergency assessments. In particular, emergency assessments necessary toimplement abnormal operating procedures, emergency operating procedures, andemergency plan implementing procedures addressing emergency classification,accident assessment, or protective action decision-making.This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity control, core cooling and RCS heat removal. The loss ofthe ability to determine any of these parameters from within the Control Room isconsidered to be more significant than simply a reportable condition. In addition, if allindication sources for any of the listed parameters are lost, then the ability to determinethe values of other SAFETY SYSTEM parameters may be impacted as well. Forexample, if the value for reactor vessel level cannot be determined from the indicationsand recorders on a main control board, the SPDS or the plant computer, the availabilityof other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation of the emergency classification level would be via IC MA4.Basis Reference(s):1. NEI 99-01 Rev 6, SU2Month 20XXTMI 3-96EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearThre Mil Isand taton AnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA5Initiating Condition:Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):1. The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)" Internal or external flooding event" High winds or tornado strike" FIRE* EXPLOSION" Other events with similar hazard characteristics as determined by theShift ManagerAND2. EITHER of the following:a. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM required by TechnicalSpecifications for the current operating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure required by Technical Specifications for thecurrent operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization. A release of steam (from highenergy lines or components) or an electrical component failure (caused by short circuits,grounding, arcing, etc.) should not automatically be considered an explosion. Suchevents may require a post-event inspection to determine if the attributes of an explosionare present.Month 20XXTMI 3-97EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMA5 (cont)Basis (cont):SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.VISIBLE DAMAGE: Damage to a component or structure that is readily observablewithout measurements, testing, or analysis. The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components, required for the current operatingmode, "required", i.e. required to be operable by Technical Specifications for the currentoperating mode. This condition significantly reduces the margin to a loss or potentialloss of a fission product barrier, and therefore represents an actual or potentialsubstantial degradation of the level of safety of the plant. Manual or automatic electricalisolation of safety equipment due to flooding, in and of itself, does not constitutedegraded performance and is classified under HU6.EAL #2.a BasisThis EAL addresses damage to a SAFETY SYSTEM train that is required to beoperable by Technical Specifications for the current operating mode, and is in operationsince indications for it will be readily available. The indications of degradedperformance should be significant enough to cause concern regarding the operability orreliability of the SAFETY SYSTEM train.EAL #2.b BasisThis EAL addresses damage to a SAFETY SYSTEM component that is required to beoperable by Technical Specifications for the current operating mode, and is not inoperation or readily apparent through indications alone, as well as damage to astructure containing SAFETY SYSTEM components. Operators will make thisdetermination based on the totality of available event and damage report information.This is intended to be a brief assessment not requiring lengthy analysis or quantificationof the damage.Escalation of the emergency classification level would be via IC FS1 or RS1.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.*Basis Reference(s):1. NEI 99-01, Rev 6 SA9Month 20XXTMI 3-98EP-AA-1009 (Revision XX)
Three Mile Islandl Station Annexv Fwalfnn NIlanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU6Initiating Condition:RCS leakage for 15 minutes or longer.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage > 10 gpm for > 15 minutes.OR2. RCS identified leakage >25 gpm for > 15 minutes.OR3. Leakage from the RCS to a location outside containment >25 gpm for > 15 minutes.Basis:UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.This IC addresses RCS leakage which may be a precursor to a more significant event.In this case, RCS leakage has been detected and operators, following applicableprocedures, have been unable to promptly isolate the leak. This condition is consideredto be a potential degradation of the level of safety of the plant.EAL #1 and EAL #2 BasisThese EALs are focused on a loss of mass from the RCS due to "unidentified leakage","pressure boundary leakage" or "identified leakage" (as these leakage types are definedin the plant Technical Specifications).EAL #3 BasisThis EAL addresses a RCS mass loss caused by an UNISOLABLE leak through aninterfacing system. These EALs thus apply to leakage into the containment, asecondary-side system (e.g., steam generator tube leakage) or a location outside ofcontainment.The leak rate values for each EAL were selected because they are usually observablewith normal Control Room indications. Lesser values typically require time-consumingcalculations to determine (e.g., a mass balance calculation). EAL #1 uses a lower valuethat reflects the greater significance of unidentified or pressure boundary leakage.Month 20XXTMI 3-99EP-AA-1009 (Revision XX)
ThrAn MiIA kI~nd St~tinn Annn~rThree Mile Island Station Annex Exellon N"d-h-arTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU6 (cont)Basis (cont):The release of mass from the RCS due to the as-designed/expected operation of arelief valve does not warrant an emergency classification. An emergency classificationwould be required if a mass loss is caused by a relief valve that is not functioning asdesigned/expected (e.g., a relief valve sticks open and the line flow cannot be isolated).The 15-minute threshold duration allows sufficient time for prompt operator actions toisolate the leakage, if possible.Escalation of the emergency classification level would be via ICs of RecognitionCategory R or F.Basis Reference(s):1. NEI 99-01 Rev 6, SU42. OP-TM-220-251 RCS Leak Rate Determination3. OP-TM-220-252, Primary -To -Secondary Leakrate Determination4. OP-TM-PRFl-0405 RB Sump Level HI5. UFSAR 6.4.3, Bases of Leakage Estimate6. UFSAR 6.4.4, Design Basis Leakage7. OP-TM-AOP-050, Reactor Coolant Leakage8. Technical Specification 3.1.6, Leakage and Table 4.1-2, Minimum EquipmentTest FrequencyMonth 20XXTMI 3-100EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU7Initiating Condition:Loss of all On-site or Off-site communications capabilities.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):1. Loss of ALL Table M3 Onsite communications capability affecting the ability toperform routine operations.OR2. Loss of ALL Table M3 Offsite communication capability affecting the ability toperform offsite notifications.OR3. Loss of ALL Table M3 NRC communication capability affecting the ability toperform NRC notifications.Table M3 Communications CaoabilitvSystem Onsite Offsite NRCRadios XPlant page XPlant Telephone System XSound Powered Phones XCommercial Telephones X X XNARS XENS X XHPN X XSatellite phones X XBasis:This IC addresses a significant loss of on-site, offsite, or NRC communicationscapabilities. While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).Month 20XXTMI 3-101EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU7 (cont)Basis (cont):EAL #1 BasisAddresses a total loss of the communications methods used in support of routine plantoperations.EAL #2 BasisAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form.EAL #3 BasisAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, SU62. 1105-12 Communications System3. FSAR Section 7.4.4, CommunicationMonth 20XXTMI 3-102EP-AA-1009 (Revision XX)
Thrain Milo laitanri -Q+mfinn AnnavIzv--Ir^n kh,,-li-,rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU8Initiating Condition:Failure to isolate containment or loss of containment pressure control.Operating Mode Applicability:1,2,3,4Emergency Action Level (EAL):1. a. Failure of containment to isolate when required by an actuation signal.ANDb. ANY required penetration remains open > 15 minutes of the actuationsignal.OR2. a. Reactor Building pressure > 30 psigANDb. Reactor Building Emergency cooling is less than ANY one of the followingconditions for > 15 minutes:SPRAY COOLERS2 00 31 1Basis:This IC addresses a failure of any containment penetrations to automatically isolate(close) when required by an actuation signal. It also addresses an event that results inhigh containment pressure with a concurrent failure of containment pressure controlsystems. Absent challenges to another fission product barrier, either conditionrepresents potential degradation of the level of safety of the plant.EAL #1 BasisThe containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); afailure resulting from testing or maintenance does not warrant classification. Thedetermination of containment and penetration status -isolated or not isolated -shouldbe made in accordance with the appropriate criteria contained in the plant AOPs andEOPs. The 15-minute criterion is included to allow operators time to manually isolatethe required penetrations, if possible.Month 20XXTMI 3-103EP-AA-1009 (Revision XX)
Three Mile Island Station Annexmmlvmvl m i ThreeMileIslan Staion Anex xelnn NuclerIzrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMU8 (cont)Basis (cont):EAL #2 BasisAddresses a condition where containment pressure is greater than the setpoint at whichcontainment energy (heat) removal systems are designed to automatically actuate, andless than one full train of equipment is capable of operating per design. The 15-minutecriterion is included to allow operators time to manually start equipment that may nothave automatically started, if possible. The inability to start the required equipmentindicates that containment heat removal/depressurization systems (e.g., containmentsprays or ice condenser fans) are either lost or performing in a degraded manner.This event would escalate to a Site Area Emergency in accordance with IC FS1 if therewere a concurrent loss or potential loss of either the Fuel Clad or RCS fission productbarriers.Basis Reference(s):1. NEI 99-01 Rev 6, SU72. FSAR Section 6.6 Reactor Building Pressure-Time Response3. Technical Specifications 3.5.3, Engineered Safeguards Protection SystemActuation Setpoints4. FSAR Section 6.3.3, Actuation5. FSAR Section 6.5.3, Hydrogen Generation6. OP-TM-EOP-006, LOCA Cooldown7. 1302-5.25 Reactor Building Sump Level8. FSAR Section 5.2 Reactor Building9. FSAR Section 9.2, Chemical Addition and Sampling System10. OP-TM-EOP-002, Loss of 250F Subcooling Margin11. OP-TM-EOP-006, LOCA Cooldown12. OP-TM-EOP-010, Emergency Procedure Rules, Guides and Graphs13. OP-TM-MAP-D0301, High Make-up FlowMonth 20XXTMI 3-104EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA1Initiating Condition:Loss of all offsite and all onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:5,6, DEmergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to Emergency 4KV buses.AND2. Failure of EG-Y-1A, EG-Y-1 B Emergency Diesel Generators and EG-Y-4 SBODiesel Generator to supply power to Emergency 4KV buses.AND3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutesfrom the time of loss of both offsite and onsite AC power.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-relatedThis IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergencycore cooling, containment heat removal/pressure control, spent fuel heat removal andthe ultimate heat sink.When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas a Site Area Emergency because of the increased time available to restore anemergency bus to service. Additional time is available due to the reduced core decayheat load, and the lower temperatures and pressures in various plant systems. Thus,when in these modes, this condition represents an actual or potential substantialdegradation of the level of safety of the plant.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via IC CS6 or RS1.Month 20XXTMI 3-105EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCAI (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CA22. FSAR Section 8.2.2, Unit Distribution System3. FSAR Section 8.2.3, Sources of Auxiliary Power4. Technical Specification Section 3.7, Unit Electric Power System5. 1107-1 Normal Electrical System6. 11 07-2A Emergency Electrical -4KV and 480 Volt7. OP-TM-AOP-020 Loss Of Station Power8. 1107-3 Diesel Generator9. 1107-9 SBO Diesel Generator10. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-106EP-AA-1009 (Revision XX)
Three Mile Island Station Annexm B Thre Mil Islnd tatin Anex xelnn NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSculInitiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:5,6, DEmergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. AC power capability to Emergency 4KV buses reduced to only one of thefollowing power sources for > 15 minutes." Auxiliary Transformer 1A" Auxiliary Transformer 1 B" Emergency Diesel Generator EG-Y-1A" Emergency Diesel Generator EG-Y-1 B" SBO Diesel Generator EG-Y-4AND2. ANY additional single power source failure will result in a loss of ALLAC powerto SAFETY SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS. In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment.When in the cold shutdown, refueling, or defueled mode, this condition is not classifiedas an Alert because of the increased time available to restore another power source toservice. Additional time is available due to the reduced core decay heat load, and thelower temperatures and pressures in various plant systems. Thus, when in thesemodes, this condition is considered to be a potential degradation of the level of safety ofthe plant.Month 20XXTMI 3-107EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCUl (cont)Basis (cont):An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below." A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).* A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator.* A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.The subsequent loss of the remaining single power source would escalate the event toan Alert in accordance with IC CA1.Basis Reference(s):1. NEI 99-01 Rev 6 CU22. FSAR Section 8.2.2, Unit Distribution System3. FSAR Section 8.2.3, Sources of Auxiliary Power4. Technical Specification Section 3.7, Unit Electric Power System5. 1107-1 Normal Electrical System6. 11 07-2A Emergency Electrical -4KV and 480 Volt7. OP-TM-AOP-020 Loss Of Station Power8. 1107-3 Diesel Generator9. 1107-9 SBO Diesel Generator10. FSAR Section 8.5, Station BlackoutMonth 20XXTMI 3-108EP-AA-1009 (Revision XX) rThree Mile~ kIslnd Station Annex Fvalnn Myt-lon&~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA2Initiating Condition:Hazardous event affecting SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:5,6Emergency Action Level (EAL):1. The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)* Internal or external flooding event" High winds or tornado strike" FIRE" EXPLOSION" Other events with similar hazard characteristics as determined by theShift ManagerAND2. EITHER of the following:a. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM required by TechnicalSpecifications for the current operating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure required by Technical Specifications for thecurrent operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization. A release of steam (from highenergy lines or components) or an electrical component failure (caused by short circuits,grounding, arcing, etc.) should not automatically be considered an explosion. Suchevents may require a post-event inspection to determine if the attributes of an explosionare present.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.Month 20XXTMI 3-109EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearThre Mil Isand taton AnexExelnn NucilearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA2 (cont)Basis (cont):VISIBLE DAMAGE: Damage to a component or structure that is readily observablewithout measurements, testing, or analysis. The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components, required for the current operatingmode, "required", i.e. required to be operable by Technical Specifications for the currentoperating mode. This condition significantly reduces the margin to a loss or potentialloss of a fission product barrier, and therefore represents an actual or potentialsubstantial degradation of the level of safety of the plant. Manual or automatic electricalisolation of safety equipment due to flooding, in and of itself, does not constitutedegraded performance and is classified under HU6.EAL #2.a BasisAddresses damage to a SAFETY SYSTEM train that is required to be operable byTechnical Specifications for the current operating mode, and is in operation sinceindications for it will be readily available. The indications of degraded performanceshould be significant enough to cause concern regarding the operability or reliability ofthe SAFETY SYSTEM train.EAL #2.b BasisAddresses damage to a SAFETY SYSTEM component that is required to be operableby Technical Specifications for the current operating mode, and is not in operation orreadily apparent through indications alone, or to a structure containing SAFETYSYSTEM components. Operators will make this determination based on the totality ofavailable event and damage report information. This is intended to be a briefassessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC CS6 or RS1.If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):1. NEI 99-01 Rev 6, CA6Month 20XXTMI 3-110EP-AA-1009 (Revision XX)
N Three MileIsa dnd St~ation Annex Fvialnn N~im-lonrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCU3Initiating Condition:Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Indicated voltage is < 105 VDC on required 125 VDC Distribution System 1A and 1Bfor> 15 minutes.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a loss of Vital DC power which compromises the ability to monitorand control operable SAFETY SYSTEMS when the plant is in the cold shutdown orrefueling mode. In these modes, the core decay heat load has been significantlyreduced, and coolant system temperatures and pressures are lower; these conditionsraise the time available to restore a vital DC bus to service. Thus, this condition isconsidered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to supportoperation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.For example, if Train A is out-of-service (inoperable) for scheduled outage maintenancework and Train B is in-service (operable), then a loss of Vital DC power affecting Train Bwould require the declaration of an Unusual Event. A loss of Vital DC power to Train Awould not warrant an emergency classification.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Depending upon the event, escalation of the emergency classification level would be viaIC CA6 or CA5, or an IC in Recognition Category R.Month 20XXTMI 3-111EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU3 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CU42. FSAR Section 8.2.2.6, 250/125 VDC System3. 1107-2C Vital DC Electrical System4. OP-TM-AOP-023, A DC System Failure5. OP-TM-AOP-024, B DC System FailureMonth 20XXTMI 3-112EP-AA-1009 (Revision XX)
Three Mile Island Station Annex 3x:lTn NuchnricTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU4Initiating Condition:Loss of all onsite or offsite communications capabilities.Operating Mode Applicability:5,6, DEmergency Action Level (EAL):1. Loss of ALL Table C1 Onsite communications capability affecting the ability toperform routine operations.OR2. Loss of ALL Table C1 Offsite communication capability affecting the ability toperform offsite notifications.OR3. Loss of ALL Table C1 NRC communication capability affectingperform NRC notifications.the ability toTable Cl Communications CapabilitySystem Onsite Offsite NRCRadios XPlant page XPlant Telephone System XSound Powered Phones XCommercial Telephones X X XNARS XENS X XHPN X XSatellite phones I X XBasis:This IC addresses a significant loss of on-site, offsite, or NRC communicationscapabilities. While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 addresses a total loss of the communications methods used in support ofroutine plant operations.Month 20XXTMI 3-113EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU4 (cont)Basis (cont):EAL #2 BasisAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration. The OROs referred to here are listed in procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form.EAL #3 BasisAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.Basis Reference(s):1. NEI 99-01 Rev 6, CU52. 1105-12 Communications System3. FSAR Section 7.4.4, CommunicationMonth 20XXTMI 3-114EP-AA-1009 (Revision XX)
Throo Milo lainnd Rfnfinn AnnavI:v,%1lnn Km,,-I--,rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA5Initiating Condition:Inability to maintain the plant in cold shutdown.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature > 2001F due to loss of decay heatremoval for > Table C2 duration.OR2. UNPLANNED RCS pressure rise > 10 psig as a result of temperature rise dueto loss of decay heat removal. (This EAL does not apply in solid plantconditions.)Table C2 RCS Heat-up Duration ThresholdsRCS Status Containment Closure Heat-upStatus DurationIntact Not Applicable 60 minutes*Not Intact Established 20 minutes*ORReduced Inventory Not Established 0 minutes* If an RCS heat removal system is in operation within this timeframe and RCS temperature is being reduced, then EAL #1 is notapplicable.Month 20XXTMI 3-115EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA5 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, etc.).This IC addresses conditions involving a loss of decay heat removal capability or anaddition of heat to the RCS in excess of that which can currently be removed. Eithercondition represents an actual or potential substantial degradation of the level of safetyof the plant.A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperaturewhen CONTAINMENT CLOSURE is established but the RCS is not intact, or RCSinventory is reduced (e.g., mid-loop operation in PWRs). The 20-minute criterion wasincluded to allow time for operator action to address the temperature rise.The RCS Heat-up Duration Thresholds table also addresses a rise in RCS temperaturewith the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in thiscondition since the intact RCS is providing a high pressure barrier to a fission productrelease. The 60-minute time frame should allow sufficient time to address thetemperature rise without a substantial degradation in plant safety.Finally, in the case where there is a rise in RCS temperature, the RCS is not intact or isat reduced inventory, and CONTAINMENT CLOSURE is not established, no heat-upduration is allowed (i.e., 0 minutes). This is because 1) the evaporated reactor coolantmay be released directly into the Containment atmosphere and subsequently to theenvironment, and 2) there is reduced reactor coolant inventory above the top ofirradiated fuel.EAL #2 BasisProvides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS6 or RS1.Month 20XXTMI 3-116EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA5 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CA32. Technical Specifications sections: 1.2.1, 1.7.a and c3. Technical Specifications sections: 3.6.12.a4. Technical Specifications sections: 3.6.55. Technical Specifications sections: 3.8.66. Technical Specifications sections: 1.2.1, 1.7.a and c, 3.6.12.a, 3.6.5, 3.8.67. 1101-3 Containment Integrity and Access Limits8. OP-TM-EOP-030, Loss of Decay Heat Removal9. Outage Fuel Protection Criteria DocumentMonth 20XXTMI 3-117EP-AA-1009 (Revision XX)
Three MileIs land Staition Annex FYAlnn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU5Initiating Condition:UNPLANNED rise in RCS temperatureOperating Mode Applicability:5,6Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature > 200OF due to loss of decay heatremoval.OR2. Loss of the following for >15 minutes.* ALL RCS temperature indicationsAND* ALL RCS level indicationsBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.This IC addresses an UNPLANNED rise in RCS temperature above the TechnicalSpecification cold shutdown temperature limit, or the inability to determine RCStemperature and level, represents a potential degradation of the level of safety of theplant. If the RCS is not intact and CONTAINMENT CLOSURE is not established duringthis event, the Emergency Director should also refer to IC CA5.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.Month 20XXTMI 3-118EP-AA-1009 (Revision XX)
N, Thra.o Mila~ IslandI Station Annex Fwainn NiirIanrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU5 (cont)Basis (cont):EAL #1 involves a loss of decay heat removal capability, or an addition of heat to theRCS in excess of that which can currently be removed, such that reactor coolanttemperature cannot be maintained below the cold shutdown temperature limit specifiedin Technical Specifications. During this condition, there is no immediate threat of fueldamage because the core decay heat load has been reduced since the cessation ofpower operation.During an outage, the level in the reactor vessel will normally be maintained above thereactor vessel flange. Refueling evolutions that lower water level below the reactorvessel flange are carefully planned and controlled. A loss of forced decay heat removalat reduced inventory may result in a rapid rise in reactor coolant temperature dependingon the time after shutdown.EAL #2 reflects a condition where there has been a significant loss of instrumentationcapability necessary to monitor RCS conditions and operators would be unable tomonitor key parameters necessary to assure core decay heat removal. During thiscondition, there is no immediate threat of fuel damage because the core decay heatload has been reduced since the cessation of power operation.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA5 based onexceeding plant configuration-specific time criteria.Basis Reference(s):1. NEI 99-01 Rev 6, CU32. 1103-11 RCS Water Level Control3. FSAR Section 7.3.2, Non-Nuclear Instrumentation4. 1302-6.6 RCS Temp/Press, TSAT Monitor, ATWS and DSS Calibration5. NEI 99-01 Rev 5, CU46. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-119EP-AA-1009 (Revision XX)
Three Mile kIslnd Station Annex FwAlnn NucleItarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCG6Initiating Condition:Loss of reactor vessel/RCS inventory affecting fuel clad integrity with containmentchallenged.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Reactor Vessel / RCS level unknown for > 30 minutes.AND2. Core uncovery is indicated by ANY of the following:" Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Erratic Source Range Neutron Monitor indication.OR* Radiation Monitor RM-G-6 or RM-G-7 reading > 3 R/hr.AND3. ANY Containment Challenge Indication (Table C4)Table C3 Indications of RCS Leakage* UNPLANNED Reactor Bldg Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise*" UNPLANNED BWST level rise** UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.Month 20XXTMI 3-120EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCG6 (cont)Emergency Action Level (EAL) (cont):Table C4 Containment Challenge Indications* Hydrogen Concentration in Containment > 4%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established** if CONTAINMENT CLOSURE is re-established prior to exceeding the30-minute core uncovery time limit, then escalation to a GeneralEmergency is not required.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.This IC addresses the inability to restore and maintain reactor vessel level above thetop of active fuel with containment challenged. This condition represents actual orIMMINENT substantial core degradation or melting with potential for loss of containmentintegrity. Releases can be reasonably expected to exceed EPA Protective ActionGuidelines (PAG) exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a directand unmonitored release of radioactivity to the environment. If CONTAINMENTCLOSURE is re-established prior to exceeding the 30-minute time limit, then declarationof a General Emergency is not required.Month 20XXTMI 3-121EP-AA-1009 (Revision XX)
Thran RAilda lainnei -Q+n+irn AnnovI~v-Inlrn K, ,ig----rThra~~ MiI~ Ic6nrI ~*~h$inn Annav ~v~Ii~n hi I *f~ I ~ rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCG6 (cont)Basis (cont):The existence of an explosive mixture means, at a minimum, that the containmentatmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity. Ittherefore represents a challenge to Containment integrity.In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to acore uncovery could result in an explosive gas mixture in containment. If all installedhydrogen gas monitors are out-of-service during an event leading to fuel claddingdamage, it may not be possible to obtain a containment hydrogen gas concentrationreading as ambient conditions within the containment will preclude personnel access.During periods when installed containment hydrogen gas monitors are out-of-service,operators may use the other listed indications to assess whether or not containment ischallenged.The 30-minute criterion is tied to a readily recognizable event start time (i.e., the totalloss of ability to monitor level), and allows sufficient time to monitor, assess andcorrelate reactor and plant conditions to determine if core uncovery has actuallyoccurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor reactor vessel/RCS level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the reactor vessel/RCS.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Month 20XXTMI 3-122EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCG6 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CG12. 1103-11 RCS Water Level Control3. 1101-3 Containment Integrity and Access Limits4. OP-TM-EOP-030, Loss of Decay Heat Removal5. FSAR Sections 5.2, Reactor Building6. FSAR Sections 6.5.2, Hydrogen Monitoring7. FSAR Sections 6.5.3, Hydrogen Generation8. Technical Specifications 3.5.5, Accident Monitoring Instrumentation9. EP-AEL-0501, Estimation of Radiation Monitor Readings Indicating CoreUncovery During Refuel10. 1301-1 Shift and Daily Checks, Data Sheet 3Month 20XXTMI 3-123EP-AA-1009 (Revision XX)
Three Mile kIslnd Sta~tion Annex FvAinn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCS6Initiating Condition:Loss of reactor vessel/RCS inventory affecting core decay heat removal capability.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. Reactor Vessel / RCS level unknown for >30 minutes.AND2. Core uncovery is indicated by ANY of the following:" Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Erratic Source Range Neutron Monitor indication.OR* Radiation Monitors RM-G-6 or RM-G-7 reading > 3 R/hr.Table C3 Indications of RCS Leakage* UNPLANNED Reactor Bldg Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise** UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.Month 20XXTMI 3-124EP-AA-1009 (Revision XX)
Three MileIsa mnd Station Annex FvAinn N~uclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSCS6 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken tosecure containment and its associated structures, systems, and components as afunctional barrier to fission product release under shutdown conditions.The lost inventory may be due to a RCS component failure, a loss of configurationcontrol or prolonged boiling of reactor coolant. These conditions entail major failures ofplant functions needed for protection of the public and thus warrant a Site AreaEmergency declaration.Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.Outage/shutdown contingency plans typically provide for re-establishing or verifyingCONTAINMENT CLOSURE following a loss of heat removal or RCS inventory controlfunctions.The 30-minute criterion is tied to a readily recognizable event start time (i.e., the totalloss of ability to monitor level), and allows sufficient time to monitor, assess andcorrelate reactor and plant conditions to determine if core uncovery has actuallyoccurred (i.e., to account for various accident progression and instrumentationuncertainties). It also allows sufficient time for performance of actions to terminateleakage, recover inventory control/makeup equipment and/or restore level monitoring.The inability to monitor reactor vessel/RCS level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the reactor vessel/RCS.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.Escalation of the emergency classification level would be via IC CG6 or RG1.Month 20XXTMI 3-125EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCS6 (cont)Basis Reference(s):1. NEI 99-01 Rev 6, CS12. OP-TM-PRF1-0405 RB Sump Level Hi3. 1101-3 Containment Integrity and Access Limits4. 1301-1 Shift and Daily Checks, Data Sheet 35. 1103-11 RCS Water Level Control6. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-126EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA6Initiating Condition:Loss of reactor vessel/RCS inventory.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of Reactor Vessel / RCS inventory as indicated by RCS level< 0 inches on Draindown Level indicator.OR2. a. Reactor Vessel / RCS level unknown for > 15 minutes.ANDb. Loss of Reactor Vessel / RCS inventory per Table C3 indications.Table C3 Indications of RCS Leakage" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise*" UNPLANNED BWST level rise*" UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.Month 20XXTMI 3-127EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearThre Mil Isand taton AnexExelon Nuclea~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCA6 (cont)Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses conditions that are precursors to a loss of the ability to adequatelycool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). Thiscondition represents a potential substantial reduction in the level of plant safety.EAL #1 BasisA lowering of water level below 0 inches on Draindown Level indicator indicates thatoperator actions have not been successful in restoring and maintaining reactorvessel/RCS water level. The heat-up rate of the coolant will rise as the available waterinventory is reduced. A continuing drop in water level will lead to core uncovery.Although related, EAL #1 is concerned with the loss of RCS inventory and not thepotential concurrent effects on systems needed for decay heat removal (e.g., loss of aResidual Heat Removal suction point). A rise in RCS temperature caused by a loss ofdecay heat removal capability is evaluated under IC CA5.EAL #2 BasisThe inability to monitor reactor vessel/RCS level may be caused by instrumentationand/or power failures, or water level dropping below the range of availableinstrumentation. If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the reactor vessel/RCS.The 15-minute duration for the loss of level indication was chosen because it is half ofthe EAL duration specified in IC CS6If the reactor vessel/RCS inventory level continues to lower, then escalation to Site AreaEmergency would be via IC CS6.Basis Reference(s):1. NEI 99-01 Rev 6, CA12. OP-TM-PRF1-0405 RB Sump Level Hi3. 1301-1 Shift and Daily Checks, Data Sheet 34. 1103-11 RCS Water Level Control5. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-128EP-AA-1009 (Revision XX) l:xmlnn Three Mile Island Station Annex Fvl:n Nucha srisTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU6Initiating Condition:UNPLANNED loss of reactor vessel/RCS inventory for 15 minutes or longer.Operating Mode Applicability:5,6Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED loss of reactor coolant results in the inability to restore andmaintain Reactor Vessel / RCS level to > procedurally established lower limitfor > 15 minutes.OR2. a. Reactor Vessel / RCS level unknown.ANDb. Loss of Reactor Vessel / RCS inventory per Table C3 indications.Table C3 Indications of RCS Leakage" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise*" UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses the inability to restore and maintain water level to a requiredminimum level (or the lower limit of a level band), or a loss of the ability to monitorreactor vessel/RCS level concurrent with indications of coolant leakage. Either of theseconditions is considered to be a potential degradation of the level of safety of the plant.Month 20XXTMI 3-129EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYCOLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONSCU6 (cont)Basis (cont):The procedurally established lower limit is not an operational band established abovethe procedural limit to allow for operator action prior to exceeding the procedural limit,but it is the procedurally established lower limit.Refueling evolutions that lower RCS water inventory are carefully planned andcontrolled. An UNPLANNED event that results in water level decreasing below aprocedurally required limit warrants the declaration of an Unusual Event due to thereduced water inventory that is available to keep the core covered.EAL #1 BasisRecognizes that the minimum required reactor vessel/RCS level can change severaltimes during the course of a refueling outage as different plant configurations andsystem lineups are implemented. This EAL is met if the minimum level, specified for thecurrent plant conditions, cannot be maintained for 15 minutes or longer. The minimumlevel is typically specified in the applicable operating procedure but may be specified inanother controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions torestore and maintain the expected water level. This criterion excludes transientconditions causing a brief lowering of water level.EAL #2 BasisAddresses a condition where all means to determine reactor vessel/RCS level havebeen lost. In this condition, operators may determine that an inventory loss is occurringby observing changes in sump and/or tank levels. Sump and/or tank level changesmust be evaluated against other potential sources of water flow to ensure they areindicative of leakage from the reactor vessel/RCS.Continued loss of RCS inventory may result in escalation to the Alert emergencyclassification level via either IC CA6 or CA5.Basis Reference(s):1. NEI 99-01, Rev. 6 CU12. Technical Specification 3.1.6. Leakage3. OP-TM-220-251 RCS Leak Rate Determination Using PPC4. OP-TM-220-252, Primary -To -Secondary Leakrate Determination (OTSGLeakage): Normal Operations5. OP-TM-MAP-C0105 RCS Draindown LVL HI/LO6. OP-TM-PRF1-0405 RB Sump Level HI7. UFSAR 6.4.3, Bases of Leakage Estimate8. 1103-11 RCS Water Level Control9. OP-TM-EOP-030, Loss of Decay Heat RemovalMonth 20XXTMI 3-130EP-AA-1009 (Revision XX)
Three Mile Islamnd Stt~ion Annex~ Fvalnn NwirlonrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1Initiating Condition:HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):1. A notification from the Security Force that a HOSTILE ACTION is occurring orhas occurred within the PROTECTED AREA.AND2. a. ANY Table H1 safety function cannot be controlled or maintained.ORb. Damage to spent fuel has occurred or is IMMINENTTable H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* Core Cooling (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.Month 20XXTMI 13-131EP-AA-1009 (Revision XX)
Three Mile Island Station Annexm m ThreeMileIslad Staion nnexFvAon Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1 (cont)Basis (cont):HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.This IC addresses an event in which a HOSTILE FORCE has taken physical control ofthe facility to the extent that the plant staff can no longer operate equipment necessaryto maintain key safety functions. It also addresses a HOSTILE ACTION leading to aloss of physical control that results in actual or IMMINENT damage to spent fuel due to1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls,etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot bemaintained.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].contained in non-public documents such as the Security Plan.Basis Reference(s):1. NEI 99-01, Rev. 6 HG12. Security and Safeguards Contingency Plan Station Security Plan -Appendix CMonth 20XXTMI 3-132EP-AA-1009 (Revision XX)
Thrina RAHAm lalnnrl -Qfnfirn AnnavPimyglrnn N, gl-nerThr~ MiIg& Ie6nrI Q*~t.vhn Ann~v Fv~Ir~n hi. ir~Ic~rTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS1.Initiating Condition:HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:1, 2,3,4,5,6, DEmergency Action Level (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTEDAREA. This event will require rapid response and assistance due to the possibility fordamage to plant equipment.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Month 20XXTMI 3-133EP-AA-1 009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS1 (cont)Basis (cont):Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Site Area Emergency declaration will mobilize OROresources and have them available to develop and implement public protective actionsin the unlikely event that the attack is successful in impairing multiple safety functions.This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTEDAREA located outside the plant PROTECTED AREA; such an attack should beassessed using IC HAl. It also does not apply to incidents that are accidental events,acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by aHOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters,physical disputes between employees, etc. Reporting of these types of events isadequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR§ 50.72.Escalation of the emergency classification level would be via IC HG1.Basis Reference(s):1. NEI 99-01 Rev 6, HS12. Security and Safeguards Contingency Plan Station Security Plan -Appendix CMonth 20XXTMI 3-134EP-AA-1009 (Revision XX)
Three Mile kIslnd S~tation Annex FvPInn NucleIarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHAIInitiating Condition:HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threatwithin 30 minutes.Operating Mode Applicability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutes fromthe site.OR2. Notification by the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the OWNER CONTROLED AREA.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.OWNER CONTROLLED AREA (OCA): The property associated with the station andowned by the company. Access is normally limited to persons entering for officialbusiness.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.This IC addresses the occurrence of a HOSTILE ACTION within the OWNERCONTROLLED AREA or notification of an aircraft attack threat. This event will requirerapid response and assistance due to the possibility of the attack progressing to theMonth 20XXTMI 3-135EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHAI (cont)Basis (cont):This IC addresses the occurrence of a HOSTILE ACTION within the OWNERCONTROLLED AREA or notification of an aircraft attack threat. This event will requirerapid response and assistance due to the possibility of the attack progressing to thePROTECTED AREA, or the need to prepare the plant and staff for a potential aircraftimpact. Timely and accurate communications between Security Shift Supervision andthe Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation,dispersal or sheltering). The Alert declaration will also heighten the awareness ofOffsite Response Organizations, allowing them to be better prepared should it benecessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience,or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputesbetween employees, etc. Reporting of these types of events is adequately addressedby other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL #1 addresses the threat from the impact of an aircraft on the plant, and theanticipated arrival time is within 30 minutes. The intent of this EAL is to ensure thatthreat-related notifications are made in a timely manner so that plant personnel andOROs are in a heightened state of readiness. This EAL is met when the threat-relatedinformation has been validated in accordance with OP-TM-AOP-008, Security Threat /Intrusion.EAL #2 is applicable for any HOSTILE ACTION occurring, or that has occurred, in theOWNER CONTROLLED AREA. This includes any action directed against an ISFSI thatis located outside the plant PROTECTED AREA.The NRC Headquarters Operations Officer (HOO) will communicate to the licensee ifthe threat involves an aircraft. The status and size of the plane may be provided byNORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNERCONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected,although not certain, that notification by an appropriate Federal agency to the site wouldclarify this point. In this case, the appropriate federal agency is intended to be NORAD,FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs,should not be unduly delayed while awaiting notification by a Federal agency.Escalation of the emergency classification level would be via IC HS1.Month 20XXTMI 3-136EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHAI (cont)Basis Reference(s):1. NEI 99-01 Rev 6, HA12. Security and Safeguards Contingency Plan Station Security Plan -Appendix C3. OP-TM-AOP-008, Security Threat / IntrusionMonth 20XXTMI 3-137EP-AA-1009 (Revision XX)
Fxelnn Three Mile~ kIslnd Station Annex FvAlnn NuclekarTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU1Initiating Condition:Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:1, 2,3,4,5,6, DEmergency Action Level (EAL):1. Notification of a credible security threat directed at the site as determined perSY-AA-101-132, Security Assessment and Response to Unusual Activities.OR2. A validated notification from the NRC providing information of an aircraft threat.OR3. Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.Basis:SECURITY CONDITION: Any Security Event as listed in the approved securitycontingency plan that constitutes a threat/compromise to site security, threat/risk to sitepersonnel, or a potential degradation to the level of safety of the plant. A SECURITYCONDITION does not involve a HOSTILE ACTIONSAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.Month 20XXTMI 3-138EP-AA-1009 (Revision XX)
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- w* .*. ...... --.... .r.. ...n fl~I %.1 I I~ L 1 ~OITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHUl (cont)Basis (cont):This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEMequipment, and thus represent a potential degradation in the level of plant safety.Security events which do not meet one of these EALs are adequately addressed by therequirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed asHOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Classification of these events will initiate appropriate threat-related notifications to plantpersonnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, SafeguardsContingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 addresses the receipt of a credible security threat. The credibility of the threatis assessed in accordance with SY-AA-101-132.EAL #2 addresses the threat from the impact of an aircraft on the plant. The NRCHeadquarters Operations Officer (HOO) will communicate to the licensee if the threatinvolves an aircraft. The status and size of the plane may also be provided by NORADthrough the NRC. Validation of the threat is performed in accordance with OP-TM-AOP-008, Security Threat / Intrusion.EAL #3 references Security Force because these are the individuals trained to confirmthat a security event is occurring or has occurred. Training on security eventconfirmation and classification is controlled due to the nature of Safeguards and 10 CFR§ 2.39 information.Escalation of the emergency classification level would be via IC HAl.Basis Reference(s):1. NEI 99-01 Rev 6, HU12. SY-AA-101-132, Security Assessment and Response to Unusual Activities3. Security And Safeguards Contingency Plan Station Security Plan -Appendix CMonth 20XXTMI 3-139EP-AA-1009 (Revision XX)
Throa RAila lainnd Rtnfinn AnnovIPvg'lrnn KIuorlimrTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS2Initiating Condition:Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per OP-TM-EOP-020, Cooldown from Outsidethe Control Room.AND2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.Table H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* Core Cooling (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Basis:The time period to establish control of the plant starts when either:a. Control of the plant is no longer maintained in the Main Control RoomORb. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations, and the control of a key safety function cannot bereestablished in a timely manner. The failure to gain control of a key safety functionfollowing a transfer of plan control to alternate locations is a precursor to a challenge toany fission product barriers within a relatively short period of time.Month 20XXTMI 3-140EP-AA-1009 (Revision XX)
I=-zpinn Niie.IprThree Mile Island Station AnnexFYnnNIAaTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS2 (cont)Basis (cont):The determination of whether or not "control" is established at the remote safeshutdown location(s) is based on Emergency Director judgment. The EmergencyDirector is expected to make a reasonable, informed judgment within 15 minuteswhether or not the operating staff has control of key safety functions from the remotesafe shutdown location(s).Escalation of the emergency classification level would be via IC FG1 or CG6.Basis Reference(s):1. NEI 99-01, Rev 6 HS62. OP-TM-EOP-020, Cooldown from Outside the Control RoomMonth 20XXTMI 3-141EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA2Initiating Condition:Control Room evacuation resulting in transfer of plant control to alternate locations.Operating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per OP-TM-EOP-020, Cooldown from Outside theControl Room.Basis:This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations outside the Control Room. The loss of the ability to controlthe plant from the Control Room is considered to be a potential substantial degradationin the level of plant safety.Following a Control Room evacuation, control of the plant will be transferred to alternateshutdown locations. The necessity to control a plant shutdown from outside the ControlRoom, in addition to responding to the event that required the evacuation of the ControlRoom, will present challenges to plant operators and other on-shift personnel.Activation of the ERO and emergency response facilities will assist in responding tothese challenges.Escalation of the emergency classification level would be via IC HS2.Basis Reference(s):1. NEI 99-01, Rev 6 HA62. OP-TM-EOP-020, Cooldown from Outside the Control RoomMonth 20XXTMI 3-142EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3Initiating Condition:FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of thefollowing FIRE detection indications:" Report from the field (i.e., visual observation)" Receipt of multiple (more than 1) fire alarms or indications* Field verification of a single fire alarmOR2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indicationsof a FIRE).ANDb. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.OR3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes ofthe initial report, alarm or indication.OR4 A FIRE within the plant PROTECTED AREA that requires firefighting support byan offsite fire response agency to extinguish.Month 20XXTMI 3-143EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexNuclearThre Mil Isand taton AnexExelnn NucilearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)Emergency Action Level (EAL) (cont):Table H2 Vital Areas* Reactor Building* Intake Building* Intermediate Building0 Control Tower0 Auxiliary and Fuel Handling Buildings0 1A and 1B Diesel Generator Buildings* BWSTo CSTBasis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of apotential degradation of the level of safety of the plant.EAL #1 BasisThe intent of the 15-minute duration is to size the FIRE and to discriminate againstsmall FIRES that are readily extinguished (e.g., smoldering waste paper basket). Inaddition to alarms, other indications of a FIRE could be a drop in fire main pressure,automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial firealarm, indication, or report. For EAL assessment purposes, the emergency declarationclock starts at the time that the initial alarm, indication, or report was received, and notthe time that a subsequent verification action was performed. Similarly, the fire durationclock also starts at the time of receipt of the initial alarms, indication or report.EAL #2 BasisAddresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e.,proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will takeprompt actions to confirm the validity of a single fire alarm. For EAL assessmentpurposes, the 30-minute clock starts at the time that the initial alarm was received, andnot the time that a subsequent verification action was performed.Month 20XXTMI 3-144EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)Basis (cont):A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipmentfailure or a spurious activation, and not an actual FIRE. For this reason, additional timeis allowed to verify the validity of the alarm. The 30-minute period is a reasonableamount of time to determine if an actual FIRE exists; however, after that time, andabsent information to the contrary, it is assumed that an actual FIRE is in progress.If an actual FIRE is verified by a report from the field, then EAL #1 is immediatelyapplicable, and the emergency must be declared if the FIRE is not extinguished within15-minutes of the report. If the alarm is verified to be due to an equipment failure or aspurious activation, and this verification occurs within 30-minutes of the receipt of thealarm, then this EAL is not applicable and no emergency declaration is warranted.EAL #3 BasisIn addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plantPROTECTED AREA not extinguished within 60-minutes may also potentially degradethe level of plant safety.EAL #4 BasisIf a FIRE within the plant PROTECTED AREA is of sufficient size to require a responseby an offsite firefighting agency (e.g., a local town Fire Department), then the level ofplant safety is potentially degraded. The dispatch of an offsite firefighting agency to thesite requires an emergency declaration only if it is needed to actively support firefightingefforts because the fire is beyond the capability of the Fire Brigade to extinguish.Declaration is not necessary if the agency resources are placed on stand-by, orsupporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix RAppendix R to 10 CFR 50, states in part:Criterion 3 of Appendix A to this part specifies that "Structures, systems, andcomponents important to safety shall be designed and located to minimize,consistent with other safety requirements, the probability and effect of fires andexplosions."When considering the effects of fire, those systems associated with achievingand maintaining safe shutdown conditions assume major importance to safetybecause damage to them can lead to core damage resulting from loss of coolantthrough boil-off.Month 20XXTMI 37145EP-AA-1009 (Revision XX)
Three Mile Isla~nd Station Annex FvieInn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)Basis (cont):Because fire may affect safe shutdown systems and because the loss of functionof systems used to mitigate the consequences of design basis accidents underpost-fire conditions does not per se impact public safety, the need to limit firedamage to systems required to achieve and maintain safe shutdown conditions isgreater than the need to limit fire damage to those systems required to mitigatethe consequences of design basis accidents.In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of1-hour fire barriers for the enclosure of cable and equipment and associated non-safetycircuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify asingle alarm is well within this worst-case 1-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA2 or MA5.Basis Reference(s):1. NEI 99-01, Rev 6 HU42. FSAR Figure 2.1-3, Extended Plot Plan TMINS3. FSAR Section 5.1, Class I Structures, Components, and Systems4. OP-TM-AOP-001, Fire5. OP-TM-EOP-020, Cooldown Outside of Control RoomMonth 20XXTMI 13-146EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU4Initiating Condition:Seismic event greater than OBE levels.Operating Mode Applicability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):Seismic event > Operating Basis Earthquake (OBE) as indicated by seismic AlarmsPRF-1-3 Operating Basis earthquake and PRF-1-2 Threshold Seismic Condition.Basis:This IC addresses a seismic event that results in accelerations at the plant site greaterthan those specified for an Operating Basis Earthquake (OBE)1.An earthquake greaterthan an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have nosignificant impact on safety-related systems, structures and components; however,some time may be required for the plant staff to ascertain the actual post-eventcondition of the plant (e.g., performs walk-downs and post-event inspections). Giventhe time necessary to perform walk-downs and inspections, and fully understand anyimpacts, this event represents a potential degradation of the level of safety of the plant.Event verification with external sources should not be necessary during or following anOBE. Earthquakes of this magnitude should be readily felt by on-site personnel andrecognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).The Shift Manager or Emergency Director may seek external verification if deemedappropriate (e.g., a call to the USGS, check internet news sources, etc.); however, theverification action must not preclude a timely emergency declaration.Depending upon the plant mode at the time of the event, escalation of the emergencyclassification level would be via IC CA2 or MA5.Basis Reference(s):1. NEI 99-01, Rev 6 HU22. OP-TM-AOP-003, Earthquake3. PRF 1-3 Operating Bases Earthquake4. PRF 1-2 Threshold Seismic Event1 An OBE is vibratory ground motion for which those features of a nuclear power plantnecessary for continued operation without undue risk to the health and safety of thepublic will remain functional.An SSE is vibratory ground motion for which certain (generally, safety-related)structures, systems, and components must be designed to remain functional.Month 20XXTMI 3-147EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5Initiating Condition:Gaseous release impeding access to equipment necessary for normal plant operations,cooldown or shutdown.Operating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):Note:If the equipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emergency classification is warranted.1. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area.Table H3Areas with Entry Related Mode ApplicabilityArea Entry Related ModeApplicabilityReactor Building* Modes 4, 5, and 6Intermediate Building* Modes 4, 5, and 6Auxiliary Building* Modes 4, 5, and 6Fuel Handling Building* Modes 4, 5, and 6*Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impededBasis:This IC addresses an event involving a release of a hazardous gas that precludes orimpedes access to equipment necessary to transition the plant from normal plantoperation to cooldown and shutdown as specified in normal plant procedures. Thiscondition represents an actual or potential substantial degradation of the level of safetyof the plant.Month 20XXTMI 3-148EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5 (cont)Basis (cont):Table H3 is a list of plant rooms or areas with entry-related mode applicability thatcontain equipment which require a manual/local action necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal operatingprocedures (establish shutdown cooling), where if this action is not completed the plantwould not be able to attain and maintain cold shutdown. This Table does not includerooms or areas for which entry is required solely to perform actions of an administrativeor record keeping nature (e.g., normal rounds or routine inspections).This Table does not include the Control Room since adequate engineered safety/designfeatures are in place to preclude a Control Room evacuation due to the release of ahazardous gas.An Alert declaration is warranted if entry into the affected room/area is, or may be,procedurally required during the plant operating mode in effect and the gaseous releasepreclude the ability to place shutdown cooling in service. The emergency classificationis not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires theEmergency Director's judgment that the gas concentration in the affected room/area issufficient to preclude or significantly impede procedurally required access. Thisjudgment may be based on a variety of factors including an existing job hazard analysis,report of ill effects on personnel, advice from a subject matter expert or operatingexperience with the same or similar hazards. Access should be considered as impededif extraordinary measures are necessary to facilitate entry of personnel into the affectedroom/area (e.g., requiring use of protective equipment, such as SCBAs, that is notroutinely employed).An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the timeof the gaseous release). For example, the plant is in Mode 1 when the gaseousrelease occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4." The gas release is a planned activity that includes compensatory measures whichaddress the temporary inaccessibility of a room or area (e.g., fire suppressionsystem testing)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.Month 20XXTMI 3-149EP-AA-1009 (Revision XX)
NtislAirThree MileIsa dnd Station Annex FvAlnn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5 (cont)Basis (cont):An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerouslevels. Most commonly, asphyxiants work by merely displacing air in an enclosedenvironment. This reduces the concentration of oxygen below the normal level ofaround 19%, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that generate smoke or thatautomatically or manually activate a fire suppression system in an area.Escalation of the emergency classification level would be via Recognition Category R, Cor F ICs.Basis Reference(s):1. NEI 99-01, Rev 6 HA52. FSAR Figure 2.1-3, Extended Plot Plan TMINS3. FSAR Section 5.1, Class I Structures, Components, and Systems4. NEI 99-01, Rev. 5 HA35. OP-TM-406-901, Hazardous Material Release6. AR-660892660892 Station Halon and IDLH Evaluations7. 29CFR1910.134(b) and 29CFR1910.134(d)(2)(iii)Month 20XXTMI 3-150EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU6Initiating Condition:Hazardous EventOperating Mode Applicability:1, 2, 3, 4, 5, 6, DEmergency Action Level (EAL):Note:EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, orvehicle breakdowns or accidents.1. Tornado strike within the PROTECTED AREA.OR2. Internal room or area flooding of a magnitude sufficient to require manual orautomatic electrical isolation of a SAFETY SYSTEM component required byTechnical Specifications for the current operating mode.OR3. Movement of personnel within the PROTECTED AREA is impeded due to an offsiteevent involving hazardous materials (e.g., an offsite chemical spill or toxic gasrelease).OR4. A hazardous event that results in on-site conditions sufficient to prohibit the plantstaff from accessing the site via personal vehicles.OR5. Abnormal river water level at the intake Pump and Screen House, as indicated byEITHER:a. > 300 ft. el. (high level)ORb. < 274 ft. el. (low level)Basis:PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.Month 20XXTMI 3-151EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU6 (cont)Basis (cont):This IC addresses hazardous events that are considered to represent a potentialdegradation of the level of safety of the plant.EAL I BasisAddresses a tornado striking (touching down) within the Protected Area.EAL #2 BasisAddresses flooding of a building room or area that results in operators isolating power toa SAFETY SYSTEM component due to water level or other wetting concerns.Classification is also required if the water level or related wetting causes an automaticisolation of a SAFETY SYSTEM component from its power source (e.g., a breaker orrelay trip). To warrant classification, operability of the affected component must berequired by Technical Specifications for the current operating mode. Manual isolation ofpower to a SAFETY SYSTEM component as a result of is an event of lesser impact andwould be expected to cause small and localized damage. The consequence of this typeof event is adequately assessed and addressed in accordance with TechnicalSpecifications.EAL #3 BasisAddresses a hazardous materials event originating at an offsite location and of sufficientmagnitude to impede the movement of personnel within the PROTECTED AREA.EAL #4 BasisAddresses a hazardous event that causes an on-site impediment to vehicle movementand significant enough to prohibit the plant staff from accessing the site using personalvehicles. Examples of such an event include site flooding caused by a hurricane, heavyrains, up-river water releases, dam failure, etc., or an on-site train derailment blockingthe access road.This EAL is not intended to apply to routine impediments such as fog, snow, ice, orvehicle breakdowns or accidents, but rather to more significant conditions such as theHurricane Andrew strike on Turkey Point in 1992, the flooding around the CooperStation during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in2011.Escalation of the emergency classification level would be based on ICs in RecognitionCategories R, F, M, H or C.Basis Reference(s):1. NEI 99-01, Rev 6 HU32. OP-TM-AOP-005 River Water System Failures3. OP-TM-AOP-002, Flood4. OP-TM-AOP-004, Tornado / High WindsMonth 20XXTMI 3-152EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU6 (cont)B asis .(co~nt): .i .,.'~ ii..i .!. '.. ...... ... ...... .... ..... .. .. .. ..... .. ....EAL #5 Basis:The level of the Susquehanna River is approaching flood stage; flood stage is definedas 302 ft el. at the Intake Pump and Screen House.A low river water condition below 274 ft el. requires a Technical Specification 3.0.1 plantshutdown per OP-TM-AOP-005 and is a precursor to a more serious condition.Escalation of the emergency classification level would be based on ICs in RecognitionCategories R, F, M, H or C.Basis Reference(s):,,1. NEI 99-01, Rev 6 HU32. OP-TM-AOP-005 River Water System Failures3. OP-TM-AOP-002, Flood4. OP-TM-AOP-004, Tornado / High WindsMonth 20XXTMI 3-153EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelnn Nucler~ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG7Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a GENERAL EMERGENCY.Operating Mode Applicability:1,2, 3, 4, 5, 6, DEimergencyi Action LevelE(EAL):Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which involve actual or IMMINENT substantialcore degradation or melting with potential for loss of containment integrity or HOSTILEACTION that results in an actual loss of physical control of the facility. Releases can bereasonably expected to exceed EPA Protective Action Guideline exposure levels offsitefor more than the immediate site area.IMMINENT: The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for aGeneral Emergency.Basis Refere.ce():1.. ........ ....e1 -O 1 ,..ev 6 H ................. ..... ... .....G..... .... ...1. NEI 99-01, Rev 6 HG7Month 20XXTMI 3-154EP-AA-1009 (Revision XX)
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- ondition~ i:"i ....... ..i. .............. ... i. .". ... ........ .... ....... ........... ...... ....Initiating Condition::Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a SITE AREA EMERGENCY.Operating ModeAppihcability:1,2, 3, 4, 5, 6, DEmergency Action Level (EAL):..Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which involve actual or likely major failures ofplant functions needed for protection of the public or HOSTILE ACTION that results inintentional damage or malicious acts, (1) toward site personnel or equipment that couldlead to the likely failure of or, (2) that prevent effective access to equipment needed forthe protection of the public. Any releases are not expected to result in exposure levelswhich exceed EPA Protective Action Guideline exposure levels beyond the siteboundary.B a s is : .. ..:. ." ......HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for a SiteArea Emergency..- ... ... ..* ..... .. ..Basis 9Reference(s):1. NEI 99-01, Rev 6HS7Month 20XXTMI 3-155EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexExelon NuclearTABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA7Initiating Condition:.,:,Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an ALERT.operating Mode Applicability. .. r.tin. ....Appl i..l....i1,2,3, 4,5,6, DEmergency Action Level (EAL): -Other conditions exist which, in the judgment of the Emergency Director, indicate thatevents are in progress or have occurred which involve an actual or potential substantialdegradation of the level of safety of the plant or a security event that involves probablelife threatening risk to site personnel or damage to site equipment because of HOSTILEACTION. Any releases are expected to be limited to small fractions of the EPAProtective Action Guideline exposure levels.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives,PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included. HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE: An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anAlert.Basis Reference(s)-:.... ....................................1 .. ... ...... ....1 .NEI 99-01, Rev 6 HA7Month 20XXTMI 3-156EP-AA-1009 (Revision XX)
Thragm Win lalanrl Qfatien AnngvPvgslrn KI"r-IghinrTkr~ MiI~ lelanri Qtat.r~n Annav ~veIii~ Mm ~ S S 55~~ *W* 55 **S.* 5 tUt*** 155 I. 1 fl~ I 5.11 I EU La 5 *~C ITABLE TMI 3-2: EAL Technical BasisRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU7Initiating Condition:..Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an UNUSUAL EVENT.Ope~rating Mode'..Applicability:..:,.., .1,2,3, 4,5,6, DEmergency Action Level (EAL):.Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which indicate a potential degradation of thelevel of safety of the plant or indicate a security threat to facility protection has beeninitiated. No releases of radioactive material requiring offsite response or monitoring areexpected unless further degradation of safety systems occurs.Basis:This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anUNUSUAL EVENT.Basis Reference(s):1. NEI 99-01, Rev 6HU7Month 20XXTMI 3-157EP-AA-1009 (Revision XX)